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OMNIVQRES&
HIGHER CARNIVORES
1
PRIMARY CARNIVORES
HERBIVOROUS
HSH
ZOOP LANK TON
PLANTS
XO1L
WATER
-I
Is
BOTTOM
ORGANISMS
i_
SEDIMENT
cxcxrnow
4 P£CXT
rr
FI6URE 4.2
Transport of DOT in an
Ecosystsffl - Adapted from
AEHA, 1577
ARMY CORPS OF ENGINEERS,
MOBILE DISTRICT
Enginaering and Environments! Study
Df DDT Contamination of HunSviHt Sprinc 3rar
Indian Cr*ck, and Adjansfrt Lands *nd Wear:
-------
The following discusses the conceptual aspects of such a study
rather than a definitive program. The design of the study can
proceed after further pre-study work, including detailed
discussions with government experts, is completed. These studies
may be especially pertinent to Reaches B and C.
Numerous laboratory studies have been undertaken to determine
the fate of DDT and other contaminants in both terrestrial and
aquatic environments. Metcalf et al. , (1971) discuss the use of the
model ecosystem approach, where an attempt is made to reproduce (to
the extent possible) in situ conditions. Others (Branson, 1978)
have stated that an environmental rates approach using a material
balance equation will more accurately predict the environmental
.concentration of contaminants. In either case, the validity of the
data generate'd is subject to question due to the inability of
laboratory conditions to accurately model*the in situ environment.
*
In an uptake study, known concentrations of radio-labeled DDT
could be introduced into a closed system, and the species .would J?.e.
tested over time to determine DDT uptake rates. Another type of test
involves determining the rate of bioconcentration from bottom
sediment. DDT could be introduced into sediments similar to those
in the KSfi-IC system. Actual DDT contaminated sediments fromHSB-IC
could also be used. Concentrations of DDT within the sediments could
be varied in various aquariums to determine the effect of sediment
concentrations on bioconcentrations.- Of special interest may be a
4-18
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test which covers DDT containing sediments with clay, plastic or
other material and establishes the rate of bioconcentration.
Finally, it could be possible, as Macek et aj.., (1979) have done, to
compare the rates of bioconcentration to bioaccumulation in aquatic
organisms. The results of this investigation showed that, unlike
Bother chemicals, DDT accumulated in higher trophic levels through
the food chain, as well as through bioconcentration.
A field study could be performed to study the uptake of DDT by
fish in HSB-IC. The study would entail obtaining channel catfish
from a hatchery and dividing them into two groups - fed and unfed.
The fish should be placed in cages and one set of fish from each
group suspended in the water and another set placed on the bottom
sediment. Another experiment would repeat the above except the
»
bottom sediment upstream from the cages would be disturbed on a
regular basis over a period of several weelcs.
The combination of field and laboratory studies could provide
an insight into the relationships, between uptake._(ojr DDT
concentrations in fish) and (1) DDT in the in situ sediment versus
suspended sediment, (2) the effects of various concentrations of
DDT in sediment, and, (3) the effects of sediment isolation
(covering). Prior to the initiation of an uptake study, detailed
literature searches and discussions with experts in this field of
study must be undertaken to thoroughly define the objectives and
parameters of study.
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4.6 Utilization of Data Base
The primary uses of the data to be collected in this project are
to help identify appropriate remedial measures and to" develop a
long-term monitoring program for the area. Migration of fish into
and out of the HSB and 1C has been suggested as one of the two
mechanisms by which DDT uptake in TR fish may be occurring (11-173).
The other is in situ exposure. Data concerning species diversity and
abundance collected from sampling of the study area will be used to
discuss the mechanism (in situ and/or migration) through which DDT
contamination in the fish occurs.
Some data has already been obtained through preliminary
sampling (Recra, June and July 1982). First, channel catfish have
been observed and collected for analysis at the Dodd Road bridge
* * •
section of the HSB (Site 4). The capture-of channel catfish is the
^
first.direct evidence that these fish are present in at least the
downstream portions of Reach A during some parts of the year.
Second, young--c-£-the-year largemouth bass and'~'catfish"fcave been
found in the vicinity of the old DDT plant on the HSB '(Site 3).
Future fish collections in the spring may provide additional
evidence concerning the life habits of fish in the HSB-1C area. The
year-long sampling program in the Proposal may yield the data on
which to base conclusions on the significance q-f fish migration.
More importantly, the data will allow one to assess and monitor
the effects of whatever remedial actions are selected. A data base
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will have been developed concerning types of fish common to each
sampled section of the HSB and 1C and levels of DDT in certain fish
for use in the long-term monitoring program and also for purposes of
evaluating the short- and long-term environmental assessment (see
Section 7.0).
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5.0 IN SITU SEDIMENT SAMPLING PROGRAM
5.1 Introduction
As a means of assessing the regional DDT concentration
distribution and the potential for significant physical DDT
transport, an in situ sediment and water sampling program was
"'conducted as a part of the W.A.R. Report. The areas investigated
include TR and tributaries (both upstream and downstream of the IC-
TR confluence) in Wheeler Reservoir, the downstream Wilson
Reservoir on the TR, and the upstream Guntersville Reservoir on the
TR (V-Task 3).
The vertical distribution of DDT (and soil particle gradation)
within the in situ channel and overbank area sediments is an
important historical indicator of hydraulically related activities.
Analysis of in" situ sediment can provide evidence on the type and
character of the DDT sediment deposition and the consequent
if
potential for sediment erosion. For example, recent depositon of
non-DDT containing sediments over DDT-containing sediments could be
an indication that significant, active DDT isolation is occurring.
It can also indicate where scouring, which may expose sediments
containing DDT, is occurring.
The influence of sediment core compositing (vertical and
horizontal), a technique sometimes used by W.A.R., masked the
relationship between more heavily contaminated core fractions with
depth, location, or along significant transect lengths. The
5-1
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approach to sediment sampling focuses, not on the areal distribution
of DDT but, more importantly for evaluating possible remedial
actions, on the vertical distribution of the DDT in the upper
(usually more erodible) six inches of sediment. It is not the intent
of the Proposal to recalculate the quantity of the DDT reported
present in the HSB-IC system. However, a more accurate vertical
profile of the DDT present must be known to determine the most
appropriate types of, and locations for, remedial actions.
The stream flow characteristics will dictate the size and
distribution of the in situ sediment that is likely to be placed, and
remain, in suspension. By Determining the in situ particle sizes
(and the associated DDT) susceptible to hydraulic transport, a
proposed remedial action measure can be designed to prevent DDT
transport. The lack of data defining the relationship between DDT
^>
and sediment characteristics is a significant problem in Reach B and
Reach C because remedial actions may need to be more selective and
specific j.n.these areas. ... .,.„.._. —— - -— -
The sediment sampling program is designed to incorporate the
information available from the existing data base, i.e., DDT
concentration and areal extent, and to obtain additional in situ
sediment data required to design cost effective remedial solutions
for the HSB-1C areas.
The method for development of remedial actions in this Proposal
dictates a more detailed, site specific understanding of the in situ
5-2
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and background sediment conditions in the HSB-IC system which is not
presently available from the existing data base. This involves the
acquisition of information necessary to address several concerns
associated with the development of remedial actions. These concerns
are &s follows:
(1) What is the interaction between the DDT-containing
sediment and the overlying water, i.e., is sediment
available for resuspension and transport?
(2) Do the sediment character and sedimentation rates above
Dodd Road differ from that downstream?
(3) What is the physical and chemical character of the
sediment upstream of Fatton Road?
(4) Are there sources of DDT-containing sediment upstream of
Patton Road? If so, what is the significance?
(5) What is the concentration of DDT in the sediment in the
ponded areas and in the reaches of tributaries entering
Indian Creek? Are these areas, such as isolated embayment
areas, potential sinks for DDT-containing sediment?
(6) What is the past sedimentation history of the HSB-IC
system and in what way does this relate to the physical
character of the in situ sediment?
(7) What is the effect of sewage treatment plant effluent on
- • --- DDT-avail ability and movement? — — "' '
(8) What effect does stormwater . from the HSB-IC basin
(including the city of Huntsville) have on the transport
of DDT?
