five-year review - triana/tennessee river - 02/25/2005third five-year review report,...

FIVE-YEAR REVIEW REPORT

THIRD FIVE-YEAR REVIEW REPORTFOR

TRIANA/TENNESSEE RIVER SITETRIANA,

MADISON COUNTY, ALABAMAEPA ID: ALD983166299

Prepared for

U.S. Environmental Protection AgencyRegion 4

Atlanta Federal Center61 Forsyth Street, SWAtlanta, GA 30303

November 2004

U.S. Army Corps of EngineersMobile District109 Saint Joseph StreetMobile, Alabama 36602

10141447

FIVE-YEAR REVIEW REPORT

THIRD FIVE-YEAR REVIEW REPORTFOR

TRIANA/TENNESSEE RIVER SITETRIANA

MADISON COUNTY, ALABAMAUSEPAID: ALD983166299

November 2004

Prepared By:

U.S. Army Corps of EngineersMobile District

109 Saint Joseph StreetMobile, Alabama 36602

Approved by:

Winston A.Director / /Waste Managgrnent DivisionUSEPA, Region 4

Date:

Third Five-Year Review Report, Triana/Tennessee River Site, Madison County, Alabama

TABLE OF CONTENTS

LIST OF ACRONYMS, SYMBOLS, AND ABBREVIATIONS iv

EXECUTIVE SUMMARY vi

FIVE-YEAR REVIEW SUMMARY FORM vii

I. INTRODUCTION 1

II. SITE CHRONOLOGY 2

III. BACKGROUND 2

PHYSICAL CHARACTERISTICS 2

LAND AND RESOURCE USE 3

HISTORY OF CONTAMINATION 3

INITIAL RESPONSE 3

BASIS FOR TAKING ACTION 4Contaminants 4Risk Assessment 5

IV. REMEDIAL ACTIONS 5

REMEDY SELECTION 5

REMEDY IMPLEMENTATION 6

OPERATION AND MAINTENANCE 6

V. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW 6

VI. FIVE-YEAR REVIEW PROCESS 7

ADMINISTRATIVE COMPONENTS 7

DOCUMENT REVIEW 7

DATA RE VIEW 7Annual Fish Sampling 7Surface Water Collection 8


INTERVIEWS 10

VII. TECHNICAL ASSESSMENT 10

QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THEDECISION DOCUMENTS? 11Remedial Action Performance 11System Operations 11Opportunities for Optimization 11Early Indicators of Potential Issues 11Implementation of Institutional Controls and Other Measures 12

QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA,CLEANUP LEVELS, AND REMEDIAL ACTION OBJECTIVES USEDAT THE TIME OF THE REMEDY STILL VALID? 12Changes in Standards 12Changes in Exposure Pathways 12Changes in Toxicity and Other Contaminant Characteristics 12Changes in Risk Assessment Methods 12Expected Progress Towards Meeting RAOs 12

QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHTTHAT COULD CALL INTO QUESTION THE PROTECTIVENESSOF THE REMEDY? 12

TECHNICAL ASSESSMENT SUMMARY ; 13

VIII. ISSUES 13

IX. RECOMMENDATIONS AND FOLLOW-UP ACTIONS 13

X. PROTECTIVENESS STATEMENT 14

XL NEXT REVIEW 14


LIST OF TABLES

Table 1-Issues 13Table 2 - Recommendations and Follow-Up Actions 13

LIST OF ATTACHMENTS

Attachment 1 - Chronology of Site Events Al-1Attachment 2 - Site Map A2-1Attachment 3 - List of Documents Reviewed A3-1Attachment 4 - Average DDT Concentration in Fish and Surface Water by Year A4-1Attachment 5 - Site Inspection Check List A5-1Attachment 6 - Photographs Documenting Site Conditions A6-1Attachment 7 - Interview Records A7-1


LIST OF ACRONYMS, SYMBOLS, AND ABBREVIATIONS

ADEMARARs

CDCERCLA

DDTDoA

EIS

FDAFS

HSB-ICHSBM

LRA

mg/kg

NCP

O&M

ppmPRP

RSARAOsRIRODRP

TRMTVA

Hg/gm

Alabama Department of Environmental ManagementApplicable or Relevant and Appropriate Requirements

Consent DecreeComprehensive Environmental Response, Compensation and Liability Act

1,1,1 -trichloro-2,2-bis-(p-chlorophenyl) ethaneDepartment of the Army

Environmental Impact Statement

Food and Drug AdministrationFeasibility Study

Huntsville Spring Branch - Indian Creek SystemHuntsville Spring Branch Mile

Lower Reach A

milligrams per kilogram

National Contingency Plan

Operation and Maintenance

parts per millionpotentially responsible party

Redstone ArsenalRemedial Action ObjectivesRemedial InvestigationRecord of DecisionReview Panel

Tennessee River MileTennessee Valley Authority

micrograms per litermicrograms per kilogrammicrograms per gram

IV


LIST OF ACRONYMS, SYMBOLS, AND ABBREVIATIONS CTD.

URA Upper Reach AUSAGE U.S. Army Corps of EngineersUSEPA U.S. Environmental Protection AgencyUSFWS U.S. Fish & Wildlife Service

WNWR Wheeler National Wildlife Refuge


EXECUTIVE SUMMARY

The Triana/Tennessee River Superfund Site resulted from the discharge of wastewater from aDDT manufacturing plant into tributaries of the Tennessee River from 1947 to 1970. In 1980, theU.S. Environmental Protection Agency (USEPA) and State of Alabama filed complaints againstOlin Corporation (Olin) alleging imminent and substantial endangerment to human health and theenvironment from DDT contamination in water of the United States. To resolve thecontamination problem, the State of Alabama, United States and Olin entered into a ConsentDecree on May 31, 1983. The Consent Decree provided for a Review Panel responsible fortechnical overview of Olin's remedial action proposals.

Remedial actions addressed DDT contamination in fish species, soil, sediments, ground waterand surface water. Remedial actions consisted of diverting stream flow around the contaminatedportions of the tributaries, excavating new channels, excavating and burying portions of thecontaminated sediments in place. These remedial actions began on April 1, 1986 and werecompleted on July 22, 1987. The USEPA issued an Interim Close-out Report for the site inDecember 1991.

The Consent Decree further established that Olin shall attain a performance standard of 5 partsper million (ppm) DDT in three fish species within 10 years after the completion of remedialactions. By the end of the ten-year period only one species, largemouth bass, had attained theperformance standard in Reaches A, B and C. In December 1998, the Review Panel granted Olina five and ten year extension to attain the performance standard for channel catfish andsmallmouth buffalo, respectively. In 2003, channel catfish met the continued attainmentrequirement in all three Reaches. Smallmouth buffalo have not met the performance standard inReaches A, B and C; therefore, sampling of this species continues. Trend analysis indicates theperformance standard will be met in smallmouth buffalo within the next two to three years.Surface water and sediment continue to be sampled but ground water has not been sampled since1997 as DDT concentrations have consistently been below action levels.

The assessment of this five-year review found that the remedy is functioning as intended by theConsent Decree. The performance standard has been attained in two of three fish species andDDT concentrations in the water column and sediment have also declined steadily over the 16years of long-term monitoring.

VI


FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION

Site name (from WasteLAN): Triana/Tennessee River Site

USEPA ID (from WasteLAN): ALD983166299

Region: 4 | State: AL | City/County: Huntsville/Madison, Limestone Counties

SITE STATUS

NPL status: : (XlFinal | | Deleted [~]other (specify)

Remediation status (choose all that apply): Qllnder Construction

Multiple ous?*

Complete

Construction completion date: 10 /14 /1987

Has site been put into reuse? DYESREVIEW STATUS

Lead agency: IX! USEPA | [state nTribe Flother Federal Agency

Author name: Stanley E. "Chip" Parrqtt

Author title: Geologist Author affiliation: U.S. Army Corps of Engineers

Review period:" 6/16/2004 to 9/10/2004

Date(s) of site inspection: 6/16/2004 and 9/2/2004

Type of review:Post-SARA n Pre-SARA Q NPL-Removal onlyNon-NPL Remedial Action Site |~l NPL State/Tribe-lead

I Regional Discretion

Review number: Q 1 (first) I I 2 (second) [XI 3 (third) [~~| Other (specify)

Triggering action:LjActual Remedial Action On-site ConstructionLJConstruction CompletionQother (specify)

^Actual Remedial Action Start at OU# NA^Previous Five-Year Review Report

Triggering action date (from WasteLAN): 5 I 20 /1999

Due date (five years after triggering action date): 5 / 20 / 2004* ["OU" refers to operable unit.]** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]

vu


Five-Year Review Summary Form, cont'd.

Issues:

1. Whether trees 3-inches in diameter and larger should be removed from fill areas anddiversion structures.

2. Utilization of monitoring wells in the future.

Recommendations and Follow-up Actions:

1. Carry out decision provided by the Review Panel.

2. If monitoring wells will be utilized in the future, they will likely requireredevelopment and must be maintained and secured with locks. Otherwise, the wellsshould be properly decommissioned.

Protectiveness Statement:

The remedy at the Triana site remains protective of human health and the environment.Based upon the site visit and review of Annual Report No. 16, the remedial action isaccomplishing its goal of preventing contact between the ecosystem and DDT. Alldiversion structures and fill areas appear sound. No signs of physical deterioration werenoted. Overall, DDT levels in smallmouth buffalo continue to decline and a review ofanalytical results shows that DDT concentrations continue to remain less than theestablished baseline in the surface water.

Other Comments:

No other comments are provided.

Vlll


TRIANA/TENNESSEE RIVER SITEHUNTSVILLE, AL

THIRD FIVE-YEAR REVIEW REPORT

I. INTRODUCTION

The U.S. Army Corps of Engineers (USAGE) was tasked by the U.S. Environmental ProtectionAgency (USEPA) to conduct a five-year review of the remedial action implemented at theTriana/Tennessee River Superfund (Triana) Site in Huntsville, Alabama, to evaluate theprotectiveness of the site remedy. This third five-year review was conducted from June toSeptember 2004 and this report documents the results of the review.

The primary purpose of the five-year review is to determine whether the site remedy remainsprotective of human health and the environment. In addition to presenting the findings andconclusions of the review, deficiencies are identified, and corrective actions are recommended.The five-year review documents the evaluation of the site remedy, operation and maintenanceactivities and the continued appropriateness of remedial action objectives (RAOs) at the site.

