FIVE-YEAR REVIEWREPORT

CELANESE CORP (SHELBY FIBER OPERATIONS) SITESHELBY, CLEVELAND COUNTY,

NORTH CAROLINA

August 2001

Prepared byU.S. Environmental Protection Agency

Region IVAtlanta, Georgia

Approved by: Date:

Richard D. GreenWaste Management Division DirectorUSEPA, Region 4

Table of Contents

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Five-Year Review Summary Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

I. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

II. Site Chronology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

III. Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

IV. Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

V. Five-Year Review Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

VI. Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

VII. Deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

VIII. Recommendations and Required Actions . . . . . . . . . . . . . . . . . . . . . . . . . . 15

IX. Protectiveness Statements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

X. Next Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Tables

Table 1 - Chronology of Site Events . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Table 2 - Annual Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Table 3 - Comparison of Initial and Current Groundwater Concentrations 12Table 4 - GW Treatment System Concentrations . . . . . . . . . . . . . . . . . . . . . . 12

Attachments

Attachment A - List of Documents Reviewed Attachment B - Site Map Attachment C - State Concurrence

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Executive Summary

The remedy for the Celanese Corp (Shelby Fiber Operations) Site in Shelby,North Carolina included pump-and-treat through air stripping of the contaminatedgroundwater and incineration of contaminated soils/sludges. The site achievedconstruction completion with the signing of the Preliminary Close Out Report on March25, 1993. The trigger for this five-year review was the signing of the last five-year reviewon December 4, 1995.

The assessment of this five-year review found that the groundwater remedyremains protective of human health and the environment, but the system is notoperating efficiently. The soil remedy is complete and no further work is needed.Therefore, this will be the last five-year review for Operable Unit 2, soil.

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Five-Year Review Summary Form

Site Identification

Site name: Celanese Corp (Shelby Fiber Operations) EPA ID: NCD003446721

Region: 4 State: NC City/County: Shelby/Cleveland County

Site Status

NPL status: Final

Remediation status (under construction, operating, complete): Operating

Multiple Ou’s* (highlight): Y N Number of OU’s: 2

Construction completion date: 3/25/93

Fund/PRP/Federal facility lead:PRP

Lead agency: EPA Region IV

Has site been put into reuse? (highlight): Y N

Review Status

Lead Agency (EPA Region, State, Federal agency): EPA Region 4

Author name: Giezelle Bennett Author title: Remedial Project Manager

Author affiliation: EPA Region 4

Review period: 5/01 - 8/01 Date(s) of site inspection: 6//01

Highlight: StatutoryPolicy

Policy Type(name): 1. Pre-SARA 2. Ongoing 3. Removal only 4. RegionalDiscretion

Review Number (1,2, etc.) 3

Triggering action event: 5-yr review

Trigger action date: 9/8/94;12/4/95

Due date: 9/01

* [“OU” refers to operable unit.]

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Deficiencies:

None

Recommendations and Required Actions:

Recommendations:

• decrease the detection limits for groundwater analytes to the contract requiredquantitation limits (CRQL);

• ‘turn-off’ the groundwater pump-and-treat system for a period of twenty-four (24months) to allow the aquifer to recover and to investigate other potentialremedies;

• grant the PRP’s request to determine if monitored natural attenuation would beeffective at the Site;

• increase the quantity of wells sampled to ensure plume remains exclusively onthe plant property; and

• periodic reconnaissance of downgradient area to determine if any new drinkingwater supply wells have been installed.

Protectiveness Statements:

The remedial actions for both soil and groundwater are protective. Because theremedial actions are protective, the remedy for the site is protective of human healthand the environment.

Other Comments:

EPA and NC DENR will continue to oversee the remediation of groundwater at this Site.The soil remedy is complete and no further work is needed. Therefore, this will be thelast five-year review for Operable Unit 2, soil.

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Celanese Corp (Shelby Fiber Operations) SiteThird Five-Year Review Report

I. Introduction

EPA Region 4 has conducted a third five-year review of the remedial actionsimplemented at the Celanese Corp, Shelby Fiber Operations Site (Celanese Site) inCleveland County, North Carolina. This review was conducted from May 2001 throughAugust 2001. This report documents the results of the review. The purpose of five-yearreviews is to determine whether the remedy at a site is protective of human health andthe environment. The methods, findings, and conclusions of reviews are documented infive-year review reports. In addition, five-year review reports identify deficiencies foundduring the review, if any, and identify recommendations to address them.