5.2 Specific Objectives
The preceding discussion identified those concerns that must
be considered and investigated further. The expansion of the
existing data base will permit development of effective remedial
actions for the HSB-IC system. The specific objectives for the in
situ sediment sampling program are as follows:
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• determine the relationship between the DDT
concentration and particle size/soil type,
above and below Dodd Road (including 1C);
• determine the organic content in the sediment
and its relationship to DDT;
* determine the vertical DDT concentration
gradient in the sediment within the HSB-IC
system (with special emphasis on each one inch
layer in the top six (6) inches of sediment);
• determine the physical character of the
sediment available for transport within the
HSB-IC system, e.g., moisture content,
specific gravity, flocculation of clays;
• determine physical and chemical character of
channel sediments upstream of Patton Road to
Martin Road;
• establish DDT concentration in the ponded areas
and in the reaches of tributaries entering
Indian Creek;
• obtain knowledge of the past sedimentation
history within the system; and .
^ determine if sedimentation or scouring is
occurring in Reaches A, B, and C.
'5.3 Utilization of W.A.R. Data
As previously noted, the W.A.R. Report has divided the HSB-IC
system into three specific areas, viz.,- ICM 0.0 to HSB-IC
confluence, HSBM 0.0 to 2.4, and HSBM 2.4 to 5.4. These areas are
referred to as Reach C, Reach B, and Reach A, respectively. In
addition, this program will include evaluation of an area upstream
of Reach A, i.e.; HSBM 5. 4 to 9. 7..
As described in the .W.A.R. Report (11-77), the surface
hydrologic regime can be divided into four major categories:
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channel, overbank, ponded, and floodplain. The terminology used,
with some modification for special situations, is defined as
follows:
" * Channel Areas - areas confined by well-defined
banks as determined from the transect profiles
and generally occupied by flowing water.
• Overbank Areas - areas outside of well-defined
channel banks, with or without a permanent
vegetative cover, periodically inundated as a
result of reservoir operations on the Tennessee
River and upstream streamflow conditions.
• Ponded Areas - areas generally inundated with
standing water and hydraulically connected to a
stream channel.
• Floodplain Areas - areas below the 100-year
flood evaluation as determined by TVA in the
course of this study."
These definitions will be used throughout the remainder of this
-discussion for consistency with the W.A.R. Report.
4»
.The data base generated during the W.A.R. Report generally
eliminates the need to determine the areal distribution of DDT
concentrations. -Exceptions-1©-this are selected--iocation-s within
Reach C and Reach B and upstream of Reach A which were -not fully
investigated during the W.A.R. study. These areas specifically
include the ponded areas and the lower reaches of tributaries in
Reaches B and C and the stream channel in the area upstream of Reach
A. The sampling program will emphasize the investigation of the DDT
concentration gradient in the top six (6) inches of sediment, the
associated physical character of the sediment and past
sedimentation history.
5-5
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5.4 Program Design
5.4.1 Sampling Locations
Data collected at selected sampling locations will supplement
the W.A.R. data base. The sampling locations will, include areas of
hydraulic interest such as channel bends, embayments, and
floodplains where sedimentation, erosion and/or fish spawning may
occur. The proposed sample locations will be provided to the RP.
Additional in situ sediment core sampling locations may be
selected during field activities in the HSB-IC system, after-
collection and analysis of the respective DDT concentration' levels
and sediment gradations of the proposed samples, and during
development/design of remedial actions.
Within the stream channel of the HSB-IC system, the proposed
sampling locations will be spaced between the existing W.A.R.
transects. Proposed sampling sites within Reaches B and C will also
be located in ponded areas and lower reaches of tributaries to
bbtaiffaata" analogous to that collected within the channel and to
determine if these areas are potential sinks ("hot spots") for DDT.
The data necessary to make this determination have not previously
been obtained. The data must be obtained because these locations
may be fish habitats and may require the development of remedial
measures in discrete locations. Overbank and floodplain areas in
Reaches B and C will also be sampled.
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In Reach C, several overbank and floodplain sampling sites will
be selected. Although this area has been extensively investigated,
sampling at these locations will provide data on the physical nature
of the sediment and DDT concentration in the top six inches and will
complement the data to be obtained from channel sampling. The core
samples obtained at these selected sites will be examined to
determine the past sedimentation history of the HSB-IC system.
5.4.2 Sampling Frequency
This program is expected to be conducted in a single sampling
period of three or four weeks duration. As the project progresses,
additional samplings may be needed and conducted.
5.4.3 Sampling Protocol
Transects will be established across the HS5-IC channel and
.tributaries at the s..tes selected. Sonar recordings and manual
A
probing will be conducted to map the sediment deposition. Sampling
locations will be marked in the field for identification and
..r.ecQrded. in .a bound field log book and on & site topographic-msp--
Conventional surveying techniques and/or aerial photographs of the
sampled areas will later be performed to verify sampling locations.
The water surface profile and elevations will be obtained from the
stream stage recording equipment discussed in Section 6.0.
Subsequently, the elevations of the extracted sediment cores will be
determined by subtracting the water depth at the sample locations
from the water surface elevation.
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Samples will be obtained in areas of the deepest sediment
deposits on each transect. Replicate samples will be taken to
insure that sufficient sample volume has been obtained to conduct
all analyses. In addition, there will be several sampling points
across each transect in order to insure that the transect is fully
*
defined.
A gravity-type sampler will be used to obtain core samples at
all locations. Briefly, this type of sampler consists of a top
section containing an encapsulated ball valve which creates a
partial vacuum necessary for retention of the sample when the unit
is retrieved, a coring tube with a plastic liner insert attached to
the top section, and a retaining basket and cutting shoe attached to
the coring tube.
Depending on the depth of the watsr at each sample location,
4»
the method used to obtain the desired sample depth will vary. Where
the water depth is sufficient, a weighted sampler will be allowed to
-•free fall--froiri--£.•-boa-;.—through"the wstrer" which' penetrates thebVttom
sediments to the desired sample depth. If free-fall sampling does
not achieve sufficient core depth, the sampler will be manually
advanced until the desired core depth is achieved. Where the water
is shallow, the sampler will be manually advanced to obtain the
desired depth of penetration.
Once the sampler and sample column have been retrieved, the
plastic liner that encapsulates the sediment sample will be removed
5-8
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from the core tube and a-new liner inserted for the next sample
location. While in the field, the entire sample column will then be
removed slowly from the plastic liner by the following procedure:
extraction from the top to minimize the possibility of smear effects
on the core, scraping of the perimeter of the sediment core to
minimize the possibility of contamination from the plastic liner,
such as phthalate esters, and separation at the desired depth
fractions, viz.. 0"-1", l"-2", 2"-3", 3"-4", 4M-5", 5"-6", and 6"-
12". ''
Each sediment sample will be visually characterized -and the
following information will be noted in the field log book: sample
location, sample number, sample depth, and sample description. Each
depth fraction of the sample will be placed in a scrupulously
cleaned, w,.de-mouth, screw-capped, glass'bottle with a TEFLON-lined
A.
lid, which will be labeled, securely packaged and chilled. Sediment
samples will be transported, via air freight, to Recra Environmental
Laboratorie§"rir~rbfiSVfaftoa"rNew"Ybrk. " " "" "
In order to assure that the required sample volume necessary to
fulfill both physical and chemical analyses is obtained, multiple
core samples (probably five to six) will be obtained in close
proximity to each sampling location.
•
Another objective of the sampling program .is to define the past
sedimentation history within the basin. This information will be
acquired by obtaining core samples through the recent stream
5-9
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deposits and, if possible, into the underlying material. This core
will be obtained by gravity type sampler or other manual core
sampling devices. The core will be retrieved, left in the plastic
tube, capped, properly labeled, frozen and returned to Recra
Environmental Laboratories, Tonawanda, New York for later visual
"* and, if necessary, microscopic identification.
5.4.4 Analytical Parameters
Samples will be thoroughly homogenized and split prior to
physical and chemical characterization. One part of the homogenized
mixture will be used to determine DDT concentration. The analytical
procedure for DDT has been stated previously in Section 3.0. The
analytical procedures for volatile solids content, Method 208E,
described in Standard Method for the Examination of Water and
Wastewater, 14*th Edition, APHA", AWWA, WPCF, will also be performed.
In addition, the organic content of the sample will be determined by
the procedures stated in Section 3.0.