This five-year review is prepared pursuant to the Comprehensive Environmental Response,Compensation and Liability Act (CERCLA) §121 and the National Contingency Plan (NCP).CERCLA § 121 states the following:

If the President selects a remedial action that results in any hazardous substances,pollutants, or contaminants remaining at the site, the President shall review suchremedial action no less often than each five years after the initiation of such remedialaction to assure that human health and the environment are being protected by theremedial action being implemented. In addition, if upon such review it is the judgment ofthe President that action is appropriate at such site in accordance with section [104] or[106], the President shall take or require such action. The President shall report to theCongress a list of facilities for which such review is required, the results of all suchreviews, and any actions taken as a result of such reviews.

This requirement is interpreted further in the NCP; 40 CFR § 300.430(f)(4)(ii) states thefollowing:

If a remedial action is selected that results in hazardous substances, pollutants, orcontaminants remaining at the site above levels that allow for unlimited use andunrestricted exposure, the lead agency shall review such action no less often than everyfive years after the initiation of the selected remedial action.

This five-year review is the third review for the Triana site. The trigger for this statutory reviewwas the second five-year review completed in May 1999. The initial trigger at the site was theinitiation of remedial action on April 1, 1986 (actual onsite construction date). The CloseoutReport was completed on December 18, 1991 with the completion of soil remediation to soil


cleanup goals. This five-year review will focus on monitoring studies offish and surface water atthe site.

II. SITE CHRONOLOGY

For a chronology of events for the Triana site see Attachment 1.

III. BACKGROUND

The following subsections present background information for the Triana site including physicalcharacteristics, land resource use, history of contamination, initial response, and basis for takingaction.

PHYSICAL CHARACTERISTICS

The Triana site is located approximately five miles southwest of Huntsville, Alabama. The siteconsists of an 11-mile-stretch of two tributaries, the Huntsville Spring Branch and Indian Creekwhich both lie almost entirely within the confines of the Wheeler National Wildlife Refuge andthe Redstone Arsenal (Attachment 2). The flow of both streams empties into the TennesseeRiver near the town of Triana, Alabama.

The site is underlain by unconsolidated surficial materials transported by ancestral streams(regolith). The materials generally lie on the Tuscumbia Limestone which averages 150 feet inthickness. This is underlain by the Fort Payne Limestone that contains beds of chert. The FortPayne Chert is generally 155 to 185 feet thick and serves as the principal aquifer in the area.

Much of the area is karstic, which is defined as "an irregular limestone region with sinks,underground streams and caverns". The construction of surface impoundments on the landsurface in karst terrains can lead to new sinkhole collapses due to the increased loading on thesurface soils caused by the weight of the water. The resulting new sinkholes may providepathways for contaminant migration in the ground water.

In general, water in the regolith moves downward toward the underlying limestone aquifer.Water level measurements at the site indicate differential head measurements are small enough toindicate reasonably good hydraulic connection between the regolith and the limestone (Hudson,1976).

The dominating factor in the surface water resources of the study area is the Tennessee River.Average flow in the river just downstream of Indian Creek is 43,200 cfs. Average annual flow inIndian Creek below its confluence with HSB is about 220 cfs (Geological Survey of Alabama,1973).


LAND AND RESOURCE USE

The future land use is not expected to change from its current use as the Wheeler NationalWildlife Refuge (WNWR) and the Redstone Arsenal (RSA).

HISTORY OF CONTAMINATION

From 1947 to 1970, a DDT manufacturing plant operated within the RSA. The manufacturing,handling and disposal practices at the facility led to the discharge of DDT residues throughRSA's drainage system into the Huntsville Spring Branch-Indian Creek (HSB-IC) system, whichenters the Tennessee River at mile 321. The Olin Corporation and the Calabama ChemicalCompany operated this facility under a lease from RSA. Fish in the vicinity became heavilycontaminated with DDT from the estimated 408.8 tons of contaminated stream sediments. Themajority of these sediments were located between mileposts 3.5 and 5.4 in HSB. Some fishsamples exceed the Food and Drug Administration (FDA) guidelines of 5 ppm of DDT for fishsold in interstate commerce. A USAGE study, completed in November 1980, defined the extentof contamination and identified a preferred engineering alternative for long-term control of DDTcontamination in the HSB-IC system.

INITIAL RESPONSE

Judicial actions commenced in 1980 when the USEPA and State of Alabama filed complaintsagainst Olin. The complaints alleged that DDT discharged from the manufacturing plant hadcreated an imminent and substantial endangerment to human health and the environment.

On May 31, 1983, the United States District Court entered a Consent Decree (CD) to develop andimplement a remedial action for DDT contamination in the HSB-IC system. This was part of anoverall order settling litigation between the United States, the State of Alabama, and four sets ofprivate parties against Olin. The CD required Olin to develop and implement a remedial plan tomeet a performance standard of 5 parts per million (ppm) of DDT in fillets of channel catfish,largemouth bass and smallmouth buffalo.

The CD also provided for a Review Panel (RP) responsible for technical overview and approval,disapproval or modification of Olin's proposals to achieve the requirements of the CD. The RP,established in June 1983, consists of members from the USEPA, Tennessee Valley Authority(TVA), U.S. Fish and Wildlife Service (USFWS), Department of the Army (DoA), the State ofAlabama Department of Environmental Management (ADEM) and nonvoting participants fromthe town of Triana, Alabama, and Olin.

The CD required Olin to conduct monitoring studies of fish, water, sediment and sedimenttransport in the HSB-IC system, as set forth in the Technical Proposal, to obtain baseline data andto evaluate the effectiveness of the remedial action. Fish collections were conducted over a three-year period to determine DDT concentrations in performance standard (and other) fish and todetermine fish species present in each Reach of HSB-IC. Water samples during normal flow andstorm flow events were collected over a period of three years to characterize sediment and DDTtransport. Extensive sediment sampling was conducted to define the quantity and distribution of

Tfakd Five-Year Review Report, Triana/Tennessee River Site, Madison County, Alabama

DDT in each Reach of the HSB-IC system. Olin also conducted ground water studies as set forthin the Proposal. Data from these studies were used to determine baseline DDT concentrations infish, water and sediment of the HSB-IC system. The baseline values are presented in RP DecisionDocument No. 2 - Baseline Data, Substitute Species, and Interim Goals for Fish and Water datedOctober 28, 1986.

The CD identified the following three phases for the project: 1.) construction of the remedialaction 2.) long-term .monitoring to demonstrate attainment and continued attainment of theperformance standard; and 3.) operations and maintenance of the remedy for an additional sevenyears of continued compliance.

BASIS FOR TAKING ACTION

Contaminants

Pest control on crops such as cotton and soybeans was carried out by application of DDT andother organochlorine insecticides. There was no data during the late 1940's of DDT impact on theenvironment via bioconcentration through food webs. The risk to man as far as health effects wasconsidered insignificant. The record of events relating to Olin's facility and the spread of DDT inthe environment shows that no water surveys were conducted for 16 years following plant startupand operation.

The pollution of the HSB-IC system continued unabated and without apparent concern during the1950's. Increasing frequency of fish kills and other pollution related events in all probability ledto sampling efforts to establish water quality levels. By 1963, the Public Health Service and TVAwere conducting surveys to determine the extent of DDT migration and levels of the compoundin water and sediment. There was increasing evidence of toxic effects to the biota.

Sampling related to DDT residues was sporadic until late 1967 when the Federal Water PollutionControl Administration established a station at Mile Marker 5.4 at HSB. Monthly collectionswere made until May, 1969. The contamination values in surface water ranged from 0.3 to 60Hg/1 and included analyses for the first four months of 1970 when the program evidently wasdiscontinued.

As evidence of long term effects of organochlorine compounds increased, the surveys in the1970's focused on DDT residues in fish and wildlife. In September 1970, the AlabamaDepartment of Conservation reported DDT residues in fish collected in Wheeler Reservoir andvicinity to be above FDA limits of 5 ppm. Those species that exceeded the standard were channelcatfish, smallmouth bass and white bass. Beginning in 1975 surveys to determine pesticideresidues in fish were more frequent. By 1977, TVA published the results of several surveyscarried out in HSB and in the Tennessee River. Bass, catfish and other edible species wereheavily contaminated in the Tennessee River at mile 320-321 (whole body analysis). Levels ashigh as 411.6 ppm were observed in catfish. Two collections offish were made by TVA in Juneand September 1978. DDT concentrations in fish ranged from 0.24 ppm for largemouth bass atTennessee River Mile (TRM) 352 to 212.7 ppm in smallmouth buffalo (Indian Creek). In an


independent analysis the Army found concentrations as high as 225 ppm in a channel catfish atTRM 321-334.

Sediment sampling and analysis was begun in 1963. The highest levels of DDT were found inHSB sediments, hi October 1977, concentrations up to 0.36 ppm were found in the TennesseeRiver below Indian Creek, hi 1978, DDT concentrations in HSB sediments were found to be over28,000 ug/gm.

Risk Assessment

There was no human health or ecological baseline risk assessment performed on this project.

IV. REMEDIAL ACTIONS

The following subsections present the remedial actions for the Triana site including remedyselection, remedy implementation, and operation and maintenance.

REMEDY SELECTION

As specified by the CD, Olin proposed a Remedial Action Plan to the RP on June 1, 1984. Olin'sproposal for remedial action included a schedule for implementation, a long term monitoring planand other information. On August 31, 1984, the Review Panel issued their Decision Document inwhich they accepted, with modifications, Olin's proposed remedial action.

Olin's proposal principally involved the construction of a bypass channel to re-route the HSBbetween miles 5.5 and 4.0 and in-situ burial of DDT contaminated sediments within and alongthe overbank of the existing HSB channel. The CD defined the stream portion between HSB mile5.4 and 2.4 as Reach A. The portion of Reach A where remedial action was approved was knownas Upper Reach A (HSB mile 5.4-4.0). The remaining stream reach between HSB mile 4.0 and2.4 is known as Lower Reach A.

Construction of the remedial action began on April 1, 1986 following detailed design andissuance of permits. The Decision Document also required Olin to submit a plan for removaland/or isolation of DDT contaminated sediments in Reach A between HSBM 4.0 and 2.4 (LowerReach A). Olin submitted a remedial action plan for Lower Reach A on August 14, 1986. TheReview Panel accepted Olin's remedial plan for Lower Reach A on November 20, 1986(Decision Document No. 3). The RP continues to issue Decision Documents for documentationon its decisions related to the project.

The Decision Document established the schedule for Olin's submission of detailed engineeringplans and specifications and permit applications to both the RP and permitting agencies. Thedocument also established the schedule for submission of a detailed long-term monitoring plan,the proposal for interim goals and a plan for additional remedial action in Lower Reach A.


