SECOND FIVE-YEAR REVIEW REPORT

FOR

FIKE/ARTEL CHEMICAL

SUPERFUND SITE

NITRO, WEST VIRGINIA

Prepared by:

U.S. Environmental Protection Agency

Region III

Philadelphia, Pennsylvania

Table of Contents

List of Acronyms.................................................................................................iExecutive Summary.............................................................................................iiFive-Year Review Summary Form......................................................................iii

1. Introduction...........................................................................................1

2. Site Chronology.....................................................................................1

3. Background............................................................................................2Site Description........................................................................................2History of Contamination......................................................................... 3Initial Response........................................................................................4

4. Remedial Actions ...................................................................................4

V. Progress Since Last Five-Year Review................................................8

VI. Five-Year Review Process.....................................................................8 Administrative Components.......................................................................8Community Involvement............................................................................9Document Review.....................................................................................9Data Review.............................................................................................9Site Inspection.........................................................................................11Interviews................................................................................................11

VII. Technical Assessment ...........................................................................11Question A: Is the remedy functioning as intended by thedecision documents?.................................................................................11Question B: Are the exposure assumptions, toxicity data,cleanup levels, and remedial action objectives (RAOs) used at the]time of the remedy still valid?....................................................................12Question C: Has any other information come to light that could call into question the protectiveness of the remedy?...................................14Technical Assessment Summary...............................................................14

VIII. Issues................................................................................................... 14

IX. Recommendations and Follow-up Actions ............................................ 15

X. Protectiveness Statement(s)....................................................................15

XI. Next Review.............................................................................................16

Tables

Table 1 Chronology of Site Events............................................................... 1

Attachments

Attachment 1- Figure 1 - Site Location MapFigure 2 - Site Plan

Attachment 2 -Table 2 - Ground Water Chemicals of Concern

Attachment 3 - List of Documents Reviewed

Attachment 4 - Five-Year Review Inspection

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List of Acronyms

CD Consent Decree

CERCLA Comprehensive Environmental Response, Compensation and Liability Act

CST Cooperative Sewage Treatment Plant

ESD Explanation of Significant Difference

FS Feasibility Study

MCL Maximum Contaminant Level

MCLG Maximum Contaminant Level Goal

NCP National Contingency Plan

NPL National Priorities List

OU Operable Unit

PRP Potentially Responsible Party

RAO Remedial Action Objective

RCRA Resource Conservation and Recovery Act

RD Remedial Design

RI Remedial Investigation

ROD Record of Decision

RPM Remedial Project Manager

WVDEP West Virginia Department of Environmental Protection

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Executive Summary

The remedies for OU1, OU2 and OU3 at the Fike/Artel Superfund site in Nitro, West Virginiaare complete. OU1 included the removal and off-site treatment and/or disposal of hazardous materialsstored in drums, cylinders, laboratory containers and tanks. OU2 included the demolition, removal andoff-site disposal of buildings and tanks. For OU3, buried drums and containers were excavated fromthe southern portion of the Site. In total, about 18,500,000 pounds of material have been removedfrom the Site. OU4 addresses soil and groundwater. The soils component of the OU4 remedyincludes an asphalt cap which is scheduled to be completed by August 2003. The ground watercomponent of the OU4 remedy includes a pump and treat system. The OU4 ROD allows a five yeartime frame (September 2006) to complete construction of the ground water pump and treat system sothat the extent of ground water contamination can be more fully defined. The trigger for this five-yearreview was the previous five-year report signed on October 28, 1996.

The assessment of this five-year review found that the remedies for OU1, OU2, and OU3 were implemented in accordance with their respective RODs and are considered protective of humanhealth and the environment. Construction of the soils component of the OU4 remedy (asphalt cap)isexpected to begin in October 2002. In the interim, there is site security and a fence to minimize humanexposure. Construction of the ground water component of the OU4 remedy is expected to becompleted in September 2006. Institutional controls are necessary to ensure that no one utilizes theground water as a drinking water source. Currently, no one is drinking the ground water. EPA, theWVDEP, and the PRPs are investigating the most appropriate institutional controls to make the remedyprotective.

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Five-Year Review Summary Form

SITE IDENTIFICATION

Site name: Fike/Artel

EPA ID: WVD047989207

Region: 3 State: WV City/County: Putnam and Kanawha

SITE STATUS

NPL status: :Final o Deleted o Other (specify)_____________________________________

Remediation Status (choose all that apply): : Under Construction o Operating o Complete

Multiple OUs?* :YES o NO Construction completion date: under construction

Has site been put into reuse? o YES : NO

REVIEW STATUS

Lead agency: : EPA o State o Tribe o Other Federal Agency ___________________________

Author name: Kate Lose

Author title: Remedial Project Manager Author Affiliation: U.S. EPA - Region 3

Review period: 06/03/02 to 09/30/02

Date(s) of site inspection: 07/08/02

Type of review: : Post-SARA o Pre-SARA o NPL-Removal only

o Non-NPL Remedial Action Site o NPL State/Tribe-lead

o Regional Discretion

Review number: o 1 (first) : 2 (second) o 3 (third) o Other(specify)__________________

Triggering action:

o Actual RA Onsite Construction at OU # _____ o Actual RA Start at OU# ______

o Construction Completion : Previous Five-Year Review Report

o Other (specify) ___________________________

Triggering action date: 10/28/96

Due date (five years after triggering action date): 10/28/01

* (“OU” refers to operable unit.)** (If a contractor writes the report, the author name should be written as, “RPM w/ (contractor name) assistance.)*** (Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.)

