National Oil and Hazardous Substances Pollution Contingency Plan; National Priorities List: Partial Deletion of the Allied Chemical & Ironton Coke Superfund Site, 37763-37777 [2020-13302]
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Federal Register / Vol. 85, No. 122 / Wednesday, June 24, 2020 / Rules and Regulations
6-[(1R)-1-fluoroethyl]-1,3,5-triazine-2,4diamine, calculated as the
stoichiometric equivalent of indaziflam,
in or on the commodity.
Parts per
million
*
*
*
*
Grass, forage, fodder and hay,
group 17, forage .....................
Grass, forage, fodder and hay,
group 17, hay ..........................
*
*
*
*
*
Sugarcane, cane ........................
*
0.01
30
10
(2) Tolerances are established for
residues of the herbicide indaziflam, N[(1R,2S)-2,3-dihydro-2,6-dimethyl-1Hinden-1-yl]-6-(1-fluoroethyl)-1,3,5triazine-2,4-diamine, including its
metabolites and degradates, in or on the
commodities in the following table.
Compliance with the tolerance levels
specified in the following table is to be
determined by measuring only
indaziflam in or on the commodity.
TABLE 2 TO PARAGRAPH (a)(2)
Parts per
million
Commodity
Cattle, fat ....................................
Cattle, meat ................................
Cattle, meat byproducts .............
Goat, fat ......................................
Goat, meat ..................................
Goat, meat byproducts ...............
Horse, fat ....................................
Horse, meat ................................
Horse, meat byproducts .............
Milk .............................................
Milk, fat .......................................
Sheep, fat ...................................
Sheep, meat ...............................
Sheep, meat byproducts ............
*
(b) [Reserved]
*
*
*
*
[FR Doc. 2020–12132 Filed 6–23–20; 8:45 am]
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BILLING CODE 6560–50–P
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40 CFR Part 300
[EPA–HQ–SFUND–1983–0002; FRL–10010–
67–Region 5]
TABLE 1 TO PARAGRAPH (a)(1)
Commodity
ENVIRONMENTAL PROTECTION
AGENCY
0.07
0.01
0.2
0.07
0.01
0.2
0.07
0.01
0.2
0.01
0.25
0.07
0.01
0.2
National Oil and Hazardous
Substances Pollution Contingency
Plan; National Priorities List: Partial
Deletion of the Allied Chemical &
Ironton Coke Superfund Site
Environmental Protection
Agency (EPA).
ACTION: Direct final rule.
AGENCY:
The Environmental Protection
Agency (EPA) Region 5 is publishing a
direct final Notice of Partial Deletion of
soil (land), lagoon, and sediment
portions of the Allied Chemical &
Ironton Coke Superfund Site (Site), in
Ironton, Ohio, from the National
Priorities List (NPL). The NPL,
promulgated pursuant to Section 105 of
the Comprehensive Environmental
Response, Compensation, and Liability
Act (CERCLA) of 1980, as amended, is
an appendix of the National Oil and
Hazardous Substances Pollution
Contingency Plan. This direct final
partial deletion is being published by
EPA with the concurrence of the State
of Ohio, through the Ohio
Environmental Protection Agency,
because all appropriate response actions
for these Site media under CERCLA
have been completed. However, this
partial deletion does not preclude future
actions under Superfund. This partial
deletion does not include the OU2 ROD
Soils Area 2 or the groundwater
portions of the Site, which will remain
on the NPL.
DATES: This direct final partial deletion
is effective August 24, 2020 unless EPA
receives adverse comments by July 24,
2020. If adverse comments are received,
EPA will publish a timely withdrawal of
the direct final partial deletion in the
Federal Register informing the public
that the partial deletion will not take
effect.
SUMMARY:
Submit your comments,
identified by Docket ID No. EPA–HQ–
SFUND–1983–0002 by one of the
following methods:
https://www.regulations.gov. Follow
the on-line instructions for submitting
comments. Once submitted, comments
cannot be edited or removed from
Regulations.gov. The EPA may publish
any comment received to its public
docket. Do not submit electronically any
information you consider to be
Confidential Business Information (CBI)
or other information whose disclosure is
ADDRESSES:
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restricted by statute. Multimedia
submissions (audio, video, etc.) must be
accompanied by a written comment.
The written comment is considered the
official comment and should include
discussion of all points you wish to
make. The EPA will generally not
consider comments or comment
contents located outside of the primary
submission (i.e. on the web, cloud, or
other file sharing system). For
additional submission methods, the full
EPA public comment policy,
information about CBI or multimedia
submissions, and general guidance on
making effective comments, please visit
https://www.epa.gov/dockets/
commenting-epa-dockets.
Email: Deletions@
usepa.onmicrosoft.com.
Written comments submitted by mail
are suspended and no hand deliveries
will be accepted. We encourage the
public to submit comments via email or
at https://www.regulations.gov.
Instructions: Direct your comments to
Docket ID no. EPA–HQ–SFUND–1983–
0002. EPA’s policy is that all comments
received will be included in the public
docket without change and may be
made available online at https://
www.regulations.gov, including any
personal information provided, unless
the comment includes information
claimed to be CBI or other information
whose disclosure is restricted by statute.
Do not submit information that you
consider to be CBI or otherwise
protected through https://
www.regulations.gov or email. The
https://www.regulations.gov website is
an ‘‘anonymous access’’ system, which
means EPA will not know your identity
or contact information unless you
provide it in the body of your comment.
If you send an email comment directly
to EPA without going through https://
www.regulations.gov, your email
address will be automatically captured
and included as part of the comment
that is placed in the public docket and
made available on the internet. If you
submit an electronic comment, EPA
recommends that you include your
name and other contact information in
the body of your comment and with any
disk or CD–ROM you submit. If EPA
cannot read your comment due to
technical difficulties and cannot contact
you for clarification, EPA may not be
able to consider your comment.
Electronic files should avoid the use of
special characters, any form of
encryption, and be free of any defects or
viruses.
Docket: All documents in the docket
are listed in the https://
www.regulations.gov index. Although
listed in the index, some information is
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not publicly available, e.g., CBI or other
information whose disclosure is
restricted by statute. Certain other
material, such as copyrighted material,
will be publicly available only in hard
copy. Publicly available docket
materials are available electronically at
https://www.regulations.gov and at
https://www.epa.gov/superfund/alliedchemical-ironton or you may contact the
person identified in the FOR FURTHER
INFORMATION CONTACT section for
additional availability information.
The EPA is suspending its Docket
Center and Regional Records Centers for
public visitors to reduce the risk of
transmitting COVID–19. In addition,
many site information repositories are
closed and information in these
repositories, including the deletion
docket, has not been updated with
hardcopy or electronic media. For
further information and updates on EPA
Docket Center services, please visit us
online at https://www.epa.gov/dockets.
The EPA continues to carefully and
continuously monitor information from
the Centers for Disease Control and
Prevention (CDC), local area health
departments, and our Federal partners
so that we can respond rapidly as
conditions change regarding COVID–19.
FOR FURTHER INFORMATION CONTACT:
Karen Cibulskis, NPL Deletion
Coordinator, U.S. Environmental
Protection Agency Region 5, at (312)
886–1843 or via email at
cibulskis.karen@epa.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
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I. Introduction
II. NPL Deletion Criteria
III. Partial Deletion Procedures
IV. Basis for Partial Site Deletion
V. Partial Deletion Action
I. Introduction
EPA Region 5 is publishing this direct
final Notice of Partial Deletion of the
Allied Chemical & Ironton Coke
Superfund Site (Allied Chemical Site or
Site), from the NPL. The Allied
Chemical Site covers 129 acres and
includes three operable units (OUs). The
Goldcamp Disposal Area (GDA) is OU1.
The former Coke Plant/Lagoon Area
(CPLA) is OU2. The former Tar Plant is
OU3. See Figures 1 and 2 in the Docket.
Groundwater contamination is present
below all three OUs, but is addressed as
part of the OU1 and OU2 cleanup
remedies.
This partial deletion pertains to the
soil (land) portion of OU1 (GDA); the
soil (land) and lagoons portion of OU2
(CPLA) except for the OU2 ROD Soils
Area 2 located within the bermed area
of the East Tank Farm (see Figure 3 in
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the Docket); and all of OU3 (which only
addressed contaminated soil and
sediment at the Tar Plant and in the
adjacent Ohio River). The OU2 ROD
Soils Area 2 located within the bermed
area of the East Tank Farm contains
components of the groundwater
treatment system and will not be
remediated until after the groundwater
cleanup is complete. Therefore, the OU2
ROD Soils Area 2 is not being
considered for deletion as part of this
action. The contaminated groundwater
at the Site, which is present below all
three OUs but is being addressed as part
of the OU1 and OU2 cleanup remedies,
is undergoing a long-term cleanup and
is also not being considered for deletion
as part of this action. The OU2 ROD
Soils Area 2 and the groundwater
portions of the Allied Chemical Site
(i.e., the groundwater portion of OU1
and OU2, which includes the
contaminated groundwater below OU3)
will remain on the NPL.
The NPL constitutes Appendix B of
the National Oil and Hazardous
Substances Pollution Contingency Plan
(NCP), which EPA promulgated
pursuant to CERCLA. EPA maintains the
NPL as the list of sites that appear to
present a significant risk to public
health, welfare, or the environment.
Sites on the NPL may be the subject of
remedial actions financed by the
Hazardous Substance Superfund (Fund).
This partial deletion of the Allied
Chemical Site is proposed in accordance
with 40 CFR 300.425(e) and is
consistent with the Notice of Policy
Change: Partial Deletion of Sites Listed
on the National Priorities List. 60 FR
55466 (Nov. 1, 1995). As described in 40
CFR 300.425(e)(3) of the NCP, a portion
of a site deleted from the NPL remains
eligible for Fund-financed remedial
actions if future conditions warrant
such actions.
Section II of this document explains
the criteria for deleting sites from the
NPL. Section III discusses the
procedures that EPA is using for this
action. Section IV discusses the soil,
lagoons, and sediment portions of OU1,
OU2, and OU3 of the Allied Chemical
Site included in this partial deletion
and demonstrates how these media/
areas meet the deletion criteria. Section
V discusses EPA’s action to partially
delete the soil, lagoons, and sediment in
OU1, OU2, and OU3 of the Allied
Chemical Site (except for the soil in
OU2 ROD Soils Area 2) from the NPL
unless adverse comments are received
during the public comment period.
II. NPL Deletion Criteria
The NCP establishes the criteria that
EPA uses to delete sites from the NPL.
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In accordance with 40 CFR 300.425(e),
sites, or portions thereof, may be deleted
from the NPL where no further response
is appropriate. In making such a
determination pursuant to 40 CFR
300.425(e), EPA will consider, in
consultation with the state, whether any
of the following criteria have been met:
i. Responsible parties or other persons
have implemented all appropriate
response actions required;
ii. all appropriate Fund-financed
response under CERCLA has been
implemented, and no further response
action by responsible parties is
appropriate; or
iii. the remedial investigation has
shown that the release poses no
significant threat to public health or the
environment and, therefore, the taking
of remedial measures is not appropriate.
Pursuant to CERCLA Section 121(c)
and the NCP, EPA conducts five-year
reviews to ensure the continued
protectiveness of remedial actions
where hazardous substances, pollutants,
or contaminants remain at a site above
levels that allow for unlimited use and
unrestricted exposure. EPA conducts
such five-year reviews even if a site or
a portion of a site is deleted from the
NPL. EPA may initiate further action to
ensure continued protectiveness at a
deleted site if new information becomes
available that indicates it is appropriate.
Whenever there is a significant release
from a site deleted from the NPL, the
deleted site may be restored to the NPL
without application of the hazard
ranking system.
III. Partial Deletion Procedures
The following procedures apply to the
deletion of the soil, lagoons, and
sediment portions of OU1, OU2, and
OU3 of the Allied Chemical Site,
excluding the OU2 ROD Soils Area 2:
(1) EPA consulted with the State of
Ohio prior to developing this direct
final Notice of Partial Deletion and the
Notice of Intent for Partial Deletion copublished in the ‘‘Proposed Rules’’
section of the Federal Register.
(2) EPA has provided the State 30
working days for review of this notice
and the parallel Notice of Intent to
Partially Delete prior to their
publication today, and the State,
through the Ohio Environmental
Protection Agency (OEPA), concurred
on the partial deletion of the Allied
Chemical Site from the NPL on March
6, 2020.
(3) Concurrent with the publication of
this direct final Notice of Partial
Deletion, an announcement of the
availability of the parallel Notice of
Intent for Partial Deletion is being
published in a major local newspaper,
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the Ironton Tribune. The newspaper
notice announces the 30-day public
comment period concerning the Notice
of Intent for Partial Deletion of the
Allied Chemical Site from the NPL.
(4) The EPA placed copies of
documents supporting the partial
deletion in the deletion docket and
made these items available for public
inspection and copying at https://
www.regulations.gov and at https://
www.epa.gov/superfund/alliedchemical-ironton.
(5) If adverse comments are received
within the 30-day public comment
period on this partial deletion action,
EPA will publish a timely notice of
withdrawal of this direct final Notice of
Partial Deletion before its effective date
and will prepare a response to
comments and continue with the
deletion process on the basis of the
Notice of Intent for Partial Deletion and
the comments already received.
Deletion of a portion of a site from the
NPL does not itself create, alter, or
revoke any individual’s rights or
obligations. Deletion of a portion of a
site from the NPL does not in any way
alter EPA’s right to take enforcement
actions, as appropriate. The NPL is
designed primarily for informational
purposes and to assist EPA
management. Section 300.425(e)(3) of
the NCP states that the deletion of a site
from the NPL does not preclude
eligibility for further response actions,
should future conditions warrant such
actions.
IV. Basis for Partial Site Deletion
The following information provides
EPA’s rationale for deleting the soil,
lagoons, and sediment portions of OU1,
OU2, and OU3, except for the soil in
OU2 ROD Soils Area 2, of the Allied
Chemical Site from the NPL.
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Site Background and History
The Allied Chemical Site
(OHD043730217) is 129 acres and is
located at 3330 South Third Street in
Ironton, Lawrence County, Ohio (see
Figure 1 in the Docket). The Site is
surrounded by industries, businesses,
private residences, waterways, and
wetlands. Part of the Site is adjacent to,
and includes, a portion of the Ohio
River.
The Allied Chemical Site is divided
into three OUs (see Figure 2 in the
Docket). OU1 is the Goldcamp Disposal
Area (GDA) and is 10 acres in size. The
GDA is a former sand and gravel pit that
was used to dispose waste from the
Site’s Tar Plant, as well as waste from
the Goldcamp Gravel Company and
foundry sand from a nearby iron works.
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OU2 is the former Coke Plant/Lagoon
Area (CPLA). The CPLA covers 91 acres
and contained the former Coke Plant
and five lagoons. The CPLA is bordered
by Ice Creek to the east and south. Ice
Creek flows into the Ohio River and
portions of the CPLA are within the 100
year floodplain. Eastern portions of the
CPLA extend into the adjacent Village of
Coal Grove, Ohio.
OU2 includes groundwater below the
CPLA and in the former Tar Plant area
(OU3). Limited areas of soil
contamination in OU3 were also
evaluated and addressed as part of OU2.
OU3 is the former Tar Plant area. The
Tar Plant OU is 28 acres and consists of
two parcels, the Main Parcel and the
River Parcel. The Main Parcel is 16
acres and contained the former Tar
Plant facility. The River Parcel is 12
acres and includes seven acres of the
Ohio River (this varies with river
elevation). The Main Parcel and the
River Parcel of OU3 are separated by an
active railroad track.
Initial operations at the Allied
Chemical Site began with the Ironton
Solvay Coke Company (Ironton) Coke
Plant (OU2). In 1926, Ironton and other
companies united to form the Allied
Chemical & Dye Corporation (Allied
Chemical). From 1981 to 1999, Allied
Chemical went through additional name
changes, mergers and acquisitions and
is currently Honeywell International
Inc. (Honeywell).
The Coke Plant operated from 1917 to
1982. Products from the coking
operations included: Crude tar, coke,
light oil, and ammonia. From 1920
through the 1960s, the facility
discharged wastewater and solid wastes
generated during the coking process into
the marshy area east of the plant
adjacent to Ice Creek. The waste streams
included process wastewater, coke and
coal fines, tar decanter sludges, boiler
ash, and weak ammonia liquor. Specific
constituents present in the waste
streams included: Ammonia, benzene,
cyanide, metals, naphthalene,
phenolics, and polynuclear aromatic
hydrocarbons (PAHs).
In the early 1970s, Allied Chemical
constructed a wastewater treatment
plant (WWTP) and a series of lagoons in
the marshy area of the Coke Plant to
treat the waste streams from the Coke
Plant and the Tar Plant. The treated
wastewater discharged to the Ohio River
through two permitted outfalls, Outfall
001 and Outfall 002. Outfall 002 was
taken out of service in 2001.
In 1977, Allied Chemical sold the
Coke Plant to the McClouth Steel
Corporation (McClouth Steel). In 1982,
McClouth Steel filed for bankruptcy and
the Coke Plant was shut down.
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37765
Iron City Fuels, Inc. (Iron City Fuels)
purchased the Coke Plant property for
salvaging after the Coke Plant closed. In
1984, Allied Chemical re-purchased the
Coke Plant property, excluding the
surface facilities, from Iron City Fuels.
Iron City Fuels retained the surface
facilities at the Coke Plant for salvaging
until 1985.
Iron City Fuels completed their
salvage operations and transferred the
surface facilities back to Allied
Chemical in 1985. In 1987, Allied
Chemical entered into a CERCLA
Section 106(a) Administrative Order on
Consent (AOC) with EPA and OEPA to
remove six remaining above-ground
storage tanks, 4,700 cubic feet of tar
decanter sludge (a K087 hazardous
waste), and the material in the #4 weak
liquor storage tank from the CPLA for
off-site disposal.
Allied Chemical operated the Tar
Plant (0U3) from 1945 until 2000 when
the Tar Plant closed. The Tar Plant
manufactured products from the crude
tar produced at the Coke Plant. The Tar
Plant contained 124 above ground
storage tanks for various coal tar
derivatives and chemicals, and
numerous buildings housing
administrative, laboratory, storage, and
maintenance activities. After the Tar
Plant closed, the Tar Plant facilities
were demolished. The Tar Plant
property demolition was completed in
2003.
Specific products from the Tar Plant
included: Phthalic anhydride, creosotes,
pitches, naphthalene, road tar, driveway
sealer, roofing pitch, and anthracene.
The Tar Plant disposed the wastes and
residues generated during the
manufacturing processes to the adjacent
GDA (OU1). These wastes included:
Anthracene residues and salts, coal tar
pitch scrap, and phthalic anhydride
residues.
The GDA was a former sand and
gravel pit that was approximately 40
feet deep. The GDA received waste from
the Tar Plant, as well as waste from the
sand and gravel company and foundry
sand from a nearby iron foundry.
Allied Chemical purchased the GDA
property in 1955. In 1961, the
construction of the Greenup Dam on the
Ohio River raised the water levels of the
river and adjacent groundwater, causing
the waste at the bottom of the GDA to
be in direct contact with the
groundwater.
Allied Chemical stopped using the
GDA for waste disposal in 1977 and
developed a plan for closing the GDA in
consultation with OEPA. The closure
included: Removing standing liquid
from the GDA for off-site disposal,
filling the GDA to surface grade, and
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capping the GDA with clay. Allied
Chemical completed the GDA closure in
1980.
EPA inspected the Allied Chemical
Site and completed a Site Inspection
Report in 1980. In 1982, OEPA sampled
the five Coke Plant lagoons and
collected groundwater samples from the
Site. OEPA detected high concentrations
of PAHs in the lagoon sludge [total PAH
concentrations as high as 148,000
milligrams per kilogram (mg/kg) in
Lagoon 5] and high levels of cyanide,
arsenic, phenol, and metals in the liquid
fractions of the lagoons. OEPA detected
arsenic in the groundwater at
concentrations as high as 120,000
micrograms per liter (mg/l) and benzene
at concentrations as high as 1,200 mg/l.
EPA completed a Preliminary
Assessment Report and a Remedial
Action Master Plan for the Site in 1983.
EPA proposed the Site to the NPL on
December 30, 1982 (47 FR 58476) due
to the potential for groundwater
contaminants to affect private well
supplies, as well as the Ohio River and
Ice Creek, which supply municipal
drinking water. EPA finalized the Allied
Chemical Site on the NPL on September
8, 1983 (48 FR 40658).
EPA finalized: Cleanup remedies for
the Allied Chemical Site in Records of
Decision (RODs) issued in 1988, 1990,
and 2007; ROD Amendments in 1995,
1997, and 1998; and Explanations of
Significant Differences (ESD) in 2015
and 2020. Allied Chemical/Honeywell
implemented the EPA-selected cleanup
actions for the Site from 1993 to 2015.
In 2016, EPA issued a Preliminary Close
Out Report documenting that Allied
Chemical/Honeywell constructed the
cleanup remedies consistent with all
requirements and that the cleanups
were protective of human health and the
environment.
The OU1 property (GDA) is currently
owned by Honeywell. The majority of
the OU1 property is a capped landfill
and the perimeter is fenced. There is
presently no anticipated future use for
the portion of OU1 located over the
landfill. Honeywell split approximately
1.4 acres of OU1 near Third Street that
is not part of the landfill from the
original parcel, and this property is
available for redevelopment.
The OU2 property (Coke Plant/Lagoon
Area) is divided into 17 parcels of land.
Allied Corporation (i.e., Honeywell)
currently owns two of the 17 parcels:
Parcel 2, located in the City of Ironton
and Parcel 1 located in the Village of
Coal Grove (see Figure 2 in the Docket).
Parcel 2 contains the former lagoons
which were converted into wetlands
and the upgraded WWTP that treats the
extracted groundwater from the Site
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prior to discharge to the Ohio River.
Parcel 2 is under security and
monitoring by a Honeywell contractor
stationed at the WWTP seven days a
week during business hours and via
telemetry 24 hours per day. Parcel 1
contains a portion of the Lagoon Area
and a portion of Ice Creek. A section of
Parcel 1 has also been converted into
wetlands. The entire perimeter of the
WWTP and the lagoons is secured by a
chain-link fence with posted warning
signs maintained by Honeywell’s
contractors.
Honeywell donated Parcel 4 of OU2 to
the Ironton Port Authority in 2008.
Honeywell sold the remaining OU2
parcels to the City of Ironton (City) for
use as an industrial park in 2002. The
City sold various parcels of OU2 for
redevelopment.
The two OU3 parcels, the Main Parcel
and the River Parcel, are currently
owned by Honeywell/Allied Chemical.
The Main Parcel is covered by a lowpermeability cover and the perimeter is
fenced. The River Parcel has a 2-foot
soil cover and a sediment cover. The
access road is gated to prevent vehicles
from entering the area.
In 2011, EPA’s contractor performed a
reuse assessment to identify future land
use considerations and opportunities
and to coordinate reuse goals for the
Site. On September 22, 2011, EPA and
the City hosted a workshop to plan for
Site reuse. Participants included Site
owners and representatives from local
businesses, adjacent properties, local
educational and healthcare institutions,
and local and state government. During
the workshop, participants gave input
regarding future uses and priorities for
the Site.
In 2012, EPA’s contractor completed a
‘‘Reuse Framework’’ report, which
summarized the outcomes of the
workshop and the findings of a reuse
suitability assessment for the Site. This
document includes reuse considerations
and opportunities for education,
workforce development, and Site
improvements that can position the Site
for productive reuse.
Several of the OU2 Site parcels have
been redeveloped. The ownership
information for the OU2 parcels is
summarized on Figure 2 in the Docket.
The active stakeholders, their interests,
and their contact information is
summarized in Table 1 of the 2020
Institutional Controls Implementation &
Assurance Plan, which is available in
the Docket.
This partial deletion pertains to the
soil (land) portion of OU1 (GDA); the
soil (land) and lagoons portion of OU2
(CPLA), except for the OU2 ROD Soils
Area 2 located within the bermed area
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of the East Tank Farm (see Figure 3 in
the Docket); and all of OU3 (which only
addressed contaminated soil and
sediment at the Tar Plant and in the
adjacent Ohio River).
The OU2 ROD Soils Area 2 located
within the bermed area of the East Tank
Farm contains components of the
groundwater treatment system and will
not be remediated until after the
groundwater cleanup is complete.