The remaining portion .of ..th_e^i,xtjjre_^i_ll be_divided..in half*
One half will be placed into a clean glass bottle, as described
previously, labeled, refrigerated, and kept for possible future
analyses. The other half of this subsample will be used for physical
characterization. The physical soil properties of concern are grain
size, specific gravity and moisture content. Grain size
distribution will be obtained via an electronic particle size
procedure using a Sedigraph particle size analyzer. Specific
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gravity and moisture content will be determined by procedures
described in ASTM-D-854 (Test for Specific Gravity of Soils) and
ASTM-D-2216 (Laboratory Determination of Moisture Content of
Soils), respectively. *
5.5 Utilization of Proposed Data Base
This in situ sediment sampling program has not been designed to
duplicate the existing W.A.R. data. The program was developed to
expand the present data base to enable the assessment-of proposed
alternate remedial actions for Reach A, Reach B and Reach C.
Information developed from the physical properties of the
* Reference: American Society of Testing and Materials, Part 19
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sediment in the MSB-1C system, knowledge of past sedimentation and
the hydraulics of the HSB-IC system are required as inputs to this
assessment.
Information obtained concerning grain size versus DDT
concentration and the DDT concentration variation with depth will
enable the determination of whether the DDT in the top six inches is
ubiquitous, whether recent deposition covered DDT sediment, and
whether the sediment is available for resuspension, erosion,
transport and deposition. In addition, establishing the properties
of the surficial in situ sediments is required for long-term
monitoring after any necessary remedial actions are implemented.
The information developed concerning any "hot spots11 that are
hydraulically connected to the main stream channel in Reaches B and
/
C will enable the assessment of the need for localized remedial
A
programs.
. A map of the areas, i.e.. Reach A, Reach B, Reach C, and
-"up-stream of Reach A, will be prepared to sh~ow~DBT~~avaTiable"foY
transport or available to water or unavailable for either: This map
will illustrate the significant findings of the field data
collection programs (fish and sediment). W.A.R. data will also be
included. This will facilitate development of appropriate remedial
action plans to address field conditions. The jnap will be a planning
tool for the selection and evaluation of potential remedial actions.
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6.0 SUSPENDED SEDIMENT TRANSPORT/WATER SAMPLING PROGRAM
_6.1 Introduction
The W.A.R. investigation contains HSB-IC field measurements at
several in-place stream gaging stations which indicate the temporal
variations of DDT transport-related parameters (W.A.R. Appendix V,
"'Task 6). These measurements include stream stage elevation and
stream velocity (and discharge) for seven (7) storm events and
related DDT concentration, total suspended sediment, and volatile
solids concentration for the last three (3) of .,seven (7) storm
events. Channel sampling of bedload material, which included solids
load and DDT concentration was also conducted in the field for four
(4) storm events. However, the bedload contribution to total
contaminant " transport was determined to be negligible (W.A.R.
Appendix II, p". 11-122).
W.A.R. statistically analyzed the river hydrology and sediment
v '
data for trends and correlations. From this analysis, sediment
transport...was found to be the major rou.te__£ojr_.DPT.movjsment This.
analytical hydraulic modeling of the HS3-IC system provided the
input for quantifying contaminated and uncontaminated sediment
transport under existing conditions.
Additional data collection and analysis of sediment transport
data are required prior to the selection and design of remedial
actions. The transport of sediment during non-storm events must be
assessed. In addition, additional storm event data is required in
6-1
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order to -provide a complete picture of sediment transport in the
HSB-IC system throughout the year.
Advanced numerical computation techniques (computer modeling)
will be applied to the modeling of the HSB-IC sediment/hydraulic
system. This approach provides the greatest advantage because
-*parametric variations can be more effectively and expeditiously
evaluated. Mathematical representations of complex real world
conditions are necessary and are accepted in practice. Several
theories have been advanced to describe the sediment transport
phenomena. They are discussed in ASCE Manual No. 54(1975),
Sedimentation Engineering.
The suspended sediment .study will determine the rate and
quantity of DDT sediment that is hydraulically transported through
and from the HSB-IC system. This data, in turn, provides the basis
for identifying and relating the principal hydrogeologic parameters
v
and processes contributing to DDT sediment transport. Remedial
action measures, as appropriate, can then be formulated to address_
these effects. The suspended sediment sampling program for non-
storm events and storm events in conjunction with fish monitoring
(Section 4.0) and in situ sediment sampling (Section 5.0), has been
developed to collect the necessary data. This data will be
supplemented by the storm event data reported by W.A.R. The field
9
measurements for determining the hydraulic transport of DDT
sediment will be conducted monthly over a year's period of time in
6-2
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order to include a range of seasons, flows and reservoir pool
elevations in the study. Olin's storm and nonstorm events data,
when combined with the W.A.R. storm event data, should provide a
complete picture of sediment and DDT transport throughout the year.
The information developed during the sediment transport study
will be used to address several concerns which include the
following:
• How do stream flow conditions affect sediment
transport?
• Are storm events more significant than normal
day-to-day flow with respect to DDT transport?
6.2 Specific Objectives
The specific objectives of the suspended sediment transport
study are as follows:
• define the rate of transport of DDT and
suspended sediment through and^out of the HSB-
IC system with respect to time of year and flow (
conditions such as stage elevation, storms,
reverse flow, etc.
.._ determine particle
suspended sediment.
size . distribution- - of -—
• quantify the concentration of settleable and
non-settleable DDT in the water of HSB-IC.
• determine the relationship between DDT and
particle size/soil type.
• develop a computer model of HSB-IC which
simulates DDT/sediment transport.
• develop design data for remedial actions which
will minimize sediment transport.
The Proposal, as related to the sediment transport program in
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the HSB-IC system, entails several components. Most importantly, a
sediment transport model must be developed for an accurate
prediction of sediment distribution and movement. The
determination of sediment deposition rates is necessary to quantify
the present situation and monitor subsequent in situ
burial/isolation of DDT sediments in any remedial action
undertaken. Based upon the stream/basin hydraulic characteristics,
determination of the relationship between DDT concentration and
particle size/soil type will be used to assess which sediments are
settleable, which are susceptible to transport, .and which surficial
in situ sediments, if containing DDT, possess the potential to be
re-entrained for fluvial transport. The flow regimes and areal
distributions of sediment characteristics are variables requiring
-j.'urther consideration for a definitive assessment of conditions now
*
existing. The factors will provide the inputs for effective
engineering design of proposed remedial actions.
—• The'iaeefd for, "feasibility" of and* effectiveness of "any remedial
alternatives can best be determined by establishing a sound data
base with which long-term monitoring data can be compared. The
study will provide data which will permit an accurate evaluation of
Reaches A, B, and C. W.A.R. Report data will be utilized, to the
extent possible, in support of this work.
6-4
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6.3 program Design
The suspended sediment sampling program consists of four
phases which are as follows:
• non-storm event water sampling
• storm event water sampling
• stream elevation and flow velocity measurements
• computer modeling (simulation of the HSB-IC system)
The first three phases will be data development and the fourth phase
will be the evaluation of that data.
6.3.1 Sampling Locations
The suspended sediment sampling program is designed to provide
information on the quantity - of sediment and the physical and
chemical characteristics of the sediment in transport for non-storm
* i
.and storm related events. Each sampling.site will be located at or
near a TVA gauging station which will provide accurate information
on stream velocity (discharge) and stage elevation coincidental
with., .each . sampling..event. TVA.- vi 11 ...operate and. maintain-.these .
stations on a reimbursable basis. Within the HSB-IC basin (Wheeler
Reservoir), the stream gauging stations which have been selected for
reactivation by the TVA are:
6-5
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• ICM 0.38, near IC-Tennessee River confluence
• ICM 4.6, Centerline Road Bridge
• ICM 8.2, Martin Road Bridge
• HSBM 2.4, Dodd Road Bridge
• HSBM 5.0, Boat launch on HSB at Road No. 5669
• HSBM 5.9, Patton Road Bridge
• HSBM 9.75, Martin Road Bridge
The transects at the above stream locations are distant from
any upstream confluences or conditions which would affect the
relationship between sediment transport rates and the pertinent
hydraulic variables. These are deemed suitable for providing
consistent and interpretable suspended sediment data. 'In addition,
these sample locations correspond to the fish sampling locations.
6.3.2 Sampling Frequency
The sampling process employed at each transect is inherently
controlled by the variable hydraulic conditions of flow velocity and
stage elevation. Stage elevation data will be collected
continuously for one year by the TVA stage recorders. Flow velocity
data will be collected monthly by TVA personnel at Olin's expense.