REMEDY IMPLEMENTATION

The approved remedial action in Upper Reach A (URA) included bypassing and burying in-placethe most heavily contaminated channel area (HSBM 5.4 to 4.0), rerouting HSB, cutting a newchannel to the large embayment area filling the isolated channel with layers of soil, stone andgeotextile fabric, and construction of blocking dams plus several rainfall runoff diversion ditches.The URA remedial action isolated 308 out of 317.9 tons of DDT-contaminated sediments(96.89%) estimated to occur in that area. The remedial action consisted of a new wastewaterdiversion ditch; a northern diversion ditch; access roads and stream crossings; north and southstaging areas for construction activities; excavation of the 1,640-foot salient cut and the 3,250-foot Oxbow cut; three diversion structures and diversion levee; the blocking off, dewatering andfilling of the HSB channel from HSBM 5.5 to HSBM 4.0, including the west portion of the loopand the small embayment at HSBM 4.2 to isolate the DDT; covering the dewatered channel withgeotextile fabric and 9 inches of crushed rock; the addition of soil and topsoil; and revegetationmeasures.

The approved remedial action in Lower Reach A (LRA) included bypassing and burying in-place71 of the 75.6 tons of DDT estimated to occur in that area, which is entirely within theboundaries of RSA and WNWR. The remedial action consisted of constructing four diversionstructures; excavating a new channel between HSB mileposts 3.4 and 2.4; filling three areas;constructing a diversion ditch around the fill areas; and excavating portions of the sediments fromthe channel. The construction area was entirely within the safety fan of one of the missile testranges at RSA and within the normal fluctuation zone of Wheeler Reservoir. Therefore,construction was closely coordinated with operations of both the test range and the reservoir.Because of activities at the test range, much of the construction work was performed at nightunder lights. Completion of remedial action in both URA and LRA effectively isolated in-placeapproximately 93% of the DDT in the HSB-IC system.

Construction of the remedial action for all of Reach A was completed by October 14, 1987. TheRP designated January 1, 1988 as the date of completion and implementation of the remedialaction, i.e. completion of construction.

OPERATION AND MAINTENANCE

During their 2003 annual site inspection, Olin representatives observed that the Remedial Actionwas in excellent condition and functioning as designed. They stated that sediment continues todeposit in the HSBM 4.0 Embayment and the low flow areas of the HSB channel. Noimpediments to water flow were noted. Some beaver activity was observed but was not impactingthe Remedial Action.

V. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW

The protectiveness statement from the second five-year review for the Triana site stated theremedial action at this site continues to be protective of human health and the environment.Based on statements in the report, the remedial action was accomplishing its goal of preventing

Third Five-Year Review Report, Triana/Tennessee River Site, Madison County, Alabama ___

contact between the ecosystem and DDT. All diversion, drainage and filled structures appearedsound and no signs of physical deterioration were noted.

Since that report, overall DDT levels in the performance standard fish species have declined. Inthe near future, the fish monitoring program will focus on smallmouth buffalo in Reaches A, Band C. Largemouth bass and channel catfish continued to attain the performance standard in allthree Reaches of HSB and will not be collected in 2004.

Since 1999, two to four surface water collection events have been conducted annually. In 2004,four surface water events are planned.

Review Panel discussions during a December 2003 conference call suggested that sedimentstudies would be valuable in monitoring the effectiveness of the remedial action. A survey ofsediment deposition is anticipated in 2004 with sediment sampling for DDT scheduled in 2005.

VI. FIVE-YEAR REVIEW PROCESS

The third five-year review was conducted by the USAGE under guidance from the USEPARemedial Project Manager for the Triana site. The five-year review process consisting ofadministrative components, document review, data review, site inspection and interviews isdescribed in the following subsections.

ADMINISTRATIVE COMPONENTS

The Triana site Five-Year Review was led by Chip Parrott of the USAGE. The State of AlabamaDepartment of Environmental Management (ADEM), the U.S. Fish & Wildlife Service (USFWS)and the Tennessee Valley Authority (TVA) were notified of the initiation of the five-year reviewfor the Triana site. A schedule was established to include document review, data review, siteinspection, interviews and report development.

DOCUMENT REVIEW

This third five-year review consisted of a review of relevant documents including decisiondocuments, monitoring reports, monthly reports and O&M records. Attachment 3 provides a listof all documents reviewed for this effort.

DATA REVIEW

Historical data of fish and surface water sampling were reviewed. The CD required Olin todevelop and implement a remedial plan to meet a performance standard of 5 ppm of DDT infillets of largemouth bass, channel catfish, and smallmouth buffalo. DDT concentrations forsurface water were compared to baseline conditions (pre-remedial action).

Annual Fish Sampling

Average DDT concentrations in largemouth bass in all Reaches have averaged less than 5.mg/kg


during each collection since 1992. Largemouth bass were collected in 1998 to confirm theircontinued attainment of the performance standard. Largemouth bass met the performancestandard in all three Reaches and have not been monitored since 1998. Attachment 4 summarizesthe data from the baseline period through 2003.

Channel catfish in Reaches A and C met the performance standard for the third consecutive yearin 1999 and 2000, respectively and were not monitored in 2001-2003. Channel catfish in Reach Bmet the performance standard in 2003. The averages for Reach B in 1999, 2001, and 2002 werebelow the performance standard of 5 ppm. Filet DDT concentrations of channel catfish in ReachB averaged 5.0 mg/kg. This average is significantly lower than the baseline values of 69 mg/kgfor Reach B. This was the third consecutive year that channel catfish in Reach B met theperformance standard. Channel catfish have demonstrated continued attainment of theperformance standard. Attachment 4 provides a comparison of the 2003 data to baseline data and1988-2002 data. Channel catfish in Reaches A and C have demonstrated continued attainment ofthe performance standard and were not sampled.

Smallmouth buffalo did not attain the performance standard in Reaches A, B, or C in 2003.Smallmouth buffalo in Reaches A and C are nearing attainment. Average DDT concentrations inReaches A and C were 7.9 and 7.7 ppm, respectively. DDT concentrations in Smallmouth buffaloin Reach B decreased and were lower than any other long term monitoring year.

In 2003, filet DDT concentrations of smallmouth buffalo in Reaches A, B, and C averaged 7.9,11, and 7.7 mg/kg, respectively. The average DDT concentrations are significantly lower than thebaseline values of 140, 180, and 110 mg/kg for Reaches A, B and C, respectively. Smallmouthbuffalo showed decreases in Reaches A and B compared to the 2002 data. The average DDTconcentrations in Reach A decreased (18 to 7.9 mg/kg) compared to 2002 data and Reach Bexhibited a decrease (39 to 11 mg/kg) compared to the 2002 data. The average DDTconcentration in Reach C was similar to 2002 (7.5 to 7.7 mg/kg). Attachment 4 provides acomparison of 2003 smallmouth buffalo data to baseline data and 1988-2002 data.

Surface Water Collection

The purpose of the HSB-IC water collection program is to evaluate the effectiveness of theremedial action in minimizing the transport of DDT in the HSB-IC system. The water planconsists of two parts: 1.) water sampling and 2.) stream elevation and water velocitymeasurements including direction of flow. Water samples were collected from selected locationsin the HSB-IC system. Samples were analyzed for total DDT and total suspended solids (TSS).Data was used to assess the transport of DDT and suspended sediment in the HSB-IC system.

As of 2003, average DDT concentrations in the water column were significantly lower thanbaseline conditions (pre-remedial action) throughout the entire HSB-IC system (Attachment 4).DDT concentrations at the former monitoring station at HSBM 4.0 averaged 12 ng/1 prior toremediation. DDT concentrations in the water at HSBM 3.9 were undetectable during three out offour water collections in 2003. The 2003 average DDT concentration at HSBM 3.9 is a reductionof greater than 99% compared to baseline. DDT concentrations at HSBM 2.4 averaged 0.10 ug/1


during the four 2003 water collections. The 2003 average is a 99% reduction of DDT comparedto baseline (13 ug/1) DDT concentrations in the water at HSBM 2.4. The average DDTconcentration at HCM 4.6 was less than 0.10 ug/1. DDT was nondetectable at ICM 4.6 during theall four collections. DDT reductions at HCM 4.6 and ICM 0.38 are 100% compared to baseline.Average DDT concentrations in the water column throughout the HSB-IC system were lower in2003 compared to 2002.

SITE INSPECTION

A site inspection by the Review Panel was conducted at 4:00 p.m. on June 16, 2004. Amongthose present were Dr. Ed Bender (USEPA), Gerald Hardy (ADEM), Don Dycus (TVA), KeithRoberts (Olin), William James and Chip Parrott (USAGE). The USAGE representative, ChipParrott, returned to the site to take photographs on September 2, 2004 and was accompanied byKeith Roberts and Steve Anderson (Olin). The tour was conducted utilizing Olin's air boat whichprovided better observation of the site's fill areas, diversion structures and channels. The purposeof the site visit was to inspect all components of the remediation to determine whether eachelement of the CD and Decision Documents had been implemented and whether the remedy isoperating in accordance with its intended function. Notes and observations from the siteinspection were recorded on the Site Inspection Check List provided in Attachment 5.Photographs of the site are provided in Attachment 6.

The tour began in the vicinity of the former DDT manufacturing plant. No structures remain inthe area; a gated fence prevents unrestricted access and warning signs are posted (Photograph 1).The tour proceeded past the entrance of the DDT Abatement Area to Diversion Structure No. 1 atmilepost 5.4 in HSB-URA (Photograph 2). The diversion structure consisting of sheet piling andrip-rap was intact and showed no signs of erosion. This area marks the beginning of theremediated area. Next, utilizing an air boat, we observed the new channel referred to as theoxbow cut at milepost 5.0 and it was open and flowing (Photograph 3). Further downstream weobserved the salient cut at milepost 4.6 (Photograph 4) followed by the embayment area. This is alarge, open expanse in the HSB channel and at the time of our visit, the water level in theembayment was at normal summer pool (Photograph 5). Milepost 4.0 at the downstream end ofthe embayment represents the division of URA and LRA.

Further downstream, we passed the confluence of the northern diversion ditch and the HSBchannel at milepost 3.9 (Photograph 6). The ditch appeared to be functioning normally and fillareas on each side of the diversion ditch showed no signs of erosion. The fill areas werevegetated with a mixture of grasses and woody plants.

Next, we saw Diversion Structures 5 and 7 (Photographs 7 and 8) then returned to Dodd RoadBridge (Photograph 9). The bridge marks the lower end of Reach A and the end of the remedialactivities.