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Five-Year Review Summary Form cont’dIssues:

Lock on one of the monitoring wells was broken.

Fence on northern perimeter of Site requires some minor repair.

The asphalt cap needs to be constructed.

Extent of ground water contamination has not been defined.

Institutional controls to prevent exposure to contaminated ground water outside the property boundariesare not in place.

Recommendations and Follow-up Actions

The lock on the monitoring well was replaced. A routine monitoring well inspection program should bedeveloped.

The fence will be repaired/replaced as part of the remedial action.

Construction of the asphalt cap is scheduled to begin in October 2002.

The PRPs are in the process of preparing a work plan, for EPA approval, to investigate the extent of groundwater contamination.

Investigate administrative measures to prevent installation of extraction wells down gradient of theChemical Plant and CST.

Protectiveness Statement

The remedy for OU1 is protective of human health and the environment as intended by the OU1 ROD toprevent fires and explosions.

The remedy for OU2 is protective of human health and the environment as intended by the OU2 ROD toremove safety hazards.

The remedy for OU3 is protective of human health and the environment as intended by the OU3 ROD to:remove sources of soil and ground water contamination; eliminate potential for direct exposure viasubsurface collapses; and remove buried drums to facilitate future site investigation and remediation.

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FIVE-YEAR REVIEW REPORT

FIKE/ARTEL SUPERFUND SITE

I. Introduction

EPA Region III conducted this second five-year review pursuant to CERCLA section 121(c),NCP section 300.400(f)(4)(ii), and OSWER Directive No. 9355.7-03B-P (June 2001). It is astatutory review. The first five-year review was completed on October 28, 1996. The five-year review is required due to the fact that hazardous substances, pollutants, or contaminantsremain at the Site above levels that allow for unlimited use and unrestricted exposure.

The purpose of a five-year review is to determine whether the remedial action at a Site isprotective of public health and the environment and is functioning as designed. In addition, five-year review reports identify issues found during the review, if any, and recommendations toaddress them. This document will become part of the Site file.

This review was conducted by the Remedial Project Manager (RPM) for the entire Site fromJune 2002 through September 2002. This report documents the results of the review.

II. Site Chronology

Table 1 - Chronology of Site Events

Event Date

Gunpowder plant during World War I 1918

Specialty chemicals manufacturing 1953 -1988

Site listed on NPL 9/01/83

EPA initiated removal activities resulting in closure of facility 6/11/88

EPA issued a ROD which authorized EPA to utilize remedial funds tocontrol, stabilize and or eliminate hazards. (OU1)

9/29/88

EPA issued a second ROD calling for the dismantling and decontaminationof all tanks, equipment and buildings. (OU2)

9/28/90

Event Date

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EPA entered into a Consent Decree with thirteen PRPs to conduct RD/RAfor OU2

2/20/92

EPA issued a third ROD to excavate buried drums and containers (OU3).This ROD was subsequently modified with two Explanation of SignificantDifferences (ESDs) on May 13, 1993 and January 30, 1996.

3/31/92

EPA issued a Unilateral Order to twenty PRPs to implement the OU3 ROD. 6/30/93

EPA entered into an Administrative Order on Consent with thirteen PRPs toconduct an RI/FS for soils and ground water (OU4).

9/30/94

EPA and West Virginia entered into a Consent Decree (Civil Action No.2:93-0654) with fifty-four PRPs which required among other things, thePRPs perform, pay for and implement the remedial/removal actionsassociated with OU3, OU4, and the Cooperative Sewage Treatment Plant(CST).

2/29/97

EPA issued a removal order to 51 PRPs to dismantle the buildings andequipment at the CST.

5/03/97

EPA issued Certification of Completion for OU2 6/19/97

EPA issues Remedial Action Report for OU3 9/30/97

EPA issued Certification of Completion for CST. 4/28/98

RI/FS for OU4 is available to the public 7/06/01

EPA issues ROD for OU4 9/28/01

EPA authorizes PRPs to proceed with soils remedy 2/28/02

The RD for the Soils Component of the OU4 ROD approved. 9/10/02

A work plan to investigate the extent of ground water contamination is beingprepared.

September 2002

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III. Background

Site Description

The Fike/Artel Superfund Site is a former small volume chemical manufacturer locatedapproximately 1.1 miles south-southwest of the intersection of Interstate 64 and State Route25, in the town of Nitro, West Virginia. The Site consists of an 11.9 acre former batchchemical production plant and a 0.9 acre former Cooperative Sewage Treatment Plant(referred to as the CST), located approximately 500 feet west of the Chemical Plant. TheKanawha River is approximately 2000 feet west of the Chemical Plant (see Attachment 1,Figure 1).

The Chemical Plant, constructed over the razed remains of a World War I gunpowder plant,began operations in 1953 under the ownership of Roberts Chemical Company. In 1971, thename was changed to Fike Chemicals Inc. and later to Artel Chemical Company. More than60 different chemicals were produced by batch reaction processes throughout the operationalhistory of the plant. The Chemical Plant consisted of chemical production areas, office andlaboratory buildings, three waste lagoons, and drum and waste burial areas.

The CST was constructed between 1966 and 1968 to treat sanitary and industrial wastewaterand storm water runoff from the Fike Chemical Plant and an adjacent truck terminal (seeAttachment 1, Figure 2).

Land use adjacent to the Chemical Plant includes a railroad yard to the east; a lumberrepackaging facility to the south, three chemical tank wagon depots and washing facilities to thewest; and a chemical manufacturing facility and industrial park to the north. Industrial facilitiesor operations surround the CST. A tank wagon washing and maintenance facility lies to theeast; a small volume specialty chemical manufacturing facility lies to the south, an industrial parklies immediately to the north; and an industrial park, landfill, and chemical manufacturing facilitylie to the west between the CST and Kanawha River.

