I I

Five-Year Review Report

I I Fourth Five-Year Review Report

for Triana/Tennessee River

I EPA 10 ALD983166299

I Triana/Huntsville

I Morgan, Limestone, Madison Counties, Alabama

I February 2010

I I

Prepared By: E2 Inc.

2417 Northfield Road

I Charlottesville, VA

22901

I For:

I United States Environmental Protection Agency

Region 4 Atlanta, Georgia

I I I Franklin E. Hill

Date:

Director, Superfund Division

I I \\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\~\\

10717145

I

I IFourth Five-Year Review Report

for Triana/Tennessee River ITriana/H untsville

Morgan, Limestone, Madison Counties, Alabama

Table of Contents I List of Acronyms .......................................................................................................................... iv I Executive Sunlmary ...................................................................................................................... \'

Five-Year Revie\v Sumnlary Form .......................................................................................... viii I 1.0 Introduction ............................................................................................................................. 1

2.0 Site Chronology ....................................................................................................................... 2 I 3.0 Background ............................................................................................................................. 4

3.1 PHYSICAL CHARACTERISTICS .......................................................................................... 4 I3.2 LAND AND RESOURCE USE .............................................................................................. 4 HISTORY OF CONTAMINATION ......................................................................................... 7 INITIAL RESPONSE ........................................................................................................... 7 IBASIS FOR TAKING ACTION ............................................................................................. 8

4.0 Remedial Actions .................................................................................................................... 8 I4.1 REr-v1EDY SELECTION ........................................................................................................ 9 4.2 REMEDY 11vlPLE1vlENTATION ........................................................................................... 11 4.3 OPERATION AND MAINTENANCE (O&M) ....................................................................... 12 I

5.0 Progress Since the Last Five-Year Revie\" ......................................................................... 13

5.1 REtvl0VAL OF TREES FROM REr'vlEDY ............................................................................... 13 I5.2 GROUND WATER rvIONrTORING\VELLS ............................................................................ 13

6.0 Five-Year Revie\" Process .................................................................................................... 14

I6.1 AD1vllNISTRATIVE CorvlPONENTS .................................................................................... 14 6.2 CorvIMUNIT't' INVOLVEMENT .......................................................................................... 14 6.3 DOCUMENT REVIEW ...................................................................................................... 14 I6.4 DATA REVIEW ............................................................................................................... 16 6.5 SITE INSPECTION ............................................................................................................ 18 6.6 INTERV I E\VS ................................................................................................................... 19 I

7.0 Technical Assessment ........................................................................................................... 21

7.1 QUESTION A: Is THE REtvIED'{ FUNCTIONING AS INTENDED BY THE DECISION

DOCU1vlENTS? ............................................................................................................... 21 I 7.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS, AND

REtvlEDIAL ACTION OBJECTIVES (RAOs) USED AT THE TIME OF RErvlEDY SELECTION

STILL VALID? ............................................................................................................... 22 I I

11

I

I I

7.3 QUESTION C: HAS ANY OTHER INFORf\MTION COf\'lE TO LIGHT THAT COULD CALL INTO

QUESTION THE PROTECTIVENESS OF THE REr"vIEDY? ...................................................... 22

I 7.4 TECHNICAL ASSESSMENT SUMi'vIARY ............................................................................. 22

8.0 Issues ...................................................................................................................................... 23

I 9.0 Recommendations and Follow-up Actions ......................................................................... 24

10.0 Protectiveness Statenlent .................................................................................................... 25

I 11.0 Next Rcvie\v ......................................................................................................................... 26

Appendix A: List of Documents Rcvic\\'ed ............................................................................. A-I

I Appendix B: Press Notice ......................................................................................................... B-1

Appendix C: Intervic\v Forms ................................................................................................. C-l

I Appendix D: Site Inspection Checklist ................................................................................... D-l

Appendix E: Photographs from Site Inspcction .................................................................... E-l

I Tables

Table I: Clu-onology of Site Events ................................................................................................ 2

I Table 2. Action Levels for DDT in Fish Fillets .............................................................................. 9 Table 3. Annual O&l\.1 Costs ........................................................................................................ 12 Table 4: Progress on Recommendations from the 2005 FYR ...................................................... 13

I Table 5: Summary of Action Levels for DDT in Fish Fillets ....................................................... 15 Table 6: DDT Concentrations in Smallmouth Buft~11o fish Fillets .............................................. 16 Table 7: IC SUl11J11ary Table .......................................................................................................... 19

I Table 8: Current Site Issues .......................................................................................................... 23 Table 9: Recommendations to Address Current Site Issues ......................................................... 24

I Figures

I Figure 1: Site Location l\1ap .................................................. : ......................................................... 5 Figure 2: Detailed Site Map ............................................................................................................ 6

I I I I I

III

I

I

List of Acronyms I

ADEM ARAR CD CERCLA CFR CPG DoA DDT EPA FDA FWPCA FYR HSB HSB-JC IC LRA ~lg/L

NCP NPL O&M ppm PRP RA RAO RCRA RP RPM RSA SARA TBC TVA URA USFWS WNWR

IAlabama Department of Environmental Management Applicable or Relevant and Appropriate Requirement Consent Decree IComprehensive Environmental Response, Compensation, and Liability Act Code of Federal Regulations Compliance and Policy Guide IDepal1ment of the Army Dic h loro-d ipheny 1-tric h I oroethane United States Environmental Protection Agency IUnited States Food and Drug Administration Federal Water Pollution Control Administration Five-Year Review IHuntsville Spring Branch Huntsville Spring Branch-Indian Creek Institutional Control ILower Reach A micrograms per liter National Contingency Plan INational Priorities List Operation and Maintenance parts per million IPotentially Responsible Party Remedial Action Remedial Action Objective I Resource Conservation and Recovery Act Review Panel Remedial Project Manager I Redstone Arsenal Superfund Amendments and Reauthorization Act To-Be-Considered Criteria I Tennessee Valley Authority Upper Reach A United States Fish and Wildlife Service I Wheeler National Wildlife Refuge

I I I I

IV

I

I I

Executive Summary

I Introduction

The Triana/Tennessee River Site (the Site) is located in Limestone/Morgan, Alabama. The Site

I consists of 11 miles of the Huntsville Spring Branch (HSB) and Indian Creek tributaries of the

I Tennessee River. The Site is located completely within the Wheeler National Wildlife Refuge (WNWR) and the Redstone Arsenal (RSA). Between 1947 and 1970, the Olin Corporation and the Calabama Chemical Company (collectively refelTed to as Olin) operated a dichloro-diphenyl­

I trichloroethane (DDT) manufacturing plant on a leased portion of the RSA. During site operations, wastewater was discharged into the HSB tributary. Fish samples from the tributaries were found to exceed United States Food and Drug Administration (FDA) guidelines for fish

I sold in interstate commerce. In November 1980, the United States Army Corps of Engineers completed a study at the Site to define the extent of contamination and identify preferred engineering alternatives for long-term control of the DDT contamination. The Site was proposed

I for listing on the United States Environmental Protection Agency's (EP A's) National Priorities List (NPL) on December 30, 1982, and finalized on the NPL on September 8, 1983. Fish, soil, sediments, ground water, and surface water at the Site were found to be contaminated with DDT, and its breakdown products dichloro-diphenyI-dichloroethylene and dichloro-diphenyl­

I dichloroethane (collectively refeITed to as DDT).

In 1983, Olin entered into a Consent Decree (CD) with the State of Alabama and the United

I States that required Olin to implement a cleanup plan to address the contamination at the Site.

I The CD required the designation of a Review Panel (RP), including members from the United States Fish and Wildlife Service (USFWS), Tennessee Valley Authority (TV A), EPA, the Depaliment of the Army (DoA), and the State of Alabama, to be responsible for the technical overview of Olin's proposed remedial action plan. The main components required by the CD for Olin's remedial action plan included:

I • Diverting stream now around contaminated pOliions of the tributaries. • Excavating new channels.

I • Excavating portions of contaminated sediments. • Burying pOliions of contaminated sediments in place. • Monitoring contam i nant concentrations.

I In addition, a performance standard of 5 pmis per million (ppm) of DDT in the fillets of three species of fish (channel catfish, largemouth bass, and smallmouth buffalo) was established. The

I performance standard was to be met during at least one year ("initial attainment") within the 10­year period following completion of construction and implementation of the remedial action. Exhibit B of the CD (entitled the "Joint Technical Proposal to Implement Remedial Activities

I Pursuant to the Consent Decree" and referenced in the CD as "the Proposal") defined initial attainment as an average concentration of DDT of 5 ppm or less in the fish fillets for one year for each performance-standard species and each Reach of the Huntsville Spring Branch-Indian

I Creek (HSB-IC) system:

I • Reach A - BegilUling at HSB mile 5.4 and extending to HSB mile 2.4.

v

I

I

I

.-II

• Reach B - Begilming at HSB mile 1.4 and extending to !-ISB mile 0.0. • Reach C - Beginning at Indian Creek mile S.6 and extending to Indian Creek mile 0.0.

IOnce initial attainment was achieved, Olin was to then demonstrate "continued attainment" for each of the three species by meeting the performance standard in each Reach for three consecutive years. After achieving "continued attainment" for all three species in all three IReaches, Olin will then maintain and operate the remedy for an additional period of seven years. If Olin demonstrates to the reasonable satisL1ction of the RP that the remedy will continue to provide achievement of the performance standard following termination of the CD, and ifOlil~ Idemonstrates to the RP after the seven-year period that the remedy remains in compliance with the performance standard of S ppm of DDT for all three species in all three Reaches, the CD shall terminate. No cleanup or performance standards were established for other media. I Cleanup activities began in 1986 and were completed in 1987. Fish tissue, surface water, and sediment sampling continues at the Site, \vhile ground water sampling stopped in 1997 because Ino significant impacts to ground \vater were detected. The triggering action for this Five-Year Review (FYR) was the signing of the Site's previous FYR on February 2S. 200S.

ICD Goals and Objectives

Although typical remedial action objectives for this Site were not explicitly set out in the CD, the Iperformance standard established in the CD was to be achieved consistent with the following goals and objectives:

I • Isolate DDT from people and the environment in order to prevent further exposure. • Minimize further transp0l1 of DDT out of the HSB-IC system. • Minimize adverse enviroJUl1ental impact of remedial actions. I • Mitigate effect of DDT on wildlife habitats in the WNWR. • Minimize adverse effects on operations at RSA, Wheeler Reservoir, and WNWR. • No increase in flooding, pm1icularly at City of Huntsville and RSA. except those I

increases in water levels which can be reasonably expected in connection with the implementation of remed ial action, provided Olin takes all reasonable steps to minimize or prevent such increase. I

• Minimize effect on loss of storage capacity for power generation, in accordance with the Tennessee Valley Authority Act ("TVA Act"). I

Technical Assessment

IThe assessment of the Site for this FYR indicates that the selected remedy is functioning as intended by the CD and RP decision documents. The goals and objectives of the CD are being met and the remedy is expected to achieve the performance standard. There have been no Ichanges in exposure assumptions at the Site.

I .. I

v\

I

I I

Protectiveness Statement

I I The Site's remedy remains protective of human health and the environment. Based upon the site

visit and document review, the remedial action is functioning as intended by the CD. All diversion structures and fill areas appear sound. No signs of physical deterioration were noted. Overall, DDT levels in small mouth buffalo continue to decline and DDT concentrations in the surface water continlle to remain less than the established baseline.

I I I I I I I I I I I I I I

VII

I

I I I I I I I I I I I

.. ..* [ OU relers to operable Lilli!.]

*' [Review period should correspond to the actual start and end dates of the FYR in CERCUS.]

REVIEW STATUS Lead agency: ~EPA D State D Tribe D Other Federal Agency Author name: Ryan Burdge and Amanda Coyne (reviewed by EPA) Author title: Associate and Senior Associate ~ Author affiliation: E- Inc.

Review period'*: 05/0 I12009 to 02125/2010 Date(s) of site inspection: 06/2412009 Type of review:

o Post-SARA ~Pre-SARA D NPL-Removal only D Non-NPL Remedial Action Site D NPL StatelTribe-lead D Regional Discretion

Review number: D 1 (first) D:2 (second) D 3 (third) ~ Other (specify) 4 (follrth)

Triggering action: D Actllal RA Onsite Construction ill ou# D Actual RA Start at OU# D COllstnlction Completion ~ Previous Five-Ye<lr Review Report D Other (specify)

,

Triggering action date (frum CERCLlS): 0212512005 Due date (jil'e yean after triggering action date): 02/2512010

I I I I I I I

VIII

I

I I I Five-Year Review Summary Form continued

Issue:

I I. Site documents at the site repository are not up to date.

Recommendation: I. Update the site repository with past FYRs and RP reports.

I Protectiveness Statement: The Site's remedy remains protective of human health and the environment. Based upon the site visit

I and document review, the remedial action is functioning as intended by the CD. All diversion structures

I and fill areas appear sound. No signs of physical deterioration were noted. Overall, DDT levels in smallmouth buffalo continue to decline and DDT concentrations in the sUli-ace water continue to remain less than the established baseline.