Due to thick vegetation, we found only one of 37 monitoring wells, designated well E-6(Photograph 10). Reportedly, the well consisted of 2-inch stainless steel and we observed therewas no lock on the well cover. The monitoring wells were last sampled in 1997, prior to the last


5-YR. If future sampling events are anticipated, the wells will likely need maintenance and re-development.

Overall, the site inspection indicated no visible signs of erosion or deterioration and it appearsthat the structures are performing as intended. We noticed trees 3-inches in diameter and largeralong fill areas, diversion structures and the former channel. It is understood the RP is currentlydiscussing whether or not to have these trees cut down.

The site inspection demonstrated that the O&M activities were carried out in accordance with theCD. The O&M activities are supporting an effective remedy at the Triana site and no unexpectedchanges in O&M scope or cost have occurred to suggest ineffectiveness of the remedy.

INTERVIEWS

During the five-year review process, the following individuals were interviewed regardingactivities at the Triana site over the last five years:

• Dr. Edward Bender, Science Administrator USEPA, is chairperson of the RP respondedto the interview questions on August 23, 2004 by email. He did not identify anysignificant problems or issues with the site. Details of his interview responses areprovided in Attachment 7.

• Mr. Gerald Hardy, Chief, Land Division, ADEM responded to the interview questions onSeptember 8, 2004 by email. He did not identify any significant problems or issues withthe site. Details of his interview responses are provided in Attachment 7.

• Mr. Don Dycus, Technical Specialist with TVA, responded to the interview questions onAugust 19, 2004 by email. He did not identify any significant problems or issues with thesite. Details of his interview responses are provided in Attachment 7.

• The Honorable Clyde Foster (former mayor of Triana) responded to the interviewquestions on September 10 and 13, 2004 over the telephone. Mr. Foster was primarilyconcerned that the health effects of DDT on human beings were not fully addressed.Details of his interview responses are provided in Attachment 7.

• Mr. Peter Tuttle, Biologist - USFWS, responded to the interview questions onSeptember 13, 2004 by email. Mr. Tuttle does not believe the selected remedy isprotective of the environment and recommends a reevaluation of ecological risks at theOlin-Triana site. Details of his interview responses are provided in Attachment 7.

VII. TECHNICAL ASSESSMENT

The following Questions A, B, and C were answered to provide a technical assessment of the siteremedy.

10


QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISIONDOCUMENTS?

Remedial Action Performance

The remedy at the Triana site is effective and functioning as designed to protect human healthand the environment. This conclusion is based on the review of site documents, fish samplingand surface water monitoring data, risk assumptions, and results from the site inspection.

The remedial action of burying in place the most contaminated sediments, rerouting certainsegments of HSB, cutting a new channel to the large embayment area, construction of blockingdams, filling channels after isolation with layers of soils, stone and geotextile fabric, severalrainfall runoff diversion ditches, construction of diversion structures, has been effective inreducing the contaminant concentrations in sediment and surface water to achieve theperformance standard.

Based on the data review, DDT concentrations of channel catfish and smallmouth buffalo havedecreased throughout the 10 years following the completion and implementation of the remedialaction. The decrease was rapid during the first three years and the DDT concentrations continuedto decline during the later years. DDT concentration in the water column, sediment andmacroinvertebrates has also declined steadily over the 16 years of long-term monitoring.Evaluation of trends of DDT concentrations for channel catfish and smallmouth buffalo in allReaches indicates a continuing decrease in DDT concentrations. Trend analysis predicted thatchannel catfish would achieve the performance standard in 2002-2003. Channel catfish achievedthe performance standard in Reaches A, B, and C during the timeframe that the trend analysespredicted. Trend analysis predicts achievement of the performance standard in smallmouthbuffalo within the next two to three years. The remedy is effective and continued complianceshould be expected without additional action.

System Operations

The USAGE site inspections in June and September 2004 demonstrated that O&M activities havecontinued in accordance with the CD. All O&M requirements are adequate for the site and arebeing implemented properly. Annual fish sampling and surface water sampling is effectivelyensuring the remedy is performing properly. No unexpected changes have occurred in cost orscope of the O&M to suggest compromised effectiveness of the remedy.

Opportunities for Optimization

Opportunities for optimization were not identified during this review. The fish and surface watersampling provide sufficient data to assess the progress of the long term monitoring.

Early Indicators of Potential Issues

No early indicators of potential issues that could lead to remedy failure or jeopardize theprotectiveness were identified during this five-year review.

11


Implementation of Institutional Controls and Other Measures

The institutional and access controls in place at the site provide adequate protection. No otheractions were identified for the site.

QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUPLEVELS, AND REMEDIAL ACTION OBJECTIVES USED AT THE TIME OF THEREMEDY STILL VALID?

Changes in Standards

There have been no changes in standards at the site. The Consent Decree established aperformance standard that the remedial action must attain. The performance standard is a DDTlevel of 5 ppm in the filets of largemouth bass, channel catfish and smallmouth buffalo inReaches A, B and C of the HSB-IC system.

Changes in Exposure Pathways

Significant changes have not occurred at the site to affect the exposure pathways. Theprotectiveness of the remedial actions is still valid. The contaminant of concern remains thesame, as well as the land usage and human usage of resources.

Changes in Toxicity and Other Contaminant Characteristics

Toxicity factors and other characteristics of the contaminant of concern have not changed at thesite to affect the protectiveness of the remedy.

Changes in Risk Assessment Methods

Neither a human health or an ecological risk assessment was performed at the site.

Expected Progress Towards Meeting RAOs

The site remedy is progressing as expected. Based on trend analysis, DDT concentrations insmallmouth buffalo are expected to meet the performance standard in the next two to three years.DDT concentrations in the water column and sediment have also declined rapidly over the 16years of long term monitoring.

QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULDCALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY?

No other information has been identified during this five-year review that calls into question theprotectiveness of the remedy.

12


TECHNICAL ASSESSMENT SUMMARY

According to the data reviewed, site inspection, and interviews, the remedy is functioning asintended by the Consent Decree. The existing remedy should achieve the performance standard,and so the protectiveness of human health and the environment has not been called into question.No other information was found during the five-year review of the Triana site to indicate theremedy is not protective.

VIII. ISSUES

Table 1 presents issues that need to be resolved at the Triana site.

Table 1. Issues

Issue

3-inch diameter and larger trees in certain fillareas and diversion structures.

Utilization of monitoring wells. If wells will beutilized in the future, they must be maintained.

Currently AffectsProtectiveness

Under review

Possibly

Affects FutureProtectiveness

Under review

Possibly

IX. RECOMMENDATIONS AND FOLLOW-UP ACTIONS

Table 2 provides recommendations and follow-up actions to address the issues presented inSection VIII.

Table 2. Recommendations and Follow-Up Actions

Issue

3-inchdiameterand largertreesUtilizationofmonitoringwells

Recommendations/Follow-up Actions

RP to reachconsensus onwhether trees shouldbe removedDetermine if wellswill be utilized in thefuture. If so, theywill likely require re-development andmust be maintained.

PartyResponsible

PRP

PRP

OversightAgency

USEPA

USEPA

MilestoneDate

3/30/05

3/30/05

AffectsProtectiveness?CurrentUnderreview

Possibly

FutureUnderreview

Possibly

13


Also, to ensure protectiveness, annual fish collections will focus on smallmouth buffalo inReaches A, B and C. Channel catfish and largemouth bass have demonstrated continuedattainment in all three Reaches and therefore, monitoring these species is not required by the CD.

In 2004, four surface water collection events will be conducted in HSB-IC.

Review Panel discussions during a December 2003 conference call suggested that sedimentstudies would be valuable in monitoring the effectiveness of the remedial action. A survey ofsediment deposition is anticipated in 2004 with sediment sampling for DDT in 2005.

X. PROTECTIVENESS STATEMENT

The remedy at the Triana site remains protective of human health and the environment. Basedupon the site visit and review of Annual Report No. 16, the remedial action is accomplishing itsgoal of preventing contact between the ecosystem and DDT. All diversion structures and fillareas appear sound. No signs of physical deterioration were noted. Overall, DDT levels insmallmouth buffalo fish continue to decline and a review of analytical results shows that DDTconcentrations continue to remain less than the established baseline in the surface water.

XI. NEXT REVIEW

The next five-year review for the Triana site is required by September 2009, five years from thedate of this review.

14


ATTACHMENTS


ATTACHMENT 1

CHRONOLOGY OF SITE EVENTS


Attachment 1.Chronology of Site Events

EVENT

Court approved Consent Decree (CD)Review Panel (RP) established; held first meetingRP adopted operating proceduresOlin submitted to RP remedial action planPublic hearing held at Triana, Alabama, to receive publiccomments on Olin's proposed remedial action planRP issued first decision document approving Olin'sremedial action plan with modificationsUSAGE Nashville District initiated EIS public scopingprocess

Olin submitted draft permit applications to RP andpermitting agenciesOlin submitted final engineering drawings andspecifications and environmental analysis reportOlin submitted permit applications to USAGE NashvilleDistrict, TV A, and USFWSOlin submitted report on field and laboratory investigationsof the Huntsville Spring Branch-Indian Creek (HSB-IC)systemUSAGE Nashville District issued notice of availability ofdraft EIS for permitting actionsOlin submitted remedial action alternatives report for LowerReach A (LRA)Olin submitted interim goals reportDepartment of Army (DOA) issued license to Olin forremedial action construction activities on Redstone ArsenalpropertyOlin submitted revised permit applications and detailedengineering plans to RP, USAGE Nashville District, TVA,and USFWSUSFWS issued limited authorization to begin sitepreparation andmobilization within the boundaries of the Wheeler NationalWildlife Refuge (WNWR)Final EIS issued by USAGE Nashville DistrictOlin submitted special reports: baseline data for water andfish; substitute fish species; long-term data acquisitionprogram (revised); and interim goals