The Site itself is currently a vacant lot with a fence. Restrictions are in place to limit the futureuse to industrial use. Ground water underlying the Site is currently not used as a drinking watersource. The dominant ground water flow direction is to the north-northwest toward theKanawha River.

History of Contamination

In the course of the batch chemical processing, waste products were land disposed on-site. Still bottoms and various reaction by-products, both liquids and solids, were placed in drumsand stockpiled or buried onsite in the waste disposal area covering the southern half of the Site.

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Contaminants in soil include benzene, toluene, ethylbenzene, xylene, arsenic, and dioxin. Theground water is contaminated with thirty-four different compounds (See Attachment 2).

Initial Response

In June 1988, due to the poor condition of storage vessels, incompatible materials storage, andlarge quantities of high hazard materials at the Fike/Artel Site, the West Virginia Division ofEnvironmental Protection, Kanawha County and Putnam County emergency services officialsrequested EPA assistance. On June 11, 1988, using federal funds and pursuant to Delegation14-1-A, EPA initiated a CERCLA removal action to mitigate the threats to public health andthe environment posed by the Fike/Artel Site.

The size and complexity of the Site required additional funds in excess of the initial activation. On September 29, 1988, a Record of Decision for the Site was signed, authorizing EPA toutilize remedial funds to control, stabilize, and/or eliminate hazards (OU1). The scope of workwith an estimated total project cost of $20,250,000 was approved by EPA Headquartersthrough the Regional Administrator. From 1988 to 1992, EPA conducted emergency responseactions to address threats posed by the Site including leaking tanks and drums; laboratorycontainers; a hydrogen cyanide cylinder, and other hazardous materials.

IV. Remedial Actions

The size and complexity of the Site required additional funds and response actions beyondthose called for in the OU1 ROD. EPA organized the long-term clean-up activities into severaloperable units (OUs) The combined efforts of EPA’s Removal, Enforcement and Remedialprograms have been used to address the many environmental problems at the Site.

On September 28, 1990, EPA issued a second Record of Decision (OU2) calling for thedismantling and decontamination of all tanks, equipment, and buildings. Between 1990 and1996 all buildings and tanks with associated piping were decontaminated, demolished anddisposed of at an off-site location.

On March 31, 1992 EPA issued a third Record of Decision (OU3) to excavate buried drumsand containers from the southern portion of the Site. The excavated materials were disposedoff-site. This ROD was subsequently modified with two Explanation of Significant Differences(ESDs) on May 13, 1993 and January 30, 1996. The first ESD eliminated the requirements fora dome during the drum excavation. The second ESD required the construction of a wastewater treatment plant to treat surface water.

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In March 1997, EPA approved a response action plan to remediate the CST. The buildingsand tanks at the CST were dismantled. The three lagoons were dewatered and the sludge andunderlying soils were excavated. All the materials generated during this removal action weredisposed off-site. The lagoons were backfilled with clean material. This work was completedin1997.

On September 28, 2001 EPA issued a fourth Record of Decision (OU4) for the final action forthe Site. The selected remedy for OU4 is divided into five (5) components: CST; ChemicalPlant and Lagoon 3; Ground Water; World War I era and other sewers; and InstitutionalControls.

The Remedial Action Objectives (RAOs) were developed to mitigate and/or prevent existingand future potential threats to human health and the environment. The RAOs for the selectedremedy for the soils for the Fike/Artel Superfund Site are to:

• Protect human health and the environment by reducing excess cancer risks to within theEPA target risk range for the anticipated future use of the Chemical Plant and CST asindustrial properties.

• Remove soils containing elevated levels of arsenic and dioxin.

The RAOs for the selected remedy for the World War I-era and other sewers for theFike/Artel Superfund Site are to:

• Investigate World War I-era sewers that originate in the vicinity of the CST anddischarge to the Kanawha River to determine if they contain contaminated sediments.

• Remove potential contaminated sediments from the 12-inch sewer line from the CST toKanawha River.

The RAOs for the selected remedy for ground water for the Fike/Artel Superfund Site are to:

• Reduce concentrations of COCs in ground water to levels which result in less than orequal to a 1 x 10-5 cumulative cancer risk and a Hazard Index less than 1.0 and achievedrinking water standards (MCLs and non-zero MCLGs);

• Ensure that ground water is not used for water supply until concentrations of COCs arereduced to levels which result in less than or equal to a 1 x 10-5 cumulative excesscancer risk and a Hazard Index less than 1.0 and achieve drinking water standards(MCLs and non-zero MCLGs).

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The major components of the remedy selected in the OU4 ROD are described below:

CST

The selected remedy for the CST is an asphalt cap to prevent human exposure tosubsurface soils.

Chemical Plant and Lagoon 3

The selected remedy for the Chemical Plant includes excavating Lagoon 3 andbackfilling with clean fill and placing an asphalt cap over the entire surface of theChemical Plant. The excavated stabilized sludge from Lagoon 3 will be disposed off-site at either a RCRA Subtitle C or Subtitle D disposal facility as appropriate.

Ground Water

The selected remedy for ground water is a pump and treat system to reduce theconcentration of contaminants of concern to risk based drinking water levels. Theoperation of the pump and treat system will be delayed for five years to conductadditional data collection and remedial design activities.