I I I I I I I

'I I

IX

I I

Fourth Five-Year Review Report Triana/Tennessee River Superfund Site I

1.0 Introduction I The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy in order to determine if the remedy will continue to be protective of human health and the environment. The methods, findings, and conclusions of FYRs are documented in five-year I review repOits. In addition, FYR reports identify issues found during the review, if any, and document recommendations to address them. I The U.S. Environmental Protection Agency (EPA) prepares FYRs pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121 and the National Contingency Plan (NCP). CERCLA Section 121 states: I

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

EPA interpreted this requirement fuIther in the NCP;40 Code of Federal Regulations (CFR) ISection 300.430(f)( 4 )(ii), which states:

"If a remedial action is selected that results in hazardous substances, pollutants, or Icontaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such actions no less often than every five years after the initiation of the selected remedial action." I

E2 hic., an EPA Region 4 contractor, conducted the FYR and prepared th is report regarding the remedy implemented at the Trianaffennessee River site (the Site) in Triana/Huntsville, IMorgan/Limestone/Madison Counties, Alabama. This FYR was conducted from May 2009 to February 2010. EPA is the lead agency for developing and implementing the remedy for the Potentially Responsible Party (PRP)-financed cleanup at the Site. The Alabama DepaItment of IEnvironmental Management (ADEM), as the support agency representing the State of Alabama., has reviewed all supporting documentation and provided input to EPA during the FYR process.

I This is the fourth FYR for the Site. The triggering action for this policy review is the previous FYR. The ComprehellSive Five-Year Revien' GlIidallce states that as a matter of policy, FYRs will be conducted for sites with Decision Documents prepared before the effect.ive date of SARA I which result in hazardous substances, pollutants, or contaminants remaining at the Site above levels that allow for unlimited use and unrestricted exposure. The Site consists of one Operable Unit. I

I I

I I

2.0 Site Chronology

I The following table lists the dates of important events for the Site.

I Table 1: Chronology of Site Events

Event

I Discovery Proposal to National Priorities List (NPL)

I Remedial investigation Remedial Action CD R P conducts tirst meeting

I Olin submits remedial action (RAJ plan to the RP RP issued first decision document approving Olin's remedial action plan with mod i tications Olin submitted Remedial Action Alternatives Rep0l1 for Lower Reach A (LRA) Olin submitted Interim Goals Repon Olin submitted special repol1s: baseline data for water and fish; substitute tish

I species; long-term data acquisition program revised; and interim goals

I Construction began at Upper Reach A (URA) RP issued Decision Document Number 2: "Baseline data, substitution species and interim goals for fish and water" Construction mobilization began for remedial action LRA RP issued Decision Document Number 3: "Remedial action plan to isolate DDT in Lower Reach A of Huntsville Spring Branch"

I Full construction began lor remedial action in LRA

I RP issued Decision Document Number 4: "Rep0l1 on DDT in Reaches Band C ofHulltsville Spring Branch-Indian Creek system" Major construction activities completed: ceremony held at remedial action site RP issued Decision Document Number 5: "Substitute species for largemouth

I bass" RP issued Decision Document Number 6: "Long-term monitoring program for the remedial action in the Huntsville Spring Branch-Indian Creek system"

I Construction completion and beginning of initial remedy required by Decision Document Number 3 RP issued Decision Document Number 7: "Quality assurance and fish sample

I size" RP approved termination of the "far-tield" ground water monitoring program and modification to the "near-field" ground water monitoring program RP issued Decision Document Number 8: "Ground water monitoring"

I Superfund Site interim Closeout Report issued RP issued Decision Document Number 9: "Process for review of monitoring data and Olin notitication of compliance by the Technical Committee"

I First FY R completed RP issued Decision Document Number 10. Appendix A: "Finding of continued attainment, largemouth bass, Reach C, January 19, 1995" RP approved Decision Document Number 10: "Process for review of 01 in's notifications of continued attainment by the Technical Committee" RP issued Decision Document Number 10, Appendix B: "Finding of continued

I attainment lar~ell1outh bass, Reach A, July 20, 1995"

I RP issued Decision Document Number 10, Appendix C: "Finding of continued attainment largemouth bass, Reach B, July 20, 1995" RP issued Decision Document Number II: "Extension of time for meeting the

2

I

Date July I, 1980

December 30. 1982 March 3 I, 1983

May 31, 1983 June 14, 1983 June I, 1984

August 31, 1984

August I, 1985 August I, 1985 March I, 1986

April I, 1986 October 28, 1986

December I, 1986 December 9, 1986

December 1986 April 16,1987

July 22, 1987 July 22, 1987

December 3, 1987

January I, 1988

June 14, 1990

June 14, 1990

December 6, 1990 December 18, 1991

January 23, 1992

June 12, 1993 January 19, 1995

January 31, 1995

July 20, 1995

July 20, 1995

December 3, 1998

Event Date performance standard for channel catfish and smallmouth buffalo" Court order moditied schedule to meet performance standards April 23, 1999 Second FY R completed June 18, 1999 RP issued Decision Document Number 12: "rvlonitoring program, interim goals and contingency plans tor attaining the performance standard for channel catfish and small mouth buffalo 1998-200r

September 27, 1999

RP issued Decision Document Number 10, Appendix D: "Findings of altainment for channel cattish in Reaches A, Band C and continued attainment for channel catfish, Reach A"

March 2, 2000

RP issued Decision Document Number 10, Appendix E: ''Findings of continued altainillent for channel catfish, Reach C"

March 15, 200 I

RP issued Decision Document Number 13: "Monitoring of stream levels and flows"

April 3. 2002

Third FYR completed February 25, 2005 RP issued Decision Document Number 10, Appendix F: "Findings of continued attainment lor channel catfish, Reach B"

March 17, 2005

RP issued Decision Document Number la, Appendix G: "Findings of continued attainment tor small mouth buffalo, Reach C"

June 18, 2007

3

I I I I I I I I I I I I I I I I I I I

I I

3.0 Background

I 3.1 Physical Characteristics

I The Site is located approximately tive miles southwest of Huntsville, Alabama. The Site consists of an II-mile stretch of two tributaries of the Tennessee River, the Huntsville

I Spring Branch (HSB) and Indian Creek (Figure I). HSB tlows south-southwest and joins Indian Creek, which then empties into the Tennessee River near the town of Triana, Alabama. Both HSB and Indian Creek are entirely within the confines of the Wheeler

I National Wildlife Refuge (WNWR) and the Redstone Arsenal (RSA). The portions of the Huntsville Spring Branch-Indian Creek (HSB-IC) system that were contaminated as a result of dichloro-diphenyl-trichloroethane (DDT) manufacturing at the RSA are divided

I into three reaches. The area of the HSB between HSB mile 5.4 and HSB mile 2.4 is Reach A, between HSB mile 2.4 and HSB mile 0.0 is Reach B, and between Indian Creek mile 5.6 and Indian Creek mile 0.0 is Reach C. Figure 2 shows the main features at the Site. Parcel information is not publicly available for the Site because it is located within

I tbe WNWR and tbe RSA.

3.2 Land and Resource Use

I The Site is located entirely within the WNWR and the RSA. Future land use at the WNWR and RSA is not expected to change from its current use. The WNWR complex

I is open for recreational use and fishing, but the Site is located on \VNWR land entirely within the RSA and public access to tbe Site is therefore restricted.

I The Site is underlain by the regolith aquifer, which is composed of unconsolidated surficial materials transported by ancestral streams. The regolith aquifer is located above the Tuscumbia limestone, which averages 150 feet in thickness and is underlain by Fort

I Payne limestone containing beds of chert. The F0I1 Payne chert is 155 to 185 feet thick and serves as the primary aquifer in the area. discharges to tbe F0I1 Payne aquifer.

I I I I I I

4

Water in the regolith aquifer typically

I

I IFigure 1: Site Location Map

,' ..~ "

TrianaiTennesse river Site

Huntsville

I I I I I I

o 1.5 3 6 __-===:=J_____Miles

I I I I I I I

o Figure 1 Site Vicinity Map

TrianalTennessee River Superfund Site Morgan/Limestone/Madison Counties, Alabama

t··JORTH

I I

Disclaimcr: This Illap and any buundary lines wllhlllth, Illap are approximate and subjcct to chang.:. Thc map is not a survey. The map is lor inlormational purposes only regarding EPA's responsc actions at the Site. and is not intended for any other purpose.

I 5

I

- - - - - - - - - - - - - - - - - - -Figure 2: Detailed Site Map

'( .~. ',"

1

rl II 1. I - .. 1

I 1

I I

I I

I 1 I

I I

I I

I I

I, I

TrianJ

o 0.5

•••IC==:::JI•••••• Miles Sile Boundary

C~=) Redslone Arsenal Boundary

Wheeler Refuge Boundary

RHl$ T.oNE ROAD

leM 1.0 Indian Creek Mile Number

HSBM 1.0 Hunlsville Spring Branch Mile Number

/\

"lEi

~"/~ -;~\ L .... ....~~~'-D.~·.\

o ~WRTH

Figure 2 General Site Map

TrianafTennessee River Superfund Site Morgan/Limestone/Madison Counties, Alabama

Disclaimer' This m,lp anu any houndary lines \\'ilhinlhe lllap arc apprn'ximale and subjecll,' changl'. Thc mar is 11<11 a survc\'. The map is It)r inll'l'lnalional pU'l'oscs onl\' regarding EPA's rcsp,'nsl' aclions:Jl lhc Sile, and IS nOl inlcnucd lor any olhcr purrosc.

6

I I3.3 History of Contamination

Olin operated a DDT manufacturing plant under a lease from the RSAfrom 1947 to I1970. The manufacturing, handling and disposal practices at the plant discharged DDT residues through RSA's drainage system and into the HSB-IC system. Stream sediments were contaminated with an eSlimated417 tons of DDT and its breakdown products Idichloro-d i phenyl-dichloroethy I ene and dichloro-dipheny l-dichloroethane (col1ecti vely referred to as DDT). During the late 1940s there were no data on DDT's environmental impacts via bioconcentration in food webs. No water surveys were conducted for the 16 Iyears following plant startup.

The pollution of the HSB-IC system continued during the 1950s. Increasing frequency of Ifish kills and other pollution-related events led to sampling efforts to establish water quality levels in the HSB-IC. By 1963, the Public Health Service and Tennessee Valley Authority (TV A) were conducting surveys to determine the extent of DDT migration and Iconcentrations of the compound in HSB-IC water and sediments. There was increasing evidence of toxic effects to the biota.

IHSB-IC sampling for DDT was sporadic until late 1967 when the Federal Water Pollution Control Administration (FWPCA) established a sampling station at HSB mile 5.4. Monthly collections were conducted until May 1969 and during the first four months Iof 1970. DDT concentrations in surface water ranged from 0.3 to 60 micrograms per liter (~lg/L).

IFish samples collected from the area were found to exceed the FDA's guidelines for fish sold in interstate commerce. The United States Army Corps of Engineers completed a study in November 1980 to define the extent of contamination and identify a preferred I engineering alternative for long-term control of DDT contamination in the HSB-JC system.

I 3.4 Initial Response

The United States, on behalf of all federal agencies, filed a complaint against Olin on I December 4, 1980, and amended it on February 5, 1982. This complaint alleged an imminent and substantial endangerment to human health and the environment as a result of Olin's alleged discharge of DDT into waters of the United States, \VNWR and the I environment from a former manufacturing plant located at RSA in northern Alabama. The complaint sought appropriate relief under federal statutory law and under common law. The State of Alabama tiled a similar complaint against Olin. In response, Olin tIled I answers and motions to dismiss and denied liability in these actions. The Site was proposed for EPA's National Priorities List (NPL) on December 30, 1982, and finalized on the NPL on September 8, 1983. The issues raised by the parties were resolved by the I settlement agreement reached in the CD tiled by the District Court on May 31, 1983.

I I

7

I

I I

3.5 Basis for Taking Action

I A baseline risk assessment was not conducted at the Site. In September 1970, the Alabama Department of Conservation and Natural Resources reported DDT residues in fish collected in the Wheeler Reservoir and its vicinity to be above the FDA's limit of 5

I ppm of DDT in fish tillets. Species found to exceed this standard were channel cat1ish, smallmouth bass and white bass. Surveys began in 1975 to determine how frequently these p~sticide residues occulTed in fish. By 1977, TV A published results of several

I surveys carried out in the HSB and the Tennessee River. Between miles 320 and 321 on

I the Tennessee River, bass, catfish and other edible fish were found to be heavily contaminated. Catfish were found to contain DDT concentrations as high as 411.6 ppm. TVA conducted sampling events in June and September 1978 and found largemouth bass at Tennessee River mile 352 to have DDT average concentrations of 0.24 ppm and

I smallmouth buffalo in Indian Creek to have DDT concentrations of 212.7 ppm. In a separate analysis conducted by the Army, channel catfish were found to have DDT concentrations as high as 225 ppm in the Tennessee River between miles 321 and 334.

I Sediment sampling and analysis began in 1963, and the highest concentrations were

I found in HSB sediments. In October 1977, sediments in the Tennessee River below Indian Creek were found to contain DDT concentrations up to 0.36 ppm. In 1978, DDT

I concentrations in HSB sediments were found to be above 28,000 ppm. By 1986, it was estimated that 417 tons of DDT had contaminated stream sediments, and that at least 94 percent of the contamination was located between HSB miles 2.4 and 5.57.