DATE

May 31, 1983June 14, 1983January 26, 1984Junel, 1984July 14, 1984

August 31, 1984

January 2, 1985

Februarys, 1985

July 1, 1985

July 1, 1985

July 1,1 985

July 17, 1985

August 1, 1985

August 1, 1985December 2, 1985

January 15, 1986

January 28, 1986

February 21, 1986March 1, 1986


EVENT

Close of public comment period on final EISAlabama Department of Environmental Management(ADEM) issued certificationApplicable permits issued to OlinUSFWS issued permitConstruction began in Upper Reach A (URA)Groundbreaking ceremony for URARP approved and regulatory agencies modified permits forrelocation of the northern diversion ditch in URAHSB diverted to a new channel in URA (salient cut openedJune 11, 1986 and oxbow cut opened July 16, 1986)U.S. EPA published report on the Remedial Action toIsolate DDT from People and the Environment in theHuntsville Spring Branch- Indi an Creek System, WheelerReservoir, Alabama. Review Panel Activities (United Statesv. Olin Corporation Consent Decree). May 31. 1983 - June30 1986Olin submitted preliminary applications for applicablepermits for LRAUSAGE issued public notice of remedial action proposal forLRAOlin, with RP concurrence, committed to start constructionof remedial action in LRA beginning December 1, 1986EPA Region IV, on behalf of RP issued notice of publicmeeting for proposed remedial action in LRAOlin issued preliminary engineering drawings for proposedremedial action in LRA highlighting areas whereconstruction activities were proposed prior to December 1RP held public information meeting at Triana concerningproposed remedial action in LRARP issued decision document 2, baseline data, substitutionspecies, and interim goals for fish and waterADEM issued 401 (a) certification for remedial action inLRAUSFWS issued permit for LRAUSAGE and TVA issued permits for LRAConstruction mobilization began for remedial action in LRARP issued Decision Document No. 3, remedial action planto isolate DDT in LRA of HSBFull construction began for remedial action in LRA

DATE

March 24, 1986March 25, 1986

March 31, 1986April 1, 1986April 1, 1986April 23, 1986July 2-8, 1986

July 16, 1986

July 1986

September 15, 1986

October 1, 1986

October 2, 1986

October 4, 1986

October 21, 1986

October 28, 1986

October 28, 1986

November 18, 1986

November 21, 1986November 28, 1986December 1, 1986December 9, 1986

December 9, 1986


EVENT

Diversion structure No. 4 in LRA completed to elevation558Mechanical excavation of bottom sediments betweenFISBM 3.4 and 4.0 in LRA completedHSB diverted to new channel in LRARP issued Decision Document No. 4, report on DDT inReaches B and C of HSB-IC systemRevised plan submitted to RP for demobilization followingcompletion of construction in URA and LRAEight-foot alligator captured in LRA and relocated withUSFWS assistanceMajor construction activities completed; ceremony held atremedial action siteRP issued decision document 5, substitute species forlargemouth bassInteragency committee of regulatory agencies jointlyinspected URA and LRAUSAGE, Nashville District, issued report of interagencycommittee inspection conducted August 3, 1987; no majordeficiencies of permit conditions identifiedRP inspection committee (including representatives of allRP agencies) conducted acceptance inspection of URA andLRARP inspection committee issued report of August 27inspection to RP Chair 1987 certifying that the "as built"remedial action for URA and LRA meets or exceedsrequirements of the decision documents 1 and 3, plans andspecifications approved by the RPRP Chair transmitted to Olin his concurrence with theinteragency regulatory inspection committee and the RPinspection committee certification; requested Olin to submitfor approval a proposed date for completion of constructionand start of long-term monitoring programOlin transmitted letter to RP chair proposing January 1 ,1988 as the date for the 'designated event" signifyingcompletion of construction and implementation of theremedy as required by Decision Document No. 3 and CD,paragraph 52(j)RP approved January 1, 1988 the date proposed by OlinRP issued Decision Document No. 6, long-term monitoringprogram for the remedial action in the HSB-IC system

DATE

January 18, 1987

February 16, 1987

March 18, 1987April 16, 1987

May 20, 1987

May 20, 1987

July 22, 1987

July 22, 1987

Augusts, 1987

August 19, 1987

August 27, 1987

September 14, 1987

October 14, 1987

October 15, 1987

Decembers, 1987Decembers, 1987


EVENT

Howard Zeller announced his resignation as Chair of the RPeffective December 31, 1987Anne L. Asbell appointed RP Chair effective January 1,1988Anne Asbell requested continuation of the technical andinspection committee. RP adopted a semi-annual meetingschedule in lieu of the quarterly meeting schedule heldthrough December 3, 1987Anne Asbell became RP ChairOfficial completion of construction and beginning of theinitial remedy as required by Decision Document No. 3 andCD, paragraph 52(j)Olin requested change in due date for the long-termmonitoring reports from March 1 to April 15 of each reportyearRP informally concurred with requested change in due datefor the long-term monitoring reportOlin submitted long-term monitoring report 1Technical committee, inspection committee, and RP jointlyinspected remedial action projectRP requested Olin and EPA jointly propose data validationfor long-term monitoring programOlin and EPA proposed long-term monitoring program datavalidation; Olin proposed optimum number of fish to becollectedRP modified Decision Document No. 6 to change due dateof "long-term monitoring program" reports to April 15Olin submitted long-term monitoring program report 2.

Inspection committee reported on June 13, 1989 inspection

Inspection committee, technical committee, and RP jointlyinspected projectRP issued Decision Document No. 7, quality assurance andfish sample sizeRP approved termination of the "far- field" groundwatermonitor program and modification to the "near-field"groundwater monitor programInspection committee reported on June 13, 1990 inspectionU.S. EPA published Second Report on the Remedial Actionto Isolate DDT from People and the Environment in theHuntsville Spring Branch-Indian Creek System, WheelerReservoir, Alabama. Review Panel Activities (United States

DATEDecembers, 1987

Decembers, 1987

Decembers, 1987

January 1, 1988January 1, 1988

February 9, 1989

February 22, 1989

April 14, 1989June 13. 1989

June 14, 1989

November 21, 1989

December 7, 1989

April 15, 1990June 11, 1990June 13, 1990

June 14, 1990

June 14, 1990

June 25, 1990November 1990


EVENT

v. Olin Corporation Consent Decree). July 1. 1986 — June30, 1990

Review Panel issued Decision Document Number 8U.S. EPA issued Superfund Site Interim Closeout ReportReview Panel approved Decision Document Number 9Roy F. Weston, Inc. submitted Five-Year Review FinalReportOlin Corp. submitted Huntsville Spring Branch-IndianCreek Long Term Monitoring Annual Report No. 6Review Panel approved Decision Document Number 10Olin Corp. submitted Huntsville Spring Branch-IndianCreek Long Term Monitoring Report Annual Report No. 7Olin Corp. submitted Huntsville Spring Branch-IndianCreek Long Term Monitoring Program Report onIntel-laboratory Quality Assurance and Quality ControlOlin Corp. submitted Huntsville Spring Branch-IndianCreek Long Term Monitoring Report Annual Report No. 8Olin Corp. submitted Post Remediation SedimentInvestigation Reach A and Reach BOlin Corp. submitted Huntsville Spring Branch-IndianCreek Long Term Monitoring Report Annual Report No. 9Olin Corp. submitted Huntsville Spring Branch-IndianCreek Long Term Monitoring Report Annual Report No. 10Review Panel reviews Olin's proposal for a time extensionPublic meeting on Olin's proposal to extend time to meetthe performance standard for channel catfish andsmallmouth buffaloLetter of Inspection Committee on vegetation and stabilityof Remedial Action Site through monitoring periodRP Decision Document Number 1 1 to extend time formeeting the Performance Standard for channel catfish andsmallmouth buffaloOlin submitted long-term monitoring program, interim goalsand contingency plans for extension periodU.S. Department of Justice and Olin jointly petitioned thecourt to modify the schedule to attain the performancestandardCourt Order modified schedule to meet performancestandardsHuntsville Long-Term Monitoring Report No. 1 1 - Reportissued by Olin

DATE

December 6, 1990

December 18, 1991

January 23, 1992

June 1993

June 1, 1994

January 31, 1995May 15, 1995

May 17, 1996

June 1, 1996

January 6, 1997

May 15, 1997

May 15, 1998

July 23, 1998September 15, 1998

October 2, 1998

December 21, 1998

Februarys, 1999

February 25, 1999

April 23, 1999

May 15, 1999


EVENT

Review Panel Meeting at Huntsville SiteReview Panel Decision Document No. 12 (The MonitoringProgram, Interim Goals, and Contingency Plans forAttained the Performance Standard for Channel Catfish andSmallmouth Buffalo) signed1999 HSB-IC Interlaboratory Data Comparison - Reportissued by OlinHuntsville Long-Term Monitoring Report No. 12 - Reportissued by OlinReview Panel Meeting at Huntsville Site. Review PanelDecision Document No. 10, Appendix D (Findings ofAttainment for Channel Catfish in Reaches A, B, and C andContinued Attainment for Channel Catfish, Reach A) signedReview Panel Internet/Conference Call Meeting2000 HSB-IC Interlaboratory Data Comparison - Reportissued by OlinHuntsville Long-Term Monitoring Report No. 13 - Reportissued by OlinReview Panel Meeting at Huntsville SiteReview Panel Decision Document No. 10, Appendix E(Findings of Continued Attainment for Channel Catfish,Reach C) signedReview Panel Internet/Conference Call Meeting2001 HSB-IC Interlaboratory Data Comparison - Reportissued by OlinHuntsville Long-Term Monitoring Report No. 14 - Reportissued by OlinReview Panel Meeting at Huntsville SiteReview Panel Decision Document No. 13 (Monitoring ofStream Water Levels and Flows) signedReview Panel Internet/Conference Call Meeting2002 HSB-IC Interlaboratory Data Comparison - Reportissued by OlinHuntsville Long-Term Monitoring Report No. 15 - Reportissued by OlinReview Panel Meeting at Huntsville SiteAnnual fish collections in Reaches A, B, and C of the HSB-IC SystemQuarterly surface water collections in Reaches A, B, and Cof the HSB-IC System

DATEJuly 29, 1999September 27, 1999

November 10, 1999

February 15, 2000

March 2, 2000

December 7, 2000January 12, 2001

February 15,2001

March 1,2001March 15, 2001

December 13, 2001January 18,2002

February 15,2002

March 14, 2002April 3, 2002

December 12, 2002January 13,2003

February 15, 2003

March 13, 2003Annually (Spring)

Quarterly


ATTACHMENT 2

SITE MAP

//• • r.~J?*ir? *

MAIITINMU*

I m<cf if « mruef

SOURCE: WAR. 1980

FIGURE i General Site Map - Huntsville Spring Branch, Indian Creek, and Vicinity


ATTACHMENT 3

LIST OF DOCUMENTS REVIEWED


LIST OF DOCUMENTS REVIEWED

Olin Corporation. Huntsville DDT Remedial Action Huntsville Spring Branch IndianCreek Long-Term Monitoring Program Annual Report No. 9. 1997.