World War I-era and other Sewers

A 12-inch sewer line runs from the CST to the Kanawha River. This line will beflushed. The material flushed from the line will be collected and sampled for disposal. The material flushed from the line will be disposed at an appropriate off-site disposalfacility. World War I-era sewers that originate northwest of the Chemical Plant and inthe vicinity of the CST and ultimately discharge into the Kanawha River will beinvestigated to determine if they contain contaminated sediments.

Institutional Controls

Institutional controls are warranted to ensure that the future use of the land remainsindustrial only. Appropriate institutional controls may include an attachment or noticeto the deed restricting future land use . Existing institutional controls for the CST andthe Chemical Plant include attachments or notices to the deeds restricting future landuse to industrial use. In addition, institutional controls are also needed to ensure that noone is exposed to the contaminated ground water.

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Remedy Implementation

OU1

On September 29, 1988, a Record of Decision (“ROD”) was signed authorizing EPA to utilizeremedial funds to control, stabilize, and/or eliminate hazards (“OU1"). The major componentsof this remedy included the removal and off-site disposal of hazardous materials stored indrums, cylinders, laboratory containers and tanks. The remedial action was completed inSeptember 1993. The CST continued to treat surface water prior to discharge to the KanawhaRiver until 1997. The remedial action for OU1 was conducted in conformance with theOU1 ROD.

OU2

One September 28, 1990, EPA issued a second ROD (“OU2") calling for the dismantling anddecontamination of all tanks, equipment and buildings. Between 1990 and 1996 all buildings,and tanks with associated piping were decontaminated, demolished, and disposed of at an off-site location. The remedy was conducted in accordance with the OU2 ROD.

OU3

On March 31, 1992 EPA issued a third Record of Decision (OU3) to excavate buried drumsand containers from the southern portion of the Site. The excavated materials were disposedoff-site. This ROD was subsequently modified with two Explanation of Significant Differences(ESDs) on May 13, 1993 and January 30, 1996. The first ESD eliminated the requirements fora dome during the drum excavation. The second ESD required the construction of a wastewater treatment plant to treat surface water. The remedy for OU3 was completed inaccordance with the ROD and ESDs in September 1997.

OU4

EPA and West Virginia entered into a Consent Decree (Civil Action No.2:93-0654) onFebruary 17, 1997 with fifty-four PRPs. This Consent Decree requires that the PRPs perform,pay for and implement the OU4 and CST remedy unless:

“i. the remedy selected in the OU-4 ROD is estimated in the OU-4 ROD to costmore than $45 million; or

ii. the remedy selected in the OU-4 ROD is not based on an assumption thatfuture land use at the Site will be industrial use.”

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Subsequent to the issuing of the OU4 ROD, the PRPs met with EPA concerning the groundwater component of the ROD. The PRPs contend that the OU4 ROD fails to satisfy the aboveconditions because the clean-up numbers for ground water are based on future use of groundwater as drinking water. In addition, they stated that the cost estimates in the ROD did notappropriately address remediation to the risk based numbers for ground water consumptionand in turn remediation of ground water could cost more than $45 million.

The PRPs are preparing a ground water work plan for EPA approval. The work plan willprovide the scope of work to collect additional ground water data to determine the extent ofground water contamination.

The PRPs have agreed to implement the soils component of the OU4 ROD. On September10, 2002, EPA approved the Remedial Design for the soils component of the OU4 ROD. EPA anticipates that construction for the CST cap will begin in October 2002 and theconstruction of the Chemical Plant remedy will begin in November 2002.

V. Progress Since Last Five-Year Review

The last Five-Year Review was completed October 28, 1996 and concluded that the remedy was notprotective of human health and the environment because the investigation of ground water and soils wasstill underway. The soils investigation is complete and construction of the soils remedy is scheduled tobegin in October 2002. Additional ground water data is needed to define the extent of contamination. Institutional controls are necessary to ensure that no one uses the ground water as a drinking watersource.

VI. Five-Year Review Process

Administrative Components

The Fike/Artel Trust, a group representing the Potentially Responsible Parties (PRPs) and members ofthe Community Liaison Panel were notified of the five-year review on July 9, 2002.Kate Lose, the EPA Remedial Project Manager for the Fike/Artel Superfund Site conducted the five-year review. Patrick Gaughan, the Community Information Coordinator for the Site, and MarkSlusarski, the representative for the West Virginia Department of Environmental Protection assisted inthe review.

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Community Involvement

The PRPs organized a Fike/Artel Trust Community Liaison Panel in 1994 to create a forum wherecitizens could gain knowledge about the project. The panel members include Fike/Artel Trustrepresentatives, EPA and WVDEP representatives, local residents, and community leaders. The panelmeets three to four times a year depending on the level of activity at the Site. At the Community Liaison Meeting on July 9, 2002, Kate Lose, the EPA Remedial Project Manager,discussed the Five-year review process. Attendees at the meeting included the mayor, communityleaders, local residents, and a representative of a business adjacent to the site. Kate Lose asked ifpeople had any concerns about the Site. They responded by saying they want to see the Site be putback to productive use as soon as possible. Kate Lose stated that if anyone wished to speak to her inprivate, that she would be available at the close of the meeting, or she could be reached via a toll freephone number which she provided at the meeting. The Five-year review topic and toll free numberwas provided in the minutes to the meeting which was distributed by regular mail to all CommunityLiaison Panel members. Noone expressed any concerns or provided information about the Site, eitherin person or by phone. Document Review

The five-year review consisted of a review of relevant documents including the OU4 RI reports, theRecords of Decision (RODs), the Remedial Design Work Plan and the Remedial Design Report forsoils, and monthly progress reports. Soils and ground water data collected during OU 1, OU2 andOU3 remedial actions were incorporated into the OU4 RI report.