This data will be collected using the same methods and personnel as
in the W.A.R. Report. .The time intervals for suspended sediment
data collection will occur coincident with the TVA stream velocity
measurements. For the latter collection, it is presently estimated
that one-month intervals will be utilized for one calendar year. In
addition, storm event sampling will be conducted.
6-6
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A schedule for the collection of recorded hydrological data
will be designed and established by TVA as a function of the type of
stage recording instrumentation selected. In general, the schedule
will be dictated by the servicing of the recorder power source(s),
the recording pen reservoir (if so equipped) or sensor or stylus,
and replacement of a recording chart and retrieval thereof. At
present, this appears to be a weekly function. The same methods and
TVA personnel used to gather data for the W.A.R. Report are being
used in this study.
6.3.3 Sampling Protocol
The suspended sediment sampling described herein represents
standards and methods developed by the Federal Inter-Agency
Sedimentation Project (F.I.A.S.P.) of the Inter-Agency Committee on
Water Resources (Guy and Norman, 1970). .The intended use of these
procedures and methods is to provide sediment-water samples for
physical and chemical analytical testing to define: DDT and
suspended sediment cp.nc^ntraJtioiis at a .given location-and time,-and
DDT and suspended sediment quantities transported per unit time past
a given location.
U.S.-series time-integrating suspended sediment samplers will
be utilized in either point or depth-integration methods to obtain
flow proportional samples at the locations described in Section
6.3.1. Point sampling methods are preferred for low stream velocity
conditions. Consistent with procedures developed for the equal
6-7
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transit rate (ETR) method of sampling for the U.S.-series samplers,
each stream section will be divided by several equally spaced points
(verticals). The number and location of the verticals will be
determined for existing field conditions and from the sampling
protocol.
Samples will be obtained at the verticals by lowering and
raising a sampler at an equal transit rate (depth integration). This
technique requires a knowledge of the immediate stream channel
profile, stage height, and mean flow velocity prior to each sampling
event. The suspended sediment program will be developed to
coordinate field sampling with the scheduled TVA hydrological data
collection (Section 6.3.2).
Existing data on channel form, stage elevation, and mean
.velocity suggest use of the U.S.-series depth-integrating
sampler(s) USDK-59 and/or USDK-48 (National Handbook of Recommended
Methods for Water Data Acquisition, 1978). Each is designed for use
with a.4.?3_.m£ glass_b.attle for..samp3-e..co.l].£ctdon,-.^-.-ee-pasate bottle -
will be used at each vertical and the total group of transect bottles
will be composited to yield a sample proportional to the total
stream flow.
The method of depth integration, used in the ETR method, is
limited to a stream depth of approximately 15 ft. If conditions
arise which exceed this limit, point integration samples (US P-72)
will be utilized to depth-integrate in a single direction (up-
6-8
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transit) or to obtain point-integrated samples at the centroids of
equal discharge increments, such as 0.2 and 0.8 or 0.6 of the stream
depth from the water surface. This technique as covered in the
method and will not result in a decrease in accuracy.
Alternatively, point sampling at stations with low stream
velocities will be accomplished using a pump-type'sampler that has a
high intake velocity relative to the stream velocity at 0.6 of the
stream depth.
Methods and personnel employed by TVA in collection of
hydrological data are expected to be the same as, or at least
equivalent to, those methods utilized by W.A.R. (V-Task 6).
Discharge measurements were taken using standard procedures as
specified in the U.S* Department of the Interior, Geological Survey
*
.Water Supply Paper 888, Stream-Gaging Procedures, A Manual
Describing Methods and Practices of* the Geological Survey,
Washington, D.C., 1943. Procedures for calculating depth, mean
ve.locity and discharges, are also. .giveii j.n.£hi.s..!nanua]_^ --_... .......
All bottles will have a cap lined with TEFLON or aluminum foil
and will, be cleaned following the procedures suggested by TVA in
their 1978 study, "DDT Residues in Sediment and Fish in the Vicinity
of Redstone Arsenal, Alabama." Site identification, date, time,
station section, bottle number, and initials of field crew members
M
will be noted on each bottle's label. It is estimated that 10 liters
of water will be required to provide sufficient volume for the
6-9
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analysis. Samples will be 'stored in ice immediately after
collection and will remain as such until received at the laboratory.
Samples will be refrigerated at 4°C at the laboratory until physical
and chemical analyses have been performed.
6.3.4 Analytical Parameters
As indicated in the Quality Assurance Program (Section 3.0),
the primary analytical parameters to be determined for composited
samples at each transect are DDT concentration and total suspended
solids. If a sufficient sample volume of sediment is available,
suspended sediment particle size will be determined. The analytical
protocols are cited by reference in Section 3.4.3.
6.4 Utilization of Proposed Data Base
Field data supplied by the W.A.R. investigation and this
* •
suspended sediment sampling program wi.ll provide representative
A
inputs of the KSB-IC average stream hydraulic characteristics and
will enable proposed remedial actions to be developed as well as
.establish the baseline conditions, for -post«-constraction-jnonitori-ng-~
of remedial actions.
The utilization of the data base to determine the type and
predicted effectiveness of any proposed actions is of paramount
importance. Hence, descriptions of the fundamental principles,
concepts of sediment deposition, and methodology employed in the
assessment of the proposed remedial action effectiveness are herein
provided.
6-10
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In general, the in situ sediment that is available for
hydraulic transport (in suspension) is a function of the
hydrodynamic forces directly acting upon discrete sediment
particles. Entrainment of the sediment is primarily dependent upon
the sediment properties (such as particle size) - stream velocity
relationship; that is, the higher the velocity the greater the
maximum particle size to be placed in suspension, while
simultaneously increasing the quantity of finer_grained sediment.
By maintaining stream velocity and turbulence of the water, sediment
particles (up to a certain maximum size) will remain in suspension.
High stream discharge/velocity conditions normally degrade or erode
the channel sediments. Low stream discharge/velocity creates
conditions conducive to sediment deposition.
6.4^1 Computer Modeling of HSB-IC
The in situ sediment sampling program and the water sampling
program will generate a significant quantity of data on the HSE-IC
system. liT'orde'r to utilize this data to the greatest extent, the
development of a computer model of the HSB-IC system is planned. The
general programming scheme is as follows:
1) Identify a computer model applicable to the ESB-IC
system.
2) Modify the program (if necessary) to incorporate - the
significant characteristics of the HSB-IC system.
3) Verify the model with field data collected during the
field sampling program.
4) Modify program to include potential remedial actions.
6-11
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5) Evaluate effectiveness of potential remedial actions
under various flow conditions.
The computer model can assist in evaluating the effectiveness
of potential remedial actions (and combinations of remedial
actions).
Any computer program which is used to model a system must
accurately simulate actual characteristics of the system. The HSB-
IC has several unique and important characteristics:
• reverse flow occurs in the system
• fine particles (clays and silts) make up a
significant portion of the sediment load
• transport of DDT in absorbed or dissolved forms
• water flow (and sediment transport) in both
channel and overbank areas
Several computer models have been reviewed to determine if they
are applicable for modeling the HSB-IC system. All available
computer models have certain limitations when applied to the HSB-IC
system. Any computer model chosen may reguire. programming
modifications. However, a computer program developed by- the
<
Hydrologic Engineering Center, Corps of Engineers has been
identified as possibly applicable for simulating the HSB-IC system
and for predicting the effectiveness of the proposed remedial
actions. The program is entitled "Scour and Deposition in Rivers
and Reservoirs, HEC-611. A descriptive abstract of the program is
presented below, along with the theoretical methods that are used to
compute the trap efficiencies for silts, clays, and sand for any
proposed containment structure, e_.g. , dam.
6-12
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The total sediment load is transported along a stream. Changes
in the stream's bed elevation and water surface profile with respect
to time are calculated at each cross section considering the
following': the inflowing water discharge, inflowing sediment load,
gradation of material in the stream's bed, armoring, and destruction
..<
of the armor layer. A series of reservoirs in tandem can be
utilized. A dredging option is available. Diversions of water can
be specified and inflowing water and sediment can be entered at
tributary junctions. Clay, silt, sand and gravel sizes are
transported and cooble sizes can be included for armor calculations.
The program is dimensioned for up to 150 cross sections, 15 grain
sizes, 20 tributary inflow points and 20 reservoirs in tandem.