Therefore, the OU2 ROD Soils Area 2 is
not being considered for deletion as part
of this action. The contaminated
groundwater at the Site, which is
present below all three OUs but is being
addressed as part of the OU1 and OU2
cleanup remedies, is undergoing a longterm cleanup and is also not being
considered for deletion as part of this
action. The OU2 ROD Soils Area 2 and
the groundwater portions of the Allied
Chemical Site (i.e., the groundwater
portion of OU1 and OU2, which
includes the contaminated groundwater
below OU3) will remain on the NPL.
Remedial Investigation and Feasibility
Study (RI/FS)
Allied Chemical entered into an AOC
with EPA and OEPA to conduct a Sitewide Remedial Investigation (RI) and
Feasibility Study (FS) at the Allied
Chemical Site in 1984. The purpose of
the RI was to characterize the nature
and extent of contamination associated
with the Site and the impact of the
contamination on human health and the
environment. The purpose of the FS was
to develop and evaluate cleanup
alternatives to address the unacceptable
risks posed by the Site.
Allied Chemical conducted field
investigations at the Site in 1984 and
finalized the RI Report in 1986. The
1986 RI included: (1) The installation
and sampling of over 45 groundwater
monitoring wells; (2) collection and
analysis of over 200 groundwater
samples; (3) collection and analysis of
over 200 soil samples; (4) collection and
analysis of over ten surface water
samples; (5) continuous sampling and
analysis of air samples during sampling
and excavation; (6) excavation and
sampling of waste in over 20 test pits;
and (7) collection and analysis of over
1000 samples of fish tissue. The soil and
waste samples were analyzed for six
Site-specific indicator chemicals:
Phenolics, benzene, naphthalene,
cyanide, ammonia, and chloride. The
groundwater and municipal water
samples were analyzed for the six
indicator chemicals and EPA’s Target
Analyte List (TAL) inorganic and Target
Compound List (TCL) chemicals.
The 1986 RI determined that the 4acre waste pit in the GDA contained
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approximately 300,000 cubic yards of
waste material, including hazardous
substances disposed from the Tar Plant
and the Coke Plant. The bottom five feet
of the waste was below the water table
and in direct contact with groundwater.
The surface of the GDA was a source of
contamination because contaminated
substances oozed up through the
existing cap and collected on the GDA
surface. The contaminants of concern
(COCs) in the GDA were: Benzene,
naphthalene, phenolics, cyanide,
ammonia, sulfate, chloride, and the
PAHs benz(a)anthracene,
benzo(a)pyrene, chrysene, and
dibenz(a,h)anthracene.
The groundwater below the GDA was
contaminated. The groundwater
contamination extended west to the
Ohio River and to the production wells
located at the Amcast company
(formerly Ironton Iron Inc.) located
1,000 feet north of the GDA. Amcast
Production Well No. 7 contained
benzene at concentrations as high as 36
mg/l. These concentrations were above
the Safe Drinking Water Act Maximum
Contaminant Level (MCL) for benzene of
5 mg/l. Dense non-aqueous phase liquid
(DNAPL) was present on top of the
bedrock below the GDA. Total
petroleum hydrocarbon concentrations
in the DNAPL were 100 to 250 parts per
million. Due to the groundwater
contamination, Allied Chemical began
providing bottled drinking water to
Amcast for its employees in 1986.
The 1986 RI found seven areas of soil
contamination in the Coke and Tar Plant
areas that required cleanup (see Figures
3 and 4 in the Docket). The soils were
contaminated with benzo(a)pyrene, a
carcinogenic PAH (PAHc). The
maximum concentrations of
benzo(a)pyrene detected in the
contaminated soil were: 150 mg/kg in
Area 1, 60 mg/kg in Area 2, 330 mg/kg
in Area 3, 96 mg/kg in Area 4, and 39
mg/kg in Area 5. The total amount of
soils requiring cleanup in the Coke
Plant area was 38,000 cubic yards.
Approximately 2,000 cubic yards of soil
required cleanup in the Tar Plant area.
The 1986 RI found that Lagoons 1
through 4 in the CPLA contained waste
coal and coke, and general debris,
including bricks, pieces of metal, and
tar. Lagoons 1 and 3 also contained lime
kiln sludge (K060), a listed hazardous
waste under the Resource Conservation
and Recovery Act (RCRA) based on the
content of cyanide, naphthalene,
phenolic compounds, and arsenic. The
analytical sampling indicated that the
material in Lagoons 1 through 4 was
contaminated with widely varying
concentrations of PAHs, ammonia,
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cyanide, phenolics, sulfate, benzene,
and arsenic.
Lagoon 5 in the CPLA was used to
dispose decanter tank tar sludge (K087),
a RCRA listed hazardous waste based on
phenol and naphthalene content.
Lagoon 5 was also believed to contain
waste coal and coke materials. Lagoon 5
was approximately 40 feet deep and
contained approximately 122,000 cubic
yards of waste. About five to 15 feet of
the waste was below the water table.
Analytical sampling in Lagoon 5
detected high concentrations of
carcinogenic PAHs. Although the
solubility and mobility of PAHs is low,
the chemicals are potent carcinogens.
The 1986 RI found that the sediments
of Ice Creek downstream from the Site
were contaminated from the discharge
of wastewater from the Coke Plant
operations. The sampling indicated that
downstream sediments contained Siterelated concentrations of phenolics,
naphthalene, ammonia, and cyanide. An
examination of 214 fish collected from
Ice Creek and the Ohio River, however,
did not show any neoplastic liver
lesions in the fish. Surface water
samples collected downstream of the
Site contained higher concentrations of
chloride and ammonia than upstream
samples, but the concentrations were
well below EPA’s Water Quality
Criteria.
The groundwater in the CPLA and the
Tar Plant area was contaminated with
several contaminants, including
phenolics, ammonia, cyanide, chloride,
naphthalene, and benzene. The pattern
of groundwater contamination indicated
that the contamination was due to a
number of localized on-site sources. The
data also indicate that DNAPL was
present above the surface of the bedrock
at some locations.
Groundwater modeling conducted
during the RI indicated that the
groundwater below the CPLA and Tar
Plant flowed toward Ice Creek and the
Ohio River. The modeling indicated that
the Coal Grove well field located
approximately 2,000 feet south of the
CPLA, which provides drinking water to
about 2,840 residents, obtains
approximately 27 percent of its water
from Ice Creek leakage, 29 percent of its
water from the Ohio River, 41 percent
of its water from the aquifer southeast
of the well field away from the Site, and
three percent of its water from Site
groundwater flowing underneath Ice
Creek. The modeling and the actual
analysis of the Coal Grove municipal
water indicated that no drinking water
standards were being exceeded in the
Coal Grove wellfield as a result of the
Allied Chemical Site.
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The 1986 RI concluded that
contaminated groundwater from the
CPLA and Tar Plant was discharging to
the Ohio River, but the discharge was
not detectable since the river contained
contaminants similar to those found in
Site groundwater upstream and
downstream of the Site. Contaminant
loading modeling indicated that the
groundwater contaminants discharging
to the Ohio River would not be
detectable at the City of Ironton’s
drinking water intake.
Allied Chemical conducted air
sampling during the 1986 RI during
worst-case conditions by collecting air
samples when the most highly
contaminated material at the Site, the
tar sludge in Lagoon 5, was disturbed
with a backhoe. Allied Chemical did not
detect any discernible atmospheric
volatile organic emissions at the
perimeter of the tar sludge area during
this sampling.
After the 1986 RI was complete, EPA,
OEPA, and Allied Chemical divided the
Site into two OUs to expedite the
completion of the FS for the GDA
(OU1). Allied Chemical completed an
Endangerment Assessment and a FS
Report for the GDA in 1988. Allied
Chemical completed an Endangerment
Assessment and a FS Report for the
remaining areas of the Site (OU2) in
1990. The OU2 Endangerment
Assessment and FS addressed the
CPLA, contaminated groundwater below
the Tar Plant, and limited areas of soil
contamination at the Tar Plant.
Allied Chemical’s EA for the GDA
examined potential contaminant
exposure pathways from the GDA
including ground water, surface water
(Ohio River contamination via ground
water), soil, and air. The potential
receptors included Amcast workers
drinking contaminated groundwater
from Amcast’s wells (if bottled water
was not supplied), recreational users in
the Ohio River ingesting surface water,
and workers at the closest business
inhaling airborne contaminants. The
GDA was covered and fenced, so direct
contact with the wastes was not
considered a major exposure pathway.
The OU2 EA for the CPLA (and some
portions of the Tar Plant) evaluated
potential risks to current Coal Grove
residents from: Inhalation of downwind
dust and vapors; dermal contact with
and the incidental ingestion of water in
Ice Creek while swimming; using Coal
Grove municipal water for drinking and
showering; incidental ingestion of
contaminated soil while trespassing;
and eating fish from Ice Creek. The EA
also evaluated potential risks to
hypothetical future residents living on
the CPLA property and using the
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contaminated groundwater as a water
supply.
The EA for the GDA determined that
the contaminated groundwater from the
GDA posed an unacceptable risk to
people using the groundwater as a
source of drinking water. The excess
lifetime cancer risk was 6.7 × 10¥3. This
risk was greater than EPA’s acceptable
cancer risk range of 1 × 10¥4 to 1 ×
10¥6. The noncancer hazard index (HI)
calculated for exposure to the GDA
groundwater was 3.0, which is greater
than EPA’s acceptable noncancer HI of
1.0.
Recreational use of the Ohio River did
not pose a risk since sampling results
did not indicate a significant increase of
Site-related contaminants in the Ohio
River downstream of the GDA. Air
modeling also indicated that potential
air releases from the GDA did not pose
a significant risk via the air pathway (an
excess lifetime cancer risk of 1.6 ×
10¥6).
The OU2 EA for the CPLA and
portions of the Tar Plant identified
unacceptable potential future risks to
hypothetical residents living on the
CPLA property. The potential future
cancer risk was 5.7 × 10¥3 for children
and 3.4 × 10¥3 for adults. The
unacceptable noncancer HIs were 7.1 for
children and 4.0 for adults. The cancer
risks were primarily due to the
concentrations of PAHs in the soil and
to benzene and arsenic in the
groundwater. The unacceptable
noncancer risks were primarily due to
cyanide contamination in the
groundwater.
The CPLA EA did not identify any
unacceptable risks to current Coal Grove
residents. The total excess lifetime
cancer risk calculated for Coal Grove
residents from all exposure pathways
was 1.0 × 10¥5 for children and 2.6 ×
10¥5 for adults. The calculated
noncancer HIs for Coal Grove residents
for all pathways were well below 1.0,
with a maximum HI of 0.163.
At the time of the OU1 and OU2 RI/
FS, the Tar Plant was an operating
facility with limited accessibility. In
2003, after the Tar Plant closed and the
area could be fully investigated,
Honeywell (formerly Allied Chemical)
entered into a separate AOC with EPA
to conduct a RI/FS for the remaining
areas of the Tar Plant (OU3) that were
not addressed or remediated as part of
OU2. Honeywell completed the Tar
Plant OU3 RI/FS in 2007 and issued an
OU3 RI Addendum in 2008.
The 2007 OU3 RI included: (1) The
collection and analysis of 235 soil
samples from 146 soil borings down to
the water table; (2) 12 paired soil vapor
and ambient air samples at locations of
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highest contaminant concentrations; (3)
the installation and sampling of 48
groundwater monitoring wells installed
from 28 to 90 feet below ground surface
(with 21 locations nested) to
horizontally and vertically delineate the
groundwater contamination; (4) the
installation of 12 DNAPL wells to
delineate the extent and thickness of the
DNAPL and allow for possible future
recovery; and (5) the collection and
analysis of 37 Ohio River water and 29
sediment samples to evaluate impacts to
the river. Honeywell analyzed the 2007
RI samples for VOCs, PAHs,
polychlorinated biphenyls (PCBs),
cyanide, arsenic, total phenols, and
ammonia. The groundwater samples
were also analyzed for nitrate.
Honeywell’s 2007 RI for the Tar Plant
(OU3) found that the shallow and deep
soil on the Main Parcel of the Tar Plant
was contaminated with high levels of
PAHs (as high as 44,100 mg/kg) and
benzene, toluene, ethylbenzene, and
xylene (BTEX) (a maximum
concentration of 406 mg/kg BTEX). The
distribution of PAHs and BTEX in the
shallow soil was similar to the
distribution of the DNAPL. The soil also
contained lesser concentrations of
arsenic (maximum concentration of 14.4
mg/kg), PCBs (maximum concentration
of 7.7 mg/kg total PCBs), phenols (280
mg/kg), cyanide, and ammonia.
Shallow soil in the River Parcel
contained high levels of PAHs and
BTEX. High levels of PAHs were also
detected in sediment samples collected
from the Ohio River adjacent to the Site.
The highest concentrations of PAHs in
sediment were located downstream of
Outfall 001 and ranged from 184 mg/kg
to 1,053 mg/kg.
Soil vapor in the Tar Plant OU
contained benzene at concentrations as
high as 55,000 parts per billion/volume
(ppbv) and other VOCs. Benzene
(maximum concentration of 0.31 ppbv),
toluene, and naphthalene were detected
in ambient air.
DNAPL is present in the southern half
of the Main Parcel of the Tar Plant and
has collected in depressions at the
surface of the bedrock. The soil boring
data indicates that the DNAPL has not,
and is not likely to, migrate toward the
Ohio River due to rises in the surface of
the bedrock between the Site and the
river.
Honeywell completed a Human
Health Risk Assessment (HHRA) and a
Screening Ecological Risk Assessment
(SERA) for the Tar Plant (OU3) in the
2007 Phase 1A RI Report. The HHRA
evaluated risks to current trespassers
and to future recreational visitors,
indoor and outdoor commercial/
industrial workers, and construction
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workers. The HHRA evaluated exposure
pathways including dermal contact with
and the incidental ingestion of surface
and subsurface soil, dust inhalation, the
inhalation of ambient air and indoor
contaminants via vapor intrusion,
dermal contact with and the incidental
ingestion of surface water, dermal
contact with sediment, and the
ingestion of groundwater. The SERA
evaluated potential impacts to
ecological receptors from exposure to
soil and to surface water and sediment
in the Ohio River adjacent to the Site.
Honeywell’s 2007 OU3 HHRA
indicated that the Tar Plant posed an
unacceptable risk to current trespassers,
future recreational users, future indoor
and outdoor commercial/industrial
workers, and future construction
workers. The total excess lifetime cancer
risks ranged from 8 × 10¥4 to 8 × 10¥3.
The noncancer HIs ranged from 2 to
1201. The majority of the cancer and
noncancer risks were posed by PAHs in
the surface and subsurface soil and by
concentrations of benzene, toluene, and
naphthalene in soil vapor.
The results of the 2007 OU3 SERA
indicated that the concentrations of
PAHs in the Tar Plant soil posed a
hazard to soil invertebrates, wormeating birds, and predatory birds.
Ecological hazard quotients (HQs)
greater than or equal to 100 were
calculated in scattered areas across the
Tar Plant. The SERA also indicated that
the concentrations of COCs detected in
surface water could cause adverse
effects to aquatic receptors.
Additionally, the concentrations of Siterelated PAHs in sediment could cause
adverse effects to benthic organisms
(direct contact) and piscivorous birds
(food chain).
Allied Chemical and Honeywell
conducted Feasibility Studies (FSs) to
develop and evaluate cleanup
alternatives to address the unacceptable
risks associated with the GDA, the
CLPA, and the Tar Plant OUs.
The 1988 OU1 FS evaluated four
cleanup alternatives for the GDA: No
action; slurry wall and cap with
groundwater recovery wells inside and
outside of slurry wall; incinerate GDA
waste and return residual material to
GDA, with slurry wall with groundwater
recovery wells inside and outside of
slurry wall (no cap); and incinerate GDA
waste and subsoils with one
groundwater recovery well (no slurry
wall or cap). All alternatives except the
no-action alternative also included
groundwater treatment at the on-site
WWTP with discharge to the Ohio River
under the existing or a modified NPDES
permit, connecting Amcast to the
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municipal water supply, and a DNAPL
investigation.
Allied Chemical completed the OU2
FS for the CPLA in 1990. The OU2 FS
evaluated varying combinations of
cleanup options for the CPLA. Cleanup
options for the lagoons and
contaminated Coke Plant and OU2 Tar
Plant soils included: No action; on-site
incineration and off-site waste fuel
recovery; partial bioremediation with
on-site incineration; partial
bioremediation and off-site waste fuel
recovery; partial off-site waste fuel
recovery with solidification/
stabilization of residual materials; and
partial bioremediation with on-site
waste fuel recovery of lagoon materials
and an asphalt and plastic layered cap
over the Coke Plant and OU2 Tar Plant
soils.
Ice Creek sediment cleanup options
included: Monitoring with trigger levels
for accelerated monitoring and
groundwater remediation; excavation
and bioremediation of Ice Creek
sediments with lagoon materials; and
solidification/stabilization of Ice Creek
sediments. All cleanup alternatives
included groundwater collection with
treatment at the on-site WWTP with
discharge to the Ohio River.
Honeywell completed the Tar Plant
OU3 FS in 2007. The 2007 FS evaluated
eight cleanup alternatives for the
contaminated Tar Plant soils, two
cleanup alternatives for air, and five
cleanup alternatives for Site-related
sediment contamination in the Ohio
River. The soil alternatives included: No
further action; soil cover; lowpermeability cover; limited excavation
and off-site disposal with either a soil
cover or a low-permeability cover;
limited excavation with on-site
consolidation and a soil cover or a lowpermeability cover; and extensive
excavation and off-site disposal.
The cleanup alternatives evaluated for
the contaminated sediment included:
No further action; monitored natural
recovery; in-situ capping; dredging and
off-site disposal; and a combination of
dredging, off-site disposal and in-situ
capping. The cleanup alternatives
evaluated for the air were no further
action and institutional controls (ICs).
Selected Remedy
EPA selected cleanup remedies for the
Allied Chemical Site in RODs EPA
issued in 1988, 1990, and 2007. EPA
issued three ROD Amendments
modifying the remedy in 1995, 1997,
and 1998. EPA documented additional
changes to the remedy in ESDs EPA
issued in 2015 and 2020.
EPA selected the OU1 GDA cleanup
remedy in the 1988 ROD. The remedial
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action objectives (RAOs) for the GDA
are to: Mitigate the future generation of
contaminated leachate; mitigate the
GDA-related contamination of the
Amcast potable/sanitary water supply
and any other private well supplies
located north and northwest of the GDA;
mitigate the migration of GDA-related
contaminants above applicable Ohio
River standards into the Ohio River
(Ohio Administrative Code 3745–1–32);
and mitigate the potential for direct or
indirect contact by the public with
hazardous substances in the buried GDA
waste.
The major components of the selected
GDA remedy included: Constructing a
low-permeability slurry wall around the
GDA from the ground surface into the
low-permeability bedrock; installing a
multi-media RCRA hazardous waste cap
over the GDA; continuous extraction of
groundwater within the containment
system with treatment at the existing
on-site WWTP located at the CPLA (to
be upgraded) to create an inward
groundwater gradient within the slurry
wall boundaries; extraction and
treatment at the on-site WWTP of
contaminated groundwater outside the
containment system until cleanup
standards are achieved; municipal water
hook-up for in-plant potable and
sanitary uses at the Amcast facility until
contaminant levels in groundwater meet
the cleanup standards; deed restrictions
to limit future uses of the disposal area
portion of the property; and a
supplemental RI/FS to identify the
nature and extent of the DNAPL,
develop and evaluate cleanup
alternatives, and implement the EPAapproved DNAPL remedy, if different
from the currently selected containment
alternative.
EPA selected the cleanup remedy for
the CPLA in the 1990 ROD. The RAOs
for the CPLA cleanup are to: Mitigate
the potential for direct or indirect
contact of the public with the lagoon
area wastes; mitigate the potential for
future mobilization of contaminants into
the groundwater; mitigate the migration
of CPLA-related contaminants into Ice
Creek, the Ohio River, and the Coal
Grove well field; and remediate all
contaminated media to meet ARARs and
acceptable risk-based levels for human
health and the environment.
The major components of the selected
CPLA remedy in the 1990 ROD were:
Excavate the entire volume of Lagoon 5
(122,000 cubic yards of material); onsite incineration and waste fuel recovery
(heat reuse) of Lagoon 5 material and
31,000 cubic yards of waste coal
excavated from the coal overburden
area, with the ash to be disposed of at
a permitted off-site solid waste facility;
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excavation and bioremediation on a
prepared pad of 40,000 cubic yards of
Coke and Tar Plant soils (OU2 ROD
Soils Areas 1 to 7); in-situ
bioremediation of the remaining volume
of material in Lagoons 1 through 4
(475,000 cubic yards), the residual soil
in Lagoon 5, and the adjacent inner and
outer dikes; monitoring the Ice Creek
area and developing a contingency plan
in the event that contaminant migration
is encountered; groundwater collection,
on-site treatment with the groundwater
from the GDA, and monitoring; and
deed restrictions and fencing.
The 1990 CPLA ROD stated that the
cleanup standard for soil was 0.97 mg/
kg of PAHc. The standard was based on
an excess lifetime cancer risk of 1 ×10¥6
assuming a direct contact residential
land use exposure. The CPLA ROD also
provided for an alternative cleanup
standard of 97 mg/kg PAHc (a 1 × 10¥4
cancer risk, which is still within EPA’s
acceptable risk range) if the threat of
direct contact from lagoon soils through
residential land use was eliminated by
flooding Lagoons 1 through 4 to create
a wetland. An assessment of Lagoons 1
through 4 indicated that this area was
more likely to be an ecological area than
a residential area due to its proximity to
Ice Creek and the fact that this low-lying
area has historically served as a flood
water storage area.
EPA issued ROD Amendments in
1995, 1997 and 1998 modifying the
cleanup remedies for the GDA and
CLPA based on additional information
collected during the predesign and
design phases of the project. The three
ROD Amendments modified the OU1
and OU2 remedies as follows: Revised
the groundwater clean-up standards for
benzo(a)pyrene and
dibenz(a,h)anthracene for OU1 and OU2
from 0.005 mg/l total to the new MCLs
of 0.2 mg/l for benzo(a)pyrene and 0.3
mg/l for dibenz(a,h)anthracene; selected
excavation and on-site storage for
eventual treatment or placement into
the lagoon area for 135,000 additional
cubic yards of CPLA soil found to be
contaminated with PAHs during the
design phase; replaced prepared-pad
bioremediation of 40,000 cubic yards of
CPLA soil with off-site disposal in an
approved landfill; replaced in-situ
bioremediation of 475,000 cubic yards
of material in Lagoons 1 through 4 with
excavation of materials above 97 mg/kg
PAHc and wetland development; and
replaced incineration of Lagoon 5
materials with recycling, treatment,
and/or disposal of the K087 listed waste
in an approved off-site hazardous waste
facility and the use of the remaining
material, excluding debris, as an
alternative fuel.
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In 2020, EPA issued an ESD for the
OU2 CPLA remedy. EPA issued the ESD
to formally document a previously
accepted change in the soil cleanup
standard for arsenic from a residential
cleanup level of 0.56 mg/kg selected in
the 1990 OU2 ROD to a Site-specific
background concentration of 15 mg/kg
calculated during the remedial design
(RD) phase of the project. See the
Cleanup Levels section of this notice for
additional information.
EPA issued the Tar Plant OU3 ROD in
2007. The OU3 ROD addressed
contaminated soil, sediment and air at
the Tar Plant OU. The RAOs for OU3
assumed that future use of the Tar Plant
property would be commercial/
industrial and may include riverside
parks or other recreational use.
The RAOs for the Tar Plant soil are to:
Prevent human ingestion and direct
contact with soil containing PAHs at
concentrations that exceed applicable
NCP and Ohio EPA risk management
criteria for applicable exposure
scenarios; prevent terrestrial
invertebrates from being exposed to
PAHs at concentrations that may be
harmful to invertebrates and wormeating birds; prevent predatory birds
from being exposed to unacceptable
concentrations of PAHs; and reduce, to
the extent practicable, contaminant
leaching from soil that may contribute
to groundwater contamination above
NCP and/or Ohio EPA risk management
criteria.
The RAOs for sediment in the
adjacent Ohio River are to prevent
human direct contact with sediment
containing PAHs that exceed applicable
NCP and Ohio EPA risk management
criteria for future exposure scenarios,
and to prevent benthic invertebrates
from direct contact with sediment
containing PAHs that exceed
preliminary remediation goals based on
background toxicity levels. The RAOs
for air are to prevent the inhalation of
vapors in indoor air in future buildings
in excess of NCP and Ohio EPA risk
management criteria and to prevent the
inhalation of vapors by construction
workers during any future grading and/
or excavation activities.