The Celanese Site has two operable units; groundwater pump and treat and soilremediation. The first operable unit cleanup, groundwater, falls under the ‘policy’ reviewcategory. Although not required by statute, this review is being conducted in accordancewith EPA policy. EPA conducts five-year reviews as a matter of policy at: (1) sites whereno hazardous substances will remain above levels that allow unlimited use andunrestricted exposure after completion of remedial actions, but the cleanup levelsspecified in the Record of Decision (ROD) will require five or more years to attain; (2)sites addressed before Superfund Amendments and Reauthorization Act (SARA) atwhich the remedy, upon attainment of cleanup levels, does/will not allow unlimited useand unrestricted exposure; and (3) removal-only sites where hazardous substancesremain onsite at levels that will not allow unlimited use and unrestricted exposure. Thissite has been reviewed because cleanup levels will require more than five years toattain.

The second operable unit, soil, falls under the ‘statutory’ review policy. EPAconducts five-year reviews of any site at which a remedy, upon attainment of thecleanup levels specified in the Record of Decision (ROD), results in hazardoussubstances, pollutants, or contaminants remaining at the site above levels that allow forunlimited use and unrestricted exposure. These statutory reviews are only required forremedies signed on or after the effective date of SARA, October 17, 1986.

EPA implements requirements for five-year reviews consistent with CERCLA andthe National Oil and Hazardous Substances Pollution Contingency Plan (NCP).CERCLA § 121(c), as amended, states:

If the President selects a remedial action that results in any hazardoussubstances, pollutants, or contaminants remaining at the site, the President shallreview such remedial action no less often than each five years after

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the initiation of such remedial action to assure that human health and theenvironment are being protected by the remedial action being implemented. Inaddition, if upon such review it is the judgment of the President that action isappropriate at such site in accordance with section [104] or [106], the Presidentshall take or require such action. The President shall report to the Congress a listof facilities for which such review is required, the results of all such reviews, andany actions taken as a result of such reviews.

The NCP part 300.430(f)(4)(ii) of the Code of Federal Regulations (CFR) states:

If a remedial action is selected that results in hazardous substances, pollutants,or contaminants remaining at the site above levels that allow for unlimited useand unrestricted exposure, the lead agency shall review such action no less oftenthan every five years after the initiation of the selected remedial action.

This is the third five-year review for the Celanese Site. The trigger for this policyreview is the first and second five-year review dates shown in EPA’s WasteLANdatabase: a policy review dated September 8, 1994 for Operable Unit 1 - groundwaterand a statutory review dated December 4, 1995 for Operable Unit 2 - soil. Due to thefact that the groundwater pump and treatment system continues to operate, a five-yearreview must be conducted.

II. Site Chronology

Table 1 lists the chronology of events for the Celanese Site.

Table 1: Chronology of Site Events

Date Event4/84 Initial discovery of the problem

6/10/86 NPL listing

3/88 RI/FS completion Operable Unit 1

3/23/88 ROD signature Operable Unit 1

6/88 Remedial design start Operable Unit 1

10/21/88 Consent Decree Operable Unit 1

10/88 Remedial design completion Operable Unit 1

10/24/88 - 8/89 Operable Unit 1 construction dates

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Date Event3/89 RI/FS completion Operable Unit 2

3/28/89 ROD signature Operable Unit 2

6/19/89 Consent Decree Operable Unit 2

6/89 Remedial design start Operable Unit 2

9/90 Remedial design completion Operable Unit 2

9/24/90 - 9/92 Operable Unit 2 construction dates

3/25/93 Construction completion date

9/8/94 Five-year review Operable Unit 1

12/4/95 Five-year review Operable Unit 2

4/17/98 Partial NPL deletion (OU2 and portions of OU1)

III. Background

The Celanese Site is a 466-acre property located six miles south of Shelby NorthCarolina in Cleveland County. The site consists of a main plant production area,wastewater treatment area, former waste disposal areas, and recreational areas.

Since 1960, the Celanese plant has produced polyester chip and filament thread.Polyester chip is used for a wide range of molded products, such as typewriter keys andautomotive parts. Until about 1972, an ethylene glycol recovery unit (GRU) was part ofthe manufacturing process. Solid residues from this recovery unit were buried in shallowtrenches on the Site. Since 1972, GRU residues have been sent to another plant forfurther recovery processing. The terrace area containing the residue trenches alsocontained former burn pit areas which were used to burn plant waste such as off-specification resins and yarns, oils, laboratory solvents, and chemicals.