Water surface profiles are calculated by the standard step
•method. The bed material load is Calculated by either Toffaleti's
application of the Einstein Bed Load function, Madden*s
modification of the Laursen Transport Relationship or a transport
=' '"•Capacity"per 'foot' of width'versus the depth-slope product. Based
upon an assumption of steady state, the silt and clay sizes are
transported until the shear stress on the streambed becomes less
than critical. Deposition then begins using fall velocity as a
variable in the exponential decay function. Changes in the bed
elevation are calculated with the Exner equation for continuity of
sediment material.
6-13
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The preceding computer program 'may require a slight
programming modification in order to incorporate the sediment
resuspension aspect. Another drawback of the model is its inability
to handle backf low. This must be investigated further.
The applicability of other relevant programs and/or theories
are actively being evaluated to determine their applicability to the
HSB-IC system.
6-14
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7.0 REMEDIAL ACTION APPROACHES
7. 1 Introduction
Previous sections of this document have presented a review of
information from the W.A.R. Report and the specific investigative
activities which will be completed in this project in order to
provide site specific data of the required degree of accuracy and
precision to evaluate and assess remedial action alternatives for
Reaches A, B, and C with the HSB-IC system.
The fundamental methodology for determining an acceptable
remedial action is to completely assess the feasibility of
alternative remedial approaches. The objectives of the sampling
program are directly relevant to and essential for both engineering
design inputs and a full understanding of existing conditions. In
* •
-this respect, the combination of existing site information as
*
provided by the W.A.R. Report and design data inputs resulting from
the fish, in situ sediment and suspended sediment sampling programs,
will prcvide -necessary- information for development of 'remedial "
actions and will permit demonstration of the adequacy and
effectiveness of any remedial action options.
7^2 Overview of Action Considerations
The study, the selection, and the design of the most
appropriate remedial action alternatives for Reaches A, B, and C are
by no means simple tasks. In the previous sections, the overall
project objectives, the project approach, the hypotheses to be
7-1
-------
tested, the data to be collected and the utilization of that data
were discussed in detail. All of this was directed toward the
development of remedial actions for the HSB-IC system.
Any "suggested" remedial action for Reaches A, B, and C would
be premature. They are very much dependent upon the outcome of
investigative programs covered in this Proposal. The types of
remedial actions that may be warranted and investigated include:
isolation of DDT "hot spots" in the stream channel; removal of DDT
"hot spots" from the stream channel; isolation of DDT-containing
embayment sediments; diversion; enhanced channel and out-of-channel
sediment deposition through artificial means; and -sedimentation
devices. Other remedial actions may also be developed and evaluated
as the study progresses.
* .
The evaluation process for selecting remedial actions will
also take into consideration future changes in the HSB-IC drainage
basin that may significantly affect the characteristics of the HSB-
_IC .system. ^ One of these changes is. .the,.p.o.tenlial_diversion of.-the-,
discharge of the Huntsville POTW directly to the Tennessee River.
This action would significantly reduce the base flow in HSB although
the peak flows would not be materially affected unless there is
diversion of Huntsville storm runoff. It would also eliminate a
source of organic matter which may have an affinity for DDT. The
effect of the diversion on flow and sediment transport and on
potential remedial actions will be "evaluated using the computer
7-2
-------
model. It will also be evaluated conceptually using
engineering/physical principles such as flow velocities, direction
of flow, etc.
7.3 Long-Term Envlronmental Monitoring Program
Throughout this Proposal, reference is made to the long-term
environmental monitoring of the HSB-IC system. The purpose of the
long-term environmental monitoring plan is to determine the
effectiveness of the implemented remedial actions, to assess any new
or residual environmental impacts or hazards, and to identify the
needs for additional remedial actions. The long-term monitoring
plan will, if appropriate, measure the rate of change in DDT levels
in fish, migration of DDT in se'diments and water, or the dynamics and
proportions of DDT components in the sediments, water and biota of
-Huntsville Spring Branch, Indian Creefc and Wheeler National
Wildl-ife Refuge, depending upon the remedial action chosen. The
long, term monitoring program developed will continue until the
termination of the Con'seTiX" Decree: ~~~' '"' " "~ """"
For the purposes of the long-term environmental"monitoring
plan, baseline conditions shall be those levels of DDT in fish,
water, and sediment determined during the Olin study supplemented
with data from the W.A.R. Report. The results of analyses performed
under the long-term monitoring program will be compared with
baseline data to evaluate the effectiveness of remedial actions.
7-3
-------
The types of samples and the sampling and analytical protocols
of the long-term monitoring program will be the same as those
detailed in Sections 3.0 through 6.0 with the exception of sampling
frequency and the groundwater program. The sampling frequency and
the groundwater program are discussed below.
Although an accurately defined time frame and completely
developed program cannot be established at this time, a long-term
monitoring plan which is similar in concept to the fish, in situ
sediment, and suspended sediment sampling programs in Sections 4.0,
S.O, and 6.0, respectively, is contemplated. It is presently
envisioned that DDT concentrations (both total, filterable and non-
filterable) and the suspended sediment concentrations in the
surface water will be determined from samples collected at semi-
annual intervals at the seven selected'locations indicated in
A
Section 6.0. For the fish species, DDT concentration levels will be
determined on an annual basis following implementation of any
remedial- acti-ins. Sampling- locations wiil~'b*e"~as" aiscussed~an~ '
Section 4.0. In situ sediment sampling may be conducted on-an annual
basis at selected locations corresponding approximately to those
presented in Section 5.0. Quantitatively, the number of sample core
locations will be fewer than indicated in Section 5.0 but will
include points common to both this Proposal and the W.A.R.
investigation. The analytical parameters to be determined will be
DDT concentration variation with depth, and soil particle size
7-4
-------
distribution with depth. The latter will be indicative of the type,
rate, and extent of the suspended sediment deposition. A relative
comparison of DDT parameters over time with the baseline conditions
established under this Proposal will indicate the rate of
effectiveness of the remedial action, e,g., the sediment transport
model predictive capabilities, the HSB basin sediment deposition
rates, and, most importantly, the rate of reducing the DDT
concentration levels in fish in specified areas to 5 ppm.
7.3.1 Groundwater Monitoring
The groundwater in the vicinity of HSB-1C will be monitored to
determine if construction and implementation of any remedial
actions affect DDT in groundwater. The monitoring program shall
consist of water samples taken from existing groundwater wells (RS
20, .RS 22, RS 23, RS 27, RS 30) and drinking water wells (X 37, X 44,
*»
Q 79, VU 67 and U 98) (see W.A.R. Report 11-74 and EPA memorandum
dated October 9, 1979 entitled "Transmittal of the Public and
Private Water Supply "investigation, Redstone Arsenal and Vicinity,
Huntsville, Alabama Area"); RS 30 is upgradient of the DDT source
area, RS 27 is immediately downgradient of the source, RS 22 and RS
23 are a downgradient shallow/deep pair at Huntsville Spring Branch,
into which the groundwater flows, and RS 20 is an additional
downgradient shallow well at the Branch. If any of these wells are
found to be dry or damaged, alternate wells may be sampled.
7-5
-------
All wells will be sampled once in 1983 and once every two years
for up to ten years after completion of construction.
The wells will be sampled with a peristaltic (surface) pump
using a dedicated, disposable inert sample tube. Each well will be
flushed until it is dry or until 2-3 well casing volumes (about 12
gal.) have been evacuated. Sampling will then be done for DDT. Each
sample will be filtered at the laboratory through a 63v filter prior
to analysis to remove suspended solids. Sample handling and
analysis will be conducted according to the procedures specified for
water samples in Section 3.4.3.
7.3.2 Measurement of Performance Standard
The performance standard'is a DDT level of 5 ppm in fillets of
channel catfish, largemouth bass and-smallmouth buffalo in Reaches
A, B, and C. Olin shall be deemed to "attain the performance
standard" when the average DDT concentration in the fillets of each
of the aforementioned fish species is five ppm (or less) in Reaches
A/ B,and "C. ' ;:Contiriued attainment of the "performance"s'tand'ard""""
occurs when the average DDT concentration in the fillets of each of
the aforementioned fish species is five ppm (or less) for three (3)
consecutive years (including year of attainment) in Reaches A, B,
and C.