EPA’s selected cleanup remedy for
soil in the 2007 OU3 ROD was the
construction of an OEPA-compliant
low-permeability solid waste cap over
all contaminated portions of the Tar
Plant (the entire 16-acre Main Parcel), a
geotextile fabric and soil cover over all
contaminated portions of the River
Parcel (approximately four acres), ICs to
protect the integrity of the cap and soil
cover, and an IC implementation plan.
EPA did not select a low-permeability
cap for the River Parcel based on
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concerns with hydraulic instability
caused by hydrostatic pressure
differences between the groundwater
and surface water which could cause a
low-permeability cover to fail.
The selected OU3 remedy for
sediment consisted of dredging
approximately 3,300 to 5,100 cubic
yards of contaminated sediment from
the Ohio River using appropriate
dredging techniques and turbidity
control measures; sediment dewatering
and disposal at an approved off-site
landfill; evaluating the water from the
dewatered sediment during the RD for
disposal at the on-site WWTP; and
installing an in-situ cap over
approximately 0.7 acres of residual
sediment contamination using earthen
materials (sand, gravel and/or cobbles),
engineered materials (geosynthetics or
marine mattresses), or a combination of
these materials to be determined during
the RD. The exact areas and volume of
sediment to be excavated and capped
would be determined based on
additional data collected and evaluated
during the RD and post-dredging
confirmation sampling.
The selected OU3 remedy for air was
ICs in the form of land use restrictions
restricting the land to industrial/
commercial use and requiring future
buildings to include measures (e.g.,
physical barriers, venting, monitoring)
to protect indoor workers against
potential risks from vapor intrusion and
outdoor workers during excavation or
grading activities.
In 2015, EPA issued an ESD
modifying the sediment component of
the OU3 remedy based on Honeywell’s
2009 and 2011 predesign investigations.
The predesign investigations indicated
that the volume of sediment requiring
excavation increased from 3,300 to
5,100 cubic yards to 50,000 to 60,000
cubic yards, and that the area of
sediment requiring capping was 2.3
acres, not 0.7 acres. Due to the
significant increase in cost and concerns
with potential river bank failure and the
destabilization of the adjacent active
railroad trackbed, the sediment
component of the OU3 remedy was
modified from dredging and capping to
capping only.
Response Actions
Allied Chemical completed the RD for
the GDA remedy in 1992 and
constructed the GDA remedial action
(RA) from 1993 to 1995 (see Figures 2
and 5 in the Docket). Allied Chemical
constructed a soil-bentonite slurry wall
around the GDA waste to provide a lowpermeability barrier to ground water inflow and contaminant migration outflow. The slurry wall has a permeability
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of approximately 1 × 10¥8 centimeters
per second (cm/sec), which exceeds the
1 × 10¥7 cm/sec permeability
requirement. Allied Chemical did not
key the slurry wall into the bedrock due
to concerns that the keying efforts
would fracture the bedrock and affect its
competence and water-bearing
capabilities.
After the slurry wall was constructed,
Allied Chemical installed a RCRA
Subtitle C hazardous waste compliant
cap over the GDA. The cap incorporated
a geosynthetic clay liner to minimize
future exposure of the buried waste and
infiltration. The cap has a permeability
of less than 1 × 10¥7 cm/sec. The cap
includes a passive gas venting system
with capabilities for adding an
emissions control system in the future,
if needed.
Allied Chemical installed two
groundwater pumping wells inside the
slurry wall (PW–3 and PW–4) to
maintain an inward hydraulic gradient
and prevent groundwater contaminants
from migrating beyond the slurry wall,
and two groundwater pumping wells
outside the slurry wall (PW–1 and PW–
2) to intercept and extract contaminated
groundwater outside the wall. Based on
the 1992 Design Report and Allied
Chemical’s 1992 Design Report
Response, EPA revised the groundwater
drawdown required to maintain the
inward gradient from ten feet to one
foot. The groundwater pumped from
inside and outside the slurry wall is
treated at the on-site WWTP at the
CPLA, which was upgraded to add
biological and carbon polishing
treatment components to the system.
The on-site WWTP was later upgraded
again in 1997 during the OU2 RA. The
treated groundwater is discharged to the
Ohio River in compliance with the
technical requirements of a Site-specific
National Pollutant Discharge
Elimination System (NPDES) permit
administered by OEPA.
Allied Chemical installed
groundwater monitoring wells to
monitor the performance of the GDA
containment system and the migration
of the dissolved and free phase
contaminant plumes to assist with
delineating the extent of DNAPL and to
evaluate potential technologies to
address the DNAPL. Allied Chemical
also constructed a security fence around
the perimeter of the GDA to prohibit
trespassing. EPA conducted a final
inspection of the OU1 GDA remedy on
August 2, 1995. Allied Chemical
submitted a final Remedial Design/
Remedial Action (RD/RA) completion
report for the GDA on September 14,
1995.
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Allied Chemical conducted
preliminary Site preparation activities
for the OU2 CPLA RA from 1994–1995.
In 1995, Allied Chemical constructed
the CPLA Stormwater Collection/
Management System to contain
stormwater runoff during the RA. Allied
Chemical conducted the OU2 CPLA RA
construction activities from 1996 to
2002 (see Figures 3, 4 and 6 in the
Docket).
Allied Chemical completed the OU2
CPLA groundwater remedy in 1996 and
1997. The RA for the groundwater
remedy included: Installing five
groundwater extraction wells and five
new groundwater monitoring wells to
supplement the existing system;
connecting a sixth groundwater
extraction well installed in 1992 to the
system; and modifying the on-site
WWTP to allow for the handling and
treatment of the extracted groundwater
from the CPLA, the GDA, and the
wastewater from the Tar Plant facility
operations and to meet NPDES permit
requirements. The WWTP modifications
included: Installing an iron/suspended
solids removal system consisting of
aeration/pH adjustment, clarification,
and sand filtration; a cyanide removal
system using ultraviolet irradiation/
oxidation; and flow modifications to the
carbon towers organics treatment
system. Formal system start-up of the
OU2 CPLA groundwater treatment
system occurred in June and July 1997.
Allied Chemical conducted the
Lagoon 5 remediation activities from
1998 to 1999. Allied Chemical
excavated the material in Lagoon 5
down to the underlying clay layer and
removed approximately 120,000 tons of
waste from the lagoon. Approximately
85,600 tons of coal/coke fines, 16,000
tons of segregated hard tar, and 500 tons
of exempted RCRA–K087 listed waste
from Lagoon 5 were shipped off-site to
power generation plants for feedstock as
part of approved alternative fuels
programs. Allied Chemical disposed of
the contaminated or unusable hard
debris (10,800 tons) and soft debris
excavated from Lagoon 5 at an off-site
landfill. Allied Chemical stabilized
7,100 tons of soft-tar material (RCRA
K087 listed waste) from Lagoon 5 onsite and disposed of it at an off-site
landfill. Allied Chemical sent the scrap
metal that was recovered from Lagoon 5
to a local recycler.
Allied Chemical backfilled the Lagoon
5 excavation with clean, hard debris
from previous Site remediation
activities (e.g., concrete pipe supports,
brick, and concrete) to an elevation
above the water table. The hard debris
was covered with 12,000 tons of
crushed hard debris and 27,200 tons of
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soil having PAHc and arsenic
concentrations below the 97 mg/kg and
15 mg/kg cleanup levels excavated from
other Site areas. Allied chemical seeded
and revegetated Lagoon 5, and placed
rip-rap along the sides of the lagoon at
the tie-ins with the City of Ironton
Floodwall.
Based on the results of additional
sampling conducted in Lagoons 1 to 4
in 1997, the Lagoon 2 materials were the
only materials with PAHc
concentrations above the alternate 97
mg/kg PAHc cleanup standard
documented in ROD Amendment #3
that required excavation. Allied
Chemical removed 8,300 tons of hard tar
and 1,200 tons of coal/coke fine
materials from Lagoon 2 in 1999 and
shipped the material to off-site energy
generators for feedstock. Allied
Chemical backfilled the excavated areas
in Lagoon 2 with 2,000 tons of clay
material excavated from Lagoon 5 that
had PAHc concentrations less than 97
mg/kg and arsenic concentrations less
than 15 mg/kg. Allied Chemical placed
a six-inch layer of imported fill material
over the excavated area then tapered
and sloped the sidewalls of Lagoon 2
downward into the partially backfilled
area to create a depression to facilitate
the collection of standing water to aid
in the development of the wetland
ecosystem.
Allied Chemical conducted a
Reconnaissance Ecological Risk
Assessment for Lagoons 1 to 4 in 1999
before the lagoons were converted into
wetlands. The assessment evaluated
potential ecological impacts from
residual PAHc concentrations in the
Lagoons 1 to 4 materials after the
Lagoon 2 materials were removed.
Allied Chemical’s 1999 assessment
followed EPA’s Sediment Quality Triad
Approach and included a vegetation
study. The assessment indicated that
residual concentrations of PAHc in
Lagoons 1 to 4 at concentrations less
than or equal to the alternate 97 mg/kg
cleanup level would not significantly
impact the planned wetland ecosystem
or the aquatic or vegetative communities
of the converted wetland areas.
Allied Chemical completed the
conversion of Lagoons 1 to 4 into
wetlands in 2002. The wetland
conversion included: Construction of an
overflow weir adjacent to Lagoon 4 and
placement of rip-rap (i.e., brick and
concrete) in selected areas to minimize
erosional effects during flood events;
permanent modification of the sluice
gate adjacent to Lagoon 3 to permit
complete hydraulic connection with Ice
Creek to allow for equalized inflow/
outflow during flood events; and
adoption of an annual monitoring
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program to evaluate the reestablishment of vegetation and assess
the condition of the biological
community.
Allied Chemical completed the OU2
soil remediation of the CPLA and OU2
Tar Plant soils, with the exception of the
soil in OU2 ROD Soils Area 2, in 2000
(see Figures 3 and 4 in the Docket). The
contaminated CPLA soils (OU2 ROD
Soils Areas 1, 3 and 4) were excavated
to a maximum depth of ten feet. The
OU2 Tar Plant soils (OU2 ROD Soils
Areas 5 to 7) were excavated to five feet
and were not fully characterized due to
the ongoing Tar Plant operations. The
remaining Tar Plant soils were later
addressed by Honeywell during the
OU3 Tar Plant investigation and
cleanup.
The CPLA OU2 ROD Soils Area 2
could not be remediated because this
area is located within the bermed area
of the East Tank Farm which contains
components of the WWTP for the longterm OU1 and OU2 groundwater
cleanup. The soil within OU2 ROD Soils
Area 2 will remain on the NPL and is
not included in this partial deletion
action. OU2 ROD Soils Area 2 is located
within the fenced portion of CPLA
Parcel 2 which is owned by Allied
Chemical/Honeywell. The area is
planned for future characterization and
remediation when decreased activity
levels in this area will minimize
potential disruption to the operations of
the ongoing groundwater cleanup. It is
expected that the OU2 ROD Soils Area
2 materials will be characterized,
excavated, and disposed of at an off-site
landfill.
Allied Chemical disposed the
excavated OU2 CPLA and Tar Plant
soils as non-hazardous solid waste in an
off-site landfill in accordance with ROD
Amendment #2. The excavated soils
included: 18,100 tons of soil from CPLA
ROD Soils Area 1; 4,000 tons of soil
from CPLA ROD Soils Area 3 and the
active Truck Scale Facility; 2,600 tons of
soil from CPLA ROD Soils Area 4; and
4,700 tons of soil from OU2 Tar Plant
ROD Soils Areas 5 to 7.
During the OU2 RA, Allied Chemical
excavated contaminated soil and
materials from additional areas of the
CPLA in accordance with the 1995 ROD
Amendment #1 (see Figure 3 in the
Docket). These included: Excavating
44,000 tons of surficial coal fines
accumulated from the off-loading of
feed materials for the coke oven
batteries for off-site use as an approved
alternative fuel at cement kiln facilities
and power generation plants; excavating
17,700 tons of fuel-grade overburden
materials from the western portions of
Lagoons 2 and 4 for off-site energy
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recovery; excavating 6,000 tons of
petroleum hydrocarbon-contaminated
soil from the former Coke Plant
Ammonia Concentration Building for
off-site disposal as a non-hazardous
solid waste; excavating 23,500 tons of
PAH-contaminated soils west and south
of the former coke oven batteries and
other Site areas and disposing the soil
with PAHc concentrations greater than
97 mg/kg or arsenic concentrations
greater than 15 mg/kg at an off-site
landfill as a non-hazardous wastes
(3,700 tons) and backfilling the
remaining soil into the Lagoon 5
excavation; excavating 3,500 tons of
contaminated soil from the Trucker’s
Parking Lot area and an area located
adjacent to the East Tank Farm and
backfilling the material into Lagoon 5;
excavating 35,000 tons of coal and coke
fines and 500 tons of hard tar from the
slope of the City of Ironton floodwall for
off-site use as alternative fuel;
excavating 63,000 tons of material with
measured concentrations of PAHc less
than 97 mg/kg and arsenic less than 15
mg/kg from the East Side Batteries Area
for use as backfill along the toe of the
City of Ironton floodwall slope and
excavating 8,600 tons of material from
this area for off-site energy recovery;
and disposing 13,000 tons of hard debris
(brick and concrete) and 500 tons of soft
debris (wood, plastic, trash, etc.,)
encountered in excavated areas as a
non-hazardous solid waste at an off-site
landfill. Allied Chemical completed
these cleanup actions in 2000.
Documentation of the OU2 RA
construction activities is provided in the
October 23, 2002 Interim Remedial
Action Report for Coke Plant/Lagoon
Area (CPLA) Operable Unit at the
Honeywell-Ironton Facility, which is
available in the Docket.
Honeywell initiated OU3 construction
activities (see Figure 7 in the Docket) in
2014 starting with the River Parcel.
Honeywell conducted Site preparation
activities and sealed eight groundwater
monitoring wells. Honeywell cleaned
out and demolished a concrete oil-water
separator type structure at the top of the
river bank and removed its associated
piping and waste material for off-site
disposal. Honeywell relocated the CPLA
WWTP outfall, Outfall 001, which
discharged to the Ohio River near the
demolished structure, to a discharge
located on Site at the south property
boundary. Honeywell constructed a new
storm water system for the Main Parcel
with direct discharge to the Ohio River
using former NPDES outfall structures
001 and 002.
Honeywell stabilized the riverbank at
the soil and sediment interface of the
River Parcel with 35,150 square feet of
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one-foot thick stone-filled Polymeric
Marine Mattresses (PMMs) and rip-rap
mixed with soil staked with live plant
stakes. The PMMs were installed from
elevation 512 feet to 515 feet. The riprap was installed from elevation 515 feet
to 519 feet with some overlap on the
PMMs. Honeywell placed the live plant
stakes in the rip-rap/soil every three feet
on center.
Honeywell removed 75 tons of debris
from the Ohio River and installed three
separate types of subaqueous sediment
caps covering a total of 2.3 acres in the
river. Cap A covers the majority of the
area and consists of a minimum six-inch
sand chemical isolation layer covered
by a minimum six-inch gravel erosion
protection and filter layer. Caps B and
C have the same sand and gravel layers
as Cap A but are covered with an
additional 12-inches (Cap B) and 18inches (Cap C) of a cobble erosion
protection layer.
Honeywell installed a soil cover over
the upland portion of the River Parcel
(i.e., the riverbank) to prevent direct
contact with affected soils by humans
and potential ecological receptors. The
soil cover consisted of 18 inches of
vegetative fill covered by six inches of
topsoil. Honeywell installed an orange
geogrid layer below the vegetative fill to
demarcate the underlying subgrade
material.
Honeywell installed coir (coconut
fiber) matting over the topsoil from the
top of the upland slope to the rip-rap at
the bottom of the slope and coir logs at
the base of the slope, between the soil
cover and the rip-rap, to prevent erosion
until the vegetation was established.
Honeywell installed a temporary
irrigation system and planted a mixture
of native grasses, sedges and forbs on
the sloped soil cover from elevation 519
(the top of the rip-rap) to elevation 547
(the bottom of the railroad
embankment), and container plants
(trees and shrubs) every ten feet on
center from elevation 519 to elevation
538. Honeywell installed a gravel access
road and gate near the top of the slope
just above the 10-year flood elevation
(about 535 feet). Honeywell completed
the River Parcel remediation and
restoration in 2015.
Honeywell conducted the remedial
action construction for the OU3 Main
Parcel in 2015. Honeywell demolished
the remaining buildings and structures
on the Main Parcel and sealed 51
groundwater monitoring wells and one
pumping well. Honeywell installed a
low-permeability solid waste-compliant
cap over the entire 16-acre Main Parcel
area (see Figure 7 in the Docket). The
low permeability cap consists of a sixinch sand cushion layer over the
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contaminated soil covered by (from the
bottom up): A geosynthetic clay liner
(GCL), a 40-mil low-density
polyethylene (LDPE) geomembrane
layer, a 12-inch sand drainage layer
with lateral underground drains to
remove water from the top of the
LLDPE, a 12-inch protective soil cover
layer for vegetative growth, and six
inches of topsoil.
Honeywell installed a gas venting
system below the cover system to
prevent any buildup of gas. The system
includes lateral gas collection pipes
installed under the six-inch bottom sand
cushion layer that are connected to
three gas vents along the western edge
of the cover. Honeywell installed soil
gas monitoring probes around the
perimeter of the cap. The gas monitoring
probes are spaced approximately 400
feet apart with screens set at 10 feet, 25
feet, and 40 feet below grade.
Honeywell seeded and mulched the
topsoil layer of the cover system,
constructed a gravel access road along
the southern and eastern boundaries of
the Main Parcel to provide access to
groundwater extraction wells, and
constructed a chain-link fence along the
perimeter of the Main Parcel, except
along South Third Street where an
ornamental fence was installed.
EPA, OEPA, and Honeywell
conducted a pre-final/final inspection of
the River Parcel on November 13, 2014
and a pre-final/final inspection of the
Main Parcel on December 16, 2015.
Documentation of the OU3 RA
construction activities is provided in the
March 2016 Final Remedial Action
Completion Report for OU3 which is
available in the Docket.
EPA, OEPA, and EPA’s contractors
provided oversight of the cleanup at the
Allied Chemical Site throughout the
OU1, OU2, and OU3 RD/RAs. EPA and
OEPA conducted a pre-final inspection
of the Allied Chemical Site on
December 19, 2015. During the
inspection EPA verified that all
remedial actions were conducted in
accordance with the approved RD plans
and specifications. A punch list of
outstanding activities was prepared
during the inspection. Honeywell
addressed and completed all of the
punch list activities by May 4, 2016. A
final OU3 inspection and Site walkthrough was conducted on June 1, 2016.
EPA completed a Preliminary Close Out
Report for the Site documenting that the
RA construction activities were
complete on September 29, 2016.
Cleanup Levels
The soil (land) remedy for the OU1
GDA is in-situ containment of the waste
disposal area; therefore the 1988 OU1
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ROD does not establish cleanup levels
for the GDA waste.
EPA established the cleanup levels for
the OU2 CPLA soil in the 1990 OU2
ROD. The OU2 soil cleanup levels
applied to soil, the materials in Lagoons
1 to 4, the soil remaining in Lagoon 5
after the removal of the Lagoon 5 waste,
and the adjacent dikes. The OU2 CPLA
soil cleanup levels were a total PAHc
concentration of 0.97 mg/kg and an
arsenic concentration of 0.56 mg/kg.
These cleanup levels are based on a
hypothetical residential exposure, with
the cumulative cancer risk level not to
exceed 1 × 10¥6. The 1990 OU2 ROD
also required ICs in the form of deed
restrictions to prevent any residential or
recreational use of the Site.
In March 1995, Allied Chemical
submitted a petition to EPA and OEPA
providing a statistical evaluation of
arsenic concentrations measured at the
Site during the 1994 CPLA predesign
investigations compared to regionally
established background concentrations
of arsenic. This petition resulted in the
Agencies’ adoption of a revised cleanup
level for arsenic in soil of 15 mg/kg.
This revised cleanup standard for
arsenic was identified in several Site
reports including the EPA and OEPAapproved 2002 Interim Remedial Action
Report for the Coke Plant/Lagoon Area
and EPA’s 2004 Five-Year Review report
for the Site.
Allied Chemical recorded
Environmental Deed Restrictions
prohibiting residential and recreational
use of the CPLA property with the
Lawrence County Recorder’s office on
August 22, 2002 in Plat Book 10/Page
181. EPA formally documented the
revised soil cleanup standard for arsenic
of 15 mg/kg in an ESD EPA issued in
May 2020.
EPA revised the PAHc cleanup level
for the Lagoons 1 to 4 material in ROD
Amendment #3 in 1998. ROD
Amendment #3 selected the alternate
cleanup level of 97 mg/kg for PAHc
provided in the 1990 OU2 ROD. The
1990 OU2 ROD allowed the 97 mg/kg
PAHc alternate cleanup level if the
threat of direct contact with the lagoon
materials through residential use was
eliminated by flooding Lagoons 1 to 4 to
create a wetland. The 1999
Reconnaissance Ecological Risk
Assessment that Honeywell conducted
before converting Lagoons 1 to 4 into a
wetland further indicated that the
residual concentrations of PAHc in
Lagoons 1 to 4 at concentrations less
than or equal to the alternate 97 mg/kg
cleanup level would not significantly
impact the planned wetland ecosystem
or the aquatic or vegetative communities
of the converted wetland areas.
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EPA selected cleanup levels for the
OU3 Tar Plant soil and Ohio River
sediment in the 2007 OU3 ROD. The
cleanup level for soil on the Main Parcel
and the River Parcel of the Tar Plant is
0.16 mg/kg of benzo(a)pyrene. This
cleanup level is based on a cancer risk
of 1 × 10¥6 under future industrial/
commercial and recreational use of the
property.
The cleanup level for the Ohio River
sediment in the 2007 ROD was total
PAH concentrations that are equal to or
less than background sediment toxicity
levels for aquatic receptors (benthos) in
sediment from upstream sources. That
is, the ROD required the sum of
Environmental Sediment Toxicity
Benchmark Units (ESTBUs) for Siteimpacted sediment to be less than or
equal to 10.0. During the RD process,
and as allowed by the OU3 ROD, the
ESTBU sediment cleanup values of 10,
which are based on direct
measurements of PAH concentrations in
pore water and may overestimate PAH
bioavailibity and pore water toxicity,
were refined to use an Equilibrium Pore
Water Toxic Unit (EPWTU) of 5 instead.
Allied Chemical’s OU2 RD/RA for the
soil and lagoon remediation was
conducted in accordance with the 1992
CPLA Quality Assurance Project Plan
(QAPP). The 1992 CPLA QAPP was
used as the governing document to
guide the field sampling, treatability
studies, and analytical activities
performed throughout the CPLA RD/RA,
including field and laboratory Quality
Assurance/Quality Control (QA/QC)
procedures and data validation
protocols. In addition, task-specific
work plans were prepared and followed
for each significant activity, including:
Pre-Design Investigations for
Bioremediation, Groundwater, and
Waste Fuel Recovery; Coal Overburden
Characterization and Removal; Site
Soils and ROD Soils Characterization
and Removal; Lagoon Materials
Delineation; Floodwall Slope
Restoration; East Side Batteries
Characterization and Removal; Ice Creek
Monitoring Program; and CPLA
Compliance Monitoring Program and
Stormwater Collection and Monitoring
Program.
QA/QC activities for the OU2 CPLA
ROD Soils, including OU2 ROD Soils
Area 1 (including the Neal Junkyard
portion), Area 3 (including the Truck
Scale portion), and Area 4, included
field sampling to delineate the areal and
vertical extent of the impacted areas,
followed by excavation to the agreed
upon maximum depth of 10 feet. The
OU2 Tar Plant ROD Soils Areas 5 to 7
were similarly delineated and the
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37773
impacted materials excavated to the
agreed upon maximum depth of 5 feet.