Olin Corporation. Huntsville DDT Remedial Action Huntsville Spring Branch IndianCreek LonR-Term Monitoring Program Annual Report No. 12. 2000.


Olin Corporation. Huntsville DDT Remedial Action Huntsville Spring Branch IndianCreek Long-Term MonitorinR Program Annual Report No. 15. 2003.


Report on the Remedial Action to Isolate DDT from People and the Environment in theHuntsville Spring Branch-Indian Creek System, Wheeler Reservoir, Alabama, ReviewPanel Activities (United States v. Olin Corporation Consent Decree), May 31. 1983 -June 30, 1986. 1986. Atlanta. U.S. Environmental Protection Agency, Region IV.

Second Report on the Remedial Action to Isolate DDT from People and the Environmentin the Huntsville Spring Branch-Indian Creek System, Wheeler Reservoir, Alabama,Review Panel Activities (United States v. Olin Corporation Consent Decree), July 1 1986-June 30, 1990. 1990. U.S. Environmental Protection Agency, Region IV. Atlanta.

Third Report on the Remedial Action to Isolate DDT from People and the Environmentin the Huntsville Spring Branch-Indian Creek System, Wheeler Reservoir. Alabama,Review Panel Activities (United States v. Olin Corporation Consent Decree), July 1 1986-June 30, 1990. Vols. 1-2. 2000. Atlanta. U.S. Environmental Protection Agency, RegionIV.

Water and Air Research, Inc. Engineering and Environmental Study of DDTContamination of Huntsville Spring Branch, Indian Creek, and Adjacent Lands andWaters. Wheeler Reservoir. Alabama. Final Contract Report. November 1980. Volume 2- Appendix II - Site Specific Information and Analysis.

Weston, Roy F. Five-Year Review Triana/Tennessee River Site. 1999. Norcross,Georgia.


ATTACHMENT 4

AVERAGE DDT CONCENTRATIONS IN FISH AND SURFACE WATERBY YEAR

AVERAGE DDT CONCENTRATIONS IN FISH BY YEAR

CHANNEL CATFISH

Year •Parameter

Baseline*

Year ] 1988

Year 2 1989

Year 3 1990

Year 4 1991

Year 5 1 992

Ye;ir 6 1 993

Year? 1994

YearS 1995

Year 9 1996

Year 10 1997

Year 11 1998

Year 12 1999

Year 132000

Year 142001

Year 152002

Year 162003

Reach An | ave i s,cL | ' nun |-max

29 95 82 2.1 320

23 33 31 3.1 100

30 45 40 5.6 210

18 9.2 12 0.7 50

15 15 16 1.1 62

34 9.3 7.8 1.6 32

37 8.4 9.2 0.1 37

23 11 9.0 0.1 29

32 7.6 6.3 0.5 23

42 6.4 5.6 0.3 24

25 5.0 4.1 0.69 17

25 5.0 3.9 0.91 20

25 3.3 3.8 0.5U 17

0 -

0 -

0 -

0 -

Reach Ba J ave j s.d f mitt | max

83 69 89 1.5 530

30 45 46 1.1 170

31 45 33 5.4 130

21 12 15 1.9 55

16 13 11 1.4 40

37 9.7 7.9 0.8 32

38 9.2 9.0 0.1 32

26 9.7 7.1 0.8 24

42 11 4.9 0.4 29

37 7.2 7.4 0.6 36

24 6.9 5.7 0.92 26

25 6.0 4.4 1.1 16

25 4.5 4.4 0.5U 20

27 8.0 5.3 0.3 19

25 4.6 3.6 0.6 14

25 4.0 3.8 0.17J 16

18 5.0 3.3 1.4 12

, Beach, C -'" , •n, [awfs;<it tniR IpSk

118 66 79 1.6 550

39 36 47 1.7 200

28 42 64 1.4 250

18 29 65 2.2 280

27 16 22 0.59 75

21 8 8.4 0.23 32

29 5.5 6.1 0.08 26

8 9.2 6.0 0.9 18

15 5.5 5.5 1.3 16

32 2.6 2.0 0.2 6.2

22 5.5 4.2 0.26 13

25 3.2 2.1 0.21 7.8

25 3.8 3.3 0.5U 13

25 4.4 4.2 0.5U 16

0 - _

0 - -

0

* Decison Document No. 2 [1982-1985 Fish Collection (Year Group IT-IV)]

n is number of samples analyzedave is average DDT concentration (mg/kg) of samples analyzeds.d. is standard deviation of the DDT concentrations (nig/kg)min is the minimum DDT concentration (mg/kg) analyzedmax is the maximum DDT concentration (mg/kg) analyzed

AVERAGE DDT CONCENTRATIONS IN FISH BY YEAR

LARGEMOUTH BASS

YearParameter

Baseline

Year 1 1988

Year 2 1 9S9

Year 3 1 990

Year 4 1991

YearS 1992

Year 6 1 993

Year 7 1994

YearS 1995

Year 9 1 996

Year 10 1997

Year 11 1998

Year 12 1999

Year 1 3 2000

Year 142001

Year 15 2002

Year 162003

f

n 'a

21

10

17

I X

14

11

10

17

22

27

0

20

0

Q

0

0

0

Reach Ave s-d | fws { max

7.1 7.8 1.2 28

5.6 5.5 0.7 16

4.9 4.1 0.2 U 15

4.3 4.2 0.1 U 16

9.7 6.8 2.0 23

1.5 2.4 0.27 3

1.2 1.3 0.13 3.8

1.6 1.7 0.51J 5.6

1.7 1.6 0.5U 5.3

1.5 0.7 0.1 9.6

0.4 0.6 0.5U 2.4

-

-

-

„

,if a1"

3

9

13

14

10

18

15

12

24

27

0

16

0

0

0

0

0

ReaettBre s d j iran j jnax

37 11 28 49

5.0 8.5 0.4 27

2.2 2.4 0.2U 8.8

3.7 4.0 0.45 .16

9.5 5.6 2.3 21

1.3 1.4 0.5U 5.6

3.8 3.5 0.08 14

1.9 2.3 0.5U 8.2

2.9 4.1 0.16 1.9

1.1 0.8 0.06 2.8

--

0.5 0.5 0.5U 2.1

--

--

--

..

-n.-

34

17

26

14

13

26

12

15

25

24

0

17

0

0

0

0

0

ReacfcC ^ -" ave | sd f oaa } jtoaX.:.

8.2 6.0 1.2 24

2.7 4.8 0.2 16

6.4 13 0.2U 56

2.4 1.4 0.64 5

4.9 3.7 0.5U 12

0.78 0.89 0.5U 4

1.4 1.7 0.5 6.8

1.1 1.1 0.5U 3.8

0.6 0.5 0.5U 2.1

0.5 0.4 0.5U 1.6

-

0.2 0.2 0.5U 0.69

..

--

„

..

- -

* Decison Document No. 2 [1982-1985 Fish Collection (Year Group II-V)]

n is number of samples analyzedave is average DDT concentration (mg/kg) of samples analyzeds.d. is standard deviation of the DDT concentrations (mg/kg)min is the minimum DDT concentration (mg/kg) analyzedmax is the maximum DDT concentration (mg'ltg) analyzed

AVERAGE DDT CONCENTRATIONS IN FJSH BY YEAR

SMALLMOUTH BUFFALO

YearParameter

Baseline

Year 1 1 988

Year 2 1 989

Year 3 1 990

Year 4 1991

Year 5 1 992

Year 6 1 993

Year 7 1 994

Year 8 1 995

Year 9 1996

Year 1 0 1 997

Year 11 1998

Year 1 2 1 999

Year 1 3 2000

Year 14 2001

Year 1 5 2002

Year 1 6 2003

Reach An | ave

12 140

0

3 31

1 24

2 89

16 42

12 19

i. 37

3 84

4 8.1

15 12

15 14

1 0 1 4

24 11

17 20

1 1 18

1 7 7.9

s d | min f max

190 1.8 600

-

34 9.3 70

-

120 3.2 170

74 0.36 290

30 0.34 90

1.2 2.9 5.1

130 7.6 230

5.8 1.1 14

13 0.66 40

14 1.4 52

14 0.57 38

9.) 0.12 35

2! 0.64 14

14 6.0 44

10 1.0 45

n

20

6

6

10

10

17

14

13

11

8

15

->*7

9

24

15

9

20

Reach Bave 1 «.d: [ ..nun

180 190 2.4

82 88 3.0

55 93 2.6

41 51 0.56

37 36 5.7

41 75 0.45

35 55 0.05

38 48 0.7

48 60 4.3

29 30 0.06

21 31 2.1

17 18 0.95

7.2 6.4 0.5U

12 12 2.3

13 15 0.06

39 35 4.6

11 12 0.6

.max

620

250

240

120

130

300

190

150

210

100

120

84

.18

57

53

110

49

ReagfaC - ' < \ - ~ . " . . . . 'n ' i ave \ s d, \ noa ',r'JaapC

70 110 100 1.4 470

16 89 110 7.0 360

19 50 45 0.2U 140

6 41 59 0.39 140

15 45 47 1.0 190

16 34 47 0.37 170

17 34 63 0.46 250

15 13 16 0.5U 51

23 17 21 0.7 79

4 3.0 1.5 0.8 4

14 9.4 6.6 0.3 23

17 5.4 5.6 0.87 21

1 1 9.3 1 1 0.5U 29

19 6.5 8.6 0.25 31

16 6.2 9.1 0.42 40

9 7.5 8.0 0.83 21

18 7.7 13.0 0.05U 55

* Decison Document No. 2 [1982-1985 Fish Collection (Year Group HI-VI)]

n is number of samples analyzedave is average DDT concentration (mg/kg) of samples analyzeds.d. is standard deviation of" the DDT concentrations (mg/V.g)min is the minimum DDT concentration (mg'kg) analyzedmax is the maximum DDT concentration (mg/kg) analyzed

HSB-IC LONG-TERM MONITORING PROGRAMAVERAGE DDT CONCENTRATION TN HSB-IC WATER

y^ir:Average £)DTConcentralKjn{uw5)ijai Water (unSJtered) ' ,,..,..„ '-.-...,

HSBM 9.75 HSBM 4 85 HSBM 3',?'- HSBM 2.4 ICM'4-,6 JCM0.38 - ICMSL2

Baseline

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

0.77

0.0 w

0.0 (:"

0.0 (3)

o.o (a>0.0 !a)

0.0 <a)

o.o v0.03 <c'

0.03 lc)

0.0 (a)

0.0 taj

o.o <:1)

o.o (:1'o.o (a)

0.0 w

o.o (;1)

.3.4

0.0 (a>

0.0 (a)

0.0 (a)

0.0 w

0.0 la}

0.0 i;a)

o -b)

0.09 (3)

0.02 w

0.0 (a)

0.02

0.05

0.0 'x'

0.0 (3)

0.02 (c)

0.0 (c'

12

0.35

0.05

0.72

0.28

0.0 w

0.26

0.06 (b)

0.21 w

0.29

0.0 °"

0.42

0.16

0.14 ( c '

0 0 w

0.0 (ai

0.06 ''">

13

1.23

067

1.28

0.6

0.2

0.58

0.2 w

0.51

0.2

0.05

0.37

0.33

0.35 w

0.33 (c)

(•, ; 2 '-c:'

O . I O ( d >

4.3

1.51

1.05

0.65

0.26

0.17

0.13

0.24 W

0.38

0.37

0.11

0.14

0.16

0.09 (c)

0.27 <c)

0.10W

0.10(d>

1.7

0.54

0.33

0.07

0.03

0.21

0.05

0.13^

0.05 (=;!