The site was proposed for the National Priorities List (NPL) on October 15, 1984,and was finalized on the NPL on June 10, 1986.

The Celanese Site was divided into two operable units - Operable Unit 1 (OU 1)was the contaminated groundwater and Operable Unit 2 (OU 2) was the contaminatedsoils and source materials.

The Remedial Investigation/Feasibility Study (RI/FS) for OU1 was started inFebruary 1986 and completed in March 1988. The RI/FS for OU2 was started inFebruary 1986 and completed in March 1989. Sampling indicated volatile organiccompound (VOC) contamination in the soil and groundwater. The contaminants ofconcern for the site include ethylene glycol, trichloroethene (TCE), acetone, benzene,

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vinyl chloride, methylene chloride, chlorobenzene, carbon tetrachloride, chloroform, 1,1-dichloroethene, 1,1-dichloroethane, 1,2-dichloroethene, 2-butanone (MEK), phenols andchromium.

IV. Remedial Actions

A. Remedy Selection

The record of decision (ROD) for the Celanese Site OU 1 was signed on March23, 1988. The remedial action objectives are to:

• control migration of the contaminated water;

• remove contaminated water;

• treat and discharge the extracted water; and

• attain specified remediation goals in the groundwater.

The remedial actions are:

• installation of extraction wells into bedrock at the perimeter of the site;

• installation of shallow extraction wells directly downgradient of sourcearea;

• pumping of contaminated water from interior wells to common holding tankto be treated biologically in an extended aeration, sequencing batchreactor then to the air stripping tower;

• pumping of contaminated water from perimeter wells to the air strippingtower;

• transportation of all contaminated water from the air stripping tower to thebiological treatment system;

• pumping of water requiring additional treatment to carbon adsorptionfiltration unit; and

• discharge of all water to the existing wastewater treatment system as longas current NPDES permit limitations are not violated.

The groundwater extraction and treatment systems are anticipated to operate 30years before achieving cleanup levels. The identified cleanup levels were based on theState groundwater standards and federal maximum contaminant levels (MCLs).

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The record of decision (ROD) for the Celanese Site OU 2 was signed on March28, 1989. The remedial action objectives are to:

• Prevent or mitigate the continued release of hazardous substances,pollutants and contaminants from the site;

• Eliminate or reduce the risks to human health associated with ingestion,inhalation, and/or direct contact with hazardous substances, pollutants orcontaminants in the soil and sediment;

• Reduce concentrations of hazardous substances, pollutants, orcontaminants in soils within the site to levels specified by the performancestandards; and

• Reduce the mobility, toxicity and/or volume of hazardous substances,pollutants, or contaminants at the site.

The remedial actions are:

• excavation of glycol recovery unit (GRU) sludges and underlying nativesoil (4549 tons), followed by incineration in an on-site rotary kiln;

• excavation of burn pit residuals and plastic chips (3259 tons);

• excavation of stream sediments (39-54 cubic yards);

• treatment of approximately 1.5 million gallons of wastewater consisting ofponded stormwater collecting in the excavations, water separated fromslurried stream sediments, and decontamination water;

• incineration on-site of contaminated soils and GRU sludges;

• solidification and stabilization of incinerated GRU sludges, soils, burn pitresiduals, plastic chips, stream sediments and wastewater treatment plantsolids;

• on-site disposal of the stabilized materials into the excavated pits;

• restoration of the site including covering with clean, native soils stockpiledduring excavation, grading of the site, and seeding to prevent erosion; and

• monitoring.

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B. Remedy Implementation

The remedial design for OU 1 was started in June 1988 and completed by thepotentially responsible parties (PRPs) in October 1988. The remedial design for OU 2was started in June 1989 and completed by the PRPs in September 1990.

In October 1988, the contract for the construction of the groundwater remediationsystem (OU 1) was awarded. In October 1990, the contract for OU 2 soil remediationwas awarded.

EPA and NC DENR conducted a final inspection of OU 1 and OU 2 on October21, 1992. The Preliminary Close Out Report was signed on March 25, 1993.