The average DDT concentration of a species will be determined
as an arithmetic mean concentration of DDT in the fillets within a
species adjusted for the weight of each individual. Mathematically,
this can be represented as follows:
7-6
-------
-------
c * Iwici
where C is the average DDT concentration of a species
W^ is the weight of fillet of each individual
fish of that species (in grams)
Cj is the concentration of DDT in the fillet
of each individual fish of that species (vg/g)
After continued attainment of the .performance standard is
achieved for each species of fish in each reach (A, B, and C), that
species will no longer be monitored. As continued attainment of the
performance standard is achieved in each reach (A, B, and C), that
reach will be eliminated from the monitoring program.
After individual analysis of the fillets, the average DDT
concentration for each species will be determined and compared to
f
the performance standard. The number of samples of each species to
be analyzed will be determined solely by the quantity caught^ during.
the sample collection. A maximum of six fish by species per site
will be analyzed. If less than six fish are caught and analyzed, the
computed average DDT concentration will be based on the number of
fish caught (one to five).
7-7
-------
-------
8.0 ENVIRONMENTAL ASSESSMENT OF REMEDIAL ACTIONS
The size of the study area in which the DDT is reported creates
a complex situation involving many components of the environment.
Remedial action(s) may affect the ecology of the HSB-IC system. In
evaluating a proposed remedial action, the RP will assess its
environmental impact. Olin will provide information with respect to
anticipated effects on people and the environment of any actions to
be implemented under the remedy. At a minimum, the information
included will be that set forth in paragraph 52 of the Consent
Decree. Such information will be patterned after the applicable
guidelines under the National Environmental Policy Act, 42 U. S. C.
§§4321 et sea., currently set forth in 40 CFR Parts 1500-1508 and 40
CFR Part 6.
8-1
-------
-------
9.0 PROPOSAL TIKE FRAME
To ensure a timely implementation of this Proposal, a
generalized project timeline was developed and is illustrated in
Figure 9.1. The elements of study, in conjunction with the assigned
durations, have been categorized as follows:
A. Fish Studies
B. Suspended Sediment Sampling and Stream Hydraulics
C. In situ Sediment Sampling
D. QA/Interlab Equivalency Program
E. Sediment Transport Model - Development and Application
F. Engineering Development of Remedial Actions
G. Preliminary Design of Remedial Actions
H. Long-term Monitoring Program Development for Remedial
Actions
I. Environmental Assessment of Remedial Actions
«J. Report - Recommendations for Remedial Actions
Each particular proposal element will encompass the accomplishment
of those detailed facets described in the preceding sections, and a
• v- , '
final report of recommended remedial actions to be implemented will
be made.
9-1
-------
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10.0 REFERENCES
American Society of Civil Engineers, (1975).
Engineering. Manual No. 54.
Sedimentation
American Society of Testing and Materials (Published annually),
Annual Book of ASTM Standards, Part 19, Natural Building
Stones, Soil and Rocks, Peats, Mosses and Numus, ASTM,
Philadelphia, Pennsylvania.
Branson, D.R. (1978). "Predicting the Fate of Chemicals in
the Aquatic Environment from Laboratory Data". Estimating
the Hazard of Chemical Substances to Aguatic Life.
Cairns/Dickson/Maki - editors. American Society for
Testing and Materials, PA.
Bennett, G.W. (1971). Management of Lakes and Ponds.
Nostrand Reinhold Co. New York. P. 182-193.
Van
Council on Environmental Quality, Regulations on Implementing
National Environmental Policy Act Procedures. 40 CFR,
Parts 1500-1508.
Eddy, Samual, -How to Know Freshwater Fishes, William C. Brown
Co. 1957.
*
Etnier, David, personal notes on fishes of Tennessee, University
of Tennessee, Knoxville, TN, 1976 (rev. 1982).
Fleming, W.M. and Cromartie, E. (1981). "Fish, Wildlife, and
Estuaries: DDE Residues in Young Wood .Ducks Near a
Former DDT Manufacturing Plant". Pesticide Monitoring
Journal. Vol. 14, p. 115-118.
Garrett, G. Lee (August, 1982) personal correspondence to
L. J. Schiffer, re "Guano samples (a/k/a meadow muffins)"
Guy, K.P. (1969). "Laboratory Theory and Metnods of Sediment
Analysis". Techniques of Water-Resources Investigations
of the U^S^ Geological Survey. U.S. Government Printing
Office. Washington, D.C.
10-1
-------
Guy, Harold P. and Norman, Vernon W. (1970). "Field Methods
for Measurement of Fluvial Sediment". Chapter C, Book
3. Techniques of Water- Re source s Investigations of the
U.S. Geological Survey. U.S. Dept. of Interior.
Kuhne, E.R. (1929). A Guide to the Fishes _of Tennessee and the
Hid-South. Tennessee Department of Conservation, Division
of Game and Fish.
.Lawrence, G.D., Jr. February 16, 1982. Letter written to
Charles E. Watkins, Jr. and G. Lee Garrett, Jr., Hansell,
Post, Brandon. & Dorsey. Atlanta, Georgia.
Macek, K.J., Petrocelli, S.R., Sleight, B.H. (1979).
"Considerations in Assessing the Potential for, and
Significance of, Biomagnification cf Chemical Residues
in Aquatic Food Chains". Aquatic Toxicology. Marking/
Kimerle - editors. American Society for Testing and
Materials, PA.
Metcalf, R.L., Gurcharan, K.S., Kapoor, I.E. (1971). "Model
Ecosystem for the Evaluation of Pesticide Biodegradability
and Ecological Magnification". Environmental Science and
Technology. Vol. 5, No. 8, August, 1971.
Micrometrics Instrument Corp (.1978),' Instruction Manual, Sedigraph
•50OOP Particle Size Analyzer, MIC P/N 500/42801/00,
Norcoss, GA.
National Environmental Policy Act of 1969.
National Handbook of Recommended Methods for Water Data
_Accru.isi,tion, . Chapter 3. r .Sediment, Section-3..D. l.b..lc.
U.S. - Series Samples, p. 3-19 to 2-22.
O'Shea, T.J., Fleming, W.J. and Cromartie, E. (1980). "DDT
Contamination at Wheeler National Wildlife Refuge".
Science. Vol. 209, p. 509-510.
Recra Research, Inc. (1982). Huntsville DDTR Environmental
Project Scope (Draft). Huntsville, Alabama.
Standard Methods for the Examination of Water and Wastewater..
14th Edition. APHA, AWWA, WPCF.
Smith-Vaniz, W.F. (1968). Freshwater Fishes of Alabama.
Auburn University, Agricultural Exp. Station.
10-2
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U.S. Department of the Interior. (1943). Stream-Gaging
Procedures, A Manual Describing Methods and Practices
of the Geological Survey, Washington, D.C.
U.S. Department of Justice. (1982). Government Response to
"Huntsville DDTR Environmental Project Scope". July 6,
1982. Prepared by Recra Research, Inc.
U.S. Environmental Protection Agency. (1979). Regulations on
Preparation of Environmental Impact Statements. 40 CFR 6.
U.S. Environmental Protection Agency. (1977). Revised October
1980. "Interim Method for the Sampling and Analysis of
Priority Pollutants in Sediment and Fish Tissue".
U.S. Environmental Protection Agency. (1979). "Guidelines
Establishing Test Procedures for the Analysis of
Pollutants". 40 CFR Part 136. December 3, 1979.
U.S. Environmental Protection Agency. (1979). Methods for
Chemical Analysis of Water and Wastes. EPA-600/4-79-
020, March 1979.
U.S. Environmental Protection Agency. (1982). "Test Method:
Organochlorine Pesticdes and PCBs - Method 617".
U.S. Environmental Protection Agency. (1980). Manual of
Analytical Methods for the Analysis of Pesticides in
Humans and Environmental Samples. "EPA-600/8-80-038,
June 1980.
Water and Air Research, Inc. (1980). "Engineering and Environmental
Study of DDT Contamination_of Huntsville Spring .., _-_...... •-
'7~i~ B'ranch, Indian Creek^ ancTXdjacent Lands and Waters, Wheeler
Reservoir, Alabama". Final Contract Report. November 1980.