Data Review

A list of documents reviewed is provided in Attachment 3.

Ground Water Monitoring Data and OU4 ROD Review

Three rounds of ground water data were collected during the OU4 RI. The results of the riskassessment identified thirty-four Chemicals of Concern that are contributing to overall ground waterrisks. These Chemicals of Concern are listed in Attachment 2. Based on the data collected during theRI, Site related ground water contamination appears to be moving in the direction of the KanawhaRiver. No one is currently using the ground water as a water supply for either residential or industrialuse.

The data collected as part of the RI did not reveal an area that serves as a continuing source of groundwater contamination. Previous remedial and removal actions have removed about 18.5 million poundsof waste material which has significantly reduced any potential continuing source of chemical

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constituents to ground water.

EPA is working with the Fike/Artel Trust to develop a scope of work to better define the extent ofground water contamination.

Soil Data, OU4 ROD and Remedial Design Review

There are a wide range of contaminants at various concentrations throughout the Chemical Plant andthe CST including volatile organic compounds, metals, pesticides, herbicides and dioxin. Thecompounds which present the greatest risk from direct contact with soils are arsenic and dioxin. Arsenic was detected in every soil sample. The average concentration of arsenic was approximately 16mg/kg with the exception of one location that contained 1,100 mg/kg. Dioxin concentrations measuredas Toxic Equivalents ranged from non-detect up to 45 ug/kg.

The soils remedy includes the excavation and off-site disposal of material from Lagoon 3, excavation ofsoils containing elevated levels of arsenic and dioxin, and placement of an asphalt cap over the areaencompassing both the CST and the Chemical Plant.

The Remedial Design for the soils remedy was approved on September 10, 2002.

Historical Data

The previous removal and remedial actions consisted of removing material from the Site. Limited datawas collected to evaluate the nature and extent of contamination. For example, a report prepared forthe OU1 remedy, “Federal On-Scene Coordinator’s Report for Fike/Artel Chemical Site, Putnam andKanawha Counties, West Virginia, 14 June, 1988 - 18 March 1993", documents the activities for thistime frame and lists the quantity and type of waste removed from the site during this time frame. Thereport estimates that 3 million pounds of solids and 774,000 gallons of waste material was removedfrom the site.

Records showing some historical soil and ground water data were located during the OU 4 RemedialInvestigation and Feasibility Study. Because the validated data was unavailable, the historical data wasused to identify appropriate sampling locations for the OU 4 investigation.

While the OU4 investigation was ongoing, EPA determined that the Kanawha River contained elevatedlevels of dioxin. The Superfund removal program collected soil and water samples at locationssuspected of containing dioxin that may be a continuing source of dioxin contamination to the KanawhaRiver. Samples were collected on and around the Fike site. The analytical results revealed that the soilsamples from these locations did not contain levels of dioxin that would serve as a continuing source ofdioxin to the Kanawha River. As part of the Kanawha River investigation, EPA reviewed historicaldata (1983) which showed elevated levels of dioxin in soil at the site. Confirmation samples were

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collected from these same locations in March 2000. The results of this sampling event showed twolocations containing elevated levels of dioxin. These samples were taken from an area that is currentlycovered with two to three feet of soil used as a construction access road used during remedial activities. The OU4 remedy will include excavation and off-site disposal of the soils at these two locationsfollowed with the placement of an asphalt cap.

Currently, surface water is treated at the onsite surface water treatment facility prior to discharge to thePublicly Owned Treatment Works (POTW) operated by the Nitro Sanitary Board. The treated surfacewater is discharged in accordance with a Nitro Sanitary Board permit and is analyzed for dioxin on aquarterly basis. To date, dioxin has not been detected in the surface water discharge.

Site Inspection

EPA and WVDEP conducted a Site inspection on July 8, 2002. A Site Inspection Report is attached(Attachment 4).

Interviews

EPA conducted interview with owners and/or operators of businesses immediately adjacent to the Site,as well as community members and elected officials. Overall, the interviewees stated that they believedthe process to restore the site to beneficial reuse was too drawn out. Everyone interviewed is anxiousto see the soils remedy constructed and the Site redeveloped.

VII. Technical Assessment

Question A. Is the remedy functioning as intended by the decision documents?

OU1

The OU1 ROD included the removal and off-site disposal of hazardous materials stored in drums,cylinders, containers, and tanks. There is no operations and maintenance and/or long term monitoringassociated with the OU1 remedy. The OU1 remedy is functioning as intended by the OU1 ROD.

OU2

The OU2 remedy included the dismantling and decontamination of all tanks, equipment and buildings. Between 1990 and 1996 all buildings, and tanks with associated piping were decontaminated,demolished, and disposed of at an off-site location. There is no operations and maintenance associatedwith the OU2 remedy. The OU2 remedy is functioning as intended by the OU2 ROD.

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OU3

The OU3 remedy included the excavation of buried drums and containers from the southern portion ofthe Site. The excavated materials were disposed off-site. The OU3 remedy also included theconstruction of a waste water treatment plant to treat surface water. The remedy for OU3 wascompleted in accordance with the ROD and ESDs in September 1997. There is no operations andmaintenance associated with the drum excavation. Surface water is treated at the on-site surface watertreatment plant on an episodic basis (precipitation events). Water is tested, prior to discharge tothePOTW operated by the Nitro Sanitary Board, to ensure that it complies with permit criteria. TheOU3 remedy is functioning as intended by the OU3 ROD and subsequent ESDs.