In 1996, CNA connected 100% of adjacent off-site residents considered to bepotentially at risk to the Cleveland County water system and plugged and abandoned allindividual domestic supply wells.

C. System Operations

The PRP contracted with Kubal-Furr and Associates (Kubal-Furr) to performsystem operations. The work is being conducted in accordance with the Operation andMaintenance (O&M) Plan. The plan incorporates all EPA and State quality assuranceand quality control procedures and protocols. System operations requirements for theCelanese Site include:

• semi-annual sampling of selected site monitoring wells;

• quarterly sampling of the groundwater system influents; and

• quarterly sampling of the groundwater system effluents.

Table 2 lists annual costs for the site as reported by the PRPs since the last five-year review.

Table 2: Annual CostsDates Total Cost rounded to nearest $10001996 $148,000

1997 $153,000

1998 $155,000

1999 $158,000

2000 $174,500

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V. Five-Year Review Findings

A. Five-Year Review Process

The Celanese five-year review was lead by Giezelle Bennett, Remedial ProjectManager. The following team members assisted in the review:

• Grover Nicholson, NC DENR Representative;• Jonathan Vail, EPA; and• Diane Barrett, EPA Community Involvement Coordinator.

This five-year review consisted of the following activities: a review of relevantdocuments (see Attachment A); interviews with local government officials andneighbors; and a site inspection. The completed five-year review report is available inthe information repository. Notice of its completion has been placed in the localnewspaper and local contacts have been notified by fact sheet.

B. Interviews

The following individuals were contacted by telephone as part of the five-yearreview:

• Barbara Meeks• Earl and Martha Causby• Patricia Buff• P.H. Gold• Martha Lavender• Gladys Brown

All individuals live near the Site and were notified of the five-year review duringthe telephone conversation. All stated that they were pleased with the EPA actions atthe Site and felt that they had been adequately informed about clean up activities. Onestated that all her concerns had been addressed when the company provided city waterand closed her well. One resident expressed concern over air quality and three of thesix expressed concerns about the water quality in the creek.

C. Site Inspection

Representatives of EPA, NC DENR, CNA Holdings, Inc (PRP), and Kubal-Furrtook part in the site inspection on June 21, 2001. During the site inspection, thegroundwater remedial system was observed and inspected and the former OperableUnit 2 source area was also observed.

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The groundwater treatment system was found to be operating and functioningproperly. All groundwater extraction well covers were intact and locked, with no signs ofdamage. Visual inspection of the pumps and treatment systems showed no signs ofwear or rust. No problems or odors were observed associated with the air strippers.

D. Risk Information Review

The following applicable or relevant and appropriate requirements (ARARs) werereviewed for changes that could affect protectiveness:

• Safe Drinking Water Act (40 CFR Parts 141); and• North Carolina Groundwater Standards NCAC -15A-2L;

ARARs for the contaminants of concern have not become more stringent sincethe last five year reviews in 1994 and 1995. Neither Federal nor State ARARs havechanged.

E. Data Review

Review of records and monitoring reports from August 1994 through December2000 indicates that approximately 4,642,525 million gallons of water have been treatedsince startup. Pumping rates have varied, averaging 86% of the design capacity rate.

The major contaminants and maximum concentrations in the groundwater aresummarized in Table 3 below. The Pre-RA data was taken from the ROD; the currentdata was taken from the July - December 2000 monitoring well data report. The datashow that contaminant concentrations have remained unchanged for somecontaminants, but dramatically decreased for others. Data from the influent and effluentsampling (August 2000) is presented in Table 4. The data show that the treatmentsystem has been effective at removing contaminants to below the detection limits.

A review of the Health and Safety Plan (HASP) and Contingency Plan indicatesthat both are in place and sufficient to control risks at the site. Further, both plans arebeing properly implemented.

In summary, the treatment system is meeting cleanup levels for all contaminantsof concern. The remedial action objective of preventing direct contact or ingestion ofcontaminated soils and groundwater continues to be met. Monitoring results indicatethat the extracted groundwater is adequately treated.