4.0 Remedial Actions

In accordance with CERCLA and the NCP, the overriding goals for any remedial action are protection of human health and the environment and com pliance with applicable or relevant and appropriate requirements (ARARs). A number of remedial alternatives were considered for the Site, and the final selection was made in accordance with the Site's 1983 CD and based on the review of a remedial plan that was submitted by the Olin COIvoration to the Review Panel (RP). The RP's evaluation criteria for the remedial plan included:

• The nature of the endangerment to human health and the environment which the remedial

I action was designed to address. • The extent to which implementation of the remedial action would reduce or increase

endangerment to human health or the environment, or would otherwise affect human

I health or the environment. • Whether implementation of such remedies is unnecessary to satisfy or is inconsistent with

the goals. objectives and performance standards set forth in the 1983 CD.

I • Whether the remedy chosen was the most cost-effective means of accomplishing the performance standard.

I The August 3 I, 1984 approval of the remedial plan by the RP represented approval from the USFWS. TVA, EPA, Department of the Army (OoA) and the State of Alabama.

I 8

I

I I4.1 Remedy Selection

To avoid prolonged litigation, Olin entered into a CD with the United States, the State of IAlabama and four sets of private parties on May 31, 1983. The CD established requirements for Olin to develop and implement a remedial plan to address DDT contamination at the Site. A RP was formed as contemplated by the CD. IResponsibilities of the RP include technical overview and approvaL disapproval or modifications to proposals from Olin to ensure that the requirements of the CD are met. The RP was established in June 1983, and includes voting members from EPA, TVA, IUSFWS, DoA, the Alabama Department of Environmental Management (ADEM) and non-voting members from the Town of Triana, Alabama and Olin. To date, the RP has issued 13 Decision Documents to which Olin must adhere. These Decision Documents Imay reflect events such as modifications to the remedy and attainment of the performance standard, but they do not supersede or alter the requirements of the CD.

IThe CD included three phases for the project: construction of the remedial action; long­term monitoring to demonstrate initial attainment and continued attainment of the performance standard; and operations and maintenance of the remedy for an additional I seven years of continued compliance. The remedial plan developed by Olin had to meet a performance standard of 5 ppm of DDT in fillets of channel catfish (fctolurus punC/allls), largemouth bass (Microptems sa/moides), and small mouth buffalo fish I (lctiobus buba/lIs) (Table 2). The performance standard was to be met for at least one year ("initial attailUl1ent") within 10 years after completion of construction and implementation of the remedial action. The CD defines initial attainment as an average I concentration of DDT of 5 ppm or less in the tish tillets for one year for each performance standard species and each Reach. Once attainment was achieved Olin must demonstrate "continued attainment" (i.e., meet the performance standard for three I consecutive years). After continued attailU11ent is achieved for all species and in all reaches, Olin must maintain and operate the remedy for a period of seven years. If attainment is again demonstrated following the seventh year and the remedial action is I deemed to be effective by the RP, the CD terminates. No other performance standards were specified for any other species or media such as sediments, surface water, or ground water. I Table 2. Action Levels for DDT in Fish Fillets

Fish Species 1983 CD Performan~e Standard (ppm)

Channel catfish 5 Largemouth bass 5 Smallmouth buffalo 5

I I I I I

9

I

I I Remedial action objectives (RAOs) for the Site were not explicitly set out in the CD.

Nevertheless, the performance standard established in the CD was to be achieved

I consistent with the following goals nnd objectives:

• Isolate DDT from people and the environment in order to prevent further

I exposure. • Minimize further transport of DDT out of the HSB-IC system.

I • Minimize adverse environmental impact of remedial actions. • Mitigate effect of DDT on \vildlife habitats in the \VNWR.

I • Minimize adverse effects on operations at the RSA, Wheeler Reservoir, and

WNWR.

I • No increase in flooding. particularly at City of Huntsville and RSA, except those

increases in water levels which can be reasonably expected in connection with the implementation of remedial action. provided Olin takes all reasonable steps to minimize or prevent such increase.

I • Minimize effect on loss of storage capacity for po\ver generation, in accordance

with the Tennessee Valley Authority Act ("TV A Act").

In I 984, Olin submitted a proposal for remedial action at the Site to the RP. which

I inc: luded results from monitoring studies of fish, \-\'aler and sediments; a conceptual

I remedial action plan; a schedule for implementation; a conceptual monitoring plan; and other information required by the CD. Fish collections were conducted over a three-year period to determine DDT concentrations in tish and to determine fish species present in each reach of HSB-IC'. Water snmples during normal flow and storm flow events were

I collected over a period of three years to characterize sediments and DDT transport. Extensive sediment sampling \vas conducted to define the quantity and distribution of DDT in each reach of the !-ISB-IC system. Olin also conducted ground water studies as set forth in the proposal. Data from these studies were used to determine baseline DDT

I concentrations in tish, water and sediments of the HSB-IC system.

The RP issued a decision document on August 31, 1984 that accepted Olin's proposed

I remedial action \vith modifications. The major components of the remedial action plan as required by the CD included:

I • Diversion of stream flo\v around contaminated portions of the tributaries; • Excavation of new channels;

I • Excavation of con tam inated portions of sediments; • Burial of portions of contaminated sediments in place; and

I • A monitoring plan to monitor concentrations of c011ta111 inated portions of the

HSB-IC tributaries.

I I

In the October 28, 1986 Decision Document Number 2, the RP established interim cleanup goals for DDT concentrations in fish and surface water to track the progress towards achieving the performance standard of 5 ppm of DDT in fish fillets. Decision Document Number 6 subsequently used the baseline values and interim goals described in Decision Document Number 2 to establish a long-tenn monitoring program. These

10

I

I Idocuments did not modity the CD in any way or change the performance standard of 5

ppm of DDT in fish fillets of selected species. The interim goals and monitoring requirements for tish, surface water and ground water were intended to improve the RP's ability to assess compliance with the performance standard. No performance standards I were required for surface water or ground \vater.

I4.- Remedy Implementation"

Remedial activities began on April 1, 1986 following the design of detailed engineering Iplans and acquisition of permits. Reach A remediation was addressed as two sections: Upper Reach A (URA), which included the area between HSB miles 5.4 and 4.0, and Lower Reach A (LRA), which included the area between HSB miles 4.0 and 2.4. IRemedial activities were initiated by Olin in April 1986 for the URA and included the isolation of 308 out of 317.9 tons of DDT-contaminated sediments. A new wastewater diversion ditch, a northern diversion ditch, access roads and stream crossings, and north Iand south staging areas were also constructed as palt of the remedial activities. In July 1986, the excavation of the L640-foot salient cut and the 3,250-foot oxbow cut; construction of three diversion structures and diversion levee; the blocking off, Ide\vatering and filling of the HSB channel between HSB miles 5.5 and 4.0; and construction of an embayment at HSB mile 4.2 to isolate DDT were completed in the URA. Additionally, the dewatered channel was covered with geotextile fabric, and nine Iinches of crushed rock, sOil, and topsoil to help with revegetation.

On December 9, ] 986. the RP issued the remedial action plan to address contamination in Ithe LRA, which included bypassing and burying DDT-contaminated sediments. The remedial action consisted of constructing four diversion structures; excavating a new channel between HSB mileposts 3.4 and 2.4; filling three areas; constructing a diversion Iditch around the fill areas; and excavating pOltions of the sediments from the channel. The construction area was entirely within the safety fan of one of the missile test ranges at the RSA and within the normal fluctuation zone of Wheeler Reservoir. Therefore, Iconstruction 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 night under lights. I Remedial activities were completed in Reach A by October 14, 1987. The remedial activities at Reach A effectively isolated in-place 93 percent of the DDT contamination I that was present in the HSB-IC system. The RP designated January 1, 1988 as the date of construction completion.

I The long~term monitoring plan for the remedial action was submitted to the RP by Olin in August 1987. The plan provided details about the type, frequency, and location of specitic parameters to be monitored and quality assurance and reporting requirements to I be followed. The long-term monitoring plan included monitoring fish, surface water and ground water in Reach A, Reach B. and Reach C. Monitoring activities began in 1988 and were required tl1r a I O-year period. In 1990, ground water monitoring in the area I designated as the "far field" was no longer required, and the frequency of ground water

1 1 I I

I I I I I I I I I I I I I I I I I I

monitoring in the area designated as the "near iield" was reduced. Ground water has not been sampled since 1997 because no significant impacts to ground water were identified. Surface water and fish sampling continue to be conducted at the Site to track progress towards meeting the performance standard of 5 ppm of DDT in fish tillets.

By 1998, 10 years after the completion of the cleanup action, only the largemouth bass had attained the performance standard as set forth in the CD. However, by leave of the Court, in December 1998 Olin was allowed a five- and I O-year extension to attain the performance standard for channel catfish and smallmouth buffalo, respectively. In 2003, channel catfish met the continued attainment requirement in all identified stream pOI1ions. Smallmouth buffalo attained the performance standard in Reach C in 2006.

During a R.P conference call in December 2003, the RP determined that sediment studies would be valuable in monitoring the effectiveness of the remedial action. A review of sediment levels was completed in 2004 and sediment sampling for DDT was completed in 2005. The sediment sampling results indicated that no additional sediment remediation was required.

4.3 Operation and Maintenance (O&M)

Regular O&M at the Site includes sampling fish fillets and surface water for DDT concentrations. No estimate of annual O&M costs was included in the remedial action plan. The current long-term monitoring program approved by the RP requires annual sampling of fish and biennial sampling of surface water at the Site until performance standards are attained in all fish species. An annual rep0I1 of monitoring effoJ1S has been submitted by Olin and presented at the RP annual meeting during each of the past five years. O&M costs for calendar years 2004 through 2008 are presented in Table 3. The average O&M cost in the past five years was approximately $142,000.

Table 3. Annual O&M Costs

Year Total Cost (rounded to the nearest $1,000)

2005 S 122,000 2006 $156,000 2007 $151,000 2008 S 137,000 2009 $142,000

12

I

--------------~~~~~~~~~~~-------

5.0 Progress Since the Last Five-Year Review

The protectiveness statement ftom the 2005 FYR for the Site stated the following:

The remedy at the Triana site remains protective of human health and the environment. Based upon the site visit and review of Annual RepOJ1 No. 16, the remedial action is accomplishing its goal of preventing contact between the ecosystem and DDT. All diversion structures and fi /I areas appear sOLlnd. No signs of physical deterioration were noted. Overall, DDT levels in smallmouth buffalo tish continue to decline and a review of analytical results shows that DDT concentrations continue to remain less than the established baseline in the surface water.

The 2005 FYR included two issues and recommendations. Each recommendation and the current status are discLlssed below.

Table 4: Progress on Recommendations from the 2005 FYR

Section Recommendations Party

Responsible Milestone

Date Action Taken and

Outcome Date of Action

5.1

RP to reach consensus on whether three-inch diameter and larger trees along fill areas, diversion structures ;:lIld the former channel should be removed.

PRP/USFWS 3/30/05

On June 27, 2007 Olin formally requested an exemption from the special use permit that requires Olin to prevent and remove all trees from the remedy that exceed three inches in diameter. USFWS has agreed verbally to this request.

Pending

5.2

Determine if wells will be utilized in the future. Ifso, they will likely require redevelopment and must be maintained.

PRP 3/30/05

The ground water monitoring wells have not been redeveloped or maintained.

Not applicable

5.1 Removal of trees from remedy

On June 27, 2007 Olin formally requested an exemption from the special use permit that requires Olin to prevent and remove all trees from the remedy that exceed three inches in diameter. USFWS has agreed verbally to this request but has not yet officially modified the special use permit.

5.2 Cround water monitoring wells

The RP has not required ground water monitoring in the past five years. The ground water monitoring wells have not been redeveloped or maintained.

13

I I I I I I I I I I I I I I I I I I I

I I 6.0 Five-Yea r Review Process

I 6.1 Administrative Components

EPA Region 4 initiated the FYR in May 2009 and scheduled its completion for February

I 2010. The EPA Triana/Tennessee River site review" team was led by Brian Farrier of

I EPA, Remedial Project Manager (RPM) for the Site, and also included input from the RP's Chairperson, Andrew Hey of EPA Region 4, the RP's legal counsel, EPA Region 4 attorney-advisor Gregory Luetscher, Community Involvement Coordinator L'Tonya Spencer, and contractor support provided to EPA by P Inc. A review schedule was

I established that consisted of the following activities:

• Community notification.

I • Document review. • Data collection and review. • Site inspection.

I • Local interviews. • FYR Report development and review.

I 6.2 Community Involvement

A public notice was published in the HUI7!sFille Times ne'vvspaper on July 30, 2009

I announcing the commencement of the FYR process for the Site. The announcement provided EPA RPM Brian F alTier's contact information and invited community participation. No citizen comments or concerns regarding cleanup activities at the Site

I have been received from the public to date. The press notice is available in Appendix B. The FYR report \:"ill be made available to the public once it has been finalized. Copies of this document will be placed in the designated public site repository: Triana Public

I Library at 280 Zierdt Rd., Madison, Alabama 35758. On June 24, 2009, as part of the site inspection, P Inc. staff visited the Triana Public Library. Previous FYRs for the Site and recent site documents were not available at the site repository. Upon completion of

I the FYR, a public notice will be placed in the Huntsville Times newspaper to announce the availability of the final FYR repol1 in the site repository.

I 6.3 Document Review

This FYR included a review of relevant, site-related documents including the CD,

I remedial action reports, and recent monitoring data. A complete list of the documents reviewed can be found in Appendix A.