OU4

The remedy is not constructed. The remedial design for the soils component of the remedy wasapproved on September 10, 2002. In the interim, the site is fenced and there is a mixture of on-siteguard patrol and police surveillance to prevent access to the Site. Institutional controls are warrantedto prevent exposure to contaminated ground water beyond the property boundary.

Question B. Are the exposure assumptions, toxicity data, cleanup levels, and remedial actionobjectives (RAOs) used at the time of the remedy selection still valid?

OU1

The OU1 ROD included the removal and off-site disposal of hazardous materials stored in drums,cylinders, containers, and tanks. Due to the volatility of a variety of chemicals in an uncontrolled setting,the OU1 ROD focused on the immediate threat of fire and explosive hazards. A risk assessment wasnot conducted and clean-up numbers were not developed. The intent of the ROD was to stabilize thesite and this was accomplished by removing the hazardous materials from the site.

OU2

The OU2 remedy included the dismantling and decontamination of all tanks, equipment and buildings. Many buildings and tanks were on the verge of collapse making it impossible to satisfactorily evaluatethe impact of the Site on human health and the environment. A risk assessment was not conducted andclean-up numbers were not developed. The objective of the remedy was to remove the structureswhich presented safety hazards and obstacles to future work at the site which was successfullyaccomplished.

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OU3

The OU3 remedy included the excavation of buried drums and container on the southern portion of thesite. Although a human health risk assessment was not conducted, the ROD identified the “risks asfollows:

• Contaminant sources contained in buried drums and containers may continue or begin tocontaminate soil, ground water, surface water, and the atmosphere.

• Contaminant sources contained in buried drums and containers present a risk of direct contactto the public through subsurface collapses or future excavations.

• Buried drums and containers are obstacles preventing the subsurface investigation of the wastedisposal area. Without removal of buried drums and containers a comprehensive investigationof contamination in these areas cannot be performed.”

The remedial action objectives included:

• “Eliminate the future or continued contamination of soil, ground water, surface water, and theatmosphere from sources contained in the buried drums and containers.

• Eliminate the potential for direct exposure of the surrounding population to hazardoussubstances contained in buried drums and containers (from subsurface collapses or futureexcavations).

• Remove buried drums and containers to facilitate future site investigation and remediation.”

The risks and remedial action objectives for OU3 were valid. The OU3 remedy allowed for theinvestigation of soils and groundwater without incident or exposure to contaminants in buriedcontainers.

OU4

Yes, the exposure assumptions, toxicity data, and remedial action objectives (RAOs) used at the timeof the remedy selection are still valid. The OU4 ROD is only one year old and there have not been anychanges in the setting. The site is still in an industrial area. No new toxicity data has been generated. No new regulations or guidance which would significantly alter the ground water clean-up criteria has

1Although the MCL for arsenic has changed since the ROD for OU4 was issued, arsenic wasonly one of many chemicals found in the ground water. The ground water clean-up standard wastherefore based on the cumulative risk posed by the multiple contaminants. Thus, while the MCL forarsenic has changed from 50 to 10 parts per billion, it is unlikely that this change would effect thedecision as to when cleanup levels have been achieved, since this decision will be a risk-based decisionrather than one based solely on the MCL.

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been published since the ROD was signed on September 28, 20011.

Question C. Has any other information come to light that could call into question the protectiveness ofthe remedy?

No, for all four operable units.

Technical Assessment Summary

Upon review of the data, the site inspection, and community interviews, the remedies for OU1, OU2,and OU3 are functioning as intended by their respective RODs and ESDs. There have been nochanges in the physical conditions of the site that would affect the remedies for OU1, OU2 and OU3. For OU4, the remedy is not constructed, but access controls are in place in the interim to protecthuman health and the environment. There have been no changes in the toxicity factors for thecontaminants of concern that were used in the baseline risk assessment, and there have been nochanges to the standardized risk assessment methodology that could affect the protectiveness of theOU4 remedy after it is constructed. EPA will review the clean-up criteria for ground water as part ofthe remedial design review for the ground water component of the OU4 ROD. There is no otherinformation that calls into question the protectiveness of the remedy.

VIII. Issues

During the site inspection, a lock was broken on one of the on-site monitoring wells. The lock hassince been replaced.

The fence requires some minor repair along the northern boundary of the Main Plant.

Construct the soils remedy.

The property boundary of the former chemical plant has restrictions to prevent the installation ofextraction wells. There are no institutional controls in place outside the property boundary to preventthe installation of extraction wells for industrial or drinking water use.

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The extent of ground water contamination has not been fully defined, but additional ground watercharacterization efforts will be performed as part of the pre-design for OU4.

IX. Recommendations and Follow-up Action

Develop and implement a periodic inspection program for all monitoring wells.

The fence will be repaired as part of the remedial action for soils which is anticipated to begin inOctober 2002.

Construct the soils remedy as described in the OU4 ROD. EPA approved the RD and construction isscheduled to begin in October 2002.

Data collection points outside the property boundary are necessary to define the extent of ground watercontamination. EPA is working with the PRPs to develop a work plan for the ground water componentof the OU4 ROD which includes ground water characterization efforts.

Institutional controls are warranted to prevent exposure to contaminated ground water beyond theproperty boundary. EPA, WVDEP, and the PRPs are evaluating various administrative options toprevent the installation of extraction wells including deed attachments, county ordinances, and stateadministrative procedures.