Allied Chemical collected soil
samples from 0–1.0 foot, 1.0–2.5 feet,
and 2.5–5.0 feet below ground surface
(bgs) in each of the OU2 ROD Soils
Areas to determine the final depth of the
excavation. CPLA ROD Soils Areas 1, 3
and 4 were additionally sampled from
5.0–7.5 and 7.5–10.0 feet bgs. The soil
samples were analyzed for PAHc and
arsenic in accordance with the approved
USEPA Contract Laboratory Program
(CLP) Statements of Work for Organics
and Inorganics, respectively, which
were in effect at the time of analysis.
The most-highly contaminated sample
from each of the excavated OU2 ROD
Soils Areas underwent additional
testing prior to disposal. The additional
tests included RCRA toxicity
characteristic leaching procedure
(TCLP) analysis, a paint filter test, and
the RCRA hazardous characteristic tests
for reactivity, corrosivity, and
ignitability.
Allied Chemical conducted an initial
characterization of the additional CPLA
soils identified for remediation in the
1995 ROD Amendment #1 in 1994 and
1995. The soil samples were collected in
incremental one-foot intervals down to
a maximum depth of 10 feet. In areas
with coal and other fuel-grade
overburden material, the overlying coal
or fuel-grade layer was removed down
to the ‘‘visually-clean’’ underlying
native materials, and afterwards
samples were collected from the top foot
and then at the 4.0–5.0 feet depth of the
native material. In 1997, the sampling
protocol was revised to be consistent
with the OU2 ROD Soils Areas
sampling, with samples collected from
0.0–1.0 foot, 1.0–2.5 feet, 2.5–5.0 feet,
5.0–7.5 feet, and 7.5–10.0 feet bgs. The
samples were analyzed for PAHc and
arsenic.
The additional CPLA soils that
required remediation based on the
predesign investigation were excavated
to a maximum depth of 10 feet and the
materials were stockpiled on-site. Soil
containing PAHc concentrations greater
than 97 mg/kg or arsenic concentrations
greater than 15 mg/kg were disposed offsite following TCLP and hazardous
characteristic testing. Before the
stockpiled materials were placed in the
Lagoon 5 excavation, the materials were
sampled again for PAHc and arsenic at
a frequency of 1 sample for every 2,000
cubic yards to confirm they were below
cleanup standards.
CPLA soil materials in the area
adjacent to the East Tank Farm were
characterized using samples collected
from 0.0–1.0 foot, 1.0–2.5 feet, 2.5–5.0
feet, 5.0–7.5 feet, and 7.5–10.0 feet
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intervals. Soil in the Truckers’ Parking
Lot was sampled incrementally at 0.5foot intervals from the ground surface to
the underlying native material (based on
visual observations). Samples of the
native material were then collected at
0.5-foot intervals until the analytical
results indicated that the concentrations
of PAHc and arsenic were below 0.97
mg/kg and 15 mg/kg, respectively. The
excavated materials from these areas
were either disposed off-site or
backfilled directly into Lagoon 5 if they
were below cleanup levels.
Characterization of the CPLA East
Side Batteries Area focused on the
materials in the former Coke Plant
processing areas and extending east to
the City of Ironton Floodwall. Nearsurface materials were removed to
expose the underlying ‘‘visually-clean’’
native material. Samples were collected
from the native material in 0.5-foot
intervals until the concentration of
PAHc was less than 0.97 mg/kg and
arsenic was less than 15 mg/kg. Based
on the analytical results, the materials
were excavated and sent off-site for
disposal (after TCLP and hazardous
characteristic testing) or stockpiled to be
placed along the toe of the floodwall in
the Lagoon Area. The stockpiled
materials were subjected to another
round of sampling for PAHc and arsenic
at a frequency of 1 sample for every
2,000 cubic yards prior to placement
along the floodwall.
Allied Chemical discovered soil
contamination in the CPLA Ammonia
Concentration Building Area during
other Site work due to the discoloration
of the soil (a green tint) and a
petroleum-like odor. This area was not
specifically identified in the CPLA ROD
or ROD Amendments. Allied Chemical
sampled the material and detected
elevated levels of total petroleum
hydrocarbons (TPHC).
Allied Chemical conducted a focused
investigation in the Ammonia
Concentration Building Area and
collected soil samples at depth intervals
corresponding to 0.0–5.0 feet and 5.0–
10.0 feet at designated locations. The
samples were analyzed for TPHC using
EPA Method 418.1. Based on a review
of State of Ohio cleanup standards for
hydrocarbon-contaminated soils that
were in effect at the time, a Site-specific
TPHC cleanup level of 100 mg/kg was
adopted for the Ammonia Concentration
Building Soils. Allied Chemical
excavated the sampled material having
TPHC concentrations greater than 100
mg/kg and disposed of it at an off-site
landfill following TCLP and hazardous
characteristic testing.
The 1990 OU2 ROD and subsequent
amendments required the entire
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contents of Lagoon 5 to be removed.
Allied Chemical excavated all of the
materials in Lagoon 5 (about 120,000
tons) down to the visually encountered
clay layer. Allied Chemical then
removed about 2,000 tons of the Lagoon
5 clay, sampled the material to confirm
that concentrations of PAHc and arsenic
were below the cleanup criteria of 97
mg/kg PAHc and 15 mg/kg arsenic, and
backfilled the clay into the excavated
areas of Lagoon 2.
The materials in Lagoon 2 that
required excavation were delineated
during Allied Chemical’s 1997 Lagoon
Materials Delineation Program. The
program involved collecting samples
from Lagoons 1 to 4 for PAHc analysis.
The PAHc sample data was combined
with other existing data for the lagoons
and used in a statistical evaluation to
determine which materials required
removal in order to maintain an overall
average concentration of PAHc less than
97 mg/kg to meet the 1998 ROD
Amendment #3 requirement for
converting the lagoons into a wetland
system. The analysis indicated that only
certain areas of Lagoon 2 required
excavation. Additionally, potential
ecological risks posed by the residual
PAHc concentrations in the lagoons
were evaluated in the 1999
Reconnaissance Ecological Risk
Assessment and through the
performance of subsequent annual
ecological assessments to confirm that
the remedial action for the constructed
wetlands met objectives.
Honeywell conducted the OU3 Tar
Plant RA in accordance with the 2013
Construction Quality Assurance Plan,
the 2013 Construction Quality
Assurance Plan—Main Parcel, and the
2014 Construction Quality Assurance
Plan—River Parcel. The RA for the Main
Parcel was a low-permeability solid
waste cap containment remedy over the
entire 16-acre Main Parcel. The RA for
the upland area (riverbank slope) of the
River Parcel was a geotextile fabric and
soil cover over the entire 4-acre upland
area of the River Parcel. Because these
remedial actions were containment/
cover remedies over the entire property,
confirmation sampling was not
required. Instead, surveys were
conducted to confirm that the RAOs
were attained.
The areas of Ohio River sediment that
exceeded the refined cleanup level of
the sum of EPWTU of 5 or where tar was
observed were identified as areas that
required remediation during the RD
based on the predesign investigation
studies. Sediment within the design
capping area had sums of EPWTU
values that ranged from 5 to 40, while
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values outside the capped area were less
than 5.
The final capped area and thickness
of the OU3 Ohio River sediment remedy
was confirmed by comparing a baseline
multi-beam bathymetric survey
conducted prior to capping to
verification multi-beam bathymetric
surveys conducted after each layer of
the cap was placed to check for areal
extent and material thicknesses.
Honeywell’s construction managing
contractor monitored the surveying
results and verified that the quality and
coverage of the cap met the specified
design. The construction manager
contractor notified the construction
contractor of any deficiencies to be
corrected during construction, and
approved the final completion of areas
post-construction.
Operation and Maintenance
Operation and maintenance (O&M)
activities at the Allied Chemical Site are
extensive and include activities
associated with groundwater/
wastewater operations, monitoring
systems, engineered structure
maintenance, landscaping, and security.
Honeywell’s O&M costs for the period
2014 to 2018 averaged over $1.1 million
annually.
Honeywell conducts the GDA
groundwater monitoring in accordance
with the 1994 GDA Remedial Action
Monitoring Plan. The CPLA
groundwater monitoring and Ice Creek
monitoring is performed in accordance
with the general protocols outlined in
the 1995 CPLA Groundwater
Compliance Sampling and Analysis
Plan. Honeywell monitors and conducts
O&M for the lagoons/wetlands in
accordance with the 2000 Lagoon Area
Wetlands/Floodplain Conversion Plan.
Honeywell conducts O&M on the Tar
Plant River Parcel in accordance with
the 2015 Operation, Maintenance and
Monitoring Plan—River Parcel. The Tar
Plant Main Parcel O&M is conducted in
accordance with the 2016 Draft Main
Parcel Operation, Maintenance, and
Monitoring Plan.
The O&M program includes
comprehensive groundwater
monitoring, potentiometric monitoring,
chemical analysis, NPDES discharge
monitoring, Site inspections, and any
necessary repairs. The groundwater
monitoring program includes
monitoring contaminant concentrations
and groundwater levels to assess the
containment of the GDA waste,
maintenance of Site-wide hydraulic
control, and for the presence of DNAPL.
Honeywell also conducts periodic
bathymetric surveying in the Ohio River
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to monitor the performance of the
underwater sediment cap.
Honeywell monitors methane gas
semiannually at the Main Parcel. In
2002, the Gas Vent Sampling Program at
the GDA was terminated based on
Honeywell’s 2002 Air Emissions
Evaluation Report. The 2002 Air
Emissions Evaluation Report evaluated
the analytical data from 14 consecutive
quarterly air monitoring events and
determined that the emissions of
volatile organic compounds from the
four GDA vents was insignificant. The
2002 report also concluded that the
ambient impact to the nearest public
receptor due to emissions from the vents
was orders of magnitude lower than the
corresponding Maximum Allowable
Ground Level Concentration. As
stipulated by EPA and OEPA,
Honeywell continues to maintain the
gas vents in the event that future
sampling is required. At this time,
however, no further sampling is
anticipated.
Honeywell began annual lagoons/
wetland monitoring in 2002. In 2012,
Honeywell submitted the Lagoon Area
Vegetation and Benthic Macroinvertebrate Monitoring Report, which
summarized the activities and findings
from the annual wetlands/ecological
assessments conducted within the
Lagoon Area (Lagoons 1, 2, 3, 4, and 5).
Based on consultation with OEPA, EPA
informed Honeywell that the final
decision to determine whether the reestablishment of the wetland/floodplain
community has been achieved would be
made after evaluating the field results
using OEPA’s Vegetation Index of Biotic
Integrity (VIBI) Assessment Process.
Honeywell agreed to perform the VIBI
assessment on three categories of
observed wetland vegetation—forested,
scrub/shrub, and emergent—in order to
properly represent and assess each
vegetative community. Honeywell
completed the VIBI Assessment in 2014.
Based on this assessment, OEPA and
EPA approved the discontinuation of
monitoring in Lagoons 1, 3, 4, and 5.
The VIBI assessment, however,
identified the need to address Lagoon 2
to control the invasive species Purple
Loosestrife.
Honeywell completed three herbicide
applications in Lagoon 2 in July 2015,
2016, and 2017. Honeywell conducted a
follow-up VIBI Assessment of Lagoon 2
in August 2019. The results of the 2019
VIBI are being evaluated. The Lagoon 2
vegetation will continue to be
monitored and maintained as part of
ongoing O&M.
The 1988, 1990, and 2007 RODs
require ICs at the Site. The ICs are a
protective measure used in conjunction
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with the containment and active
treatment methods to restrict property
use, maintain the integrity of the
cleanup remedies, and to assure longterm protectiveness for Site areas which
do not allow for unrestricted use/
unlimited exposure (UU/UE). The ICs
implemented at the Allied Chemical
Site include Environmental Covenants
(ECs), Environmental Restrictions, city
ordinances, and local zoning
requirements. A 1989 Unilateral
Administrative Order and a 2010
Consent Decree made the ICs a binding
requirement on Allied Chemical/
Honeywell. Copies of the ICs for the
Allied Chemical Site are available in the
February 2020 Updated Institutional
Control Implementation and Assurance
Plan (ICIAP) in the Docket.
The IC for the 8.5-acre portion of the
OU1 GDA that includes the landfill cap
and slurry wall (see ID 18 on Figure 2
in the Docket) is an EC that was
recorded with the Lawrence County
Recorder’s office on September 14,
2018. The EC requires isolation and
containment of the waste pit and
DNAPL, prohibits the use of
groundwater, prohibits residential
activities and exposure, and prohibits
activities that would interfere with the
slurry wall, cap and, groundwater
extraction remedies.
The EC for the remaining 1.5 acres of
the GDA that are outside the boundaries
of the cap and slurry wall, but above
areas with groundwater contamination
(Figure 2, IDs 22 and 23), restricts the
land use to commercial/industrial
activities, prohibits residential use and
other residential-type activities such as
schools, hospitals, assisted living and
daycare facilities, food stores,
restaurants and indoor and outdoor
entertainment and recreational facilities,
prohibits the consumption of
groundwater, and prohibits food chain
products, manufacturing, and
warehousing. This EC was recorded
with the County on September 14, 2018.
Land and groundwater use on the
OU2 CPLA (Figure 2, IDs 1 to 17) is
restricted by Environmental Deed
Restrictions recorded with the
Recorder’s office on August 22, 2002 in
Plat Book 10/Page 181. These deed
restrictions: Prohibit residential and
recreational exposure on the properties;
prohibit future use that is incompatible
with the remedial actions; prohibit the
consumption of groundwater and
interference with the remedy; and
ensure proper maintenance.
ECs are implemented on two on-site
parcels of the Tar Plant OU3 and one
off-site parcel (approximately 0.19 acres
of the sediment cap on off-site
property). The EC for the Tar Plant Main
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37775
Parcel property, which consists of the
16-acre landfill cap (Figure 2, ID 19) and
the EC for the 12-acre River Parcel
property, which includes the soil cap on
the river bank and part of the Ohio River
sediment cap, permit the properties to
be used only for commercial/industrial
activities, prohibit residential use and
other residential-type use, prohibit the
use of groundwater, and prohibit future
use that is incompatible with the
remedial actions and any interference
with the remedy. The EC for the River
Parcel also prohibits drilling, dredging,
and/or vessel anchoring on the capped
sediment area. These ECs were recorded
with the Lawrence County Recorder’s
office on September 14, 2018.
The EC for the off-site sediment parcel
in the Ohio River (Figure 2, ID 21) was
recorded with the Lawrence County
Recorder’s office on September 26,
2018. This EC prohibits any activities
which would interfere with or adversely
affect the integrity or the protectiveness
of the sediment cap, and does not
permit any drilling, dredging, and/or
vessel anchoring on the property.
Land and groundwater use on OU1,
OU3, and most of OU2 (the portion of
OU2 located within the City of Ironton)
is additionally restricted by the City of
Ironton Municipal Code Chapter 1272,
1977 and Code 1046.35, 2013. Chapter
1272 prohibits the installation of
groundwater wells within the City, with
the exception of wells installed on
commercial property used exclusively
and solely for irrigation. Zoning
ordinance Code 1046.35 restricts OU1,
OU3 and the OU2 property located in
Ironton to General Industrial Use.
Long-term stewardship (LTS) is
addressed at the Allied Chemical Site
through the implementation of the
ICIAP and IC monitoring, the ECs,
Environmental Deed Restrictions, and
local government controls, in
conjunction with engineering controls,
O&M, and routine Site inspections, to
ensure that the remedy remains
protective and continues to function as
intended. The Allied Chemical Site
achieved EPA’s Site-Wide Ready for
Anticipated Use designation on October
2, 2018.
Five-Year Reviews
The Allied Chemical Site requires
statutory five-year reviews (FYRs) due
to the fact that hazardous substances,
pollutants, or contaminants remain at
the Site above levels that allow for
unrestricted use/unlimited exposure
(UU/UE). EPA completed FYRs for the
Allied Chemical Site in 1999, 2004,
2009, 2014, and 2019.
EPA completed the most recent FYR
for the Site in September 2019. EPA’s
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2019 FYR found that the Site-wide
remedy protects human health and the
environment. The exposure pathways
that could result in unacceptable risks
are being controlled and the cleanup
remedies are operating as expected.
Site-wide threats have been addressed
through: Waste containment and
isolation (through the slurry wall, lowpermeability hazardous waste and solid
waste-compliant caps, soil, and
sediment covers, and wetlands
conversion); excavation with off-site
disposal or off-site energy recovery; onsite groundwater containment,
extraction and treatment; and ICs that
restrict land use, prohibit groundwater
use, and prevent activities that could
impair the integrity of the engineering
controls.
The 2019 FYR concluded that in order
for the remedy to be protective in the
long-term, an ICIAP needed to be
completed and the LTS procedures from
the ICIAP need to be incorporated into
the O&M plans for OUs 1, 2, and 3.
Honeywell submitted a revised ICIAP to
EPA on March 11, 2019 and an updated
ICIAP to EPA on February 14, 2020.
EPA approved Honeywell’s updated
ICIAP on March 5, 2020. EPA and OEPA
are currently evaluating whether the
O&M Plans for the Site need to be
amended to incorporate the ICIAP, or
whether the ICIAP can be implemented
as a stand-alone document in
conjunction with the current O&M Plans
for OU1, OU2 and OU3.
Copies of EPA’s 1999, 2004, 2009,
2014, and 2019 FYR Reports are
available in the Docket. EPA expects to
complete the next FYR for the Allied
Chemical Site in 2024.
Community Involvement
EPA satisfied public participation
activities for the Allied Chemical Site as
required by Sections 113(k)(2)(B)(i–v)
and 117 of CERCLA, 42 U.S.C.
9613(k)(2)(B)(i–v) and 9617. In 1986,
EPA developed a Community Relations
Plan for the Allied Chemical Site. EPA
established a local information
repository for the Site at the Briggs
Lawrence County Public Library in
Ironton, Ohio. EPA maintains a copy of
the administrative record documents for
the Allied Chemical Site at the local
information repository, at EPA’s Region
5 office in Chicago, Illinois, and on
EPA’s web page for the Allied Chemical
Site at https://www.epa.gov/superfund/
allied-chemical-ironton.
EPA distributed fact sheets to the
community throughout the Site
investigations and cleanups to inform
the public about Site activities. In 1986,
EPA held a public meeting to present
the findings of the OU1 and OU2 RI to
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the community. EPA released the FS
Reports and proposed cleanup plans for
the Site to the public in August 1988,
September 1990, and July 2007 at the
start of the OU1, OU2, and OU3 public
comment periods. EPA published
newspaper announcements advertising
EPA’s proposed cleanup plans for the
Site, the 30-day public comment
periods, and the availability of public
meetings, in the Ironton Tribune. EPA
mailed fact sheets summarizing the
proposed OU1, OU2 and OU3 cleanup
plans to individuals on the Site mailing
list.
EPA and OEPA conducted public
meetings on August 16, 1988 and
October 23, 1990. At the meetings, EPA
and OEPA explained the details of the
Allied Chemical OU1 and OU2 FSs,
discussed the proposed cleanup plans,
answered questions from the
community, and accepted public
comments. A court reporter was present
to record the meetings. EPA distributed
copies of the Proposed Plan fact sheets
at the meetings. EPA offered to hold a
public meeting to present and discuss
EPA’s proposed cleanup plan for OU3,
but a meeting was not requested.
EPA received a request to extend the
public comment period for the OU2
proposed cleanup plan during the
October 23, 1990 meeting. As a result,
EPA extended the comment period for
30 days. EPA published a notice of the
public comment period extension in the
Ironton Tribune. On November 7 and 8,
1990, EPA conducted interviews with
local officials, residents, and a local
environmental interest group to assess
community concerns regarding the Site
and to evaluate past community
relations activities. EPA used the
information collected during these
interviews to update the 1986
Community Relations Plan and EPA’s
mailing list.
On November 19, 1990, EPA and Ohio
EPA appeared before the Ironton City
Council and members of the public to
answer additional questions about the
Site and the proposed OU2 cleanup
plan. EPA distributed a ‘‘Question &
Answer’’ fact sheet to provide easy-tounderstand answers to the questions
raised by the community. EPA mailed a
copy of the ‘‘Question & Answer’’ fact
sheet to all individuals on the updated
mailing list for the Site.
EPA received three public comments
during the proposed plan public
comment period for OU1, 25 public
comments and one concern during the
comment period for OU2, and two
public comments during the comment
period for OU3. EPA responded to the
comments in Responsiveness
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Summaries attached to the 1988, 1990,
and 2007 RODs.
EPA issued fact sheets summarizing
the proposed ROD Amendments #1
(1995), #2 (1997), and #3 (1998), and
held thirty-day public comment periods
to accept comments on the proposed
ROD Amendments. EPA also held a
public meeting on March 30, 1995 to
discuss EPA’s proposed ROD
Amendment #1. EPA did not receive
any public comments on proposed ROD
Amendments #1 or #2, and only
positive comments on EPA’s proposed
ROD Amendment #3.
EPA placed a copy of the 2015 OU3
ESD and the 2020 OU2 ESD in the
information repositories at the Briggs
Lawrence Public Library and at EPA’s
Region 5 office, in the administrative
record file, and on EPA’s web page for
the Allied Chemical Site at https://
www.epa.gov/superfund/alliedchemical-ironton.
EPA published advertisements
announcing EPA’s FYRs for the Allied
Chemical Site in the local newspaper,
the Ironton Tribune, at the start of the
1999, 2004, 2009, 2014, and 2019 FYRs.
The newspaper announcements
informed the community about the start
and purpose of the FYRs and invited the
public to submit comments and
concerns about the Site to EPA. EPA
placed copies of the FYR Reports in the
local information repository at the
Briggs Lawrence County Public Library
and made them available on EPA’s
website.
In 2011, EPA and the City hosted a
workshop with Site property owners
and representatives from local
businesses, adjacent properties, local
educational and healthcare institutions,
and local and state government to plan
for Site reuse. In 2018, EPA conducted
interviews with the City of Ironton
mayor, residents, and businesses as part
of the 2019 FYR process, to document
any perceived problems or successes
with the remedy.
EPA has satisfied public participation
activities for this partial deletion of the
Allied Chemical Site as required by
CERCLA section 113(k), 42 U.S.C.
9613(k), and CERCLA section 117, 42
U.S.C. 9617. EPA arranged to publish an
advertisement announcing this
proposed direct final Partial Deletion
and the 30-day public comment period
in the Ironton Tribune concurrent with
publishing this partial deletion in the
Federal Register. Documents in the
deletion docket, which EPA relied on
for recommending the partial deletion of
the Allied Chemical Site from the NPL,
are available to the public at https://
www.regulations.gov and at https://
www.epa.gov/superfund/allied-
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chemical-ironton. Documents in the
Docket include maps which identify the
Allied Chemical Site; the locations of
OU1, OU2 and OU3; areas of
contamination and remediation; and the
ICIAP, FYRs, and other Site reports.
Determination That the Criteria for
Partial Deletion Have Been Met
The soil (land) portion of OU1 (GDA);
the soil (land) and lagoons portion of
OU2 (CPLA), except for the OU2 ROD
Soils Area 2 located within the bermed
area of the East Tank Farm (see Figure
3 in the Docket); and all of OU3 (which
only addressed contaminated soil and
sediment at the Tar Plant and in the
adjacent Ohio River), meet all of the site
completion requirements specified in
Office of Solid Waste and Emergency
Response (OSWER) Directive 9320.2–22,
Close Out Procedures for National
Priorities List Sites. All cleanup actions
and remedial action objectives for OU1
soil, OU2 soil and lagoons (except for
OU2 ROD Soils Area 2), and OU3 set
forth in the 1988, 1990, and 2007 RODs,
the 1995 to 1998 ROD Amendments #1
to #3, and the 2015 ESD have been
implemented for all pathways of
exposure. The selected remedial actions,
RAOs, and associated cleanup levels for
OU1 soil, OU2 soil, and lagoons (except
for OU2 ROD Soils Area 2) and OU3 are
consistent with EPA policy and
guidance. No further Superfund
response is necessary to protect human
health or the environment from the soil
portion of OU1, the soil and lagoons
portion of OU2 (except for OU2 ROD
Soils Area 2), or from OU3.
Section 300.425(e) of the NCP states
that a Superfund site or a portion of a
site may be deleted from the NPL when
deletion will not take effect. EPA will
prepare a response to comments and
continue with the deletion process on
the basis of the notice of intent to
partially delete and the comments
already received. There will be no
additional opportunity to comment.
no further response is appropriate. EPA,
in consultation with the State of Ohio,
has determined that all required
response actions have been
implemented for the soil portion of
OU1, the soil and lagoons portion of
OU2 (except for the OU2 ROD Soils
Area 2), and all of OU3, and that no
further response action is appropriate
for these media/areas.