I ARARs Review

I Section J21 (d)(2)(A) of CERCLA specifies that Superfund Remedial Actions (RAs) must meet any federal standards, requirements, criteria or limitations that are determined

I to be legally ARARs. ARARs are those standards, criteria or limitations promulgated under federal or state law that specifically address a hazardous substance, pollutant,

14

I

I

----------------------------,

contaminant, RA, location, or other circumstance at a CERCLA site. To-Be-Consiclered I criteria (TBCs) are nonpromulgated advisories and guidance that are not legally binding, but should be considered in determining the necessary level of cleanup for protection of human health or the environment. While TBCs do not have the status of ARARs, EPA's I approach to determining if a RA is protective ofhLiman health and the environment involves consideration o1'TBCs along with ARARs. Chemical-specific ARARs are specific numerical quantity restrictions on individually listed contaminants in specific I media. Examples of chemical-specific ARARs include the Maximum Contaminant Levels specified under the Safe Drinking Water Act as well as the ambient water quality criteria that are enumerated under the Clean Water Act. Because there are usually I numerous contaminants of potential concern for any Site, various numerical quantity requirements can be ARARs. I The final remedy selected for this Site was designed to meet or exceed all chemical­specific ARARs and meet location- and action-specific ARARs. The chemical-specific ARARs are the DDT concentrations in channel catfish, largemouth bass, and smallmouth I buffalo fish fillets that were identified in the selected remedy for the Site (Table 5). The current DDT performance standard is in accordance with the recommended Action Levels for Unavoidable Pesticides in Food and Feed Commodities set by the FDA's I Compliance and Policy Guides (CPGs). This review did not identify any changes to the assumptions applied at the time of the 1983 CD: therefore, the ARAR has not changed, as indicated in the table below. I Table 5: Summary of Action Levels for DDT in Fish Fillets I

Fish Species

Channel catfish

Largemouth bass

Smallmouth buffalo

1983 CD Performance Standard (ppm)

Current FDA Action Levels' (ppm)

ARARs Changed?

I 5

5

5

5

5

5

No

No

No

I I

a) FDA·s CPG Sec. 575.100 Pesticide Residues in Food and Feed - Enforcement Criteria (CPG 7141.0 I) at hltp:!/w,,"w. fda. ~ov/ICECI!Compl iance M anua Is/ColllQ I iance Pol icvG u idancc Manual!ucill 123 ') 36.hlll1 I , lasl accessed on October 15,2009. The FDA Action Level is based on the total alllounts of DDT, TDE ancl DDE, individually or in combination, found within the food source. Calculation of total DDT, TDE and DDE pesticide residues exclude values for any of the three found below 0.2 pplll for Itish. The performance standard provided in CPG 7141.0 I is established for tish in general, and does not provide specific standards for a particular fish species.

I I

15 I I

I I 604 Data Review

I Fish Fillets Fillets from channel catf-ish achieved continued attainment of the performance standard in Reach A in 2000, Reach B in 2005, and Reach C in 2001. Largemouth bass fillets

I achieved continued attainment of the performance standard in Reaches A, B, and C in 1995. According to the CD and as specitied in decision documents, sampling offish is no longer required once continued attainment has been achieved. As a result, DDT

I concentration data were not collected for these two species over the last five years. Average annual DDT concentrations in smallmouth buffalo tillets between pre-1988 and 2008 are presented in Table 6. Data collected in 2009 have not yet undergone EPA

I quality assurance and quality control and therefore were not available in time to be included in this FYR.

I Table 6: DDT Concentrations in Smallmouth Buffalo Fish Fillets

I I I I I I I I I I I

Year Avg

Reach A

Min Max Avg

Reach B

I'vlin Max

. Reach C

Avg Min Max

Baseline 140 1.8 600 180 2.4 620 110 1.4 470 Year I,

1988 -­ -­ -­ 82 3 250 89 7 360

Year 2, 1989

31 9.3 70 55 2.6 240 50 0.2U 140

Year3, 1990

24 -­ -­ 41 0.56 120 41 0.39 140

Year 4, 1C)91 89 ' ..,J.-'. 170 37 5.7 130 45 I 190

Year5. 1992 42 0.36 290 41 0.45 300 34 0.37 170

Year 6, 1993

19 0.34 90 35 0.05 190 34 0.46 250

Year 7, 1994 3.7 2.9 5.1 38 0.7 150 13 0.5U 51

Year 8, 1995

84 7.6 230 48 4 ' .J 210 17 0.7 79

Year 9, 1996 8.1 1.1 14 29 0.06 100 ,

J 0.8 4

Year 10, 1997

12 0.66 40 21 2.1 120 9.4 0.3 /"'_J

Year II, 1998

14 1.4 52 17 0.95 84 5.4 0.87 21

Year 12, 1999

14 0.57 38 7.2 0.5U 18 9.3 0.5U 29

Year 13, 2000

II 0.12 35 12 ") ,_.J 57 6.5 0.25 31

Year 14, 2001 20 0.64 83 13 0.06 53 6.2 0.42 40

Year 15, 2002

18 6 44 39 4.6 110 7.5 0.83 21

Year 16, 2003

7.9 I 45 II 0.6 49 7.7 0.05U 55

16

I

I

Reach.,A ReachB " "

, .ReachC:. .. ~.: .. ~. <':":." ··0 " Year ).".

Avg f'vlin Max .A vg Min Max Avg Min Max

Year 17, 12 0.5 63 15 0.83 54 4.4 0.51 15

2004 Year 18,

7.5 0.02U 20 7.5 0.62 44 3.8 0.02U 202005

Year 19, ")~ 0.02U 58 8.8 0.79 24 3.5 0.02U 1I

2006 -,)

Year 20, 6.3 O.OlU ")~ 3.4 0.02U 17

2007 Co,) -­ -­ --

Year 21, 10 0.25U 98.40 2.9 0.25U 14.06

2008 -­ -­ --

Notes:

avg = average DDT concentration (ppm) of samples analyzed

min = minimum DDT concentration (ppm) analyzed

max = maximum DDT concentration (ppm) analyzed

U = material was analyzed but not detected. The number is the minimum quantitation limit.

I I I I I I I

The overall trend is toward dccreasing DDT concentrations over time. In 2006, small mouth buffalo in Reach C achieved continued attainment of the performance standard. Smallmouth buffalo in Reach B achieved initial attainmcnt of the performance I standard in 2007 and maintained the performance standard again in 2008. Although the 2009 data had not been through quality assurance and control at the time of this FYR, preliminary results indicate that smallmouth buffalo in Reach B maintained the I performance standard in 2009 and would thus have achieved continued attainment. Smallmouth buffalo in Reach A attained the initial performance standard in 1994, but DDT concentrations in smallmouth buffalo in Reach A have been above the performance I standard for each of the past five years. However, prelim inary results from 2009 sam pIes indicate that the average DDT concentration in smallmouth buffalo in Reach A was below the 5 ppm performance standard. I SlIIj('/ce vVater IDDT concentrations in all surface water samples collected in 2004 through 2008 were below tbe 0.094 pg/L detection limit and therefore were below the baseline concentrations at each sampling mile. The CD did not establish performance standards Ifor surface water.

Ground lFaler IGround water has not been sampled since 1997 because DDT concentrations were found to be consistently below action levels. The CD did not establish performance standards for ground water. I Sec/ill/enls In 2004 an eff0l1 was made to reassess the DDT concentrations in the sediments within IReach B. Based on review of those data, the RP determined that no additional

I 17

I

I I remediation of sediments was necessary. The CD did not establish performance

standards for sediments.

I 6.5 Site Inspection

I On June 24, 2009, the FYR site inspection was attended by the follO\:ving participants:

I • Mr. Andrew Hey of EPA Region 4 • Mr. Gregory Luetscher of EPA Region 4

I • Mr. Gerald Hardy of ADEM • Mr. Jason Wilson of ADEM • Mr. Peter Tuttle of USFWS

I • Mr. Bill Starkel of USFWS • Mr. Jason Yarbrough of TVA • Mr. Danny Dunn of RSA

I • Mr. Keith Robel1s of Olin • Dr. Amanda Goyne of E2 Inc. • Mr. Ryan Burdge of £2 Inc.

I The purpose of the site inspection \vas to inspect the general condition of the Site and take photographs to document current site conditions. During the site inspection,

I participants observed the work that has been completed in accordance with the CD, including the tilled channel, diversion structures, and embayment area. None of the ground water monitoring wells were located or inspected due to heavy vegetation cover.

I The entrance to the Site from within the RSA is through a locked gate and includes a sign warning of DOT contamination. The Site was well-maintained and vegetation has been

I established on the filled channels. No maintenance of the basic structures has been required during the 20 years of monitoring. From 1999 through :2008, the RP Inspection Committee has made annual site inspections to assess the integrity of the Site's remedy.

I In a July 31,2008 letter summarizing the inspections during this period, Mr. William Gerald Hardy, Chairman of the Inspection Committee, stated that "natural succession has and is occurring without threatening the stability of the remedy" and that there is "no

I cause for concern relative to the integrity of the remedy."

I The Alabama OepaJ1ment of Health currently has a tish consumption advisory in place due to the DDT contamination from the Site. Access to refuge lands within the RSA's

I borders is restricted, but no advisory signs were noted during the site visit. At the time of this FYR, the RP was evaluating the need for additional fish consumption advisory signage along the HSB-IC system.

I Table 7 lists the institutional controls (lCs) associated with areas of interest at the Site. Although it is not an official IC, the RSA and the \VNWR essentially function as an IC because they prevent public access and land use change at the Site.

I 18

I

Table 7: Ie Summary Table

Area of Intt'rest - Huntsville S 1ring Branch-Indian Creel, System

Media ICs

Needt'd

ICs Called for in the Decision

Docu II1cnts

Impacted Parcel(s)

IC Objective

Instrument in Place

Notes

Fish Yes No NA

Offer guidance to individuals who wish to eat fish caught in HS8-IC system.

Alabama Department of Health "Do Not Consume" advisory for smallmouth buffalo from HS8-IC system due to DDT contamination. I

I A "No Consumption Advisory" issued for any species is interpreted to mean that the fish sampled have been analyzed to show the presence of a contaminant in excess of advisory levels. Consumption of any fish of this type from a specific water body may place the consumer at risk for harm from the contaminant. Consumption advisory can be found at: i1tlp://w'I\'w.adph.orgitoxh1ssets/2n09FishAdvisorv.pdf.

6.6 Interviews

During the FYR process. interviews were conducted with parties impacted by the Site. including the current landowners and regulatory agencies involved in site activities or aware of the Site. The purpose orthe interviews was to document the perceived status of the Site and any perceived problems or successes with the phases of the remedy that have been implemented to date. Interview participants submitted completed interview forms for inclusion in this FYR. Interviews are summarized below and complete interviews are included in Appendix C.

Gerald Hardv: Mr. Hardy of ADEM has found the project to have a good overall cooperative relationship between the members of the RP. He believes that the remedy is performing as required by the CD, and that DDT is being isolated in the HSB-IC system away from people and the environment. Mr. Hardy has been the Chair of the Inspection Committee for the past five years and regularly prepares a report about Inspection Committee activities. Mr. Hardy is not aware of any complaints or inquiries about the remedial actions at the Site, and there have been no specitic problems at the Site. The Inspection Committee has noted that there is potential for damage to the remedial action by roots from trees that have been blown over by high winds. There may also be potential uptake of DDT by deep-rooted vegetation and subsequent deposition on the surface tlu-ough leaves and/or bark, which may have potential effects on the HS8-IC food chain.

Susan Tidwell: Ms. Tidwell of TVA has found the project to be well-managed and that it has been progressing towards meeting the goals set in the CD, although slower than initially expected. Ms. Tidwell is unaware of any complaints about the Site, and is not aware of any changes to federal or state laws that could affect the protectiveness of the

19

I I I I I I I I I I I I I I I I I I I

I I remedy. TVA also plans to collect samples again during fall 2009. Ms. Tidwell believes

that all of the agencies involved at the Site cooperate well with each other and has no

I comments or suggestions about the site's management.

Andrew Hev: Mr. Hey, the RP Chair Person from EPA Region 4, believes the

I remediation called for by the CD continues to work well, and that environmental conditions continue to improve. He is not aware of any complaints or inquires about the Site, and is not aware of any anticipated changes that could affect the protectiveness of

I the remedy. According to Mr. Hey, the RP has been exemplary at cooperating with each other over the past 19 years they have been meeting. Although there has been some recent concern over the cleanup levels that were agreed upon in the CD, the agencies

I within the RP continue to work together to resolve matters concerning the Site.

Peter Tuttle: Mr. Tuttle ofUSFWS has found the remedy to be a good initial step in

I mitigating the risk of DDT and its degradation products in the HSB-IC system. He is concerned that residual DDT contamination in the HS8-IC system continues to represent a threat to fish. wildlife. and habitat ~uality. Because USFv,is is one of the agencies that

I I will assume m~nageme;1t responsibiliti'es ~Ipon completion of the remedy. US~FWS has

concerns about future impacts due to the )~idual contamination on the Comprehensive Conservation Plan for WNWR. Mr. Tuttle irl-so voiced USFWS' s concern that DDT is not readily degrading or being effectively contained based on recent sediment sampling

I indicating the continued presence of DDT. He \vas also concerned that current contaminant concentrations in the system are not protective. USFWS conducted an investigation to evaluate the tlu'eat of residual DDT in the system in 2004. Findings from

I the investigation raised USFWS's concerns about the slowing rate of DDT decline, and USFW believes that a more comprehensive characterization ofresidual DDT is needed to fully evaluate the ecological risks and assess implications to the management of the

I WNWR. USFWS also SUPP011S taking additional measures, sllch as spot removal of highly contaminated soil and sediments to reduce the threat of DDT in the system. The

I RP has continued to work with each other at the Site. Mr. Tuttle feels that USFWS has not received much assistance from Olin when acquiring historical data in an electronic format. MI< Tuttle suggests that remedial planning should be reinitiated if residual contamination is found to present unacceptable risks.