X. Protectiveness Statement

OU1

The OU1 remedy included the removal and off-site disposal of hazardous materials stored in drums,cylinders, containers, and tanks. Due to the volatility of a variety of chemicals in an uncontrolled setting,the OU1 remedy focused on the immediate threat of fire and explosive hazards. The intent of the RODwas to stabilize the site and this was accomplished by removing the hazardous materials from the site.The remedy for OU1 is protective of human health and the environment as intended in the OU1 RODto prevent fire and explosions.

OU2

The OU2 remedy included the dismantling and decontamination of all tanks, equipment and buildings. Many buildings and tanks were on the verge of collapse making it impossible to satisfactorily evaluatethe impact of the Site on human health and the environment. The objective of the remedy was toremove the structures which presented safety hazards and obstacles to future work at the site whichwas successfully accomplished. The remedy for OU2 is protective of human health and the environmentas intended in the OU2 ROD to remove safety hazards and allow future work at the Site to proceed..

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OU3

The OU3 remedy included the excavation of buried drums and containers in the southern portion of thesite. The remedial action objectives included:

• remove sources of soil and ground water contamination;• eliminate potential for direct exposure via subsurface collapses or future excavations; and• remove buried drums to facilitate future site investigation and remediation.

The remedy for OU3 is protective of human health and the environment as intended in the OU3 ROD.

• Next Review

The next five-year review for the Fike/Artel Superfund Site is required by September 30, 2007, fiveyears from the date of this review.

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Attachment 1

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Attachment 2

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Fike/Artel Superfund Site OU4

Ground Water Chemicals of Concern

aldrinarsenicbenzenealpha-BHCbeta-BHCgamma BHCgamma-chlordanebis(2-chloroethyl) etherbis (2-chloroisopropyl bis(2-ethylhexy)phthalatebromodichloromethanecarbon tetrachloridechlorobenzenechloroform4,4'-DDT1,1-dichloroethene1,2-dichloroethane

1,2-dichloropropanedieldrin1,3-dimethyl-2-thioureaheptachlorheptachlor epoxidehexamethyl phosphoramideironmanganeseMCPAMCPPphenyl ether1,1,2,2-tetrachloroethanetetrachloroethene1,1,2-trichloroethanetoxaphenetrichloroethenevinyl chloride

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Attachment 3

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Documents Reviewed for Five-Year Review

Fike/Artel Superfund Site

1. Record of Decision (for Operable Unit One), September 29, 1988

2. Record of Decision for Operable Unit Two, September 28, 1990

3. Record of Decision, Operable Unit Three, March 31, 1992

4. Federal On-Scene Coordinator’s Report for Fike/Artel Chemical Site, Putnam and KanawhaCounties, West Virginia, 14 June 1988 - 18 March 1993

5. Explanation of Significant Differences, Operable Unit Three, January 30, 1996

6. Final Soil Remedial Investigation Report , Volume I of III, prepared by IT Corporation, 1/5/01

7. Soil Feasibility Study, prepared by GeoSyntec Consultants, January, 2001

8. Pre-Final Operable Unit Four, Remedial Investigation/Feasibility Study for Ground Water at the FikeChemical Superfund Site, Volume I of III, prepared by GeoSyntec Consultants, February 2001

9. Trip Report, Offsite Sewer System Investigation, Fike/Artel Superfund Site, prepared by West VirginiaDepartment of Environmental Protection, May 31, 2001

10. Soils FS Addendum, Chemical Plant Remedial Alternative 6, Fike Chemical Superfund Site, preparedby GeoSyntec Consultants, June 20, 2001

11. A packet of information, prepared by GeoSyntec Consultants, of Direct Push Boring Logs for August2001 drilling, and an undated Table entitled, Table 1: Post RI Lagoon 3, Waste CharacterizationAnalytical Results for Waste/Fill Material.

12. Record of Decision, Operable Unit 4, September 28, 2001.

13. Remedial Design Workplan for remedial design activities associated with the soils remedy componentof the Operable Unit Four ROD , prepared by GeoSyntec Consultants, March 2002.

14. Site Management Plan Operable Unit Four and Cooperative Sewage Treatment Plant RemedialDesign, prepared by GeoSyntec Consultants, March 2002.

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15. Site Health and Safety Plan Operable Unit Four and Cooperative Sewage Treatment Plant RemedialDesign, prepared by GeoSyntec Consultants, March 2002.

16. Operable Uniit Four and Cooperative Sewage Treatment Plant Remedial Design, prepared byGeoSyntec Consultants, March 2002.

17. Sampling and Analysis Plan Operable Unit Four and Cooperative Sewage Treatment Plant RemedialDesign, prepared by GeoSyntec Consultants, March 2002.

18. Final Design Submittal, Remedial Activities Soils Remedy Component, Operable Unit Four ROD, prepared by GeoSyntec Consultants, June 2002.

19. Fike/Artel Superfund Site Monthly Progress Reports, prepared by demaximis for the Fike/Artel Trust.

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Attachment 4

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5-Year Review Inspection

I. Site Information

Site Name: Fike/Artel Superfund Site

Location: Nitro, West Virginia

Date of Inspection: July 8, 2002

Weather/Temperature: Sunny, hot and humid, approximately 90 degrees Fahrenheit

Inspection Team: Kate Lose, EPAMark Slusarski, WVDEP

Remedy:

Due to its complexity, the site is carved into several operable units (OUs). The remedy for OU1 included theremoval and off-site disposal of hazardous materials stored in drums, cylinders, containers, and tanks whichwas completed in 1993. The OU2 remedy included the dismantling and decontamination of all tanks,equipment, and buildings and was completed in 1996. The OU3 remedy included the excavation of burieddrums and containers from the southern portion of the site. It also included the construction of a waste watertreatment plant to treat surface water. The OU 3 remedy was completed in September 1997. The finalremedy for the site (OU4) contains a component for soils and a component for ground water. The final remedyfor the soils is an asphalt cap. The final remedy for the ground water is a pump and treat remedy. NeitherOU4 remedy is constructed. EPA anticipates that the cap for the CST area will be constructed in October2002, and the soils remedy for the Chemical Plant will be completed in July 2003. In turn, the inspection waslimited to ensure that site access is restricted until the remedy is completed.