List of Subjects in 40 CFR Part 300
Environmental protection, Air
pollution control, Chemicals, Hazardous
substances, Hazardous waste,
Intergovernmental relations, Penalties,
Reporting and recordkeeping
requirements, Superfund, Water
pollution control, Water supply.
V. Deletion Action
EPA, with concurrence of the State of
Ohio, through the OEPA, has
determined that all appropriate
response actions under CERCLA, other
than maintenance, monitoring, and fiveyear reviews, have been completed for
the soil (land) portion of OU1 (GDA),
the soil (land) and lagoons portion of
OU2 (CPLA), except for the OU2 ROD
Soils Area 2 located within the bermed
area of the East Tank Farm (see Figure
3 in the Docket), and all of OU3 (which
only addressed contaminated soil and
sediment at the Tar Plant and in the
adjacent Ohio River) of the Allied
Chemical Site. Therefore, EPA is
deleting the soil portion of OU1, the soil
and lagoons portion of OU2 except for
the OU2 ROD Soils Area 2, and all OU3,
of the Allied Chemical Site from the
NPL.
Because EPA considers this action to
be noncontroversial and routine, EPA is
taking it without prior publication. This
action will be effective August 24, 2020
unless EPA receives adverse comments
by July 24, 2020. If adverse comments
are received within the 30-day public
comment period, EPA will publish a
timely notice of withdrawal of this
direct final Notice of Partial Deletion
before its effective date and the partial
Dated: June 11, 2020.
Kurt Thiede,
Regional Administrator, Region 5.
For the reasons set out in this
document, 40 CFR part 300 is amended
as follows:
PART 300—NATIONAL OIL AND
HAZARDOUS SUBSTANCES
POLLUTION CONTINGENCY PLAN
1. The authority citation for part 300
continues to read as follows:
■
Authority: 33 U.S.C. 1251 et seq.; 42
U.S.C. 9601–9675; E.O. 13626, 77 FR 56749,
3 CFR, 2013 Comp., p. 306; E.O. 12777, 56
FR 54757, 3 CFR, 1991 Comp., p. 351; E.O.
12580, 52 FR 2923, 3 CFR, 1987 Comp.,
p. 193.
2. Table 1 of appendix B to part 300
is amended by revising the entry under
‘‘Allied Chemical & Ironton Coke’’,
‘‘OH’’ to read as follows:
■
Appendix B to Part 300—[Amended]
TABLE 1—GENERAL SUPERFUND SECTION
State
Site name
City/county
*
*
OH ............................................
*
*
*
Allied Chemical & Ironton Coke ...............................................
*
Ironton .....................................
*
*
*
*
*
*
(a) * * *
P = Sites with partial deletion(s).
*
*
*
*
*
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(a)
*
P
*
Agencies
[Federal Register Volume 85, Number 122 (Wednesday, June 24, 2020)]
[Rules and Regulations]
[Pages 37763-37777]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-13302]
-----------------------------------------------------------------------
ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 300
[EPA-HQ-SFUND-1983-0002; FRL-10010-67-Region 5]
National Oil and Hazardous Substances Pollution Contingency Plan;
National Priorities List: Partial Deletion of the Allied Chemical &
Ironton Coke Superfund Site
AGENCY: Environmental Protection Agency (EPA).
ACTION: Direct final rule.
-----------------------------------------------------------------------
SUMMARY: The Environmental Protection Agency (EPA) Region 5 is
publishing a direct final Notice of Partial Deletion of soil (land),
lagoon, and sediment portions of the Allied Chemical & Ironton Coke
Superfund Site (Site), in Ironton, Ohio, from the National Priorities
List (NPL). The NPL, promulgated pursuant to Section 105 of the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) of 1980, as amended, is an appendix of the National Oil and
Hazardous Substances Pollution Contingency Plan. This direct final
partial deletion is being published by EPA with the concurrence of the
State of Ohio, through the Ohio Environmental Protection Agency,
because all appropriate response actions for these Site media under
CERCLA have been completed. However, this partial deletion does not
preclude future actions under Superfund. This partial deletion does not
include the OU2 ROD Soils Area 2 or the groundwater portions of the
Site, which will remain on the NPL.
DATES: This direct final partial deletion is effective August 24, 2020
unless EPA receives adverse comments by July 24, 2020. If adverse
comments are received, EPA will publish a timely withdrawal of the
direct final partial deletion in the Federal Register informing the
public that the partial deletion will not take effect.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
SFUND-1983-0002 by one of the following methods:
https://www.regulations.gov. Follow the on-line instructions for
submitting comments. Once submitted, comments cannot be edited or
removed from Regulations.gov. The EPA may publish any comment received
to its public docket. Do not submit electronically any information you
consider to be Confidential Business Information (CBI) or other
information whose disclosure is restricted by statute. Multimedia
submissions (audio, video, etc.) must be accompanied by a written
comment. The written comment is considered the official comment and
should include discussion of all points you wish to make. The EPA will
generally not consider comments or comment contents located outside of
the primary submission (i.e. on the web, cloud, or other file sharing
system). For additional submission methods, the full EPA public comment
policy, information about CBI or multimedia submissions, and general
guidance on making effective comments, please visit https://www.epa.gov/dockets/commenting-epa-dockets.
Email: [email protected].
Written comments submitted by mail are suspended and no hand
deliveries will be accepted. We encourage the public to submit comments
via email or at https://www.regulations.gov.
Instructions: Direct your comments to Docket ID no. EPA-HQ-SFUND-
1983-0002. EPA's policy is that all comments received will be included
in the public docket without change and may be made available online at
https://www.regulations.gov, including any personal information
provided, unless the comment includes information claimed to be CBI or
other information whose disclosure is restricted by statute. Do not
submit information that you consider to be CBI or otherwise protected
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Docket: All documents in the docket are listed in the https://www.regulations.gov index. Although listed in the index, some
information is
[[Page 37764]]
not publicly available, e.g., CBI or other information whose disclosure
is restricted by statute. Certain other material, such as copyrighted
material, will be publicly available only in hard copy. Publicly
available docket materials are available electronically at https://www.regulations.gov and at https://www.epa.gov/superfund/allied-chemical-ironton or you may contact the person identified in the FOR
FURTHER INFORMATION CONTACT section for additional availability
information.
The EPA is suspending its Docket Center and Regional Records
Centers for public visitors to reduce the risk of transmitting COVID-
19. In addition, many site information repositories are closed and
information in these repositories, including the deletion docket, has
not been updated with hardcopy or electronic media. For further
information and updates on EPA Docket Center services, please visit us
online at https://www.epa.gov/dockets.
The EPA continues to carefully and continuously monitor information
from the Centers for Disease Control and Prevention (CDC), local area
health departments, and our Federal partners so that we can respond
rapidly as conditions change regarding COVID-19.
FOR FURTHER INFORMATION CONTACT: Karen Cibulskis, NPL Deletion
Coordinator, U.S. Environmental Protection Agency Region 5, at (312)
886-1843 or via email at [email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
II. NPL Deletion Criteria
III. Partial Deletion Procedures
IV. Basis for Partial Site Deletion
V. Partial Deletion Action
I. Introduction
EPA Region 5 is publishing this direct final Notice of Partial
Deletion of the Allied Chemical & Ironton Coke Superfund Site (Allied
Chemical Site or Site), from the NPL. The Allied Chemical Site covers
129 acres and includes three operable units (OUs). The Goldcamp
Disposal Area (GDA) is OU1. The former Coke Plant/Lagoon Area (CPLA) is
OU2. The former Tar Plant is OU3. See Figures 1 and 2 in the Docket.
Groundwater contamination is present below all three OUs, but is
addressed as part of the OU1 and OU2 cleanup remedies.
This partial deletion pertains to the soil (land) portion of OU1
(GDA); the soil (land) and lagoons portion of OU2 (CPLA) except for the
OU2 ROD Soils Area 2 located within the bermed area of the East Tank
Farm (see Figure 3 in the Docket); and all of OU3 (which only addressed
contaminated soil and sediment at the Tar Plant and in the adjacent
Ohio River). The OU2 ROD Soils Area 2 located within the bermed area of
the East Tank Farm contains components of the groundwater treatment
system and will not be remediated until after the groundwater cleanup
is complete. Therefore, the OU2 ROD Soils Area 2 is not being
considered for deletion as part of this action. The contaminated
groundwater at the Site, which is present below all three OUs but is
being addressed as part of the OU1 and OU2 cleanup remedies, is
undergoing a long-term cleanup and is also not being considered for
deletion as part of this action. The OU2 ROD Soils Area 2 and the
groundwater portions of the Allied Chemical Site (i.e., the groundwater
portion of OU1 and OU2, which includes the contaminated groundwater
below OU3) will remain on the NPL.
The NPL constitutes Appendix B of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), which EPA promulgated
pursuant to CERCLA. EPA maintains the NPL as the list of sites that
appear to present a significant risk to public health, welfare, or the
environment. Sites on the NPL may be the subject of remedial actions
financed by the Hazardous Substance Superfund (Fund). This partial
deletion of the Allied Chemical Site is proposed in accordance with 40
CFR 300.425(e) and is consistent with the Notice of Policy Change:
Partial Deletion of Sites Listed on the National Priorities List. 60 FR
55466 (Nov. 1, 1995). As described in 40 CFR 300.425(e)(3) of the NCP,
a portion of a site deleted from the NPL remains eligible for Fund-
financed remedial actions if future conditions warrant such actions.
Section II of this document explains the criteria for deleting
sites from the NPL. Section III discusses the procedures that EPA is
using for this action. Section IV discusses the soil, lagoons, and
sediment portions of OU1, OU2, and OU3 of the Allied Chemical Site
included in this partial deletion and demonstrates how these media/
areas meet the deletion criteria. Section V discusses EPA's action to
partially delete the soil, lagoons, and sediment in OU1, OU2, and OU3
of the Allied Chemical Site (except for the soil in OU2 ROD Soils Area
2) from the NPL unless adverse comments are received during the public
comment period.
II. NPL Deletion Criteria
The NCP establishes the criteria that EPA uses to delete sites from
the NPL. In accordance with 40 CFR 300.425(e), sites, or portions
thereof, may be deleted from the NPL where no further response is
appropriate. In making such a determination pursuant to 40 CFR
300.425(e), EPA will consider, in consultation with the state, whether
any of the following criteria have been met:
i. Responsible parties or other persons have implemented all
appropriate response actions required;
ii. all appropriate Fund-financed response under CERCLA has been
implemented, and no further response action by responsible parties is
appropriate; or
iii. the remedial investigation has shown that the release poses no
significant threat to public health or the environment and, therefore,
the taking of remedial measures is not appropriate.
Pursuant to CERCLA Section 121(c) and the NCP, EPA conducts five-
year reviews to ensure the continued protectiveness of remedial actions
where hazardous substances, pollutants, or contaminants remain at a
site above levels that allow for unlimited use and unrestricted
exposure. EPA conducts such five-year reviews even if a site or a
portion of a site is deleted from the NPL. EPA may initiate further
action to ensure continued protectiveness at a deleted site if new
information becomes available that indicates it is appropriate.
Whenever there is a significant release from a site deleted from the
NPL, the deleted site may be restored to the NPL without application of
the hazard ranking system.
III. Partial Deletion Procedures
The following procedures apply to the deletion of the soil,
lagoons, and sediment portions of OU1, OU2, and OU3 of the Allied
Chemical Site, excluding the OU2 ROD Soils Area 2:
(1) EPA consulted with the State of Ohio prior to developing this
direct final Notice of Partial Deletion and the Notice of Intent for
Partial Deletion co-published in the ``Proposed Rules'' section of the
Federal Register.
(2) EPA has provided the State 30 working days for review of this
notice and the parallel Notice of Intent to Partially Delete prior to
their publication today, and the State, through the Ohio Environmental
Protection Agency (OEPA), concurred on the partial deletion of the
Allied Chemical Site from the NPL on March 6, 2020.
(3) Concurrent with the publication of this direct final Notice of
Partial Deletion, an announcement of the availability of the parallel
Notice of Intent for Partial Deletion is being published in a major
local newspaper,
[[Page 37765]]
the Ironton Tribune. The newspaper notice announces the 30-day public
comment period concerning the Notice of Intent for Partial Deletion of
the Allied Chemical Site from the NPL.
(4) The EPA placed copies of documents supporting the partial
deletion in the deletion docket and made these items available for
public inspection and copying at https://www.regulations.gov and at
https://www.epa.gov/superfund/allied-chemical-ironton.
(5) If adverse comments are received within the 30-day public
comment period on this partial deletion action, EPA will publish a
timely notice of withdrawal of this direct final Notice of Partial
Deletion before its effective date and will prepare a response to
comments and continue with the deletion process on the basis of the
Notice of Intent for Partial Deletion and the comments already
received.
Deletion of a portion of a site from the NPL does not itself
create, alter, or revoke any individual's rights or obligations.
Deletion of a portion of a site from the NPL does not in any way alter
EPA's right to take enforcement actions, as appropriate. The NPL is
designed primarily for informational purposes and to assist EPA
management. Section 300.425(e)(3) of the NCP states that the deletion
of a site from the NPL does not preclude eligibility for further
response actions, should future conditions warrant such actions.
IV. Basis for Partial Site Deletion
The following information provides EPA's rationale for deleting the
soil, lagoons, and sediment portions of OU1, OU2, and OU3, except for
the soil in OU2 ROD Soils Area 2, of the Allied Chemical Site from the
NPL.
Site Background and History
The Allied Chemical Site (OHD043730217) is 129 acres and is located
at 3330 South Third Street in Ironton, Lawrence County, Ohio (see
Figure 1 in the Docket). The Site is surrounded by industries,
businesses, private residences, waterways, and wetlands. Part of the
Site is adjacent to, and includes, a portion of the Ohio River.
The Allied Chemical Site is divided into three OUs (see Figure 2 in
the Docket). OU1 is the Goldcamp Disposal Area (GDA) and is 10 acres in
size. The GDA is a former sand and gravel pit that was used to dispose
waste from the Site's Tar Plant, as well as waste from the Goldcamp
Gravel Company and foundry sand from a nearby iron works.
OU2 is the former Coke Plant/Lagoon Area (CPLA). The CPLA covers 91
acres and contained the former Coke Plant and five lagoons. The CPLA is
bordered by Ice Creek to the east and south. Ice Creek flows into the
Ohio River and portions of the CPLA are within the 100 year floodplain.
Eastern portions of the CPLA extend into the adjacent Village of Coal
Grove, Ohio.
OU2 includes groundwater below the CPLA and in the former Tar Plant
area (OU3). Limited areas of soil contamination in OU3 were also
evaluated and addressed as part of OU2.
OU3 is the former Tar Plant area. The Tar Plant OU is 28 acres and
consists of two parcels, the Main Parcel and the River Parcel. The Main
Parcel is 16 acres and contained the former Tar Plant facility. The
River Parcel is 12 acres and includes seven acres of the Ohio River
(this varies with river elevation). The Main Parcel and the River
Parcel of OU3 are separated by an active railroad track.
Initial operations at the Allied Chemical Site began with the
Ironton Solvay Coke Company (Ironton) Coke Plant (OU2). In 1926,
Ironton and other companies united to form the Allied Chemical & Dye
Corporation (Allied Chemical). From 1981 to 1999, Allied Chemical went
through additional name changes, mergers and acquisitions and is
currently Honeywell International Inc. (Honeywell).
The Coke Plant operated from 1917 to 1982. Products from the coking
operations included: Crude tar, coke, light oil, and ammonia. From 1920
through the 1960s, the facility discharged wastewater and solid wastes
generated during the coking process into the marshy area east of the
plant adjacent to Ice Creek. The waste streams included process
wastewater, coke and coal fines, tar decanter sludges, boiler ash, and
weak ammonia liquor. Specific constituents present in the waste streams
included: Ammonia, benzene, cyanide, metals, naphthalene, phenolics,
and polynuclear aromatic hydrocarbons (PAHs).
In the early 1970s, Allied Chemical constructed a wastewater
treatment plant (WWTP) and a series of lagoons in the marshy area of
the Coke Plant to treat the waste streams from the Coke Plant and the
Tar Plant. The treated wastewater discharged to the Ohio River through
two permitted outfalls, Outfall 001 and Outfall 002. Outfall 002 was
taken out of service in 2001.
In 1977, Allied Chemical sold the Coke Plant to the McClouth Steel
Corporation (McClouth Steel). In 1982, McClouth Steel filed for
bankruptcy and the Coke Plant was shut down.
Iron City Fuels, Inc. (Iron City Fuels) purchased the Coke Plant
property for salvaging after the Coke Plant closed. In 1984, Allied
Chemical re-purchased the Coke Plant property, excluding the surface
facilities, from Iron City Fuels. Iron City Fuels retained the surface
facilities at the Coke Plant for salvaging until 1985.
Iron City Fuels completed their salvage operations and transferred
the surface facilities back to Allied Chemical in 1985. In 1987, Allied
Chemical entered into a CERCLA Section 106(a) Administrative Order on
Consent (AOC) with EPA and OEPA to remove six remaining above-ground
storage tanks, 4,700 cubic feet of tar decanter sludge (a K087
hazardous waste), and the material in the #4 weak liquor storage tank
from the CPLA for off-site disposal.
Allied Chemical operated the Tar Plant (0U3) from 1945 until 2000
when the Tar Plant closed. The Tar Plant manufactured products from the
crude tar produced at the Coke Plant. The Tar Plant contained 124 above
ground storage tanks for various coal tar derivatives and chemicals,
and numerous buildings housing administrative, laboratory, storage, and
maintenance activities. After the Tar Plant closed, the Tar Plant
facilities were demolished. The Tar Plant property demolition was
completed in 2003.
Specific products from the Tar Plant included: Phthalic anhydride,
creosotes, pitches, naphthalene, road tar, driveway sealer, roofing
pitch, and anthracene. The Tar Plant disposed the wastes and residues
generated during the manufacturing processes to the adjacent GDA (OU1).
These wastes included: Anthracene residues and salts, coal tar pitch
scrap, and phthalic anhydride residues.
The GDA was a former sand and gravel pit that was approximately 40
feet deep. The GDA received waste from the Tar Plant, as well as waste
from the sand and gravel company and foundry sand from a nearby iron
foundry.
Allied Chemical purchased the GDA property in 1955. In 1961, the
construction of the Greenup Dam on the Ohio River raised the water
levels of the river and adjacent groundwater, causing the waste at the
bottom of the GDA to be in direct contact with the groundwater.
Allied Chemical stopped using the GDA for waste disposal in 1977
and developed a plan for closing the GDA in consultation with OEPA. The
closure included: Removing standing liquid from the GDA for off-site
disposal, filling the GDA to surface grade, and
[[Page 37766]]
capping the GDA with clay. Allied Chemical completed the GDA closure in
1980.
EPA inspected the Allied Chemical Site and completed a Site
Inspection Report in 1980. In 1982, OEPA sampled the five Coke Plant
lagoons and collected groundwater samples from the Site. OEPA detected
high concentrations of PAHs in the lagoon sludge [total PAH
concentrations as high as 148,000 milligrams per kilogram (mg/kg) in
Lagoon 5] and high levels of cyanide, arsenic, phenol, and metals in
the liquid fractions of the lagoons. OEPA detected arsenic in the
groundwater at concentrations as high as 120,000 micrograms per liter
([micro]g/l) and benzene at concentrations as high as 1,200 [micro]g/l.
EPA completed a Preliminary Assessment Report and a Remedial Action
Master Plan for the Site in 1983. EPA proposed the Site to the NPL on
December 30, 1982 (47 FR 58476) due to the potential for groundwater
contaminants to affect private well supplies, as well as the Ohio River
and Ice Creek, which supply municipal drinking water. EPA finalized the
Allied Chemical Site on the NPL on September 8, 1983 (48 FR 40658).
EPA finalized: Cleanup remedies for the Allied Chemical Site in
Records of Decision (RODs) issued in 1988, 1990, and 2007; ROD
Amendments in 1995, 1997, and 1998; and Explanations of Significant
Differences (ESD) in 2015 and 2020. Allied Chemical/Honeywell
implemented the EPA-selected cleanup actions for the Site from 1993 to
2015. In 2016, EPA issued a Preliminary Close Out Report documenting
that Allied Chemical/Honeywell constructed the cleanup remedies
consistent with all requirements and that the cleanups were protective
of human health and the environment.
The OU1 property (GDA) is currently owned by Honeywell. The
majority of the OU1 property is a capped landfill and the perimeter is
fenced. There is presently no anticipated future use for the portion of
OU1 located over the landfill. Honeywell split approximately 1.4 acres
of OU1 near Third Street that is not part of the landfill from the
original parcel, and this property is available for redevelopment.
The OU2 property (Coke Plant/Lagoon Area) is divided into 17
parcels of land. Allied Corporation (i.e., Honeywell) currently owns
two of the 17 parcels: Parcel 2, located in the City of Ironton and
Parcel 1 located in the Village of Coal Grove (see Figure 2 in the
Docket). Parcel 2 contains the former lagoons which were converted into
wetlands and the upgraded WWTP that treats the extracted groundwater
from the Site prior to discharge to the Ohio River. Parcel 2 is under
security and monitoring by a Honeywell contractor stationed at the WWTP
seven days a week during business hours and via telemetry 24 hours per
day. Parcel 1 contains a portion of the Lagoon Area and a portion of
Ice Creek. A section of Parcel 1 has also been converted into wetlands.
The entire perimeter of the WWTP and the lagoons is secured by a chain-
link fence with posted warning signs maintained by Honeywell's
contractors.
Honeywell donated Parcel 4 of OU2 to the Ironton Port Authority in
2008. Honeywell sold the remaining OU2 parcels to the City of Ironton
(City) for use as an industrial park in 2002. The City sold various
parcels of OU2 for redevelopment.
The two OU3 parcels, the Main Parcel and the River Parcel, are
currently owned by Honeywell/Allied Chemical. The Main Parcel is
covered by a low-permeability cover and the perimeter is fenced. The
River Parcel has a 2-foot soil cover and a sediment cover. The access
road is gated to prevent vehicles from entering the area.
In 2011, EPA's contractor performed a reuse assessment to identify
future land use considerations and opportunities and to coordinate
reuse goals for the Site. On September 22, 2011, EPA and the City
hosted a workshop to plan for Site reuse. Participants included Site
owners and representatives from local businesses, adjacent properties,
local educational and healthcare institutions, and local and state
government. During the workshop, participants gave input regarding
future uses and priorities for the Site.
In 2012, EPA's contractor completed a ``Reuse Framework'' report,
which summarized the outcomes of the workshop and the findings of a
reuse suitability assessment for the Site. This document includes reuse
considerations and opportunities for education, workforce development,
and Site improvements that can position the Site for productive reuse.
Several of the OU2 Site parcels have been redeveloped. The
ownership information for the OU2 parcels is summarized on Figure 2 in
the Docket. The active stakeholders, their interests, and their contact
information is summarized in Table 1 of the 2020 Institutional Controls
Implementation & Assurance Plan, which is available in the Docket.
This partial deletion pertains to the soil (land) portion of OU1
(GDA); the soil (land) and lagoons portion of OU2 (CPLA), except for
the OU2 ROD Soils Area 2 located within the bermed area of the East
Tank Farm (see Figure 3 in the Docket); and all of OU3 (which only
addressed contaminated soil and sediment at the Tar Plant and in the
adjacent Ohio River).
The OU2 ROD Soils Area 2 located within the bermed area of the East
Tank Farm contains components of the groundwater treatment system and
will not be remediated until after the groundwater cleanup is complete.
Therefore, the OU2 ROD Soils Area 2 is not being considered for
deletion as part of this action. The contaminated groundwater at the
Site, which is present below all three OUs but is being addressed as
part of the OU1 and OU2 cleanup remedies, is undergoing a long-term
cleanup and is also not being considered for deletion as part of this
action. The OU2 ROD Soils Area 2 and the groundwater portions of the
Allied Chemical Site (i.e., the groundwater portion of OU1 and OU2,
which includes the contaminated groundwater below OU3) will remain on
the NPL.
Remedial Investigation and Feasibility Study (RI/FS)
Allied Chemical entered into an AOC with EPA and OEPA to conduct a
Site-wide Remedial Investigation (RI) and Feasibility Study (FS) at the
Allied Chemical Site in 1984. The purpose of the RI was to characterize
the nature and extent of contamination associated with the Site and the
impact of the contamination on human health and the environment. The
purpose of the FS was to develop and evaluate cleanup alternatives to
address the unacceptable risks posed by the Site.