I I I I I

20

I

I I7.0 Technical Assessment

7.1 Question A: Is the remedy functioning as intended by the decision documents? I The review of the site documents, monitoring data, interviews \vith the RP and the site inspection indicate that the remedy is functioning as intended by the CD and RP decision Idocuments. No damage to the remedy was noted during the site inspection.

The selected remedial activities are etfectively reducing the DDT concentrations in fish Ifillets in accordance with the performance standard. The performance standard of 5 ppm of DDT in fish tlilets has been attained for all three .fIsh species and continued attainment has been achieved for channel catfIsh and largemouth bass in all reaches and for Ismallmouth bun~110 in Reach C. According to the CD, monitoring must continue until all tlsh achieve continued attainment within all reaches. Average concentrations of DDT in smallmouth bUft~110 in Reach B have been below 5 ppm for two consecutive years (2007 Iand 2008) and preliminary 2009 data indicate that average concentrations were again below 5 ppm and that continued attainment 'vvas achieved. If the RP determine that EPA quality assurance and quality control reviews confIrm the preliminary 2009 data, then it Iwill issue a decision document stating that continued attainment has been achieved for smallmouth buffalo in Reach B. Preliminary data also indicate that smallmouth but1alo in Reach A achieved attainment in 2009. I Although ICs were not called for in the remedy and are not present to prevent disturbance of buried sediments on site, access to the Site is highly restricted given its physical I location \vithin the perimeter of the RSA. The Alabama Department of Health cunently has a fIsh consumption advisory in place due to the DDT contamination from the Site, although the state is not required to post fish consumption advisorysignage and no tlsh I consumption advisory signs were observed during the site inspection. The RP is in the process of evaluating the need for additional signs along the HS8-IC system. I Ground water has not been sanipled since 1997, as DDT concentrations were fClLll1d to be consistently been below action levels. As noted in the remedial action plan, the potential for sllbsllrt~1Ce migration of DDT either laterally or vertically is extremely low because of I the low permeability of soils in the contaminated areas, the low solubility of DDT in water, the strong tendency of DDT to adsorb to clay soils, and the limited mobility of particulates in ground water. Even if traces of DDT were to migrate into the regolith I aquifer, further migration downward to and through the underlying limestone bedrock aquifer is not expected because this area is a ground water discharge area rather than a recharge area. I Based on the site inspection and annual repOl1s, O&M activities are being conducted in accordance with the CD. Opportunities for optimization were not identitled in this FYR. I

I I

21

I

I I 'I

7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of remedy selection still valid?

There have been no changes in standards at the Site. The CD established a performance standard of 5 ppm of DDT in the fillets of channel catfish, largemouth bass, and

I smallmouth bumtJo in Reaches A, B, and C and the RP has not altered this standard. No changes in exposure pathways were identified in this FYR. Neither a human bealth nor an ecological risk assessment was performed at the Site. The CD did not establish

I performance standards for other media and did not specify RA.Os for the Site.

The Site's remedy is performing as expected and is expected to ultimately achieve the

I performance standard. Given events to date, the CD may terminate no earlier than 2018,

'I and then only if smallmouth buffalo in Reaches A and B achieve continued attainment in 2011, followed by a seven-year period after which each species is demonstrated to have achieved the performance standard.

I 7.3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy?

I No other information has been identified during this FYR that calls into question the protectiveness of the remedy.

7.4 Technical Assessment Summary

The assessment of the Site for this FYR indicates that the selected remedy is functioning as intended by the CD and RP decision documents. The goals and objectives oftbe CD are being met and the remedy is expected to achieve the performance standard. There have been no changes in exposure assumptions at the Site. The remedy is protective of human health and the environment because the contaminants are contained and no exposure pathways were identified in this FYR.

I

I I I

22

I

I I8.0 Issues

TabJe 8 summarizes the current issues for the Site. I Table 8: Current Site Issues

I I

Issue Affects Current Protectiveness

(YesorNo)

Affects Future Protectiveness

(Yes or No) Site documents at the site repository arc not up to date.

No No

I I I I I I I I I I I I I

23

I

I I 9.0 Recommendations and Follow-up Actions

I Table 9 provides recommendations to address the current issues at the Site.

I Table 9: Recommendations to Address Current Site Issues

I I

Issue Recom rnendations/ Follow-Up Actions

Party Responsible

Oversight Agency

Milestone Date

Affects Protectiveness?

(Yes or No) Current Future

Site documents at the site repository are not lip to date.

Update the site repository with past FYRs and RP repol1S.

EPA EPA 06/30/2010 No No

I In addition, there are no fish consumption advisory signs posted at public boat ramps and other access points near the Site. The RP should evaluate the need for additional fish consumption advisory signage and post additional signs as needed. The RP should also consider conducting

I outreach to residents of newly developed neighborhoods in Triana to inform them of the tish consumption advisory.

I I I I I I I I I I

24

I

'1 I10.0 Protectiveness Statement

The Site's remedy remains protective of human health and the environment. Based upon the site Ivisit and document review, the remedial action is functioning as intended by the CD. All diversion structures and fill areas appear sound. No signs ofpbysical deterioration were noted. Overall, DDT levels in small mouth buffalo continue to decline and DDT concentrations in the Isurface water continue to remain less than the established baseline.

I I I I I I I I I I I I I

25 I I

I I

11.0 Next Review

I I Superfund's five-year review requirement applies to remedial actions selected under CERCLA

§121. Generally, five-year reviews are required by CERCLA, as amended by the Superfund· Amendments and Reauthorization Act (SARA) of 1986, whenever a remedial action results in

I contaminants remaining on site above levels that allow for an unlimited land use and unrestricted exposure. Since the 1983 Consent Decree for this site pre-dates SARA, five-year reviews performed for the Triana/Tennessee River Site are considered policy reviews. The next five-year review for this site will be due within five years of the signature/approval date of this five-year review.

I I I I

:1 I I !I

I I I I

26

I

I I

Appendix A: List of Documents Reviewed

IReport on the Remedial Action to Isolate DDT from People and the Environment in the Huntsville Spring Branch-Indian Creek System, Wheeler Reservoir, Alabama, Review Panel Activities (United States v. Olin Corporation Consent Decree), May 31. 1983 - June 30, 1986. I1986. Atlanta. U.S. Environmental Protection Agency, Region IV.

Second Rep0l1 on the Remedial Action to Isolate DDT from People and the Environment in the IHuntsville Spring Branch-Indian Creek System, Wheeler Reservoir, Alabama, Review Panel Activities (United States v. Olin Corporation Consent Decree), July I 1986 - June 30, 1990. 1990. U.S. Environmental Protection Agency, Region IV. Atlanta. I Third Report on the Remedial Action to·Isolate DDT from People and the Environment in the Huntsville Spring Branch-Indian Creek System, Wheeler Reservoir. Alabama, Review Panel IActivities (United States v. Olin Corporation Consent Decree), July 1 1986 - June 30,1990. Vols. 1-2.2000. Atlanta. U.S. Environmental Protection Agency, Region IV.

I Army Corps of Engineers. Five-Year Review TrianalTennessee River Site. 2004.

Weston, Roy F. Five-Year Review TrianaiTelmessee River Site. 1999. Norcross, Georgia. I Weston, Roy F. Five-Year Review TrianalTennessee River Site. 1993. Norcross, Georgia. I 2 pt Annual Huntsville Spring Branch- Indian Creek Long Term Monitoring Rep0l1 for the Huntsville DDT Project. Olin Corporation. June 19,2009. I 20th Amlllal Huntsville Spring Branch-Indian Creek Long Term Monitoring Report for the Huntsville DDT Project. Olin Corporation. June 3, 2008. I Consent Decree: United States of America, Plaintiff, v. Olin Corporation, A Virginia Corporation, Defendant, Town of Triana, Intervenor, Sate of Alabama ex reI Charles A. Graddick, Attomey GeneraL et al., Plantiffs, v. Olin Mathieson Chemical Corporation, a Virginia I Corporation, Defendant. 1983.

I I I I I

A-I

I

I I

Appendix B: Press Notice Published in Huntsville Times on July 30, 2009

I -0~\\t.O Si47"~<S'

I · ft · ~ ~"%".",,, ~ - Li.J

I ~. .;p ~ ''c•• " ~

<.<'1;)': ,<",,0 -41.. PRO\t.C

I I U. S. Environmental Protection Agency Region 4

Announces a Five- \'ear Review for the Triana/Tennessee River Superfund Site,

Triana, Morgan/Limestone/Madison Counties, Alabama

Purpose/Objective: The U.S. Environmental Protection Agency (EPA) is conducting a Five­

I Year Review of the remedy for the Triana/Tennessee River site (Site) in Triana, Alabama. The purpose of the Five-Year Review is to ensure that the selected cleanup actions effectively protect human health and the environment.

I I Site Background: The Triana/Tennessee River site is located approximately five miles

southwest of Huntsville, Alabama. The Site consists of an II-mile stretch of two tributaries, the Huntsville Spring Branch and Indian Creek, which empty into the Tennessee River near the town of Triana, Alabama. From 1947 to 1970, the Olin Corporation (Olin) operated a dichlorodiphenyltrichloroethane (DDT) manufacturing plant within Redstone Arsenal and

I discharged wastewater into Huntsville Spring Branch. Fish in the vicinity became contaminated with DDT from contaminated stream sediments. On September 8, 1983, the Site was added to the Superfund National Priorities List (NPL) of hazardous sites.

I I Clean-up Actions: To resolve the contamination problem, the State of Alabama, EPA, and Olin

entered into a Consent Decree (CD) on May 31, 1983. The CD required Olin to implement a remedial plan to meet a performance standard of five parts per million of DDT in tillets of channel cattish, largemouth bass, and smallmouth buffalo fish within ten years from the date of construction completion. The CD also provided for a Review Panel responsible for technical

I overview of 0 Ii n's proposals to meet the performance standard.

Remedial actions consisted of diverting stream flow around the contaminated portions of the

I tributaries, excavating new channels, excavating p0l1ions of the contaminated sediments, and burying pOl1ions of the contaminated sediments in place. These remedial actions began on April I, 1986 and were completed on January I, 1988. An extension of the tish monitoring has been

I granted to ensure achievement of the DDT performance standard in tish fillets as specified in the CD. Continued attainment of the performance standard has been achieved in both largemouth bass and channel cattish, which will no longer be monitored, while progress continues towards

I meeting the performance standard in small mouth buffalo.

I B-1

I

I IFive-Year Review Schedule: The National Contingency Plan requires that remedial actions that

resul tin any hazardous su bst;:ll1ces, poll utants, or contam i nants remaini ng at the Si te above leve Is that allow for unlimited usc and unrestricted exposure be revieyved every five years to ensure protection of human health and the environment. Five-Year Reviews were completed for the I Site in 1993, 1999, and 2005. Each previous Five-Year Review found the Site to be protective of human health and the environment. The fourth of these Five-Year Reviews for this Site will be Icompleted by February 25,2010.

EPA invites community participation in the Five-Year Review process. I EPA is conducting this Five-Year Review to evaluate the effectiveness of the remedy and to ensure that the remedy remains protective of human health and the environment. As part of the IFive-Year Review process, EPA is available to answer questions about the Site. Community members who have questions about the Site, the Five-Year Review process, or who \vould like to participate in a community interview, are asked to contact the following: I

Brian Farrier, Remedial Project Manager U.S. EPA - Region 4 I61 Forsyth Street, S.W.

Atlanta, GA 30303-8960 Phone: 404-562-8952 Ifanier.brian@.epa.gov

More information about the Site can be found at the Triana Public Library at 280 Zierdt Road, IMadison, Alabama, 35758, or online at: hrf[J://cIjJUb. epa. gov/lupercpoc(:ClIl'SiICS,/csil ill/i). cjill? id=0405546

I I I I I I I

B-2 I I

I I

Appendix C: Interview Forms

I Interview Form for Triana/Tennessee River Five-Year Revien'

I Site Name: Triana/Tennessee River EPA ID No.: ALD983166299 Interviewer Name: Rvan Burdge Affiliation: PIne.

Subject's Name: Gerald Hardv Affiliation: Chief, Land Division, ADEM

Date: 6/29/2009I -------------------Type of Interview: In Person Phone Other

I /. IFhat is .vollr overall impression olthe project '! Good cooperative relationship.

I 2. HOlF ,veil do ),011 believe rhe remedy cllrrently in place is peljo,.,ning? As required by the Consent Decree, 1 believe that the remedy implemented is isolating

I DDT in the Huntsville-Spring Branch system from people and the environment.

I 3. Are you aH.'are ofallY complaints or inquiries regarding environmel1fal issues or the remedial action/f·om residellls in the lastlhle years? No.

I 4. Has yOl/r oj/ice condllcted any site-related activities or communicatiol7s in the lastJive years? /(so. please give purpose and results o/"these activities.

I I have served as Chair of the Inspection Committee for the past five years and as such, I prepare a report of the Inspection Committee's activities.