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Table 3: Comparison of Initial and Current Groundwater Concentrations(Based on Monitoring Well Data)

ContaminantROD (1988) Highest

Concentrations (ppb)

Current (7/2000) Highest Concentrations

(ppb)

CleanupGoal

Acetone 2190 470 NA

Trichloroethene 36 72 2.8

2-Butanone (MEK) 119 420 170

Benzene 89 29 1

Carbon Disulfide 38 52 NA

Chlorobenzene 16 20 100

1,2-Dichloroethene 88 <5 70

Tetrachloroethene 10 <5 1

Table 4: GW Treatment System Concentrations (3rd Quarter 2000)

Contaminant Influent (ppb) Effuent (ppb) Cleanup Goal (ppb)Ethylene Glycol 802,000J <7,000 7,000

Total Organic Carbon (TOC)

1,580,000 12,000 NA

Acetone 130 <10 NA

Trichloroethene <5 <5 2.8

2,-Butanone (MEK) <10 <10 170

Benzene 29 <5 1

Carbon Disulfide 52 <5 NA

Chlorobenzene 20 <5 100

F. Groundwater Pump and Treat Concerns

The PRP has expressed concerns about the efficiency and effectiveness of thegroundwater pump and treat system. The system, as shown above, effectively treats thegroundwater extracted. However, the performance of the overall system is beingquestioned. Specifically, the PRP identified the following concerns in a July 11, 2001letter to the Agency:

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• “While the pumping remains protective, it is not particularly efficient. The InnerTier has shown a steady decline in its ability to recover residual groundwatercontamination despite repeated attempts to maintain and upgrade systemperformance including redeveloping and rehabilitating all wells; installing largerdiameter, higher capacity replacement well; and replacing the problematicbladder pumps with different types of submersible pumps.

• The decline in production is due to a combination of physical, chemical, andbiological factors. Physically, the upper water bearing formation in which thewells are installed is composed of saprolite, a residual clayey material resultingfrom the weathering of the native bedrock. Although this formation containswater, it is not considered an aquifer in the classical sense because it’s incapableof producing water at appreciable rates. Chemically, iron and manganese causethe submersible pumps to freeze up. Biologically, the principal contaminant,ethylene glycol, is readily degradable and has caused biofouling and bacterialbuild-up outside the well casings and along the well screens. This combination offactors has produced a pump and treat remedy which is inefficient.”

The PRP has expressed an interest in pursuing a monitored natural attenuationremedy for groundwater. They state that “As the wells extracts groundwater, it creates acone of depression around each well which extends toward the former source area.This produces an unsaturated zone above the water table which still contains residualsoil contamination. When the pumps are shut off, the area becomes saturated, residualcontamination is released to the groundwater system and concentrations of constituentsat monitor wells rebound to levels that may exceed remedial goals. A monitored naturalattenuation approach would address this residual source material and may be apreferable remedy in combination with periodic or cyclic pumping to removecontaminated groundwater.”

VI. Assessment

The following conclusions support the determination that the remedy at theCelanese Site remains protective of human health and the environment:

Question A: Have Conditions External to the Remedy Changed Since the RemedyWas Selected?

• No Changes in Land Use: There are no current or planned changes in land use,currently industrial.

• No Changes in Known Contaminants, Sources, or Pathways at the Site: Nonew contaminants, sources, or exposure pathways were identified as part of thisfive-year review.

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• Changes in Known Hydrologic/Hydrogeologic Conditions: A decrease ofcontaminant levels in groundwater has occurred, however, the rate of extractionof groundwater is not consistent with expectations at the time of the ROD.

Question B: Has the Remedy Been Implemented in Accordance With DecisionDocuments?

• HASP/Contingency Plan: Both the HASP and the Contingency Plan are inplace, sufficient to control risks, and properly implemented.

• Access and Institutional Controls: Access to the Site is controlled by the PRP.Institutional controls have not been instituted because there are no current orplanned changes in land use.

• Remedy Performance: As noted above in Section V, “Five-Year ReviewFindings,” the pump-and-treat system is meeting cleanup levels but continues tohave operational and functional problems.

• Adequacy of System Operations: System operations procedures are acontinuous problem. Continued difficulties that have occurred with the system todate have been handled properly.

• No Need for Optimization: Given the repeated efforts by the PRP to optimizeand maintain the system, there is no need for continued optimization of thecurrent system.

• No Early Indicators of Potential Remedy Failure: The remedy will remainprotective and remove/treat contaminated groundwater. However, the remedy’sability to attain the remedial goals is questionable. Costs and maintenanceactivities have been consistently higher than expectations.

Question C: Has Any Risk Information Changed Since the Remedy Was Selected?