Allied Chemical conducted field investigations at the Site in 1984
and finalized the RI Report in 1986. The 1986 RI included: (1) The
installation and sampling of over 45 groundwater monitoring wells; (2)
collection and analysis of over 200 groundwater samples; (3) collection
and analysis of over 200 soil samples; (4) collection and analysis of
over ten surface water samples; (5) continuous sampling and analysis of
air samples during sampling and excavation; (6) excavation and sampling
of waste in over 20 test pits; and (7) collection and analysis of over
1000 samples of fish tissue. The soil and waste samples were analyzed
for six Site-specific indicator chemicals: Phenolics, benzene,
naphthalene, cyanide, ammonia, and chloride. The groundwater and
municipal water samples were analyzed for the six indicator chemicals
and EPA's Target Analyte List (TAL) inorganic and Target Compound List
(TCL) chemicals.
The 1986 RI determined that the 4-acre waste pit in the GDA
contained
[[Page 37767]]
approximately 300,000 cubic yards of waste material, including
hazardous substances disposed from the Tar Plant and the Coke Plant.
The bottom five feet of the waste was below the water table and in
direct contact with groundwater. The surface of the GDA was a source of
contamination because contaminated substances oozed up through the
existing cap and collected on the GDA surface. The contaminants of
concern (COCs) in the GDA were: Benzene, naphthalene, phenolics,
cyanide, ammonia, sulfate, chloride, and the PAHs benz(a)anthracene,
benzo(a)pyrene, chrysene, and dibenz(a,h)anthracene.
The groundwater below the GDA was contaminated. The groundwater
contamination extended west to the Ohio River and to the production
wells located at the Amcast company (formerly Ironton Iron Inc.)
located 1,000 feet north of the GDA. Amcast Production Well No. 7
contained benzene at concentrations as high as 36 [micro]g/l. These
concentrations were above the Safe Drinking Water Act Maximum
Contaminant Level (MCL) for benzene of 5 [micro]g/l. Dense non-aqueous
phase liquid (DNAPL) was present on top of the bedrock below the GDA.
Total petroleum hydrocarbon concentrations in the DNAPL were 100 to 250
parts per million. Due to the groundwater contamination, Allied
Chemical began providing bottled drinking water to Amcast for its
employees in 1986.
The 1986 RI found seven areas of soil contamination in the Coke and
Tar Plant areas that required cleanup (see Figures 3 and 4 in the
Docket). The soils were contaminated with benzo(a)pyrene, a
carcinogenic PAH (PAHc). The maximum concentrations of benzo(a)pyrene
detected in the contaminated soil were: 150 mg/kg in Area 1, 60 mg/kg
in Area 2, 330 mg/kg in Area 3, 96 mg/kg in Area 4, and 39 mg/kg in
Area 5. The total amount of soils requiring cleanup in the Coke Plant
area was 38,000 cubic yards. Approximately 2,000 cubic yards of soil
required cleanup in the Tar Plant area.
The 1986 RI found that Lagoons 1 through 4 in the CPLA contained
waste coal and coke, and general debris, including bricks, pieces of
metal, and tar. Lagoons 1 and 3 also contained lime kiln sludge (K060),
a listed hazardous waste under the Resource Conservation and Recovery
Act (RCRA) based on the content of cyanide, naphthalene, phenolic
compounds, and arsenic. The analytical sampling indicated that the
material in Lagoons 1 through 4 was contaminated with widely varying
concentrations of PAHs, ammonia, cyanide, phenolics, sulfate, benzene,
and arsenic.
Lagoon 5 in the CPLA was used to dispose decanter tank tar sludge
(K087), a RCRA listed hazardous waste based on phenol and naphthalene
content. Lagoon 5 was also believed to contain waste coal and coke
materials. Lagoon 5 was approximately 40 feet deep and contained
approximately 122,000 cubic yards of waste. About five to 15 feet of
the waste was below the water table. Analytical sampling in Lagoon 5
detected high concentrations of carcinogenic PAHs. Although the
solubility and mobility of PAHs is low, the chemicals are potent
carcinogens.
The 1986 RI found that the sediments of Ice Creek downstream from
the Site were contaminated from the discharge of wastewater from the
Coke Plant operations. The sampling indicated that downstream sediments
contained Site-related concentrations of phenolics, naphthalene,
ammonia, and cyanide. An examination of 214 fish collected from Ice
Creek and the Ohio River, however, did not show any neoplastic liver
lesions in the fish. Surface water samples collected downstream of the
Site contained higher concentrations of chloride and ammonia than
upstream samples, but the concentrations were well below EPA's Water
Quality Criteria.
The groundwater in the CPLA and the Tar Plant area was contaminated
with several contaminants, including phenolics, ammonia, cyanide,
chloride, naphthalene, and benzene. The pattern of groundwater
contamination indicated that the contamination was due to a number of
localized on-site sources. The data also indicate that DNAPL was
present above the surface of the bedrock at some locations.
Groundwater modeling conducted during the RI indicated that the
groundwater below the CPLA and Tar Plant flowed toward Ice Creek and
the Ohio River. The modeling indicated that the Coal Grove well field
located approximately 2,000 feet south of the CPLA, which provides
drinking water to about 2,840 residents, obtains approximately 27
percent of its water from Ice Creek leakage, 29 percent of its water
from the Ohio River, 41 percent of its water from the aquifer southeast
of the well field away from the Site, and three percent of its water
from Site groundwater flowing underneath Ice Creek. The modeling and
the actual analysis of the Coal Grove municipal water indicated that no
drinking water standards were being exceeded in the Coal Grove
wellfield as a result of the Allied Chemical Site.
The 1986 RI concluded that contaminated groundwater from the CPLA
and Tar Plant was discharging to the Ohio River, but the discharge was
not detectable since the river contained contaminants similar to those
found in Site groundwater upstream and downstream of the Site.
Contaminant loading modeling indicated that the groundwater
contaminants discharging to the Ohio River would not be detectable at
the City of Ironton's drinking water intake.
Allied Chemical conducted air sampling during the 1986 RI during
worst-case conditions by collecting air samples when the most highly
contaminated material at the Site, the tar sludge in Lagoon 5, was
disturbed with a backhoe. Allied Chemical did not detect any
discernible atmospheric volatile organic emissions at the perimeter of
the tar sludge area during this sampling.
After the 1986 RI was complete, EPA, OEPA, and Allied Chemical
divided the Site into two OUs to expedite the completion of the FS for
the GDA (OU1). Allied Chemical completed an Endangerment Assessment and
a FS Report for the GDA in 1988. Allied Chemical completed an
Endangerment Assessment and a FS Report for the remaining areas of the
Site (OU2) in 1990. The OU2 Endangerment Assessment and FS addressed
the CPLA, contaminated groundwater below the Tar Plant, and limited
areas of soil contamination at the Tar Plant.
Allied Chemical's EA for the GDA examined potential contaminant
exposure pathways from the GDA including ground water, surface water
(Ohio River contamination via ground water), soil, and air. The
potential receptors included Amcast workers drinking contaminated
groundwater from Amcast's wells (if bottled water was not supplied),
recreational users in the Ohio River ingesting surface water, and
workers at the closest business inhaling airborne contaminants. The GDA
was covered and fenced, so direct contact with the wastes was not
considered a major exposure pathway.
The OU2 EA for the CPLA (and some portions of the Tar Plant)
evaluated potential risks to current Coal Grove residents from:
Inhalation of downwind dust and vapors; dermal contact with and the
incidental ingestion of water in Ice Creek while swimming; using Coal
Grove municipal water for drinking and showering; incidental ingestion
of contaminated soil while trespassing; and eating fish from Ice Creek.
The EA also evaluated potential risks to hypothetical future residents
living on the CPLA property and using the
[[Page 37768]]
contaminated groundwater as a water supply.
The EA for the GDA determined that the contaminated groundwater
from the GDA posed an unacceptable risk to people using the groundwater
as a source of drinking water. The excess lifetime cancer risk was 6.7
x 10-\3\. This risk was greater than EPA's acceptable cancer
risk range of 1 x 10-\4\ to 1 x 10-\6\. The
noncancer hazard index (HI) calculated for exposure to the GDA
groundwater was 3.0, which is greater than EPA's acceptable noncancer
HI of 1.0.
Recreational use of the Ohio River did not pose a risk since
sampling results did not indicate a significant increase of Site-
related contaminants in the Ohio River downstream of the GDA. Air
modeling also indicated that potential air releases from the GDA did
not pose a significant risk via the air pathway (an excess lifetime
cancer risk of 1.6 x 10-\6\).
The OU2 EA for the CPLA and portions of the Tar Plant identified
unacceptable potential future risks to hypothetical residents living on
the CPLA property. The potential future cancer risk was 5.7 x
10-\3\ for children and 3.4 x 10-\3\ for adults.
The unacceptable noncancer HIs were 7.1 for children and 4.0 for
adults. The cancer risks were primarily due to the concentrations of
PAHs in the soil and to benzene and arsenic in the groundwater. The
unacceptable noncancer risks were primarily due to cyanide
contamination in the groundwater.
The CPLA EA did not identify any unacceptable risks to current Coal
Grove residents. The total excess lifetime cancer risk calculated for
Coal Grove residents from all exposure pathways was 1.0 x
10-\5\ for children and 2.6 x 10-\5\ for adults.
The calculated noncancer HIs for Coal Grove residents for all pathways
were well below 1.0, with a maximum HI of 0.163.
At the time of the OU1 and OU2 RI/FS, the Tar Plant was an
operating facility with limited accessibility. In 2003, after the Tar
Plant closed and the area could be fully investigated, Honeywell
(formerly Allied Chemical) entered into a separate AOC with EPA to
conduct a RI/FS for the remaining areas of the Tar Plant (OU3) that
were not addressed or remediated as part of OU2. Honeywell completed
the Tar Plant OU3 RI/FS in 2007 and issued an OU3 RI Addendum in 2008.
The 2007 OU3 RI included: (1) The collection and analysis of 235
soil samples from 146 soil borings down to the water table; (2) 12
paired soil vapor and ambient air samples at locations of highest
contaminant concentrations; (3) the installation and sampling of 48
groundwater monitoring wells installed from 28 to 90 feet below ground
surface (with 21 locations nested) to horizontally and vertically
delineate the groundwater contamination; (4) the installation of 12
DNAPL wells to delineate the extent and thickness of the DNAPL and
allow for possible future recovery; and (5) the collection and analysis
of 37 Ohio River water and 29 sediment samples to evaluate impacts to
the river. Honeywell analyzed the 2007 RI samples for VOCs, PAHs,
polychlorinated biphenyls (PCBs), cyanide, arsenic, total phenols, and
ammonia. The groundwater samples were also analyzed for nitrate.
Honeywell's 2007 RI for the Tar Plant (OU3) found that the shallow
and deep soil on the Main Parcel of the Tar Plant was contaminated with
high levels of PAHs (as high as 44,100 mg/kg) and benzene, toluene,
ethylbenzene, and xylene (BTEX) (a maximum concentration of 406 mg/kg
BTEX). The distribution of PAHs and BTEX in the shallow soil was
similar to the distribution of the DNAPL. The soil also contained
lesser concentrations of arsenic (maximum concentration of 14.4 mg/kg),
PCBs (maximum concentration of 7.7 mg/kg total PCBs), phenols (280 mg/
kg), cyanide, and ammonia.
Shallow soil in the River Parcel contained high levels of PAHs and
BTEX. High levels of PAHs were also detected in sediment samples
collected from the Ohio River adjacent to the Site. The highest
concentrations of PAHs in sediment were located downstream of Outfall
001 and ranged from 184 mg/kg to 1,053 mg/kg.
Soil vapor in the Tar Plant OU contained benzene at concentrations
as high as 55,000 parts per billion/volume (ppbv) and other VOCs.
Benzene (maximum concentration of 0.31 ppbv), toluene, and naphthalene
were detected in ambient air.
DNAPL is present in the southern half of the Main Parcel of the Tar
Plant and has collected in depressions at the surface of the bedrock.
The soil boring data indicates that the DNAPL has not, and is not
likely to, migrate toward the Ohio River due to rises in the surface of
the bedrock between the Site and the river.
Honeywell completed a Human Health Risk Assessment (HHRA) and a
Screening Ecological Risk Assessment (SERA) for the Tar Plant (OU3) in
the 2007 Phase 1A RI Report. The HHRA evaluated risks to current
trespassers and to future recreational visitors, indoor and outdoor
commercial/industrial workers, and construction workers. The HHRA
evaluated exposure pathways including dermal contact with and the
incidental ingestion of surface and subsurface soil, dust inhalation,
the inhalation of ambient air and indoor contaminants via vapor
intrusion, dermal contact with and the incidental ingestion of surface
water, dermal contact with sediment, and the ingestion of groundwater.
The SERA evaluated potential impacts to ecological receptors from
exposure to soil and to surface water and sediment in the Ohio River
adjacent to the Site.
Honeywell's 2007 OU3 HHRA indicated that the Tar Plant posed an
unacceptable risk to current trespassers, future recreational users,
future indoor and outdoor commercial/industrial workers, and future
construction workers. The total excess lifetime cancer risks ranged
from 8 x 10-\4\ to 8 x 10-\3\. The noncancer HIs
ranged from 2 to 1201. The majority of the cancer and noncancer risks
were posed by PAHs in the surface and subsurface soil and by
concentrations of benzene, toluene, and naphthalene in soil vapor.
The results of the 2007 OU3 SERA indicated that the concentrations
of PAHs in the Tar Plant soil posed a hazard to soil invertebrates,
worm-eating birds, and predatory birds. Ecological hazard quotients
(HQs) greater than or equal to 100 were calculated in scattered areas
across the Tar Plant. The SERA also indicated that the concentrations
of COCs detected in surface water could cause adverse effects to
aquatic receptors. Additionally, the concentrations of Site-related
PAHs in sediment could cause adverse effects to benthic organisms
(direct contact) and piscivorous birds (food chain).
Allied Chemical and Honeywell conducted Feasibility Studies (FSs)
to develop and evaluate cleanup alternatives to address the
unacceptable risks associated with the GDA, the CLPA, and the Tar Plant
OUs.
The 1988 OU1 FS evaluated four cleanup alternatives for the GDA: No
action; slurry wall and cap with groundwater recovery wells inside and
outside of slurry wall; incinerate GDA waste and return residual
material to GDA, with slurry wall with groundwater recovery wells
inside and outside of slurry wall (no cap); and incinerate GDA waste
and subsoils with one groundwater recovery well (no slurry wall or
cap). All alternatives except the no-action alternative also included
groundwater treatment at the on-site WWTP with discharge to the Ohio
River under the existing or a modified NPDES permit, connecting Amcast
to the
[[Page 37769]]
municipal water supply, and a DNAPL investigation.
Allied Chemical completed the OU2 FS for the CPLA in 1990. The OU2
FS evaluated varying combinations of cleanup options for the CPLA.
Cleanup options for the lagoons and contaminated Coke Plant and OU2 Tar
Plant soils included: No action; on-site incineration and off-site
waste fuel recovery; partial bioremediation with on-site incineration;
partial bioremediation and off-site waste fuel recovery; partial off-
site waste fuel recovery with solidification/stabilization of residual
materials; and partial bioremediation with on-site waste fuel recovery
of lagoon materials and an asphalt and plastic layered cap over the
Coke Plant and OU2 Tar Plant soils.
Ice Creek sediment cleanup options included: Monitoring with
trigger levels for accelerated monitoring and groundwater remediation;
excavation and bioremediation of Ice Creek sediments with lagoon
materials; and solidification/stabilization of Ice Creek sediments. All
cleanup alternatives included groundwater collection with treatment at
the on-site WWTP with discharge to the Ohio River.
Honeywell completed the Tar Plant OU3 FS in 2007. The 2007 FS
evaluated eight cleanup alternatives for the contaminated Tar Plant
soils, two cleanup alternatives for air, and five cleanup alternatives
for Site-related sediment contamination in the Ohio River. The soil
alternatives included: No further action; soil cover; low-permeability
cover; limited excavation and off-site disposal with either a soil
cover or a low-permeability cover; limited excavation with on-site
consolidation and a soil cover or a low-permeability cover; and
extensive excavation and off-site disposal.
The cleanup alternatives evaluated for the contaminated sediment
included: No further action; monitored natural recovery; in-situ
capping; dredging and off-site disposal; and a combination of dredging,
off-site disposal and in-situ capping. The cleanup alternatives
evaluated for the air were no further action and institutional controls
(ICs).
Selected Remedy
EPA selected cleanup remedies for the Allied Chemical Site in RODs
EPA issued in 1988, 1990, and 2007. EPA issued three ROD Amendments
modifying the remedy in 1995, 1997, and 1998. EPA documented additional
changes to the remedy in ESDs EPA issued in 2015 and 2020.
EPA selected the OU1 GDA cleanup remedy in the 1988 ROD. The
remedial action objectives (RAOs) for the GDA are to: Mitigate the
future generation of contaminated leachate; mitigate the GDA-related
contamination of the Amcast potable/sanitary water supply and any other
private well supplies located north and northwest of the GDA; mitigate
the migration of GDA-related contaminants above applicable Ohio River
standards into the Ohio River (Ohio Administrative Code 3745-1-32); and
mitigate the potential for direct or indirect contact by the public
with hazardous substances in the buried GDA waste.
The major components of the selected GDA remedy included:
Constructing a low-permeability slurry wall around the GDA from the
ground surface into the low-permeability bedrock; installing a multi-
media RCRA hazardous waste cap over the GDA; continuous extraction of
groundwater within the containment system with treatment at the
existing on-site WWTP located at the CPLA (to be upgraded) to create an
inward groundwater gradient within the slurry wall boundaries;
extraction and treatment at the on-site WWTP of contaminated
groundwater outside the containment system until cleanup standards are
achieved; municipal water hook-up for in-plant potable and sanitary
uses at the Amcast facility until contaminant levels in groundwater
meet the cleanup standards; deed restrictions to limit future uses of
the disposal area portion of the property; and a supplemental RI/FS to
identify the nature and extent of the DNAPL, develop and evaluate
cleanup alternatives, and implement the EPA-approved DNAPL remedy, if
different from the currently selected containment alternative.
EPA selected the cleanup remedy for the CPLA in the 1990 ROD. The
RAOs for the CPLA cleanup are to: Mitigate the potential for direct or
indirect contact of the public with the lagoon area wastes; mitigate
the potential for future mobilization of contaminants into the
groundwater; mitigate the migration of CPLA-related contaminants into
Ice Creek, the Ohio River, and the Coal Grove well field; and remediate
all contaminated media to meet ARARs and acceptable risk-based levels
for human health and the environment.
The major components of the selected CPLA remedy in the 1990 ROD
were: Excavate the entire volume of Lagoon 5 (122,000 cubic yards of
material); on-site incineration and waste fuel recovery (heat reuse) of
Lagoon 5 material and 31,000 cubic yards of waste coal excavated from
the coal overburden area, with the ash to be disposed of at a permitted
off-site solid waste facility; excavation and bioremediation on a
prepared pad of 40,000 cubic yards of Coke and Tar Plant soils (OU2 ROD
Soils Areas 1 to 7); in-situ bioremediation of the remaining volume of
material in Lagoons 1 through 4 (475,000 cubic yards), the residual
soil in Lagoon 5, and the adjacent inner and outer dikes; monitoring
the Ice Creek area and developing a contingency plan in the event that
contaminant migration is encountered; groundwater collection, on-site
treatment with the groundwater from the GDA, and monitoring; and deed
restrictions and fencing.
The 1990 CPLA ROD stated that the cleanup standard for soil was
0.97 mg/kg of PAHc. The standard was based on an excess lifetime cancer
risk of 1 x10-\6\ assuming a direct contact residential land
use exposure. The CPLA ROD also provided for an alternative cleanup
standard of 97 mg/kg PAHc (a 1 x 10-\4\ cancer risk, which
is still within EPA's acceptable risk range) if the threat of direct
contact from lagoon soils through residential land use was eliminated
by flooding Lagoons 1 through 4 to create a wetland. An assessment of
Lagoons 1 through 4 indicated that this area was more likely to be an
ecological area than a residential area due to its proximity to Ice
Creek and the fact that this low-lying area has historically served as
a flood water storage area.
EPA issued ROD Amendments in 1995, 1997 and 1998 modifying the
cleanup remedies for the GDA and CLPA based on additional information
collected during the predesign and design phases of the project. The
three ROD Amendments modified the OU1 and OU2 remedies as follows:
Revised the groundwater clean-up standards for benzo(a)pyrene and
dibenz(a,h)anthracene for OU1 and OU2 from 0.005 [micro]g/l total to
the new MCLs of 0.2 [micro]g/l for benzo(a)pyrene and 0.3 [micro]g/l
for dibenz(a,h)anthracene; selected excavation and on-site storage for
eventual treatment or placement into the lagoon area for 135,000
additional cubic yards of CPLA soil found to be contaminated with PAHs
during the design phase; replaced prepared-pad bioremediation of 40,000
cubic yards of CPLA soil with off-site disposal in an approved
landfill; replaced in-situ bioremediation of 475,000 cubic yards of
material in Lagoons 1 through 4 with excavation of materials above 97
mg/kg PAHc and wetland development; and replaced incineration of Lagoon
5 materials with recycling, treatment, and/or disposal of the K087
listed waste in an approved off-site hazardous waste facility and the
use of the remaining material, excluding debris, as an alternative
fuel.
[[Page 37770]]
In 2020, EPA issued an ESD for the OU2 CPLA remedy. EPA issued the
ESD to formally document a previously accepted change in the soil
cleanup standard for arsenic from a residential cleanup level of 0.56
mg/kg selected in the 1990 OU2 ROD to a Site-specific background
concentration of 15 mg/kg calculated during the remedial design (RD)
phase of the project. See the Cleanup Levels section of this notice for
additional information.
EPA issued the Tar Plant OU3 ROD in 2007. The OU3 ROD addressed
contaminated soil, sediment and air at the Tar Plant OU. The RAOs for
OU3 assumed that future use of the Tar Plant property would be
commercial/industrial and may include riverside parks or other
recreational use.
The RAOs for the Tar Plant soil are to: Prevent human ingestion and
direct contact with soil containing PAHs at concentrations that exceed
applicable NCP and Ohio EPA risk management criteria for applicable
exposure scenarios; prevent terrestrial invertebrates from being
exposed to PAHs at concentrations that may be harmful to invertebrates
and worm-eating birds; prevent predatory birds from being exposed to
unacceptable concentrations of PAHs; and reduce, to the extent
practicable, contaminant leaching from soil that may contribute to
groundwater contamination above NCP and/or Ohio EPA risk management
criteria.
The RAOs for sediment in the adjacent Ohio River are to prevent
human direct contact with sediment containing PAHs that exceed
applicable NCP and Ohio EPA risk management criteria for future
exposure scenarios, and to prevent benthic invertebrates from direct
contact with sediment containing PAHs that exceed preliminary
remediation goals based on background toxicity levels. The RAOs for air
are to prevent the inhalation of vapors in indoor air in future
buildings in excess of NCP and Ohio EPA risk management criteria and to
prevent the inhalation of vapors by construction workers during any
future grading and/or excavation activities.
EPA's selected cleanup remedy for soil in the 2007 OU3 ROD was the
construction of an OEPA-compliant low-permeability solid waste cap over
all contaminated portions of the Tar Plant (the entire 16-acre Main
Parcel), a geotextile fabric and soil cover over all contaminated
portions of the River Parcel (approximately four acres), ICs to protect
the integrity of the cap and soil cover, and an IC implementation plan.
EPA did not select a low-permeability cap for the River Parcel based on
concerns with hydraulic instability caused by hydrostatic pressure
differences between the groundwater and surface water which could cause
a low-permeability cover to fail.
The selected OU3 remedy for sediment consisted of dredging
approximately 3,300 to 5,100 cubic yards of contaminated sediment from
the Ohio River using appropriate dredging techniques and turbidity
control measures; sediment dewatering and disposal at an approved off-
site landfill; evaluating the water from the dewatered sediment during
the RD for disposal at the on-site WWTP; and installing an in-situ cap
over approximately 0.7 acres of residual sediment contamination using
earthen materials (sand, gravel and/or cobbles), engineered materials
(geosynthetics or marine mattresses), or a combination of these
materials to be determined during the RD. The exact areas and volume of
sediment to be excavated and capped would be determined based on
additional data collected and evaluated during the RD and post-dredging
confirmation sampling.