0.1

0.0 w

0.06

0.03

0.04 (c)

0.03 (c;i

0.0 la)

0.0 w

0.6

0.0 (a)

0.0 Ca)

o.o (a)

o.o (n)

0.0 w

0.0 (a)

o.o w0.08 (a)

0.03 (c;'

0.0 (a)

0.0 <a)

o.o (3)

o.o (a)

0.0 w

0.0 w

0.0 (a)

Notes: HSBM 4.85 (Baseline) was located at HSBM 5.0 in the filled channel.HSBM 4.85 is located in the salient cut.

HSBM 3.9 (Baseline) was located at HSBM 4.0 in the filled channel.

(a) Practical quantitation limit tor DOT in water is 0.10 ug'l (0.0 ug/'l usedlor calculations).

(h) I,ab blank results (0.04 ue/1) was subtracted from June, 1994 sampleresults before calculations.

(c) Practical quarititation limit for DDT in water is 0.1 ng/1 (one or n<cr esamples had estimated values between 0.04 and 0.09 ug/1).

(d) Practical quantitolion limit for DDT in water is 0.1 ug/l (one or tnoiesv.3i.ples had iindeteclable values. See note, (a).


ATTACHMENT 5

SITE INSPECTION CHECK LIST


I. SITE INFORMATION

Site Name: Triana/Tennessee River Site

Location and Region: Huntsville, ALAgency, office or company leading thefive-year review:U.S. Environmental Protection Agency

Date of Inspection:September 2, 2004USEPAID: ALD983166299Weather/temperature:Partly cloudy and humid

Remedy Includes (Check all that apply)I I Landfill cover/containmentIXI Access controlsI | Institutional controlsI I Groundwater pump and treatmentI I Surface water collection and treatment

Monitored natural attenuationGroundwater containmentVertical barrier walls

Other: Fish, surface water and sediment samplingInspection team roster provided in Five-Year Review ReportSite map provided in Attachment 2

II. INTERVIEWS (Check all that apply)

1. O&M Site Manager N/A

Interviewed I I at site I I at office | | by phone Phone no.Problems, suggestions; I I Report attached

2. O&M Staff N/A

Interviewed I I at site | | at office | | by phone Phone no.Problems, suggestions; f~1 Report attached

3. Local regulatory authorities and response agencies (i.e., State and Tribal Offices,emergency response office, police department, office of public health or environmentalhealth, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in allthat apply.

Agency: Alabama Department of Environmental ManagementContact: Gerald Hardy Chief Land Division September 2, 2004

Name Title DateProblems, suggestions: 1X1 Report provided in Attachment 7


4. Other Interviews: [X] Reports provided in Attachment 7

o Dr. Ed Bender EPA Committee Chair August 23, 2004o Don Dycus TVA, Technical Specialist August 19, 2004o Wm. Gerald Hardy ADEM, Chief, Land Division August 19, 2004o Hon. Clyde Foster Town of Triana September 10 and 13, 2004o Peter Tuttle USFWS, Biologist September 13, 2004

III. ON-SITE DOCUMENTS & RECORD VERIFIED (Check all that apply)

1. O&M DocumentsD As-builts O Readily available. D Up to date [X] N/AQ Maintenance Logs Q Readily available O Up to date £3 N/A

Remarks

2. Site Specific Health and Safety Plan Q Readily available Q Up to date [Xj N/A

Contingency Plan/Emergency Response Plan [~1 Readily available |~~] Up to dateIE! N/ARemarks

3. O&M and OSHA Training Records Q Readily available Q Up to date [XJN/A

Remarks

4. Permits and Service Agreements

l~~l Air Discharge Permit I I Readily available | | Up to date IXI N/AO Effluent discharge Q Readily available d Up to date [X] N/AD Waste disposal, POTW Q] Readily available D Up to date |E1 N/ADOther permits Q Readily available Q Up to date [X]N/A

Remarks:5. Gas Generation Records

D Readily available Q Up to date [X] N/ARemarks

6. Settlement Monument RecordsD Readily available D Up to date £<] N/ARemarks


7. Groundwater Monitoring RecordsE3 Readily available £><j Up to date D N/ARemarks: The last ground water sampling round occurred prior to the second 5-YR

.in 1997.

8. Leach ate Extraction RecordsD Readily available Q Up to date £<] N/ARemarks

9. Discharge Compliance RecordsI I Air | | Readily available II Up to date [XI N/AD Water (effluent) Q Readily available D Up to date [g] N/A

Remarks

4. O&M COSTS

1. O&M OrganizationI I State in-house | | Contractor for State[X] PRP in-house Q Contractor for PRPD Other

2. O&M Cost RecordsI I Readily available I I Up to date1X1 Funding mechanism/agreement in placeI I Original O&M cost estimate: Total annual O&M costs since 1999 are$130,000. Olin declined to provide cost breakdown. ^^^^

3. Unanticipated or UnusuaHly High O&M Costs During Review PeriodDescribe costs and reasons: None noted.

V. ACCESS AND INSTITUTIONAL CONTROLS

A. Fencing

1. Fencing damaged Q Location shown on map |̂ ]Gates secured I I N/ARemarks:

B. Other Access Restrictions


1. Signs and other security measures Q Location shown on mapRemarks: All required signs and warnings are posted on fencing.

C. Institutional Controls (ICS) [X] N/A

D. General

1. Vandalism/trespassing Q Location shown on site map [X] No vandalism evidentRemarks

2. Land use changes on siteRemarks

N/A

3. Land use changes off siteRemarks

N/A

VI. GENERAL SITE CONDITIONS

A. Roads ^Applicable D N/A

1. Roads damaged [J Location shown on site maplXl Roads adequate I I N/ARemarks:B. Other Site Conditions Q Applicable ̂ N/ARemarks

VII. LANDFILL COVERS D Applicable [XJNot Applicable

A. Landfill Surface |~1 Applicable ^]Not Applicable

B. Benches Applicable Applicable

C. Letdown Channels I I Applicable £<]Not Applicable

D. Cover Penetrations [~] Applicable Applicable


E. Gas Collection and Treatment D Applicable £<]Not Applicable

F. Cover Drainage Layer Q Applicable [XJNot Applicable

G. Detention/Sedimentation Ponds [U Applicable ^Not Applicable

H. Retaining Walls |~~1 Applicable ^Not Applicable

I. Ponds/Off-Site Discharge Q Applicable [X]Not Applicable

1. Siltation [^Location shown on site map IXISiltation not evidentRemarks

2. Vegetative Growth [^Location shown on site map[^Vegetation does not impede flow

Remarks

3. Erosion LJLocation shown on site map IXlErosion not evidentRemarks

4. Discharge Structure [^Functioning [X]N/ARemarks

VIII. VERTICAL BARRIERS D Applicable |E1 Not Applicable

IX. GROUND WATER/SURFACE WATER REMEDIES

A. Groundwater extraction wells, pumps and pipelines[~~1 Applicable ^ Not Applicable

B. Surface water collection structures, pumps and pipelinesQ Applicable ^ Not Applicable


1. Collection Structures, Pumps and ElectricalD Good condition Q Needs O&M

RemarksN/A

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and OtherAppurtenances

D Good condition G Needs O&M £<] N/ARemarks

3. Spare Parts and Equipment

I I Readily available EX] Good ConditionI I Needs to be provided

Remarks:

Requires upgrade

C. Treatment System |~] Applicable Not Applicable

D. Monitored Natural Attenuation

1. Monitoring Wells Q N/AI I Functioning Q Routinely sampled | | Properly secured/lockedI I Good condition | | All required wells located IXI Needs O&M

Remarks: Due to thick vegetation, only one monitoring well out of 37 observed. If wellswill be utilized in the future, they will likely require re-development and mustbe maintained and secured with locks.

X. OTHER REMEDIES

Q Applicable [X] Not Applicable


XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

Based upon the site visit and review of Annual Report No. 16, the remedial action isaccomplishing its goal of preventing contact between the ecosystem and DDT. DDT levelsin performance standard fish have declined with only smallmouth buffalo requiring furthermonitoring. DDT concentrations in the water column and sediment have also declinedsteadily over the 16 years of long-term monitoring. No significant DDT contaminationobserved in monitoring wells in the filled channel areas.

B. Adequacy of O&M

All O&M requirements are adequate for the site. The RP will determine whether trees 3-inches in diameter and larger should be removed from diversion structures and fill areas.It should be determined if monitoring wells will be utilized in the future. If so, they willlikely require re-development and must be maintained and secured with locks. Otherwise,the wells should be properly decommissioned.

C. Early Indicators of Potential Remedy Problems

No early indicators of potential remedy problems were identified during this five-yearreview.

D. Opportunities for Optimization

Opportunities for optimization were not identified during this review. The fish, surfacewater and sediment sampling provide sufficient data to assess compliance with the CD.