• Changes in ARARs: No changes in ARARs have occurred since the last fiveyear review.

VII. Deficiencies

No deficiencies were discovered during the five-year review.

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VIII. Recommendations and Required Actions

Recommendations:

! decrease the detection limits for groundwater analytes to the contract requiredquantitation limits (CRQL);

! ‘turn-off’ the groundwater pump-and-treat system for a period of twenty-four (24months) to allow the aquifer to recover and to investigate other potentialremedies;

! grant the PRPs request to determine if monitored natural attenuation would beeffective at the Site;

! increase the quantity of wells sampled to ensure plume remains exclusively onthe plant property; and

! periodic reconnaissance of downgradient area to determine if any new drinkingwater supply wells have been installed.

IX. Protectiveness Statements

Because the remedial actions are protective, the remedy for the site is protectiveof human health and the environment.

The system is operating and functioning, but with decreasing effectiveness andefficiency. Levels of most contaminants are falling, but under current conditions, it isdoubtful if the cleanup levels will be achieved within the time frame anticipated at thetime of the ROD.

X. Next Review

The next review will be conducted within five years of the completion of this five-year review report. The completion date is the date of the signature shown on thesignature cover attached to the front of the report. The soil remedy is complete and nofurther work is needed. Therefore, this will be the last five-year review for Operable Unit2, soil.

Attachment ADocuments Reviewed

Documents Reviewed

CERCLA Record of Decision for Celanese Fibers Operations; Shelby, North Carolina,March 23, 1988.

CERCLA Record of Decision for Celanese Fibers Operations; Shelby, North Carolina,March 28, 1989.

“Five Year Review Report, Operable Unit 1/Operable Unit 2; CNA Holdings, Inc. ShelbyNorth Carolina (F.K.A. Hoechst Celanese Corporation),” December 1999.

“Operable Unit 1 - Semiannual Report; January 2000 - June 2000. CNA Holdings, Inc.Shelby, North Carolina (F.K.A. Hoechst Celanese Corporation),” August 2000.

“Operable Unit 1 - Semiannual Report; July 1999 - December 1999. CNA Holdings, Inc.Shelby, North Carolina (F.K.A. Hoechst Celanese Corporation),” March 2000.

“Operable Unit 1 - Semiannual Report; July 2000 - December 2000. CNA Holdings, Inc.Shelby, North Carolina (F.K.A. Hoechst Celanese Corporation),” March 2001.

“Petition for Partial Deletion of the Celanese Corporation Shelby Fiber Operations Sitefrom the National Priorities List; Hoechst Celanese Corporation, Shelby, NorthCarolina”, November 1996.

“Revised Final Five-Year Review Report for Operable Unit 1 Remedial Action” August1994.

“Five-Year Review Report for Operable Unit 2 Remedial Action” August 1995.

“Remedial Action Report Operable Unit 2 Remedial Action, Celanese Shelby FiberOperations Superfund Site,” June 30, 1993.

“Letter to Giezelle Bennett, USEPA from Jerry Kubal, dated July 11, 2001. CelaneseFive-Year Review.”

Attachment BSite Map

Attachment CState Concurrence

1646 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1646401 OBERLIN ROAD, SUITE 150, RALEIGH, NC 27605

PHONE: 919-733-4996 \ FAX: 919-715-3605AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER

NORTH CAROLINADEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WASTE MANAGEMENT

MICHEAL F. EASLEY, GOVERNORWILLIAM G. ROSS, JR., SECRETARYDEXTER R. MATTHEWS, INTERIM DIRECTOR

24 July 2001

Giezelle S. BennettRemedial Project Manager US EPA Region 4 61 Forsyth Street, SW Atlanta, Georgia 30303-3104

Subject: Celanese Corp Site NCD003446721 Draft Five Year Remedy Review Report

Dear Ms. Bennett:

I have reviewed the subject report. I concur with the information supplied in the reportand with the Recommendations and Required Actions.

If the remedy is eventually changed to monitored natural attenuation, which may result ina very long term cleanup, the state would like to include land use controls on the Celaneseproperty as part of the remedy in order to ensure long-term protectiveness.

If you have any questions, please contact me at 919-733-2801 x.291 orgrover.nicholson@ncmail.net.

Sincerely,

Grover Nicholson, Head Federal Remediation Branch NC Superfund Section