The selected OU3 remedy for air was ICs in the form of land use
restrictions restricting the land to industrial/commercial use and
requiring future buildings to include measures (e.g., physical
barriers, venting, monitoring) to protect indoor workers against
potential risks from vapor intrusion and outdoor workers during
excavation or grading activities.
In 2015, EPA issued an ESD modifying the sediment component of the
OU3 remedy based on Honeywell's 2009 and 2011 predesign investigations.
The predesign investigations indicated that the volume of sediment
requiring excavation increased from 3,300 to 5,100 cubic yards to
50,000 to 60,000 cubic yards, and that the area of sediment requiring
capping was 2.3 acres, not 0.7 acres. Due to the significant increase
in cost and concerns with potential river bank failure and the
destabilization of the adjacent active railroad trackbed, the sediment
component of the OU3 remedy was modified from dredging and capping to
capping only.
Response Actions
Allied Chemical completed the RD for the GDA remedy in 1992 and
constructed the GDA remedial action (RA) from 1993 to 1995 (see Figures
2 and 5 in the Docket). Allied Chemical constructed a soil-bentonite
slurry wall around the GDA waste to provide a low-permeability barrier
to ground water in-flow and contaminant migration out-flow. The slurry
wall has a permeability of approximately 1 x 10-8
centimeters per second (cm/sec), which exceeds the 1 x 10-7
cm/sec permeability requirement. Allied Chemical did not key the slurry
wall into the bedrock due to concerns that the keying efforts would
fracture the bedrock and affect its competence and water-bearing
capabilities.
After the slurry wall was constructed, Allied Chemical installed a
RCRA Subtitle C hazardous waste compliant cap over the GDA. The cap
incorporated a geosynthetic clay liner to minimize future exposure of
the buried waste and infiltration. The cap has a permeability of less
than 1 x 10-7 cm/sec. The cap includes a passive gas venting
system with capabilities for adding an emissions control system in the
future, if needed.
Allied Chemical installed two groundwater pumping wells inside the
slurry wall (PW-3 and PW-4) to maintain an inward hydraulic gradient
and prevent groundwater contaminants from migrating beyond the slurry
wall, and two groundwater pumping wells outside the slurry wall (PW-1
and PW-2) to intercept and extract contaminated groundwater outside the
wall. Based on the 1992 Design Report and Allied Chemical's 1992 Design
Report Response, EPA revised the groundwater drawdown required to
maintain the inward gradient from ten feet to one foot. The groundwater
pumped from inside and outside the slurry wall is treated at the on-
site WWTP at the CPLA, which was upgraded to add biological and carbon
polishing treatment components to the system. The on-site WWTP was
later upgraded again in 1997 during the OU2 RA. The treated groundwater
is discharged to the Ohio River in compliance with the technical
requirements of a Site-specific National Pollutant Discharge
Elimination System (NPDES) permit administered by OEPA.
Allied Chemical installed groundwater monitoring wells to monitor
the performance of the GDA containment system and the migration of the
dissolved and free phase contaminant plumes to assist with delineating
the extent of DNAPL and to evaluate potential technologies to address
the DNAPL. Allied Chemical also constructed a security fence around the
perimeter of the GDA to prohibit trespassing. EPA conducted a final
inspection of the OU1 GDA remedy on August 2, 1995. Allied Chemical
submitted a final Remedial Design/Remedial Action (RD/RA) completion
report for the GDA on September 14, 1995.
[[Page 37771]]
Allied Chemical conducted preliminary Site preparation activities
for the OU2 CPLA RA from 1994-1995. In 1995, Allied Chemical
constructed the CPLA Stormwater Collection/Management System to contain
stormwater runoff during the RA. Allied Chemical conducted the OU2 CPLA
RA construction activities from 1996 to 2002 (see Figures 3, 4 and 6 in
the Docket).
Allied Chemical completed the OU2 CPLA groundwater remedy in 1996
and 1997. The RA for the groundwater remedy included: Installing five
groundwater extraction wells and five new groundwater monitoring wells
to supplement the existing system; connecting a sixth groundwater
extraction well installed in 1992 to the system; and modifying the on-
site WWTP to allow for the handling and treatment of the extracted
groundwater from the CPLA, the GDA, and the wastewater from the Tar
Plant facility operations and to meet NPDES permit requirements. The
WWTP modifications included: Installing an iron/suspended solids
removal system consisting of aeration/pH adjustment, clarification, and
sand filtration; a cyanide removal system using ultraviolet
irradiation/oxidation; and flow modifications to the carbon towers
organics treatment system. Formal system start-up of the OU2 CPLA
groundwater treatment system occurred in June and July 1997.
Allied Chemical conducted the Lagoon 5 remediation activities from
1998 to 1999. Allied Chemical excavated the material in Lagoon 5 down
to the underlying clay layer and removed approximately 120,000 tons of
waste from the lagoon. Approximately 85,600 tons of coal/coke fines,
16,000 tons of segregated hard tar, and 500 tons of exempted RCRA-K087
listed waste from Lagoon 5 were shipped off-site to power generation
plants for feedstock as part of approved alternative fuels programs.
Allied Chemical disposed of the contaminated or unusable hard debris
(10,800 tons) and soft debris excavated from Lagoon 5 at an off-site
landfill. Allied Chemical stabilized 7,100 tons of soft-tar material
(RCRA K087 listed waste) from Lagoon 5 on-site and disposed of it at an
off-site landfill. Allied Chemical sent the scrap metal that was
recovered from Lagoon 5 to a local recycler.
Allied Chemical backfilled the Lagoon 5 excavation with clean, hard
debris from previous Site remediation activities (e.g., concrete pipe
supports, brick, and concrete) to an elevation above the water table.
The hard debris was covered with 12,000 tons of crushed hard debris and
27,200 tons of soil having PAHc and arsenic concentrations below the 97
mg/kg and 15 mg/kg cleanup levels excavated from other Site areas.
Allied chemical seeded and revegetated Lagoon 5, and placed rip-rap
along the sides of the lagoon at the tie-ins with the City of Ironton
Floodwall.
Based on the results of additional sampling conducted in Lagoons 1
to 4 in 1997, the Lagoon 2 materials were the only materials with PAHc
concentrations above the alternate 97 mg/kg PAHc cleanup standard
documented in ROD Amendment #3 that required excavation. Allied
Chemical removed 8,300 tons of hard tar and 1,200 tons of coal/coke
fine materials from Lagoon 2 in 1999 and shipped the material to off-
site energy generators for feedstock. Allied Chemical backfilled the
excavated areas in Lagoon 2 with 2,000 tons of clay material excavated
from Lagoon 5 that had PAHc concentrations less than 97 mg/kg and
arsenic concentrations less than 15 mg/kg. Allied Chemical placed a
six-inch layer of imported fill material over the excavated area then
tapered and sloped the sidewalls of Lagoon 2 downward into the
partially backfilled area to create a depression to facilitate the
collection of standing water to aid in the development of the wetland
ecosystem.
Allied Chemical conducted a Reconnaissance Ecological Risk
Assessment for Lagoons 1 to 4 in 1999 before the lagoons were converted
into wetlands. The assessment evaluated potential ecological impacts
from residual PAHc concentrations in the Lagoons 1 to 4 materials after
the Lagoon 2 materials were removed. Allied Chemical's 1999 assessment
followed EPA's Sediment Quality Triad Approach and included a
vegetation study. The assessment indicated that residual concentrations
of PAHc in Lagoons 1 to 4 at concentrations less than or equal to the
alternate 97 mg/kg cleanup level would not significantly impact the
planned wetland ecosystem or the aquatic or vegetative communities of
the converted wetland areas.
Allied Chemical completed the conversion of Lagoons 1 to 4 into
wetlands in 2002. The wetland conversion included: Construction of an
overflow weir adjacent to Lagoon 4 and placement of rip-rap (i.e.,
brick and concrete) in selected areas to minimize erosional effects
during flood events; permanent modification of the sluice gate adjacent
to Lagoon 3 to permit complete hydraulic connection with Ice Creek to
allow for equalized inflow/outflow during flood events; and adoption of
an annual monitoring program to evaluate the re-establishment of
vegetation and assess the condition of the biological community.
Allied Chemical completed the OU2 soil remediation of the CPLA and
OU2 Tar Plant soils, with the exception of the soil in OU2 ROD Soils
Area 2, in 2000 (see Figures 3 and 4 in the Docket). The contaminated
CPLA soils (OU2 ROD Soils Areas 1, 3 and 4) were excavated to a maximum
depth of ten feet. The OU2 Tar Plant soils (OU2 ROD Soils Areas 5 to 7)
were excavated to five feet and were not fully characterized due to the
ongoing Tar Plant operations. The remaining Tar Plant soils were later
addressed by Honeywell during the OU3 Tar Plant investigation and
cleanup.
The CPLA OU2 ROD Soils Area 2 could not be remediated because this
area is located within the bermed area of the East Tank Farm which
contains components of the WWTP for the long-term OU1 and OU2
groundwater cleanup. The soil within OU2 ROD Soils Area 2 will remain
on the NPL and is not included in this partial deletion action. OU2 ROD
Soils Area 2 is located within the fenced portion of CPLA Parcel 2
which is owned by Allied Chemical/Honeywell. The area is planned for
future characterization and remediation when decreased activity levels
in this area will minimize potential disruption to the operations of
the ongoing groundwater cleanup. It is expected that the OU2 ROD Soils
Area 2 materials will be characterized, excavated, and disposed of at
an off-site landfill.
Allied Chemical disposed the excavated OU2 CPLA and Tar Plant soils
as non-hazardous solid waste in an off-site landfill in accordance with
ROD Amendment #2. The excavated soils included: 18,100 tons of soil
from CPLA ROD Soils Area 1; 4,000 tons of soil from CPLA ROD Soils Area
3 and the active Truck Scale Facility; 2,600 tons of soil from CPLA ROD
Soils Area 4; and 4,700 tons of soil from OU2 Tar Plant ROD Soils Areas
5 to 7.
During the OU2 RA, Allied Chemical excavated contaminated soil and
materials from additional areas of the CPLA in accordance with the 1995
ROD Amendment #1 (see Figure 3 in the Docket). These included:
Excavating 44,000 tons of surficial coal fines accumulated from the
off-loading of feed materials for the coke oven batteries for off-site
use as an approved alternative fuel at cement kiln facilities and power
generation plants; excavating 17,700 tons of fuel-grade overburden
materials from the western portions of Lagoons 2 and 4 for off-site
energy
[[Page 37772]]
recovery; excavating 6,000 tons of petroleum hydrocarbon-contaminated
soil from the former Coke Plant Ammonia Concentration Building for off-
site disposal as a non-hazardous solid waste; excavating 23,500 tons of
PAH-contaminated soils west and south of the former coke oven batteries
and other Site areas and disposing the soil with PAHc concentrations
greater than 97 mg/kg or arsenic concentrations greater than 15 mg/kg
at an off-site landfill as a non-hazardous wastes (3,700 tons) and
backfilling the remaining soil into the Lagoon 5 excavation; excavating
3,500 tons of contaminated soil from the Trucker's Parking Lot area and
an area located adjacent to the East Tank Farm and backfilling the
material into Lagoon 5; excavating 35,000 tons of coal and coke fines
and 500 tons of hard tar from the slope of the City of Ironton
floodwall for off-site use as alternative fuel; excavating 63,000 tons
of material with measured concentrations of PAHc less than 97 mg/kg and
arsenic less than 15 mg/kg from the East Side Batteries Area for use as
backfill along the toe of the City of Ironton floodwall slope and
excavating 8,600 tons of material from this area for off-site energy
recovery; and disposing 13,000 tons of hard debris (brick and concrete)
and 500 tons of soft debris (wood, plastic, trash, etc.,) encountered
in excavated areas as a non-hazardous solid waste at an off-site
landfill. Allied Chemical completed these cleanup actions in 2000.
Documentation of the OU2 RA construction activities is provided in
the October 23, 2002 Interim Remedial Action Report for Coke Plant/
Lagoon Area (CPLA) Operable Unit at the Honeywell-Ironton Facility,
which is available in the Docket.
Honeywell initiated OU3 construction activities (see Figure 7 in
the Docket) in 2014 starting with the River Parcel. Honeywell conducted
Site preparation activities and sealed eight groundwater monitoring
wells. Honeywell cleaned out and demolished a concrete oil-water
separator type structure at the top of the river bank and removed its
associated piping and waste material for off-site disposal. Honeywell
relocated the CPLA WWTP outfall, Outfall 001, which discharged to the
Ohio River near the demolished structure, to a discharge located on
Site at the south property boundary. Honeywell constructed a new storm
water system for the Main Parcel with direct discharge to the Ohio
River using former NPDES outfall structures 001 and 002.
Honeywell stabilized the riverbank at the soil and sediment
interface of the River Parcel with 35,150 square feet of one-foot thick
stone-filled Polymeric Marine Mattresses (PMMs) and rip-rap mixed with
soil staked with live plant stakes. The PMMs were installed from
elevation 512 feet to 515 feet. The rip-rap was installed from
elevation 515 feet to 519 feet with some overlap on the PMMs. Honeywell
placed the live plant stakes in the rip-rap/soil every three feet on
center.
Honeywell removed 75 tons of debris from the Ohio River and
installed three separate types of subaqueous sediment caps covering a
total of 2.3 acres in the river. Cap A covers the majority of the area
and consists of a minimum six-inch sand chemical isolation layer
covered by a minimum six-inch gravel erosion protection and filter
layer. Caps B and C have the same sand and gravel layers as Cap A but
are covered with an additional 12-inches (Cap B) and 18-inches (Cap C)
of a cobble erosion protection layer.
Honeywell installed a soil cover over the upland portion of the
River Parcel (i.e., the riverbank) to prevent direct contact with
affected soils by humans and potential ecological receptors. The soil
cover consisted of 18 inches of vegetative fill covered by six inches
of topsoil. Honeywell installed an orange geogrid layer below the
vegetative fill to demarcate the underlying subgrade material.
Honeywell installed coir (coconut fiber) matting over the topsoil
from the top of the upland slope to the rip-rap at the bottom of the
slope and coir logs at the base of the slope, between the soil cover
and the rip-rap, to prevent erosion until the vegetation was
established. Honeywell installed a temporary irrigation system and
planted a mixture of native grasses, sedges and forbs on the sloped
soil cover from elevation 519 (the top of the rip-rap) to elevation 547
(the bottom of the railroad embankment), and container plants (trees
and shrubs) every ten feet on center from elevation 519 to elevation
538. Honeywell installed a gravel access road and gate near the top of
the slope just above the 10-year flood elevation (about 535 feet).
Honeywell completed the River Parcel remediation and restoration in
2015.
Honeywell conducted the remedial action construction for the OU3
Main Parcel in 2015. Honeywell demolished the remaining buildings and
structures on the Main Parcel and sealed 51 groundwater monitoring
wells and one pumping well. Honeywell installed a low-permeability
solid waste-compliant cap over the entire 16-acre Main Parcel area (see
Figure 7 in the Docket). The low permeability cap consists of a six-
inch sand cushion layer over the contaminated soil covered by (from the
bottom up): A geosynthetic clay liner (GCL), a 40-mil low-density
polyethylene (LDPE) geomembrane layer, a 12-inch sand drainage layer
with lateral underground drains to remove water from the top of the
LLDPE, a 12-inch protective soil cover layer for vegetative growth, and
six inches of topsoil.
Honeywell installed a gas venting system below the cover system to
prevent any buildup of gas. The system includes lateral gas collection
pipes installed under the six-inch bottom sand cushion layer that are
connected to three gas vents along the western edge of the cover.
Honeywell installed soil gas monitoring probes around the perimeter of
the cap. The gas monitoring probes are spaced approximately 400 feet
apart with screens set at 10 feet, 25 feet, and 40 feet below grade.
Honeywell seeded and mulched the topsoil layer of the cover system,
constructed a gravel access road along the southern and eastern
boundaries of the Main Parcel to provide access to groundwater
extraction wells, and constructed a chain-link fence along the
perimeter of the Main Parcel, except along South Third Street where an
ornamental fence was installed.
EPA, OEPA, and Honeywell conducted a pre-final/final inspection of
the River Parcel on November 13, 2014 and a pre-final/final inspection
of the Main Parcel on December 16, 2015. Documentation of the OU3 RA
construction activities is provided in the March 2016 Final Remedial
Action Completion Report for OU3 which is available in the Docket.
EPA, OEPA, and EPA's contractors provided oversight of the cleanup
at the Allied Chemical Site throughout the OU1, OU2, and OU3 RD/RAs.
EPA and OEPA conducted a pre-final inspection of the Allied Chemical
Site on December 19, 2015. During the inspection EPA verified that all
remedial actions were conducted in accordance with the approved RD
plans and specifications. A punch list of outstanding activities was
prepared during the inspection. Honeywell addressed and completed all
of the punch list activities by May 4, 2016. A final OU3 inspection and
Site walk-through was conducted on June 1, 2016. EPA completed a
Preliminary Close Out Report for the Site documenting that the RA
construction activities were complete on September 29, 2016.
Cleanup Levels
The soil (land) remedy for the OU1 GDA is in-situ containment of
the waste disposal area; therefore the 1988 OU1
[[Page 37773]]
ROD does not establish cleanup levels for the GDA waste.
EPA established the cleanup levels for the OU2 CPLA soil in the
1990 OU2 ROD. The OU2 soil cleanup levels applied to soil, the
materials in Lagoons 1 to 4, the soil remaining in Lagoon 5 after the
removal of the Lagoon 5 waste, and the adjacent dikes. The OU2 CPLA
soil cleanup levels were a total PAHc concentration of 0.97 mg/kg and
an arsenic concentration of 0.56 mg/kg. These cleanup levels are based
on a hypothetical residential exposure, with the cumulative cancer risk
level not to exceed 1 x 10-6. The 1990 OU2 ROD also required
ICs in the form of deed restrictions to prevent any residential or
recreational use of the Site.
In March 1995, Allied Chemical submitted a petition to EPA and OEPA
providing a statistical evaluation of arsenic concentrations measured
at the Site during the 1994 CPLA predesign investigations compared to
regionally established background concentrations of arsenic. This
petition resulted in the Agencies' adoption of a revised cleanup level
for arsenic in soil of 15 mg/kg. This revised cleanup standard for
arsenic was identified in several Site reports including the EPA and
OEPA-approved 2002 Interim Remedial Action Report for the Coke Plant/
Lagoon Area and EPA's 2004 Five-Year Review report for the Site.
Allied Chemical recorded Environmental Deed Restrictions
prohibiting residential and recreational use of the CPLA property with
the Lawrence County Recorder's office on August 22, 2002 in Plat Book
10/Page 181. EPA formally documented the revised soil cleanup standard
for arsenic of 15 mg/kg in an ESD EPA issued in May 2020.
EPA revised the PAHc cleanup level for the Lagoons 1 to 4 material
in ROD Amendment #3 in 1998. ROD Amendment #3 selected the alternate
cleanup level of 97 mg/kg for PAHc provided in the 1990 OU2 ROD. The
1990 OU2 ROD allowed the 97 mg/kg PAHc alternate cleanup level if the
threat of direct contact with the lagoon materials through residential
use was eliminated by flooding Lagoons 1 to 4 to create a wetland. The
1999 Reconnaissance Ecological Risk Assessment that Honeywell conducted
before converting Lagoons 1 to 4 into a wetland further indicated that
the residual concentrations of PAHc in Lagoons 1 to 4 at concentrations
less than or equal to the alternate 97 mg/kg cleanup level would not
significantly impact the planned wetland ecosystem or the aquatic or
vegetative communities of the converted wetland areas.
EPA selected cleanup levels for the OU3 Tar Plant soil and Ohio
River sediment in the 2007 OU3 ROD. The cleanup level for soil on the
Main Parcel and the River Parcel of the Tar Plant is 0.16 mg/kg of
benzo(a)pyrene. This cleanup level is based on a cancer risk of 1 x
10-6 under future industrial/commercial and recreational use
of the property.
The cleanup level for the Ohio River sediment in the 2007 ROD was
total PAH concentrations that are equal to or less than background
sediment toxicity levels for aquatic receptors (benthos) in sediment
from upstream sources. That is, the ROD required the sum of
Environmental Sediment Toxicity Benchmark Units (ESTBUs) for Site-
impacted sediment to be less than or equal to 10.0. During the RD
process, and as allowed by the OU3 ROD, the ESTBU sediment cleanup
values of 10, which are based on direct measurements of PAH
concentrations in pore water and may overestimate PAH bioavailibity and
pore water toxicity, were refined to use an Equilibrium Pore Water
Toxic Unit (EPWTU) of 5 instead.
Allied Chemical's OU2 RD/RA for the soil and lagoon remediation was
conducted in accordance with the 1992 CPLA Quality Assurance Project
Plan (QAPP). The 1992 CPLA QAPP was used as the governing document to
guide the field sampling, treatability studies, and analytical
activities performed throughout the CPLA RD/RA, including field and
laboratory Quality Assurance/Quality Control (QA/QC) procedures and
data validation protocols. In addition, task-specific work plans were
prepared and followed for each significant activity, including: Pre-
Design Investigations for Bioremediation, Groundwater, and Waste Fuel
Recovery; Coal Overburden Characterization and Removal; Site Soils and
ROD Soils Characterization and Removal; Lagoon Materials Delineation;
Floodwall Slope Restoration; East Side Batteries Characterization and
Removal; Ice Creek Monitoring Program; and CPLA Compliance Monitoring
Program and Stormwater Collection and Monitoring Program.
QA/QC activities for the OU2 CPLA ROD Soils, including OU2 ROD
Soils Area 1 (including the Neal Junkyard portion), Area 3 (including
the Truck Scale portion), and Area 4, included field sampling to
delineate the areal and vertical extent of the impacted areas, followed
by excavation to the agreed upon maximum depth of 10 feet. The OU2 Tar
Plant ROD Soils Areas 5 to 7 were similarly delineated and the impacted
materials excavated to the agreed upon maximum depth of 5 feet.
Allied Chemical collected soil samples from 0-1.0 foot, 1.0-2.5
feet, and 2.5-5.0 feet below ground surface (bgs) in each of the OU2
ROD Soils Areas to determine the final depth of the excavation. CPLA
ROD Soils Areas 1, 3 and 4 were additionally sampled from 5.0-7.5 and
7.5-10.0 feet bgs. The soil samples were analyzed for PAHc and arsenic
in accordance with the approved USEPA Contract Laboratory Program (CLP)
Statements of Work for Organics and Inorganics, respectively, which
were in effect at the time of analysis.
The most-highly contaminated sample from each of the excavated OU2
ROD Soils Areas underwent additional testing prior to disposal. The
additional tests included RCRA toxicity characteristic leaching
procedure (TCLP) analysis, a paint filter test, and the RCRA hazardous
characteristic tests for reactivity, corrosivity, and ignitability.
Allied Chemical conducted an initial characterization of the
additional CPLA soils identified for remediation in the 1995 ROD
Amendment #1 in 1994 and 1995. The soil samples were collected in
incremental one-foot intervals down to a maximum depth of 10 feet. In
areas with coal and other fuel-grade overburden material, the overlying
coal or fuel-grade layer was removed down to the ``visually-clean''
underlying native materials, and afterwards samples were collected from
the top foot and then at the 4.0-5.0 feet depth of the native material.
In 1997, the sampling protocol was revised to be consistent with the
OU2 ROD Soils Areas sampling, with samples collected from 0.0-1.0 foot,
1.0-2.5 feet, 2.5-5.0 feet, 5.0-7.5 feet, and 7.5-10.0 feet bgs. The
samples were analyzed for PAHc and arsenic.
The additional CPLA soils that required remediation based on the
predesign investigation were excavated to a maximum depth of 10 feet
and the materials were stockpiled on-site. Soil containing PAHc
concentrations greater than 97 mg/kg or arsenic concentrations greater
than 15 mg/kg were disposed off-site following TCLP and hazardous
characteristic testing. Before the stockpiled materials were placed in
the Lagoon 5 excavation, the materials were sampled again for PAHc and
arsenic at a frequency of 1 sample for every 2,000 cubic yards to
confirm they were below cleanup standards.