I 5. Are .VOIl aware qlony changes 10 state laws fhat might Cifleet the protectiveness olthe rel17e(~v? Are you {/\vore olony changes in projecfed l(/nd use at the Site?

I No.

I 6. Please describe the level olcooperation between agencies (USEP.4.. ADEM, TVA.

USFfVS. and DoA). Good.

I I

7 Do you hare any commenrs, slIggt!srions, or recommendations regarding the site's management or operation? Although no specific problems have been noted, the woody vegetation both along the

I edges of the chalmel cuts and \vithin areas of the fill chalmel have raised concerns among members of the Inspection Committee regarding t\VO issues:

1) The potential for damage to the remedial action by the roots of trees blown over by high winds; and

I C-1

I

I I2) The potential for DDT uptake by deep-rooted vegetation, the subsequent

redeposition on the surt~lce through the lcaves and/or bark, and the pokntial effects of associated residues on the HSB-IC food chain. I

I I I I I I I I I I I I I I

('-2 I I

I I

Interview Form for Triana/Tennessee River Five-Year Review

I Site Name: Triana/Tennessee River EPA ID No.: ALD983166299 Interviewer Name: Rvan Burdge Affiliation: P Inc.

SUbject's Name: Susan Tidwell Affiliation: TVA Date: 8/31/2009I ------------------Type of Interview (Circle one): In Person Phone Other

I I. I+'hat isyollr overall impression ofthe proiect?

I The project is \vell-managed and seems to be progressing toward Consent Decree Goals although progress is slower than initially envisioned in the Consent Decree.

2. How well do you believe the remedy currelllly in place is IJe/forming?

I From the reports, the project seems to be meeting the goals set.

3. 'i4re )'fJlI (I\vare qf~(II7J' cOlJ1plain/s OJ' inquirie,)' regarding envirol1171enlol isslIes or Ihe

I remedial actionji'om residents il1 the last jIve years? No.

4. Has your o/flce condllcted any site-related acfiviries or C()1111111l17icatiol7S in the lastj7ve I years? f/so, please give purpose and results (?/these activities.

I TVA collects smallmouth buffalo and channel catfish in the area of the mouth of Indian Creek and within one mile up and down stream of its convergence with the Tennessee River. TVA has been out two times in the five-year period being discussed and plans to go out this fall.

I 5. Are you aware (?lany chonges tofederal or state 1011'S fhatlllight ql/ecl the protectiveness qlthe l'elllcc(v? Are )'Oll aware q/al7Y changes in projected land use (ltlhe Site?

I No.

I 6. Please describe the level ofcooperation betl-Feell agencies (USEPA. ADEAI. TV4.

USFf,VS. and DoA). Good cooperation between the agencies.

I 7. Do you have (lI7Y commel7ts. suggestions. or recolllmendations regarding the site's management or operarion?

I No.

I I I

C-3

I

I

Interview Form for Triana/Tennessee River Five-Year Review I Site Name: Triana/Tennessee River EPA ID No.: ALD983166299 IInterviewer Name: Rvan Burdge Affiliation: P Inc.

Subject's Name: Andrew Hev Affiliation: Review Panel Chair Person, EPA Region 4 Date: 7/21/2009-------------------- IType of Interview: In Person Phone Other

I1. 11'hat is y()ur overall impression olthe project?

The remediation called for by the Consent Decree continues to work well and environmental conditions continue to improve. I

2. HOll' wt!11 do you belit~l'e the remec()' currently in place is pe,.!onning? The remedy is \\Torking well. I

3. Are }'Ol/ all'are olany complaints or imp/iries regarding environmental issues or the remedial aCfionjj'ollI residents in the last jive years? I No.

4. Has your office cone/ucted any site-related activities or comlllunications in the last jive I years? l.(so. please givt! purpose (lnd results o.lthese activities. No.

I 5. Are you ({\1'are ofOI1Y changes tofederal 01' state laws that might alfect the protectiveness

(!lrhe remedy? Are );011 aware o.lan.v changes in projected land lise at the Sile? No. I

6. Please describe the level olcooperation henveen agencies (USEPA. ADEM. TVA, USFf'r~r;;;, and DoA). I During the 19 years I have been attending the Review Panel meetings, there has always been exemplary cooperation among the agencies. Recently, one agency has expressed some concern over the cleanup levels agreed to when the Consent Decree was written 25 I years ago, Nevertheless, the agencies continue to work. together well in resolving all matters before the Panel. I

7 Do YOIi have any cOlI/menls, suggestions. or recommendations regarding the site's management or operation? No. I

I I I

C-4

I

I I USFWS Interview Response for Triana/Tennessee River Five-Year Review

I 2009-EC-0004

I Mr. Brian FalTier

I Remedial Project Manager, TrianalTennessee River NPL Site U.S. Environmental Protection Agency, Region 4 64 Forsyth Street, SW

I Atlanta, Georgia 30303

I Dear Mr. Farrier,

Thank you for the opportunity to contribute to the 2009 Five-Year Review for the

I Triana/Tennessee River National Priorities List (NPL) Site. Under the Comprehensive Response, Compensation, and Liability Act (CERCLA), the U.S. Environmental Protection Agency (EPA) is required to review remedial actions which result in any hazardous substances

I remaining at the site following implementation of the remedy. The purpose of the review is to

I evaluate the implementation and performance of a remedy in order to determine if it is or will be protective of human health and the environment. Such reviews must be conducted every five years or may be conducted more fr'equently if necessary to ensure remedy protectiveness.

I Attached is the Five-Year Review Interview Form provided to participants at the June 25 TrianalTennessee River NPL Site Review Panel meeting, Below, \ve also offer additional

comments on the 2009 Five-Year Review of the Triana/TelUlessee River NPL Site.

I Among other requirements, the EPA Comprehensive Five- Year Review Guidance (EPA 2001)

identifies three questions that should be examined in the Five-Year Review process:

I I Question A - Is the remedy functioning as intended in the decision document?

Question B - Are the exposure assumptions, toxicity data, cleanup levels, and remedial

I action objectives used at the time of remedy selection still valid?

Question C - Has any other information come to light that could call into question the

I protectiveness of the remedy?

I Below, We offer a few comments on these questions.

I C-5

I I

Question A -Is Ihe remec(J'./[lI1ctiol7ing as intended il1 the decision document: I The Consent Decree required attainment of the performance standard (5 parts per million [ppm]

DDT, DOD, and DOE (collectively termed DDT) in fillets of largemouth bass, channel catfish, Iand small mouth bufblo) for Reaches A, 8. and C within 10 years from the date of completion of

the construction and implementation of the initial remedy. Attainment of the performance

standard was not achieved for channel catfish and small mouth buffalo in two reaches at the end I of this period and a I O-year extension was granted. At the end of this second ten-year period (20

years after remedy completion) contillued attainment for smallmoLlth butTalo in two reaches has not been achieved. I In addition to the performance standard, the Consent Decree established seven goals and

objectives for the remedy at this NPL Site, including: I a. Isolate DDT from people and the environment in order to prevent further exposure; and I d. Mitigate effects of DDT on wildlife habitats in the Wheeler National Wildlife Refuge.

The continued identification of elevated DDT concentrations in sediment tish, and bird eggs· I indicate that Goal a. has not been fully achieved. Also, DDT concentrations in sediment, fish,

and birds collected from Wheeler National Wildlife Refuge continue to exceed literature-based Ieffect levels. These findings would suggest that Goal d. has also not been fully achieved.

80th the lack of continued attainment for all tish species in all reaches 20 years after remedy Icompletion and the lack of attainment of all goals and objectives indicate that the remedy is not

functioning as intended in the decision document.

I Question B - Are the e.\pasure assumptions. toxicilY data. cleanup levels. and remedial action Iobject ivl:.'s lIsed (II the lime ofreme(~v select ion SI ill valid?

The performance standard for the remedy (5 ppm DDTr in fish fillets) is less protective than risk­ Ibased consumption criteria for human health recommended by EPA (EPA 1997). \vhich are

based on meal size, DDT concentration, and frequency of consumption. For c1u-onic systemic

health endpoints for the general population, EPA recommends the consumption of one meal per I. month offish containing 5 ppm DDT for the smallest meal size considered (4 ounces [oz]). For

moderate meal sizes (8- and 12-oz servings), EP A recommends the consumption of six meals per Iyear. No consumption is recommended at larger meal sizes (16 oz). Limited consumption is

recommended for tish containing more than 0.1 ppm for moderate and large meal sizes and 0.3

ppm for smaller meal sizes. Consumption recommendations are more restrictive for I carcinogenic endpoints and clu-onic systemic endpoints for children.

C-6 I I

I I Additionally, DDT compounds are lipid soluble and, therefore, tend to reside in fatty areas

within the body, sLlch as the belly nap, the lateral line, and immediately under the skin.

I Accordingly, DDT concentrations in whole tish tend to be substantially higher than concentrations in skinless tillets. For example, sampling by Olin at the Olin-Mcintosh NPL Site

I in Washington County. Alabama, found that DDT concentration in whole largemouth bass \vere more than ten times higher than concentrations in fillets of the same tish. Consequently, accurate determination of human exposure to DDT is dependent on the method of preparation. If

I skin, lateral lines, and belly flaps are not removed, DDT exposure would be higher than that predicted based on skinless fillets.

I During the drafting oftlle Consent Decree, it was assumed that a remedy protective of human health would also be protective of fish and wildlife. Consequently, risk to ecological receptors

I does not appear to have been appropriately considered during remedy selection. Recent data indicate that DDT continues to represent a substantial risk to ecological receptors in the HSB-IC System. For example, Olin (2006) repol1ed that DDT concentrations in surface sediment (0 to 3

I inches in depth) from six transects in the HSB-IC system ranged from 0.59 to 206 ppm, with a mean of27 ppm. All surface sediment samples exceeded the consensus-based probable effect

I concentration (PEC) for total DDT (0.57 ppm) identified by i'vlacDonald et al. (2000). The PEC is defined as a level of contamination in sediment above which adverse effects to sediment

dwelling organisms are expected to frequently occur. Tuttle et a!. (2006) found that DDT

I concentration ranged from 1.3 to 37 ppm in whole largemouth bass (n= 17) and 6.8 to 16.7 ppm in whole smallmouth buffalo (n=3) from the HSB-IC System. All fish exceeded a protective level of 0.6 to 0.7 ppm DDTI' in whole fish recommended by Beckvar et al. (2005). Tuttle et al.

I also found that DOE (a metabolite of DDT) concentrations in hooded merganser eggs from the

I HSB-IC System ranged from 0.4 to 220 ppm, with a mean concentration of 70 ppm for HSB-IC System. Critical eggshell thinning and/or substantial declines in productivity has been associated with DOE concentrations in eggs, including black-crowned night heron (8 ppm; Benny et a!. 1984), snowy egret (5 ppm; Findholdt 1984), white-face ibis (4 to 8 ppm; Henny and HelTon

I 1989), osprey (4.2 ppm; Wi emeyer et a1. 1988), and bald eagle (3.6 ppm; Wiemeyer et a1. 1993).

I I

Question C - Has any other il'?/orll1{[tion come to lighr rhat cOlild call into question the

protectiveness ofthe rell1e(~v?

I Monitoring by the Olin Corporation demonstrated significant declines in the concentrations of DDT in fish tillets immediately following the initiation of remedial actions in 1986. However, after the initial decrease, the decline of DDT concentrations in tish fillets continued at an

increasingly slower rate. Similar patterns of decline are also apparent in sediment. These

I patterns are consistent with the exponential rates of decline for DDT and other persistent contaminants in aquatic ecosystems (Van Metre and Mahler 2005, Gilliom et a!. 2007). Such patterns are marked by steep initial declines followed by a gradual slowing of the rate of change.

I C-7

I

I The rate of decline of DDT in environmental samples from the HSB-IC System has slowed I substantially in recent years.

Stream sediment sampling by Olin in :::.005 demonstrated that, although levels had declined since I initiation of the remedy, DDT concentrations in sediment remained wel1 above protective levels. This

assessment also found that the highest average DDT concentrations remained in the surface sediment I(0 to 3 inches) foliowed by the 3 to 6 inch core sections. Average concentrations were lower in the 6 to

9 inch and 9 to 12 inch core sections. These results suggest that bUlial of DDT in the sediment is

occlllTing at a slow rate. The sediment evaluation also fOlmd that technical DDT, as opposed to DDT I degradation products (DOD and DOE), represented the majOlity of the DDT compounds in stream sediment. This finding suggests that DDT is degrading at a slow rate in the HS8-IC System. I These data sUQ,gests that. although DDT in the HSB-IC System will continue to slowly decline. ........... ...... '" .'

lev'els H--ill remaillelevatedinto the foreseeable future. As indicated in our comments on Iquestions A and B, residual levels of DDT contamination in the HSB-IC System do not appear to be protective of environment and may not be protective of human health.

I We appreciate the opportunity to assist in the 2009 Five-Year Review for the Triana/Tennessee IRiver NPL Site. As noted in our comments, we continue to have high levels of concerns for the protectiveness orthe remedy at this site and implications of residual contamination to the

attainment of management goals and objectives of Wheeler NWR and future liabilities to FWS. I We look forward to discussing these matters fUl1her. Please contact Peter Tuttle at (25 J) 441­

6633 if you have additional questions regarding our comments or ifyOll would like to schedule a Imeeting.