ATTACHMENT 6

PHOTOGRAPHS DOCUMENTING SITE CONDITIONS

€>€> Third Five-Year Review Report, Triana/Tennessee River Site, Madison County, Alabama

€>

4

€

ATTACHMENT 7

INTERVIEW RECORDSo

o

oooooooooooooooo


INTERVIEW RECORD


Subject: Five- Year Review

Type: QTelephone QVisit £<]OtheLocation of Visit: Responses emailed

Contact Made By:

Name: Chip Parrott Title: Geologist

USEPA IT) No.: ALD983 1 66299

Time: 7:01 a.m. Date: 8/23/04

r |~| Incoming |~~| Outgoing

Organization: USAGE

Individual Contacted:

Name: Dr. Edward Bender Title: RP Chairperson

Telephone No: 202/564-6483 StreeFax No: 202/564-2070E-Mail Address: [email protected]

City,

Organization: USEPA

t Address: Office of the Science Advisor

Office of Research and Development

1200 Pennsylvania Ave., NWState, Zip: Washington, D.C. 20460

Summary Of Conversation (See next page)


Summary Of Conversation

When asked if the remedy of isolating DDT in the Huntsville-Spring Branch system from people andthe environment is working, Dr. Bender replied as follows:

Yes. The remedy for isolating DDTR in Huntsville Spring Branch-Indian Creek system from peopleand the environment is working. The results of monitoring indicate that residues in fish,invertebrates, and other wildlife are continuing to decrease. Levels in water are quite low and furtherwork on sediments is planned. We have not seen DDTR in groundwater and inspections of theremedy show that the physical integrity of the remedy has been maintained.

When asked to describe the level of cooperation between agencies (USEPA, ADEM, TV A, USFWSand USAGE), Dr. Bender replied as follows:

From my perspective, there is a high level of cooperation. Data are freely shared, several groupsengage in joint monitoring exercises, and members feel free to raise concerns and questions in groupdiscussions.

When asked if he was aware of any areas of non-compliance, Dr. Bender replied as follows:

No. In fact all of the performance standards for channel catfish were achieved during the last fiveyear interval. Smallmouth buffalo also declined during the same period. That is the last remainingperformance standard which should be achieved initially by monitoring data collected during 2007.

When asked if he knew of any unexpected O&M difficulties in the last 5 years, Dr. Bender replied asfollows:

No. We perform annual inspections of the remedy and our primary concern is the density of thevegetation over the filled channel area. We will be discussing this later this year.

When asked if he was aware of any effects of site operations on the surrounding community, Dr.Bender replied as follows:

No. Our feedback from the community through Clyde Foster indicates that the community is pleasedwith the project and the progress of the remediation.

When asked if he had knowledge of any incidents onsite including vandalism, trespassing, oremergency responses Dr. Bender replied as follows:

Sfone. I have inquired of Danny Dunn, who works for the Environmental Management Unit of theRedstone Arsenal Facilities Engineers and he has not indicated any incidents related to this site.

Dr. Bender had no additional comments.

Third Five-Year Review Report. Triana/Tennessee River Site, Madison County, Alabama

INTERVIEW RECORD


Subject: Five-Year Review

Type: [^TelephoneLocation of Visit: Responses

QVisit Botheremailed

USEPA ID No.: ALD983 166299

Time: 4:31 p.m.

1 I Incoming [

Date: 8/19/04

[] Outgoing

Contact Made By:

Name: Chip Parrott Title: Geologist Organization: USAGE


Name: Mr. Wm. Gerald Hardy Title: Chief, Land Division

Telephone No: 334/271-7732Fax No: 334/279-3050E-Mail Address: [email protected]

Street Address:

City, State, Zip:

Organization: ADEM

Alabama Dept. of Env. Mgmt.

P.O. Box 301463

1400 Coliseum Blvd.Montgomery, AL 36110


When asked his overall impression of the project, Mr. Hardy replied that he believed the remedy ofisolating DDT in the Huntsville Spring Branch system from people and the environment is working.

He described the level of cooperation between the government agencies (USEPA, ADEM, TVA,USFWS and USAGE) as good. He was not aware of any areas of non-compliance.

Mr. Hardy was not aware of any unexpected O&M difficulties in the last five years and had noknowledge of any incidents including vandalism, trespassing, or emergency responses at the site.

Mr. Hardy was not aware of any effects of site operations on the surrounding community.

Mr. Hardy had the following additional comments:

Although no specific problems have been noted, the woody vegetation both along the edges ofthe channel cuts and within areas of the fill channel have raised concerns among members ofthe Inspection Committee regarding two issues:

i. The potential for damage to the remedial action by the roots of trees blownover by high winds; and

ii. The potential for DDT uptake by deep rooted vegetation, the subsequentredeposition on the surface through the leaves and/or bark, and thepotential effects of associated residues on the HSB-IC food chain.


INTERVIEW RECORD



Type: QTelephoneLocation of Visit: Responses

QVisit Botheremailed

USEPA ID No

Time: 11:25 a

Q Incoming

.: ALD983 166299

m. Date: 8/19/04

n Outgoing

Contact Made By:



Name: Mr. Don Dycus

Telephone No: 423/751-7322Fax No:E-Mail Address: dldycus@tva

Title: Technical Specialist

gov

Street Address:City, State, Zip:

Organization: TVA

1101 Market St. (MR 25)Chattanooga, TN 37402


When asked his overall impression of the project, Mr. Dycus replied that he believed the remedy ofisolating DDT in the Huntsville Spring Branch system from people and the environment is working.

He described the level of cooperation between the government agencies (USEPA, ADEM, TVA,USFWS and USAGE) as good to excellent. He was not aware of any areas of non-compliance.

Mr. Dycus was not aware of any unexpected O&M difficulties in the last five years and had noknowledge of any incidents including vandalism, trespassing, or emergency responses at the site.

Mr. Dycus was not aware of any effects of site operations on the surrounding community.

Third Five-Year Review Report, Triana/Termessee River Site, Madison County, Alabama

INTERVIEW RECORD

Site Name: Triana/Termessee River Site


Type: ^Telephone QVisit QOtherLocation of Visit:

USEPA ID No.

Time:

[~~l Incoming

: ALD983 166299

Dates: 9/10/04and 9/1 3/04

n Outgoing

Contact Made By:



Name: Hon. Clyde Foster Title:

Telephone No: 256/464-0124Fax No: 256/464-9801E-Mail Address: [email protected]

Street Address:

City, State, Zip:

Organization: Town of Triana

380ZierdtRoad

Triana, AL 35756


When asked his overall impression of the project, Mr. Foster replied that he believed the remedy ofisolating DDT in the Huntsville Spring Branch system from people and the environment is working.

He described the level of cooperation between the government agencies (USEPA, ADEM, TV A,USFWS and USAGE) as unprecedented. He was not aware of any areas of non-compliance.However, he stated that while there was adequate attention paid to the effects of DDT on theenvironment, there was not enough attention paid to the effects of DDT on human beings.

[n terms of any unexpected O&M difficulties in the last five years, Mr. Foster was concerned aboutthe amount of trash (bottles, tires etc.) making its way into the HSB-IC system. He had no knowledgeof any incidents including vandalism, trespassing, or emergency responses at the site.

As far as additional comments, Mr. Foster reiterated that the success of the project was due in largepart to the cooperation of the government agencies listed above.


INTERVIEW RECORD



Type: QTelephone QVisit [X]OtherLocation of Visit: Responses emailed

Contact Made By:

Name: ChipParrott


Name: Peter Turtle

Title: Geologist

Title: Biologist

Telephone No: 251/441-6633 Street^Fax No: 251/441-6222E-Mail Address: Pete [email protected]

City, St

USEPA ID No.: ALD983 1 66299

Time: 9:25 a.m. Date: 9/13/04

[]] Incoming O Outgoing

Organization: USAGE

Organization: USFWS

iddress: U.S. Fish and Wildlife Service

1208-BMainSt.

P.O. Drawer 1190

ate, Zip: Daphne, AL 36526

Summary Of Conversation (See next page)



When asked if the remedy of isolating DDT in the Huntsvilie-Spring Branch system from people andthe environment is working, Mr. Turtle replied as follows:

Available data indicated that significant progress has been made to reduce DDT levels in fish fillets.However, as discussed below, the remedy may not be protective of humans regularly consuming fishcollected from contaminated areas. Also, the selected remedial goals are not protective of ecologicalreceptors. Therefore, the selected remedy is not protective of the environment.

When asked to describe the level of cooperation between agencies (USEPA, ADEM, TVA, USFWSand USAGE), Mr. Turtle replied as follows:

It appears that interagency cooperation on this action has been very good.

When asked if he was aware of any areas of non-compliance, Mr. Tuttle replied as follows:

Remedial goals for fish fillets were not attained within the originally-specified time frame. As of2004, goals for smallmouth buffalo have still not been attained.

When asked if he knew of any unexpected O&M difficulties in the last 5 years, Mr. Tuttle replied asfollows:

No.

When asked if he was aware of any effects of site operations on the surrounding community, Mr.Tuttle replied as follows:

DDT contaminated fish obviously represent a threat to human consumers. The selected remedialgoals (5 ppm DDT in skinless fish fillets) were based on fish consumption guidelines issued by theFood and Drug Administration (FDA) to protect the national food supply as a whole. Theseguidelines are reportedly not designed to protect humans regularly consuming fish collected fish froma specific contaminated site. Fish consumption guidelines developed by EPA, which moreappropriately consider actual exposure based on consumption habits, are more protective of humanlealth in these scenarios.

It would seem that a reevaluation offish consumption habits in local communities is warranted. Ifonsumption of local fish continues, we recommend characterizing potential exposure and risk to

luman consumer. Such characterization should include assessment offish species consumed, theDDT concentrations in edible tissues of each species, and the frequency of consumption across thejotentially affected community. Also, methods offish preparation by local consumers should beevaluated. For example, are catfish skinned before cooking or are fish cooked whole? Exposure toDDT would be much greater in the latter case.

When asked if he had knowledge of any incidents onsite including vandalism, trespassing, ormergency responses Mr. Tuttle replied as follows:

No.

€»€>€>ft0ftftft€1ft


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Summary Of Conversation ctd.

Mr. Tuttle had the following additional comments:

Remedial goals for this site appear to have been designed exclusively to protect human health. Theremedial goals (5 ppm DDT in skinless fillets) exceed levels needed to protect fish-eating birds (~2ppm). Also, DDT concentrations in whole fish are likely to be much higher in whole fish than inskinless fillets. For example, DDT concentrations in fish fillets from the Ciba-Mclntosh NPL Site areroughly 10% of the DDT concentrations found in whole fish. Therefore, risk to fish eating wildlife islikely much greater that what may be predicted using fish fillet data. Additionally, no goals wereestablished for water or sediment quality and we are not aware of regular efforts to monitorcontaminant concentrations in the media. Therefore, it is difficult to evaluate the ability of theremedial action to protect aquatic organisms or the environment as a whole.

We recommend a reevaluation of ecological risks at the Olin-Triana Site. Such an action shouldinclude the collection of water, sediment, and biological samples and the preparation of an EcologicalRisk Assessment. We offer our assistance in the design and implementation of additional datacollection activities and preparation of an ecological risk assessment.

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