CPLA soil materials in the area adjacent to the East Tank Farm were
characterized using samples collected from 0.0-1.0 foot, 1.0-2.5 feet,
2.5-5.0 feet, 5.0-7.5 feet, and 7.5-10.0 feet
[[Page 37774]]
intervals. Soil in the Truckers' Parking Lot was sampled incrementally
at 0.5-foot intervals from the ground surface to the underlying native
material (based on visual observations). Samples of the native material
were then collected at 0.5-foot intervals until the analytical results
indicated that the concentrations of PAHc and arsenic were below 0.97
mg/kg and 15 mg/kg, respectively. The excavated materials from these
areas were either disposed off-site or backfilled directly into Lagoon
5 if they were below cleanup levels.
Characterization of the CPLA East Side Batteries Area focused on
the materials in the former Coke Plant processing areas and extending
east to the City of Ironton Floodwall. Near-surface materials were
removed to expose the underlying ``visually-clean'' native material.
Samples were collected from the native material in 0.5-foot intervals
until the concentration of PAHc was less than 0.97 mg/kg and arsenic
was less than 15 mg/kg. Based on the analytical results, the materials
were excavated and sent off-site for disposal (after TCLP and hazardous
characteristic testing) or stockpiled to be placed along the toe of the
floodwall in the Lagoon Area. The stockpiled materials were subjected
to another round of sampling for PAHc and arsenic at a frequency of 1
sample for every 2,000 cubic yards prior to placement along the
floodwall.
Allied Chemical discovered soil contamination in the CPLA Ammonia
Concentration Building Area during other Site work due to the
discoloration of the soil (a green tint) and a petroleum-like odor.
This area was not specifically identified in the CPLA ROD or ROD
Amendments. Allied Chemical sampled the material and detected elevated
levels of total petroleum hydrocarbons (TPHC).
Allied Chemical conducted a focused investigation in the Ammonia
Concentration Building Area and collected soil samples at depth
intervals corresponding to 0.0-5.0 feet and 5.0-10.0 feet at designated
locations. The samples were analyzed for TPHC using EPA Method 418.1.
Based on a review of State of Ohio cleanup standards for hydrocarbon-
contaminated soils that were in effect at the time, a Site-specific
TPHC cleanup level of 100 mg/kg was adopted for the Ammonia
Concentration Building Soils. Allied Chemical excavated the sampled
material having TPHC concentrations greater than 100 mg/kg and disposed
of it at an off-site landfill following TCLP and hazardous
characteristic testing.
The 1990 OU2 ROD and subsequent amendments required the entire
contents of Lagoon 5 to be removed. Allied Chemical excavated all of
the materials in Lagoon 5 (about 120,000 tons) down to the visually
encountered clay layer. Allied Chemical then removed about 2,000 tons
of the Lagoon 5 clay, sampled the material to confirm that
concentrations of PAHc and arsenic were below the cleanup criteria of
97 mg/kg PAHc and 15 mg/kg arsenic, and backfilled the clay into the
excavated areas of Lagoon 2.
The materials in Lagoon 2 that required excavation were delineated
during Allied Chemical's 1997 Lagoon Materials Delineation Program. The
program involved collecting samples from Lagoons 1 to 4 for PAHc
analysis. The PAHc sample data was combined with other existing data
for the lagoons and used in a statistical evaluation to determine which
materials required removal in order to maintain an overall average
concentration of PAHc less than 97 mg/kg to meet the 1998 ROD Amendment
#3 requirement for converting the lagoons into a wetland system. The
analysis indicated that only certain areas of Lagoon 2 required
excavation. Additionally, potential ecological risks posed by the
residual PAHc concentrations in the lagoons were evaluated in the 1999
Reconnaissance Ecological Risk Assessment and through the performance
of subsequent annual ecological assessments to confirm that the
remedial action for the constructed wetlands met objectives.
Honeywell conducted the OU3 Tar Plant RA in accordance with the
2013 Construction Quality Assurance Plan, the 2013 Construction Quality
Assurance Plan--Main Parcel, and the 2014 Construction Quality
Assurance Plan--River Parcel. The RA for the Main Parcel was a low-
permeability solid waste cap containment remedy over the entire 16-acre
Main Parcel. The RA for the upland area (riverbank slope) of the River
Parcel was a geotextile fabric and soil cover over the entire 4-acre
upland area of the River Parcel. Because these remedial actions were
containment/cover remedies over the entire property, confirmation
sampling was not required. Instead, surveys were conducted to confirm
that the RAOs were attained.
The areas of Ohio River sediment that exceeded the refined cleanup
level of the sum of EPWTU of 5 or where tar was observed were
identified as areas that required remediation during the RD based on
the predesign investigation studies. Sediment within the design capping
area had sums of EPWTU values that ranged from 5 to 40, while values
outside the capped area were less than 5.
The final capped area and thickness of the OU3 Ohio River sediment
remedy was confirmed by comparing a baseline multi-beam bathymetric
survey conducted prior to capping to verification multi-beam
bathymetric surveys conducted after each layer of the cap was placed to
check for areal extent and material thicknesses. Honeywell's
construction managing contractor monitored the surveying results and
verified that the quality and coverage of the cap met the specified
design. The construction manager contractor notified the construction
contractor of any deficiencies to be corrected during construction, and
approved the final completion of areas post-construction.
Operation and Maintenance
Operation and maintenance (O&M) activities at the Allied Chemical
Site are extensive and include activities associated with groundwater/
wastewater operations, monitoring systems, engineered structure
maintenance, landscaping, and security. Honeywell's O&M costs for the
period 2014 to 2018 averaged over $1.1 million annually.
Honeywell conducts the GDA groundwater monitoring in accordance
with the 1994 GDA Remedial Action Monitoring Plan. The CPLA groundwater
monitoring and Ice Creek monitoring is performed in accordance with the
general protocols outlined in the 1995 CPLA Groundwater Compliance
Sampling and Analysis Plan. Honeywell monitors and conducts O&M for the
lagoons/wetlands in accordance with the 2000 Lagoon Area Wetlands/
Floodplain Conversion Plan. Honeywell conducts O&M on the Tar Plant
River Parcel in accordance with the 2015 Operation, Maintenance and
Monitoring Plan--River Parcel. The Tar Plant Main Parcel O&M is
conducted in accordance with the 2016 Draft Main Parcel Operation,
Maintenance, and Monitoring Plan.
The O&M program includes comprehensive groundwater monitoring,
potentiometric monitoring, chemical analysis, NPDES discharge
monitoring, Site inspections, and any necessary repairs. The
groundwater monitoring program includes monitoring contaminant
concentrations and groundwater levels to assess the containment of the
GDA waste, maintenance of Site-wide hydraulic control, and for the
presence of DNAPL. Honeywell also conducts periodic bathymetric
surveying in the Ohio River
[[Page 37775]]
to monitor the performance of the underwater sediment cap.
Honeywell monitors methane gas semiannually at the Main Parcel. In
2002, the Gas Vent Sampling Program at the GDA was terminated based on
Honeywell's 2002 Air Emissions Evaluation Report. The 2002 Air
Emissions Evaluation Report evaluated the analytical data from 14
consecutive quarterly air monitoring events and determined that the
emissions of volatile organic compounds from the four GDA vents was
insignificant. The 2002 report also concluded that the ambient impact
to the nearest public receptor due to emissions from the vents was
orders of magnitude lower than the corresponding Maximum Allowable
Ground Level Concentration. As stipulated by EPA and OEPA, Honeywell
continues to maintain the gas vents in the event that future sampling
is required. At this time, however, no further sampling is anticipated.
Honeywell began annual lagoons/wetland monitoring in 2002. In 2012,
Honeywell submitted the Lagoon Area Vegetation and Benthic Macro-
invertebrate Monitoring Report, which summarized the activities and
findings from the annual wetlands/ecological assessments conducted
within the Lagoon Area (Lagoons 1, 2, 3, 4, and 5). Based on
consultation with OEPA, EPA informed Honeywell that the final decision
to determine whether the re-establishment of the wetland/floodplain
community has been achieved would be made after evaluating the field
results using OEPA's Vegetation Index of Biotic Integrity (VIBI)
Assessment Process.
Honeywell agreed to perform the VIBI assessment on three categories
of observed wetland vegetation--forested, scrub/shrub, and emergent--in
order to properly represent and assess each vegetative community.
Honeywell completed the VIBI Assessment in 2014. Based on this
assessment, OEPA and EPA approved the discontinuation of monitoring in
Lagoons 1, 3, 4, and 5. The VIBI assessment, however, identified the
need to address Lagoon 2 to control the invasive species Purple
Loosestrife.
Honeywell completed three herbicide applications in Lagoon 2 in
July 2015, 2016, and 2017. Honeywell conducted a follow-up VIBI
Assessment of Lagoon 2 in August 2019. The results of the 2019 VIBI are
being evaluated. The Lagoon 2 vegetation will continue to be monitored
and maintained as part of ongoing O&M.
The 1988, 1990, and 2007 RODs require ICs at the Site. The ICs are
a protective measure used in conjunction with the containment and
active treatment methods to restrict property use, maintain the
integrity of the cleanup remedies, and to assure long-term
protectiveness for Site areas which do not allow for unrestricted use/
unlimited exposure (UU/UE). The ICs implemented at the Allied Chemical
Site include Environmental Covenants (ECs), Environmental Restrictions,
city ordinances, and local zoning requirements. A 1989 Unilateral
Administrative Order and a 2010 Consent Decree made the ICs a binding
requirement on Allied Chemical/Honeywell. Copies of the ICs for the
Allied Chemical Site are available in the February 2020 Updated
Institutional Control Implementation and Assurance Plan (ICIAP) in the
Docket.
The IC for the 8.5-acre portion of the OU1 GDA that includes the
landfill cap and slurry wall (see ID 18 on Figure 2 in the Docket) is
an EC that was recorded with the Lawrence County Recorder's office on
September 14, 2018. The EC requires isolation and containment of the
waste pit and DNAPL, prohibits the use of groundwater, prohibits
residential activities and exposure, and prohibits activities that
would interfere with the slurry wall, cap and, groundwater extraction
remedies.
The EC for the remaining 1.5 acres of the GDA that are outside the
boundaries of the cap and slurry wall, but above areas with groundwater
contamination (Figure 2, IDs 22 and 23), restricts the land use to
commercial/industrial activities, prohibits residential use and other
residential-type activities such as schools, hospitals, assisted living
and daycare facilities, food stores, restaurants and indoor and outdoor
entertainment and recreational facilities, prohibits the consumption of
groundwater, and prohibits food chain products, manufacturing, and
warehousing. This EC was recorded with the County on September 14,
2018.
Land and groundwater use on the OU2 CPLA (Figure 2, IDs 1 to 17) is
restricted by Environmental Deed Restrictions recorded with the
Recorder's office on August 22, 2002 in Plat Book 10/Page 181. These
deed restrictions: Prohibit residential and recreational exposure on
the properties; prohibit future use that is incompatible with the
remedial actions; prohibit the consumption of groundwater and
interference with the remedy; and ensure proper maintenance.
ECs are implemented on two on-site parcels of the Tar Plant OU3 and
one off-site parcel (approximately 0.19 acres of the sediment cap on
off-site property). The EC for the Tar Plant Main Parcel property,
which consists of the 16-acre landfill cap (Figure 2, ID 19) and the EC
for the 12-acre River Parcel property, which includes the soil cap on
the river bank and part of the Ohio River sediment cap, permit the
properties to be used only for commercial/industrial activities,
prohibit residential use and other residential-type use, prohibit the
use of groundwater, and prohibit future use that is incompatible with
the remedial actions and any interference with the remedy. The EC for
the River Parcel also prohibits drilling, dredging, and/or vessel
anchoring on the capped sediment area. These ECs were recorded with the
Lawrence County Recorder's office on September 14, 2018.
The EC for the off-site sediment parcel in the Ohio River (Figure
2, ID 21) was recorded with the Lawrence County Recorder's office on
September 26, 2018. This EC prohibits any activities which would
interfere with or adversely affect the integrity or the protectiveness
of the sediment cap, and does not permit any drilling, dredging, and/or
vessel anchoring on the property.
Land and groundwater use on OU1, OU3, and most of OU2 (the portion
of OU2 located within the City of Ironton) is additionally restricted
by the City of Ironton Municipal Code Chapter 1272, 1977 and Code
1046.35, 2013. Chapter 1272 prohibits the installation of groundwater
wells within the City, with the exception of wells installed on
commercial property used exclusively and solely for irrigation. Zoning
ordinance Code 1046.35 restricts OU1, OU3 and the OU2 property located
in Ironton to General Industrial Use.
Long-term stewardship (LTS) is addressed at the Allied Chemical
Site through the implementation of the ICIAP and IC monitoring, the
ECs, Environmental Deed Restrictions, and local government controls, in
conjunction with engineering controls, O&M, and routine Site
inspections, to ensure that the remedy remains protective and continues
to function as intended. The Allied Chemical Site achieved EPA's Site-
Wide Ready for Anticipated Use designation on October 2, 2018.
Five-Year Reviews
The Allied Chemical Site requires statutory five-year reviews
(FYRs) due to the fact that hazardous substances, pollutants, or
contaminants remain at the Site above levels that allow for
unrestricted use/unlimited exposure (UU/UE). EPA completed FYRs for the
Allied Chemical Site in 1999, 2004, 2009, 2014, and 2019.
EPA completed the most recent FYR for the Site in September 2019.
EPA's
[[Page 37776]]
2019 FYR found that the Site-wide remedy protects human health and the
environment. The exposure pathways that could result in unacceptable
risks are being controlled and the cleanup remedies are operating as
expected. Site-wide threats have been addressed through: Waste
containment and isolation (through the slurry wall, low-permeability
hazardous waste and solid waste-compliant caps, soil, and sediment
covers, and wetlands conversion); excavation with off-site disposal or
off-site energy recovery; on-site groundwater containment, extraction
and treatment; and ICs that restrict land use, prohibit groundwater
use, and prevent activities that could impair the integrity of the
engineering controls.
The 2019 FYR concluded that in order for the remedy to be
protective in the long-term, an ICIAP needed to be completed and the
LTS procedures from the ICIAP need to be incorporated into the O&M
plans for OUs 1, 2, and 3. Honeywell submitted a revised ICIAP to EPA
on March 11, 2019 and an updated ICIAP to EPA on February 14, 2020. EPA
approved Honeywell's updated ICIAP on March 5, 2020. EPA and OEPA are
currently evaluating whether the O&M Plans for the Site need to be
amended to incorporate the ICIAP, or whether the ICIAP can be
implemented as a stand-alone document in conjunction with the current
O&M Plans for OU1, OU2 and OU3.
Copies of EPA's 1999, 2004, 2009, 2014, and 2019 FYR Reports are
available in the Docket. EPA expects to complete the next FYR for the
Allied Chemical Site in 2024.
Community Involvement
EPA satisfied public participation activities for the Allied
Chemical Site as required by Sections 113(k)(2)(B)(i-v) and 117 of
CERCLA, 42 U.S.C. 9613(k)(2)(B)(i-v) and 9617. In 1986, EPA developed a
Community Relations Plan for the Allied Chemical Site. EPA established
a local information repository for the Site at the Briggs Lawrence
County Public Library in Ironton, Ohio. EPA maintains a copy of the
administrative record documents for the Allied Chemical Site at the
local information repository, at EPA's Region 5 office in Chicago,
Illinois, and on EPA's web page for the Allied Chemical Site at https://www.epa.gov/superfund/allied-chemical-ironton.
EPA distributed fact sheets to the community throughout the Site
investigations and cleanups to inform the public about Site activities.
In 1986, EPA held a public meeting to present the findings of the OU1
and OU2 RI to the community. EPA released the FS Reports and proposed
cleanup plans for the Site to the public in August 1988, September
1990, and July 2007 at the start of the OU1, OU2, and OU3 public
comment periods. EPA published newspaper announcements advertising
EPA's proposed cleanup plans for the Site, the 30-day public comment
periods, and the availability of public meetings, in the Ironton
Tribune. EPA mailed fact sheets summarizing the proposed OU1, OU2 and
OU3 cleanup plans to individuals on the Site mailing list.
EPA and OEPA conducted public meetings on August 16, 1988 and
October 23, 1990. At the meetings, EPA and OEPA explained the details
of the Allied Chemical OU1 and OU2 FSs, discussed the proposed cleanup
plans, answered questions from the community, and accepted public
comments. A court reporter was present to record the meetings. EPA
distributed copies of the Proposed Plan fact sheets at the meetings.
EPA offered to hold a public meeting to present and discuss EPA's
proposed cleanup plan for OU3, but a meeting was not requested.
EPA received a request to extend the public comment period for the
OU2 proposed cleanup plan during the October 23, 1990 meeting. As a
result, EPA extended the comment period for 30 days. EPA published a
notice of the public comment period extension in the Ironton Tribune.
On November 7 and 8, 1990, EPA conducted interviews with local
officials, residents, and a local environmental interest group to
assess community concerns regarding the Site and to evaluate past
community relations activities. EPA used the information collected
during these interviews to update the 1986 Community Relations Plan and
EPA's mailing list.
On November 19, 1990, EPA and Ohio EPA appeared before the Ironton
City Council and members of the public to answer additional questions
about the Site and the proposed OU2 cleanup plan. EPA distributed a
``Question & Answer'' fact sheet to provide easy-to-understand answers
to the questions raised by the community. EPA mailed a copy of the
``Question & Answer'' fact sheet to all individuals on the updated
mailing list for the Site.
EPA received three public comments during the proposed plan public
comment period for OU1, 25 public comments and one concern during the
comment period for OU2, and two public comments during the comment
period for OU3. EPA responded to the comments in Responsiveness
Summaries attached to the 1988, 1990, and 2007 RODs.
EPA issued fact sheets summarizing the proposed ROD Amendments #1
(1995), #2 (1997), and #3 (1998), and held thirty-day public comment
periods to accept comments on the proposed ROD Amendments. EPA also
held a public meeting on March 30, 1995 to discuss EPA's proposed ROD
Amendment #1. EPA did not receive any public comments on proposed ROD
Amendments #1 or #2, and only positive comments on EPA's proposed ROD
Amendment #3.
EPA placed a copy of the 2015 OU3 ESD and the 2020 OU2 ESD in the
information repositories at the Briggs Lawrence Public Library and at
EPA's Region 5 office, in the administrative record file, and on EPA's
web page for the Allied Chemical Site at https://www.epa.gov/superfund/allied-chemical-ironton.
EPA published advertisements announcing EPA's FYRs for the Allied
Chemical Site in the local newspaper, the Ironton Tribune, at the start
of the 1999, 2004, 2009, 2014, and 2019 FYRs. The newspaper
announcements informed the community about the start and purpose of the
FYRs and invited the public to submit comments and concerns about the
Site to EPA. EPA placed copies of the FYR Reports in the local
information repository at the Briggs Lawrence County Public Library and
made them available on EPA's website.
In 2011, EPA and the City hosted a workshop with Site property
owners and representatives from local businesses, adjacent properties,
local educational and healthcare institutions, and local and state
government to plan for Site reuse. In 2018, EPA conducted interviews
with the City of Ironton mayor, residents, and businesses as part of
the 2019 FYR process, to document any perceived problems or successes
with the remedy.
EPA has satisfied public participation activities for this partial
deletion of the Allied Chemical Site as required by CERCLA section
113(k), 42 U.S.C. 9613(k), and CERCLA section 117, 42 U.S.C. 9617. EPA
arranged to publish an advertisement announcing this proposed direct
final Partial Deletion and the 30-day public comment period in the
Ironton Tribune concurrent with publishing this partial deletion in the
Federal Register. Documents in the deletion docket, which EPA relied on
for recommending the partial deletion of the Allied Chemical Site from
the NPL, are available to the public at https://www.regulations.gov and
at https://www.epa.gov/superfund/allied-
[[Page 37777]]
chemical-ironton. Documents in the Docket include maps which identify
the Allied Chemical Site; the locations of OU1, OU2 and OU3; areas of
contamination and remediation; and the ICIAP, FYRs, and other Site
reports.
Determination That the Criteria for Partial Deletion Have Been Met
The soil (land) portion of OU1 (GDA); the soil (land) and lagoons
portion of OU2 (CPLA), except for the OU2 ROD Soils Area 2 located
within the bermed area of the East Tank Farm (see Figure 3 in the
Docket); and all of OU3 (which only addressed contaminated soil and
sediment at the Tar Plant and in the adjacent Ohio River), meet all of
the site completion requirements specified in Office of Solid Waste and
Emergency Response (OSWER) Directive 9320.2-22, Close Out Procedures
for National Priorities List Sites. All cleanup actions and remedial
action objectives for OU1 soil, OU2 soil and lagoons (except for OU2
ROD Soils Area 2), and OU3 set forth in the 1988, 1990, and 2007 RODs,
the 1995 to 1998 ROD Amendments #1 to #3, and the 2015 ESD have been
implemented for all pathways of exposure. The selected remedial
actions, RAOs, and associated cleanup levels for OU1 soil, OU2 soil,
and lagoons (except for OU2 ROD Soils Area 2) and OU3 are consistent
with EPA policy and guidance. No further Superfund response is
necessary to protect human health or the environment from the soil
portion of OU1, the soil and lagoons portion of OU2 (except for OU2 ROD
Soils Area 2), or from OU3.
Section 300.425(e) of the NCP states that a Superfund site or a
portion of a site may be deleted from the NPL when no further response
is appropriate. EPA, in consultation with the State of Ohio, has
determined that all required response actions have been implemented for
the soil portion of OU1, the soil and lagoons portion of OU2 (except
for the OU2 ROD Soils Area 2), and all of OU3, and that no further
response action is appropriate for these media/areas.
V. Deletion Action
EPA, with concurrence of the State of Ohio, through the OEPA, has
determined that all appropriate response actions under CERCLA, other
than maintenance, monitoring, and five-year reviews, have been
completed for the soil (land) portion of OU1 (GDA), the soil (land) and
lagoons portion of OU2 (CPLA), except for the OU2 ROD Soils Area 2
located within the bermed area of the East Tank Farm (see Figure 3 in
the Docket), and all of OU3 (which only addressed contaminated soil and
sediment at the Tar Plant and in the adjacent Ohio River) of the Allied
Chemical Site. Therefore, EPA is deleting the soil portion of OU1, the
soil and lagoons portion of OU2 except for the OU2 ROD Soils Area 2,
and all OU3, of the Allied Chemical Site from the NPL.
Because EPA considers this action to be noncontroversial and
routine, EPA is taking it without prior publication. This action will
be effective August 24, 2020 unless EPA receives adverse comments by
July 24, 2020. If adverse comments are received within the 30-day
public comment period, EPA will publish a timely notice of withdrawal
of this direct final Notice of Partial Deletion before its effective
date and the partial deletion will not take effect. EPA will prepare a
response to comments and continue with the deletion process on the
basis of the notice of intent to partially delete and the comments
already received. There will be no additional opportunity to comment.
List of Subjects in 40 CFR Part 300
Environmental protection, Air pollution control, Chemicals,
Hazardous substances, Hazardous waste, Intergovernmental relations,
Penalties, Reporting and recordkeeping requirements, Superfund, Water
pollution control, Water supply.
Dated: June 11, 2020.
Kurt Thiede,
Regional Administrator, Region 5.
For the reasons set out in this document, 40 CFR part 300 is
amended as follows:
PART 300--NATIONAL OIL AND HAZARDOUS SUBSTANCES POLLUTION
CONTINGENCY PLAN
0
1. The authority citation for part 300 continues to read as follows:
Authority: 33 U.S.C. 1251 et seq.; 42 U.S.C. 9601-9675; E.O.
13626, 77 FR 56749, 3 CFR, 2013 Comp., p. 306; E.O. 12777, 56 FR
54757, 3 CFR, 1991 Comp., p. 351; E.O. 12580, 52 FR 2923, 3 CFR,
1987 Comp., p. 193.
0
2. Table 1 of appendix B to part 300 is amended by revising the entry
under ``Allied Chemical & Ironton Coke'', ``OH'' to read as follows:
Appendix B to Part 300--[Amended]
Table 1--General Superfund Section
----------------------------------------------------------------------------------------------------------------
State Site name City/county Notes (a)
----------------------------------------------------------------------------------------------------------------
* * * * * * *
OH.................................... Allied Chemical & Ironton Coke Ironton................. P
* * * * * * *
----------------------------------------------------------------------------------------------------------------
(a) * * *
P = Sites with partial deletion(s).
* * * * *
[FR Doc. 2020-13302 Filed 6-23-20; 8:45 am]
BILLING CODE 6560-50-P