I Sincerely,

I \Villiam 1. Pearson I Field Supervisor

IAlabama Ecological Services Field OHice

cc Review Panel Chairman, Olin Review Panel, U.S. Environmental Protection Agency, Atlanta, I

GA Environmental Manager, Olin Corporation, Cleveland, Tennessee Chiee Lands DiVision, Alabama Department of Enviromnental Protection, Montgomery, AL I Regional Environmental Contaminants Coordinator, U.S. Fish and Wildlife Service, Atlanta, GA

IC-8

I

I I

Interview Form for Triana/Tennessee River Five-Year Review

I Site Name: Triana/Tennessee River EPA 10 No.: ALD983166299 Interviewer Name: Ryan Burdge Affiliation: E2 Inc.

Subject's Name: Peter Tuttle Affiliation: U.S. Fish and Wildlife Service Date: 8/04/2009I -------------------Type of Interview: In Person Phone IMaill Other

I 1. lVlwt is your ol'erall impression o/"the project?

I The remedy is a good initial step in mitigating the risk of DDT and its degradation

I products, DDD and DOE (collectively termed DDT) in the Huntsville Spring Branch and Indian Creek (HSB-IC) System. However, recent monitoring indicates that residual DDT contamination in the HSB-IC System continues to represent a significant threat to fish, wildlife and habitat quality. Continued risk to human health is also a concern. As such, additional action is needed to mitigate risks.

I As one of the federal agencies that will assume management responsibility for this site upon the completion of the remedy, USFWS is concerned about the implications of

I residual contamination on the attainment of refuge goals and objectives, as outlined in the Comprehensive Conservation Plan for the WNWR. We are also concerned about future

I human health liabilities associated with the consumption of contaminated fish taken from waters on pOl1ions of the WNWR.

I 2. HOlt' well do you believe the remelZ)-' clIrrentzy in place is pelforming? Monitoring initially demonstrated significant declines in the concentrations of DDT in fish fillets. However, the rate of DDT decline has slowed substantially in recent years

I and appears to be leveling off. Recent sediment sampling in HSB-IC System indicates

I 'thITfDDT is not readily degrading or being effectively bori"e"d in sediment. USF\VS is concerned that that current levels of DDT in this system are not protective of fish, wildlife or habitat quality on the WNWR. The slow rate of DDT degradation and/or natural attenuation suggests that DDT contamination in the HSB-IC System will persist at

I levels that have the potential to adversely affect fish, wildlife, and habitat quality for an

extended period.

I 3. Are you aware olany complaints or inquiries regarding environmental issl/es or the remedial action./j·om residel7ls in the last./ive years?

I No.

4. Has .VOl/1" of}lce conducted any site-related activities or communications in the lasifive years? Ifso, please give pUipose and reslIlts o.f these activities.

I In 2004, USFWS conducted a limited investigation to evaluate the threat of residual DDT

I in the HSB-IC System to benthic organisms, tish and birds (Tuttle et al. 20(5). The investigation compared DDT concentrations in sediment, fish and bird eggs to literature-

I

C-9

I

I Ibased effect levels. External tish condition \vas also evaluated. Among the findings were

that DDT concentrations in 10 composite sediment samples from the off-channel wetlands in the HSB t100dplain, I-ISB and Indian Creek ranged from I to 7 ppm, with the I exception of two samples from HSB (25 ppm and 1,300 ppm). DDTr in all sediment

samples exceeded the consensus-based probable effect concentration for total DDTr (0.57

ppm) identitied by MacDonald et a!. (2000). The probable effect concentration is defined I as a level of contamination in sediment above which adverse effects to sediment dwelling

organisms are expected to frequently occur. DDT in 17 whole largemouth bass from IHSB and Indian Creek ranged from 1.3 to 37 ppm. Mean concentrations were higher in HSB (17 ppm) than in Indian Creek (8.0 ppm). DDT in three whole smallmouth buffalo ranged from 6.8 to 16.7 ppm, with a mean of 12.2 ppm. All fish exceeded a protective I level of 0.6 to 0.7 ppm DDT in whole fish recommended by Bechar et a!. (2005). About

halfofthe largemouth bass (9 of 17) and all smallmouth buffalo had one or more external Ianomalies, including parasite. lesions, fin erosion, developmental aberrations and tumors.

DDT in hooded merganser eggs collected from wood duck boxes along HSB and Indian Creek ranged from 0.4 to 287 ppm (adjusted to expected moisture content). Critical I eggshell thinning and/or substantial declines in productivity has been associated with

DDE (a metabolite of DDT) concentrations in eggs, including the black-crowned night heron (8 ppm; Henny et 31. 1984), snowy egret (5 ppm; Findholdt 1984), white-face ibis I (4 to 8 ppm; Henny and HelTon 1989), osprey (4.2 ppm; Wiemeyer et a!. 1988), and bald eagle 0.6 ppm; Wiemeyer et a!. 1993). Adjusted DOE concentrations in hooded I merganser eggs from HSB and IC ranged from 0.4 to 220 ppm, with a mean concentration of 70 ppm. I The findings of this investigation heightened USFWS concerns that DDT in HSB-IC System continues to represent a significant threat to fish, wildlife and habitat quality on

WNWR. The slO\ving rate of DDT decline in this systen1.Suggests that the threat of DDT I will persist for an extended period. USFWS has recommended a more comprehensive

characterization of DDT contamination in HSB and Indian Creek to more thoroughly Ievaluate ecological risks and assess implications to the management of the WNWR. FWS also advocated the evaluation of additional measures, such as the spot removal of

areas of highly contaminated soil and sediment, to reduce the threat of DDT in the HSB­ I IC System.

5. Are yo II mvare {?/aI1Y changes tofcderal or state lent's Ihat might ({tlect the protectiveness I o/the "eme(~v? A.rt' .1'Oll mvaJ"e qfany changes in projecled land lise {II the Site? No. I

6. Please describe the level q/cooperation belween agencies (USEPA, ADEM, TVA. USFIVS. and DoA). Under the leadership of the Review Panel Chairman, federal and state agencies I palticipating on the RP are continuing a high level of coordination and cooperation.

C-10 I I

I I I

However, we remain disappointed that Olin has been unwilling to share site data in an electronic format or to assist USFWS in acquiring historical data generated as part of this remedial action.

I 7. Do YOli have any comments. slfggeslions. or recolJlmendations regarding the site's lJIonogemcI11 or operation? Consistent with the EPA CERCLA guidance (EPA 1989, EPA 1999, EPA 2005), \Ne

I recommend the completion of human health and ecological risk assessments to appropriately characterize risks to human health and the environment. If residual contamination is found to present unacceptable risks, we recommend the reinitiation of

I remedial planning.

I References

Beckvar, N., T.M. Dillon, and L.R. Read. 2005. Approaches for linking whole-body fish tissue

I residues of mercury or DDT to biological effects thresholds. Environmental Toxicology and Chemistry 24:2094-2105.

I Findholt, S.L. 1984. Organochlorine residues, eggshell thickness, and reproductive success of sno\vy egrets nesting in Idaho. The Condor. 86: 163-169.

I Gilliom, RJ.,.l.E. Barbasll, C.G. Crawford, P.A. Hamilton, J.D. Martin, N. Nakagaki, L.H.

I Nowell, .I.e. Scott, P.E. Stackelberg, G.P. Thelin, and D.M. Wolock. 2007. The Quality of Our Nation's Waters: Pesticides in the Nation's Streams and Ground Water, 1992­200 I. U.S. Geological Survey Circular 1291,172 p.

I Henny. e.l and G.B. Herron. 1989. DOE, selenium, mercury, and white-faced ibis reproduction at Carson Lake, Nevada. Journal of Wildlife Management 53: I 032-1045.

I Henny, e., L. Lawrence, A. Krynitsky, and e. Bunck. 1984. Current impact of DOE on black crowned night-herons in the intermountain west. Journal of Wildlife Management

48:1-13.

I MacDonald, D.O., e.G. Ingersoll, T Berger. 2000. Development and evaluation of consensus­based sediment quality guidelines for freshwater ecosystems. Archives of Environmental

I Contamination and Toxicology 39:20-31.

I U.S. Environmental Protection Agency. 1989. Risk Assessment Guidance for Superfund. U.S. Environmental Protection Agency, Oftice of Emergency and Remedial Response,

I Washington, De. EPA Document 540/l-89/002.

__. 1999. Ecological Risk Assessment and Risk Management Principles for Superfund Sites. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response, Washington, De. OSWER Directive 9285.7-28P.

I C-II

I

I I__. 2001. Comprehensive Five-Year Review Guidance. U.S. Environmental Protection

Agency, Office of Emergency and Remedial Response, Washington, DC. EPA Document 540-R-O 1-007 . I. 2005. Contaminated Sediment Remediation Guidance for Hazardous Waste Sites. U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Washington, DC. EPA Document 540-R-05-0 12. I

VanMetre, P.C., and BJ. Mahler. 2005. Trends in Hydrophobic Organic Contaminants in Urban and Reference Lake Sediments across the United States, 1970-2001. I Environmental Science and Technology 2005:5567-5574.,

Wiemeyer, S.N., C.M. Bunck and c..J. Stafford. 1993. Environmental contaminants in bald I eagle eggs - 1980-1984 - and further interpretations of relationships to productivity and shell thickness. Archives of Environmental Contamination and Toxicology 24:213-227. I

__, C.N. Bunck, and A.J. Krynitsky. 1988. Organochlorine pesticides, polychlorinated biphenyls, and mercury in osprey eggs, 1970-79, and their relationship to shell thinning and productivity. Archives of Environmental Toxicology 17:767-787. I

I I I I I I I I I I

C-12

I

I Appendix D: Site Inspection Checklist

I I I I I I I I I

FIVE-YEAR REV lEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site n:lme: Tri:lna/Tennessee H.iver Date of inspection: 06/25/2009

Locatioll and Region: Limestone/Madison, AL EPA 10: ALD983166299

Agency, office, or com pan)' leading the five-year review: EPA Region 4

Weather/temperature: SUlln)" 94 degrees

Remedy Includes: (Check all that apply) o Landfill cover/containment o Monitored natural attenuation ~ Access controls o Groundwater containment ~ Institutional controls o Vel1ical barrier walls D Groundwater pump and treatment D Surface water collection and treatment ~ Other: sediment burial

Attach ments: D Inspection team roster attached D Site map attached

II. INTERVIEWS (Check all that apply) I. O&M site manager N/A -­ / /

Name Title Date

Interviewed D at site D at office D by phone Phone no. --Problems, suggestions: D Report attached

2. O&M staff N/A ,I /--Name Title Date

Interviewed D at site D at office D by phone Phone no. --

Problems, suggestions; D Rep0l1 attached

I I I I I I I

0-1

I

3. Local regulatory authorities anti response agencies (i.e., State and Tribal offices, emergency response office, police ciepm1lllent, office of public health or environmental health, zoning office, recorder of deeds, or other city and county oftlces, etc.). Fill in all th:1I apply.

Agency A Iabama Department of Environment Management Contact Gerald Hardy Chief. Land 6/19/2009 334-)]1-773 '

Name Division Date Phone No. Title

Problems; suggestions; 0 Report attached _.__

Agency U.S. Fish and Wildlife Service Contact Peter Tuttle Biologist 8/04/2009 251-441-6633

Name Title Date Phone No. Problems; suggestions; 0 Report attached

Agency U.S. Environmental Protection Agencv Contact And\' Hev RP 7/1 112009 --

Name Chaill1erson Date Phone No. Title

Problems; suggestions; [SJ Rep0l1 attached

Agency Tennessee Valle\' Authoritv Contact Susan Tidwell Manager 8/31/2009 '">56-386-2350

Name Title Date Phone No. Problems; suggestions; [SJ Report attached

4. Other interviews (optional) D Rep0l1 attached

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

I. O&M Documents

D O&M manual D Readily available D Up to date ~N/A

D As-built drawings D Readily available D Up to date ~N/A

D Maintenance logs D Readily available D Up to date ~N/A

Remarks:

2. Site-Specific Health and Sa rety Plan D Readily available D Up to date [SJ N/A

D Contingency plan/emergency response plan D Readily available D Up to date [SJ N/A

Remarks:

3. O&M and OSHA Training Records D Readily available D Up to date [SJ N/A

Remarks:

.:I. Permits and Service Agreements

D Air discharge permit D Readily available D Up to date [SJ N/A

D Effluent discharge D Readily available D Up to date [SJ NIA

D Waste disposal, POTW D Readily available D Up to date [SJ N/A

D Other permits __ o Readily available D Up to clate [SJ N/A

Remarks:

S. Gas Generation Records D Readily available D Up to date ~N/A

Remarks:

I I I I I I I I I I I I I I I I I

D-2 I I

I I I I I I I I I I I I I I I I I

6. Settlement Monument Records o Readily available o Up to date lZ::I NIA

Remarks:

7. Ground water Monitoring Records 0 Readily available o Up to dare lZ::I N/A

Remarks: The last ground water monitoring sampling occulTed in 1997.