Volume 1 - Summary Document. Volume 2 - Appendices I-III;
Appendix I - General Information on DDT and DDTR; Appendix
II - Site Specific Information and Analysis; Appendix III -
Alternatives for Mitigation of DDTR Contamination in
Huntsville Spring Branch and Indian Creek. Volume 3 -
Appendices IV-VI; Appendix IV - Quality Assurance Document;
Appendix V - Worktask Descriptions and Results for 7 TVA
Worktasks; Appendix VI - Worktask Descriptions and Results
for 3 W.A.R. Worktasks and Quality Assurance Document.
10-3
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Watkins, C.E., Jr. and Garrett, G.L., Jr. December 4, 1981.
Letter written to Kenneth A. Reich, Department of Justice,
Washington, D.C.
Welch, N.H., Allen, P.B. and Galindo, D.J., "Particle-Size
Analysis by Pipette and Sedigraph," prepublication
manuscript (.refer to W.A.R. Report, Appendix IV).
10-4
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i
i Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix C
REVIEW PANEL MEMBERSHIP
Review Panel Chair
Dr. Edward S. Bender
Office of Science Policy (8103R)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
E-mail Address: bender.ed@epamail.epa.gov
Period of Review Panel service-June 14, 1983 to present
(Dr. Bender was appointed Chair of the Review Panel on December 5, 1996
following the death of Anne Asbell)
Dr. Bender is an aquatic biologist with the U.S. Environmental Protection
Agency in Washington DC. He chairs the Technical Committee which provides
advice and support for Review Panel activities. In 1977, while working for the U.S.
Army, Dr. Bender became involved with DDTR sampling at Redstone Arsenal. He
joined EPA in 1979 and served as the technical coordinator for the litigation that
led to the Consent Decree in U.S. vs Olin Corporation, and the establishment of the
Review Panel. Dr. Bender has more than twenty years experience in environmental
monitoring, aquatic ecology and toxicology. His dissertation, entitled "Recovery of a
Macroinvertebrate Community from Chronic DDTR Contamination," studied the
toxic effects of DDTR runoff from an abandoned manufacturing facility on fish and
aquatic invertebrates in a south-central Arkansas stream. Dr. Bender has a
bachelor of science degree in biology from Westminster College, a master of science
degree in zoology from the University of Florida, and a doctorate in biology from the
Virginia Polytechnic Institute and State University.
C-l
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
State of Alabama
James W. Warr
Director
Alabama Dept. Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
Email "jww@adem.state.al.us"
Period of Review Panel Service: June 14,1983 to present
Mr. Warr is the Director of the Alabama Department of Environmental
Management (ADEM), a position that he has held since April 1996. Prior to April
1996, Mr. Warr was the Deputy Director from August 1982 (when ADEM was
created) to November 1993 and from November 1994 to September 1995. He served
as the Acting Director from November 1993 to November 1994 and from September
1995 until April 1996 when he became the Director. .ADEM is responsible for the
implementation and coordination of the State of Alabama's environmental program
activities. Mr. Warr was previously the Director of the Alabama Water
Improvement Commission (AWIG), which administered the Alabama Water
Pollution Control Act. He joined the AWIC in 1968 and has several years of
experience and knowledge concerning the environmental conditions in the Wheeler
Reservoir, Huntsville Spring Branch — Indian Creek System. Mr. Warr has a
Bachelor of Science Degree in Civil Engineering, a Masters Degree in Civil
Engineering, and a Master of Business Administration, all from Auburn University.
He is a registered professional engineer and is a member of several professional
associations. He currently holds the rank of Major General in the U.S. Army
Reserve.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Department of Army. RSA
Colonel Steven C. Hamilton
Deputy Post Commander
AMSAM
Redstone Arsenal, AL 35898-5300
Period of Review Panel service—July 1998 to present
Colonel Hamilton was assigned as Deputy Post Commander, Redstone
Arsenal, Alabama in July 1998. Previous assignments have been Platoon Leader, 2-
34th Infantry, Ft. Stewart, GA; Executive Officer, 24th Ordnance Company, Ft.
Stewart, GA; Commander, Surveillance and Accountability Control Team #1
(SAACT #1), 6th Ordnance Battalion, Uijongbu, Korea; Materiel Officer, 80th
Ordnance Battalion, Ft. Lewis, WA; Commander, 63rd Ordnance Company, Ft.
Lewis, WA; and Operations Officer, Test and Evaluation Division, Army
Development and Employment Agency (ADEA), Ft. Lewis, WA. He served as
Executive Officer, 80th Ordnance Battalion, Ft. Lewis, WA; Chief, Ammunition
Management Branch, 3D COSCOM, Germany; Chief, Supply Management Division,
3D COSCOM, Germany and Commander, 6th Ordnance Battalion, Korea. His most
recent assignments have been as Action Officer, J-4, The Joint Staff, Pentagon;
Chairman, Joint Munitions Rule Implementation Council (MRIC), Pentagon and
Chief, Plans and Operations Division, ODCSLOG, Pentagon. Colonel Hamilton's
awards and decorations include the Defense Meritorious Service Medal, the
Meritorious Service Medal with 3 Oak Leaf Clusters, the Joint Service
Commendation Medal, the Army Commendation Medal with Oak Leaf Cluster, the
Joint Chiefs of Staff Identification Badge, the Army Staff Identification Badge, the
Parachutist Badge and the Ranger Tab. Colonel Hamilton holds a bachelor of
science degree in Medical Technology from the University of Utah, a master of
business administration degree from Utah State University and a master of science
in National Resource Strategy from the National Defense University. Colonel
Hamilton was commissioned a second lieutenant in the Ordnance Corps with a
detail in infantry in 1975. He is a graduate of the Infantry Officer Basic Course, the
Ordnance Officer Advance Course, the Materiel Acquisition Management Course,
the Command and General Staff College, and the Industrial College of the Armed
Forces.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
US Fish and Wildlife Service
Dr. W. Allen Robison
Environmental Contaminants
Coordinator-Southeast Region
U.S. Fish & Wildlife Service
1875 Century Blvd.
Suite 200
Atlanta, GA 30345
Email "allen_robison@fws.gov"
Period of Service: July 15, 1993 to present.
Dr. Robison holds degrees in wildlife biology, aquatic biology and toxicology.
He has worked for the Fish and Wildlife Service (Sendee) as a Biological Technician,
an Environmental Contaminants Biologist, and as an Ecologist. Dr. Robison has
also worked in the areas of water quality assessment, fish community analysis, fish
contaminant residue evaluation, and the transport/fate of PCBs for the
Commonwealth of Kentucky. His involvement with the HSB-IC DDT project began
when he came to work in the Service's Tennessee/Kentucky Field Office located in
Cookeville, Tennessee. Dr. Robison has continued tho monitoring programs at
Wheeler National Wildlife Refuge. He is presently employed in the Service's
Southeast Regional Office located in Atlanta, Georgia.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Tennessee Valley Authority
Robert Pryor
Business Development
Tennessee Valley Authority
400 Summit Hill Drive (WT-10D)
Knoxville, TN 37902-1499
Email "rjpryor@tva.com"
Period of Review Panel Service: January 1, 199 Ito present.
Mr. Pryor has over 20 years of accountable management experience in
environmental and pollution prevention disciplines. He has a technical background
in scientific and environmental engineering professions and broad experience in all
TVA businesses. For example, he has managed assessment and protection
programs for natural resources, served as Project Engineer for capacity additions to
the Power System from siting to sub-system modifications. Advised agency
management on effects of operations on natural resources and provided corporate-
level oversight of environmental activities at operating sites, has management
responsibility for performing National Environmental Policy Act reviews.
He has a master of science in zoology and a bachelor of science in biology and
chemistry from the University of Texas at San Angelo, Texas. He also has an
engineering certification from Texas A&M.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
NON-VOTING MEMBERS
Town of Triana. AL
Honorable Clyde Foster (Town Hall)
480 Zierdt Road
Triana, AL 35756
E-mail "cfoster293@aol.com"
Mr. Foster, formerly the Mayor of the Town of Triana, Alabama, is a
prominent community leader. He was instrumental in the restoration of the town
charter for Triana, originally chartered in 1819, and was appointed Triana Mayor in
1964, serving in that capacity until 1984. He has been a strong community
advocate and instrumental in focusing community concerns. His efforts on behalf of
the town of Triana have been successful in improving many areas of community life.
Mayor Foster has been involved with the resolution of the DDTR
contamination problem in the Huntsville Spring Branch-Indian Creek System for
many years. His contributions include effective and successful coordination of the
Review Panel activities with the local community. His efforts have resulted in a
spirit of cooperation and understanding within the community.