II. Interviews

EPA interviewed the City of Nitro’s mayor, and the owners and/or operators of the businesses immediatelyadjacent to the Site. Interview notes are in the Site file. A Community Liaison Panel Meeting was held onTuesday, July 9, 2002. Kate Lose, the EPA RPM for the Site, spoke to residents about the 5-year reviewprocess and asked if anyone wanted to speak in private about the site to call her at the toll free number 1-800-352-1973, ext 43240. The RPM did not receive any phone calls about the Site.

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III. On-Site Records

Daily Access/Security Logs

The security logs are readily available and up to date.

Surface Water Treatment Plant

Monthly activity reports and quarterly analytical reports are submitted to EPA.

IV. O&M Costs

The PRPs perform O&M of the surface water treatment plant and cost date is not provided to EPA. Monthly O&M status reports are provided to EPA in addition to quarterly analytical reports.

The pump and treat system is not constructed and therefore there is no O&M associated with thesystem at this time.

V. Access and Institutional Controls

A. Fencing

There is minor damage to the fence along the northern edge of the Chemical Plant. The fence needs tobe reattached to the header bar. All the gates were locked and secured.

B. Other Access Restrictions

Signs are well placed and easy to read. Security is present during the week and the area is patrolled bylocal police during off-hours and week-ends.

C. Institutional Controls

There is an attachment to the deed for the property boundaries of the CST and Chemical Plant whichprevent the installation of extraction wells for industrial or potable water. Institutional controls toprevent the extraction of ground water outside the property boundary need to be developed andimplemented.

VI. General Site Conditions

A. Roads

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Access to the Site is via a private secondary road. The road is surfaced with stone and containsnumerous pot holes and dips but driving is manageable and the road is adequate.

B. Other Site Conditions

CST

The CST, approximately one acre in size, is relatively flat and surrounded by a fence with a lockedgate. The area is covered with grass which is growing well. The grass is mowed on an as neededbasis. On July 8, 2002, the grass was about six inches in height.

There are several wells within and outside the fenced area. All wells were secured and locked. Thefence was in excellent condition and there was no evidence of any trespassing.

Chemical Plant

The Chemical Plant, approximately 12 acres in size, is generally flat with a berm constructed around theperimeter of the site to prevent run-off from leaving the site. The Chemical Plant is surrounded with achain link fence with two entrances. The site is gently graded to allow the collection of surface water toa sump, which is pumped to the surface water treatment plant. The site is vacant, with no aboveground structures except a small surface water treatment plant building and a security trailer at theentrance. The site is level, except for a closed lagoon, approximately five to six feet in height andoccupying one acre on the southwest corner of the site. The lagoon is sloped to allow for drainage. There was no evidence of erosion of the lagoon slopes or ponding of water on top of the lagoon. Thelagoon is scheduled for total excavation and removal as part of the OU4 remedial action.

The site contains numerous concrete foundations and is sparsely vegetated where there are no concretefoundations. It is mowed on an as needed basis. On July 8, 2002, the vegetation was under 12 inchesthroughout most of the site and mostly dry due to an unusually dry summer.

All buildings and above ground structures were removed during the OU2 remedial action. The surfacewater treatment plant, constructed in 1996, occupies approximately one acre of the site along the westproperty line. It consists of several above ground tanks and a small building. In 2001, new precastconcrete lintels were installed to anchor the tanks. The tanks appear to be in good condition. Sincethese tanks are scheduled to be removed after the asphalt cap is placed on the site, no physical testingof the tanks was performed. The plant is only operated as necessary, i.e. after heavy precipitationevents. The treatment plant is enclosed with a chain link fence and the entrance is locked.

The monitoring wells within the fence were locked and secured with the exception of Monitoring Well111D. The monitoring wells outside the fence were not inspected.

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Overall the fence is in good condition with some minor damage along the north property line identifiedabove under access controls.

Both entrances to the Chemical Plant were locked. Entrance was through the security trailer, where aguard was on duty.

VII. Landfill Covers N/A

VIII. Vertical Barrier Walls N/A

IX. Ground Water/Surface Water Remedies

Implementation of the ground water remedy will not be completed until 2006. Additional investigationactivities are necessary to generate data for the design and construction of a pump and treat system. Currently there is a surface water collection and treatment system which is in good condition anddescribed above in Section VI. The surface water treatment plant has been in operation since 1996.The treatment plant processes surface water on an episodic basis (after precipitation events). Treatedwater is discharged to the POTW operated by the Nitro Sanitary Board in compliance with dischargerequirements. WVDEP recently issued a new WV/NPDES Permit (Number WV0023299) for thePOTW. This permit became effective January 26, 2002 and covers, among other things, thepretreated discharge from the Fike/Artel Site.

X. Other Remedies N/A

XI. Overall Observations

The Site is secure. There was no evidence of vandalism or trespassing. The monitoring wells (both on-site and off-site) need to be routinely inspected. The community and adjacent businesses are eager tosee the site capped and developed.