8. Leachate Extraction Records o Readily available o Up to date lZ::I NIA

Remarks:

9. Discharge Compliance Records

o Air o Readily available o Up to date lZ::I NIA

o Water (eftluent) o Readily available D Up to date lZ::I NIA

Remarks:

10. Daily AccesslSecurity Logs o Readily available o Up to date lZ::I NIA

Remarks:

IV. O&M COSTS

I. O&M Organization

o State in-house o Contractor for State

[g] PRP in-house o Contractor for PRP

o Federal Facilitv in-house o Contractor for Federal Facility

0­2. 0& M Cost Records

[g] Readily available o Up to date

[gJ Funding mechanism/agreement in place o Unavailable Original O&M cost estimate Unknown 0 Breakdown attached

Total annual cost by year for review period ifavailable:

From 1/01/2005 To 1213112005 $121,902 o Breakdown attached

Date Date Total cost

From 1/01/2006 To 1213112006 $155,642 o Breakdown attached

Date Date Total cost

From 1/0112007 To 12/3112007 $150.908 o Breakdown attached

Date Date Total cost

from I/O 112008 To 12/3112008 $136,617 o Breakdown attached

Date Date Total cost

From 1/0212009 To 12131/2009 $142,137 o Breakdown attached

Date Date Total cost

3. Unanticipated or Unusually High O&M Costs During Review Period

Describe costs and reasons: No unanticiQated or unusually high O&M costs were identified in this FYR.

V. ACCESS AND INSTITUTIONAL CONTROLS lZ::I Applicable DN/A

A. Fencing

I D-3

I

I. Fencing damaged D Location shown on site map [?3J Gates secured DN/A

RernJrks:

B. Other Access Restrictions

I. Signs and other security measures D Location shown on site map [?3J N/A

Remarks: Signage on fences.

C. Institutional Controls (ICs)

I. Implementation and enforcement

Site conditions imply ICs not properly implemented DYes [?3J No D N/A

Site conditions imply ICs not being fully enforced DYes [?3J No D N/A

Type of monitoring (e.g .. self-reporting, drive by) __

Frequency __

Responsible pal1y/agency A laballla Department of Health

Contm.:t -- I I --Name Title Date Phone no.

Reporting is up-to-date DYes DNa [?3J N/ A

Reports are verified by the lead agency DYes DNo [?3J N/A

Specific requirements in deed or decision documents have been Illet DYes DNo [SJ N/A

Violations have been repol1ed DYes DNo [?3J N/ A

Other problems or suggestions: D Rep0l1 attached

2. Adequacy [?3J ICs are adequate D ICs are inadequate DN/A

Remarks: Posting additional fish consumption advisory signage may be necessary.

D. Ceneral

I. Vandalism/trespassing D Location shown on site map [?3J No vandalism evident

Rem<Jrks: ") Land use changes on site [SJ N/A -

Remarks: ,-'. Land use changes off site [?3J N/ A

Remarks:

VI. CENERAL SITE CONDITIONS

A. Roads [SJ Applicable ON/A

I. Roads damaged D Location shown on site map [?3J Roads adequate DN/A

Remarks:

B. Other Site Conditions

Remarks:

VII. LANDFILL COVERS D Applicable [?3J N/ A

A. Landfill Surface

0-4

I I I I I I I I I I I I I I I I I I I

I I I I I I I I I I I I I I I I I

1. Settlement (Low spots) o Location shown on site map o Settlement not evident

Arial extent -- Depth __

Remmks:

2. Cracks o Location shown on site map o Cracking not evident

Lengths __ \Vidths -- Depths __

Remarks:

3. Erosion o Location shown on site map o Erosion not evident

Arial extent -- Depth __

Remarks:

4. Holes o Location shown on site map o Holes not evident

Arial extent -- Depth __

Remarks:

5. Vegetative Cover o Grass o Cover properly established

o No signs of stress o Trees/Shrubs (indicate size and locations on a diagram)

Remarks:

6. Alternative Cover (armored rock, concrete, etc.) DN/A

Remarks:

7. Bulges o Location shown on site map [ZJ Bulges not evident

Arial extent -- Height __

Remarks:

8. Wet Areas/Water Damage [ZJ Wet areas/water damage not evident

o Wet areas o Location shown on site map Arial extent -­

o Ponding o Location shown on site map Arial extent -­o Seeps o Location shown on site map Arial extent -­

o Soft subgrade o Location shown on site map Arial extent -­

_Remarks:

9. Slope Instability o Slides o Location shown on site map

[ZJ No evidence of slope instability

Arial extent --

Remarks:

B. Benches o Applicable DN/A

(Horizontally constructeclmounds of earth placed across a steep landnll side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and ·convey the runoff to a I ined channeL)

I. Flows Bypass Bench o LocatiOll' shown on site map o N/A or okay

Remarks:

2. Bench Breached o Location shown on site map o N/A or okav

Remarks:

3. Bench Overtopped o Location shown on site map o N/A or okay

Remarks:

I 0-5

I

----------------------------------------------------------------------------

C. Letdown Channels o Applicable ON/A

(Channel lined with erosion colltrolmats, riprap. grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move offofthe landfill cover without creating erosion gullies.)

I. Settlement (Low spots) o Location shown on site map o No evidence of settlement

Arial e.\tent -- Depth __

Remarks: ') Material Degradation o Location shown on site map o No evidence of degradation

Material type _____ Arial extent --

Remarks:

3. Erosion o Location shown on site map o No evidence of erosion

Arial extent -- Depth __

Remarks:

4. Undercutting o Location shown on site map o No evidence of undercuning

Arial extent -- Depth __

Remarks: - ­5. Obstructions Type __ o No obstructions

o Location shown on site map Arial extent --Size --

Remarks:

6. Excessive Vegetative C rowth Type __

o No evidence of excessive growth

o Vegetation in channels does not obstruct flow

o Location shown on site map Arial extent --

Remarks: --

D. Cover Penetrations o Applicable ON/A

1. Cas Vents o Active o Passive

o Properly secured/locked o Functionin~ o ROlltinely sampled o Good condition

o Evidence of leakage at penetration o Needs Maintenance ON/A

Remarks:

2. Cas Monitoring Probes

o Properly secured/locked o Functioning o Routinely sampled o Good condition

o Evidence of leakage at penetration o Needs Maintenance ON/A

Remarks:

3. Monitoring Wells (within surface area of landfill)

o Properly secured/locked o Functioning o Routinely sampled o Good condition

o Evidence of leakage at penetration o Needs Maintenance ON/A

Remarks:

0-6

I I I I I I I I I I I I I I I I I I

I I I I I I I I I I I I I I I I I

4. Extraction Wells Leachate

o Properly secured/locked o Functioning o Routinely sampled o Good condition

o Evidence of leakage at penetration o Needs Maintenance ON/A

Remarks:

5. Settlement Monuments o Located o Routinely surveyed DN/A

Remarks:

E. Gas Collection and Treatment o Applicable ON/A

I. Gas Treatment Facilities

D Flaring D Thermal destruction D Collection for reuse

D Good condition o Needs Maintenance

Remarks: -­

2. Gas Collection Wells, Manifolds and Piping

o Good condition o Needs Maintenance

Remarks:

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

o Good condition o Needs Maintenance ON/A

Remarks:

F. Cover Drainage Layer o Applicable ON/A

I. Outlet Pipes Inspected D Functioning DN/A

Remarks:

2. Outlet Rock Inspected o Functioning ON/A

Remarks:

G. Detention/Sedimentation Ponds o Applicable ON/A

1. Silta tion Area extent -- Depth __ ON/A

D Siltation not evident

Remarks: ~ ... "---". - . . - ­ ~

2. Erosion Area extent -- Depth __

D Erosion not evident

Remarks: -­

3. Outlet Works D Functioning ON/A

Remarks:

4. Dam D Functioning DN/A

Remarks:

H. Retaining Walls o Applicable DN/A

1. Deformations D Location shown on site map D Defonnation not evident

Horizontal displacement __ Vertical displacement __

Rotational displacement __

Remarks: --

I D-7

I

2. Degradation o Location shown on site map o Degradation not evident

Remarks:

I. Perimeter Ditches/Off-Site Discharge o Applicable ON/A

I. Siltation o Locillion shown on site Illap o Siltation not evident

Area extent ---- Depth __

Remarks:

2. Vegetative Growth o Location shown on site map ON/A

o Vegetation does not impede flow

Area extent --- Type __

Remarks: There is some vegetative £ro\\'th in ditch, but does not apl2ear to iml2ede flow.

3. Erosion o Location shown on site map o Erosion not evident

Area extent -- Depth __

Remarks:

4. Discharge Structu re o Functionin Ll ~

[8J N/A

Remarks:

VIII. VERTICAL BARRIER WALLS o Applicable [8J N/A

I. Settlement o Location shown on site map o Senlement not evident

Area extent -- Depth __

Remarks:

2. Performance Monitoring Type of monitoring __

o Perfollllance not mOil itored

Frequency __ o Evidence of breaching

Head differential --Remarks: --

IX. GROUND WATER/SURFACE WATER REMEDIES o Applicable [8J N/A

A. Ground water Extraction Wells, Pumps, and Pipeline:; o Applicable [8J N/A

I. Pumps, Wellhead Plumbing, and Electrical

o Good condition o All required wells properly operating o Needs Maintenance [8J N/A

Remarks:

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances

o Good condition o Needs Maintenance

Remarks:

3. Spare Parts and Equipment

o Readily available o Good condition D Requires upgrade o Needs to be provided

Remarks:

B. Surface Water Collection Structures, Pumps, and Pipelines D Applicable [8J N/A

I. Collection Structures, Pumps, and Electrical

o Good condition o Needs Maintenance

Remarks:

----.--------------------------------

I I I I I I I I I I I I I I I I I

D-8 I I

I I I I I I I I I I I I -

I I I I I I

0-9

I

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

o Good condition o Needs 1'v1aintenance

Remarks:

3. Spare Parts and Equipment

o Readilv available D Good condition D Requires upgrade o Needs to be provided

Remarks:

C. Treatment System o Applicable [gj N/A

I. Treatment Train (Check components that apply)

o Metals removal D Oi I/water separation D Bioremediation

o Air stripping o Carbon adsorbers

o Filters __

o Additive (e.g., chelation agent, tlocculent) __

o Others __

o Good condition o Needs Maintenance

o Sampling ports properly marked and functional

o Sampling/maintenance log displayed and up to date

o Equipment properly identified

o Quantity of groundwater treated annually __

o Quantity of surface water treated annually __

Remarks:

2. Electrical Enclosures and Panels (properly rated and functional)

ON/A o Good condition o Needs 1\1aintenance

Remarks: ,

Tanks, Vaults, Storage Vessels -'.

ON/A o Good condition o Proper secondary containment o Needs Maintenance

----- Remarks: -' _ ..0­ _--­4. Discharge Structure and Appurtenances

ON/A D Good condition D Needs Maintenance

Remarks:

5. Treatment Building(s)

ON/A D Good condition (esp. roof and doorways) D Needs repair

o Chemicals and equipment properly stored

Remarks:

6. Monitoring Wells (pump and treatment reilledy)

o Properly secured/locked o Functioning o ROlltinely sampled D Good condition

o All required wells located o Needs Maintenance ON/A

Remarks:

D_ Monitoring Data

I. Monitoring Data

o Is routinely submitted 011 time 0 Is of acceptable quality

2. Monitoring dllta suggests:

o Ground water plume is effectively contained o Contaminant concentrations are declining E. Monitored Natural Attelluatioll

1. Monitoring Wells (natural attenuation remedy)

o Properly securecl/locked o Functioning o Routinely sampled o Good condition

o All required wells located o Needs Maintenance o N/A

Remarks:

x. OTHER REMEDIES

XI. OVERALL OBSERVATIONS A. Implementation of the Remcdv

The remedial action appears to be successful at achieving the required performance standard of 5 ppm in selected fish fillets.

B. Adequacy of 0& M All O&M requirements are adequate for the Site. The CUITent and long-term protect i veness 0 f the remedy is effective.

C. Early Indicators of Potential Remedy Problems No early indicators of problems were identified in this review.

D. Opportunities for Optimization No oppol1lll1ities for optimization were identified in this review.

Site Inspection Team: Mr. Andy Hey of EP A Region 4 Mr. Gregory Luetscher of EPA Region 4 Mr. Gerald Hardy of ADEM MI": ./"Sl)11 Wilson of ADEM Mr. Peter Tuttle ofUSFWS Mr. Bill Starkel ofUSFWS Mr. Jason Yarbrough of TVA Mr. Danny Dunn of RSA Tvlr. Keith Roberts ofOtin Dr. Amanda Goyne of E2 Inc. Mr. Ryan Burdge of £2 Inc.

I I I I I I I I I I I I I I I I I I

0-10

I

I I Appendix E: Photographs from Site Inspection

I I I I I I I I I I I I I I I

.. ' .

', ...... , :,'

.';.'; ..: ... \: ~-

.~~:~ , '.~: .

Locked gate entrance and warning sign at entrance to access road.

Rip-rap and sheet piling at Diversion Structure # 1 in Reach A.

£-1

Looking downstream at Reach A from Diversion Structure #1.

View of the old, filled chmmel across access road from Diversion Structure # 1.

E-2

I I I I I I I I I I I I I I I I I I I

I I I I I I I I I I I I I I I I I View of embayment area in Reach A.

I £-3

I

I ,;., I ~.;.

~;;~~:. (0·. I

I I I I I

Pond along access road in Reach A with sign warning of potential ground water contamination. I I I I I I I IView of Reach A near Dodd Road.

I

E-4 I I

I I I I I I I I I View of Dodd Road Bridge at end of Reach A.

I I I

- ----..---

II i! I

I I I I

E-5

I