Mayor Foster was the Director of the Equal Employment Office at the
National Aeronautics and Space Agency, George C. Marshall Space Flight Center in
Huntsville, Alabama until his retirement in January 1987. He has a bachelor of
science degree in mathematics and chemistry from Alabama A & M, and has taken
graduate courses at that university.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Olin Corporation
Mrs. Laura B. Tew
Director, Community Outreach
Olin Corporation
PO Box 248
Charleston, TN 37310
E-Mail: lbtew@corp.olin.com
Period of Review Panel service: 1998 to present
Mrs. Tew is Director of Corporate Community Outreach with Olin
Corporation's Public Affairs department. She has been with Olin for twenty-two
years and has served on the Review Panel as Olin's non-voting member since 1998.
Mrs. Tew has an undergraduate degree in chemistry from the University of North
Carolina at Greensboro, advanced studies in chemistry at Duke University, and an
MBA in marketing from Pace University in White Plains, NY. Mrs. Tew's career
with Olin has included positions in quality, environmental, production management
and marketing. She was plant manager of Olin's packaging facility in Livonia, MI.
Mrs. Tew holds an advanced certificate from Boston College, Center for Corporate
Community Relations.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
FORMER REVIEW PANEL MEMBERS
Past Chairs
U.S. Environmental Protection Agency
Mr. Howard D. Zeller
Period of Review Panel service: June 14, 1983 through December 31, 1987
Mr. Zeller served as the first Chair of the Review Panel and the United
States' designated Program Coordinator for the implementation of the Consent
Decree in U.S. vs Olin Corporation. Mr. Zeller was the Assistant Administrator for
Policy and Management for the U.S. Environmental Protection Agency in Atlanta,
Georgia until his retirement in January 1987. Mr. Zeller retired with more than
thirty years experience in environmental matters. He lead the Review Panel
through the initial phases of implementing the Consent Decree and adopting
procedures for functioning as a body. Mr. Zeller has a bachelor of science degree in
biology and chemistry from the University of Nebraska and a master of science
degree in zoology from the University of Missouri.
Ms. Anne Asbell
Period of Review Panel service: June 14, 1983 through November 2, 1996
Ms. Asbell was the second Chair of the Review Panel from January 1987
until her death, November 2, 1996. She served as the Legal Counsel for the Review
Panel from 1983 until her appointment as Chair. She was an Associate Regional
Counsel for the U.S. Environmental Protection Agency, Region IV, in Atlanta,
Georgia. Ms. Asbell represented the Region in the litigation that led to the Consent
Decree and the establishment of the Review Panel. She was actively involved in all
aspects of the Review Panel activities and the implementation of the Consent
Decree. Ms. Asbell had a juris doctor degree from Woodrow Wilson College of Law.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Former Members
Tennessee Valley Authority
Mr. Bruce Brye
Period of Review Panel service: June 14, 1983 to December 31, 1990
During Mr. Brye's service as TVA's representative on the Review Panel, he
also served as Chairman of Review Panel's Inspection Committee. Mr. Brye was a
staff Environmental Engineer in the TVA's Division of Water Resources and served
as TVA's senior technical expert on water quality issues. Since 1963, Mr. Brye has
been involved in the environmental review , permitting, licensing, and litigation of
many major TVA projects. During 1979-1980, Mr. Brye was extensively involved in
the data acquisition activities for the DDTR studies of the environment in the
Huntsville Spring Branch-Indian Creek System. During 1981-1983, he provided
assistance to the U.S. Environmental Protection Agency and the Department of
Justice in the development and review of technical documents during the
negotiations which led to the final consent decree in U.S. vs. Olin Corporation.
After his retirement from TVA in 1991, Mr. Brye was retained by the Review Panel
as a consultant. Mr. Brye has a bachelor of arts in mathematics from Wartburg
College, a bachelor of science in civil engineering (sanitary option) from the
University of Iowa, and a master of science in sanitary engineering from the
University of Iowa. He is a Diplomat in the American Academy of Environmental
Engineers, a Certified Hazardous Materials Manager, and a registered professional
engineer in 14 states including Alabama.
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Review Panel Activities HSB4C System DDT Remedial Action (3rd Report)
U.S. Fish and Wildlife Service
1. Mr. W. Waynon Johnson
Period of Review Panel service: June 14, 1983, to March 10, 1987
Mr. Johnson was the Senior Staff Specialist with the US FWS in Atlanta, Georgia.
2. Dr. Lee A. Barclay
Period of Review Panel service-March 10, 1987, to December 3, 1987
Dr. Barclay was the Environmental Contaminants Specialist with the US FWS in
Cookville, Tennessee.
3. Dr. Donald P. Schultz
Period of Review Panel service: December 3, 1987 through June 15, 1990
Dr. Schultz was the contaminant coordinator for the Southeast Region of the U.S.
FWS.
4. Mr. R. Mark Wilson
Period of Review Panel service: June 15, 1990-December 12, 1992
Mr. Wilson was the Environmental Contaminants Specialist with the US FWS in
Cookville, Tennessee.
4. Dr. Charles Facemire
Period of Review Panel service: December 12, 1992 - July 15, 1993
Dr. Facemire was the Regional Contaminants Coordinator for U.S. Fish and
Wildlife Service, Atlanta, Georgia during that time.
Department of the^Army
1. Colonel Dahl J. Cento (Retired)
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Period of Review Panel service: June 14, 1983 to October 30, 1985
Colonel Cento was the Deputy Post Commander of Redstone Arsenal during his
Review Panel service. He was active in soliciting participation by the Corps of
Engineers.
2. Colonel James A. Hall (Retired)
Period of Review Panel service-August 1986 to June 1988.
Colonel Hall was named Deputy Post Commander, Redstone Arsenal in August
1986.
3. Colonel Perry C. Butler (Retired)
Period of Review Panel service: July 1988 to July 1991.
Colonel Butler was assigned as Deputy Post Commander in July 1988.
4. Colonel Stephen Peter Moeller (Retired)
Period of Review Panel service: July 1994 to July 1996.
Colonel Moeller was assigned as Deputy Post Commander in June 1994.
5. Colonel Duane E. Brandt
Period of Review Panel service: July 1996 to July 1998.
Colonel Brandt was assigned as Deputy Post Commander, Redstone Arsenal,
Alabama in July 1996.
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Review Panel Activities HSEMC System DDT Remedial Action (3rd Report)
Former Non- Voting Review Panel Members
Olin Corporation
Mr. William G. McGlasson
Corporate Director, Environment, Health, & Safety
Olin Corporation
PO Box 248
Charleston, TN 37310
Phone: (423) 336-4734
Period of Review Panel service: 1990 to 1998
Mr. McGlasson was Corporate Director, Environmental, Health, and Safety
for Olin Corporation and Olin's designated Program Coordinator for the
implementation of the Consent Decree in U. S. vs. Olin Corporation frgm,,199Q to
1998. He succeeded Mr. Verrill Norwood in July, 1990, who was Olin's primary
technical representative in the negotiation of the Consent Decree and the
development and implementation of the environmental remedy in the Huntsville
Spring Branch-Indian Creek System. Mr. McGlasson. served as Olin's non-voting
member of the Review Panel from 1990 to until his retirement in 1998. During 22
years of service with Olin, Mr. McGlasson served in various technical and
management positions within Olin Corporation. He has a Bachelor of Science
degree in Chemical Engineering from the University of Missouri and a Master of
Science degree in Chemical Engineering from Louisiana State University.
Olin Advisor to the Technical Committee/Review Panel and Former
Review Panel Participant
Mr. Verrill M. Norwood
Olin Consultant
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
116 Sunburst Lane NW
Cleveland, TN 37312
Phone: (423) 476-1082
E-Mail: vmnorwoo@piona.com
Period of Review Panel service: 1983 to 1990
Mr. Norwood was Vice President, Environmental Affairs, for Pioneer Chlor
Alkali and is retired. Previously, he was Vice President, Environmental Affairs, for
Olin Corporation and Olin's designated Program Coordinator for the
implementation of the Consent Decree in U. S. vs. Olin Corporation. He was Olin's
primary technical representative in the negotiation of the Consent Decree. Mr.
Norwood served as Olin's non-voting member of the Review Panel from its inception
until he was succeeded by Mr. William G. McGlasson in July, 1990. Mr. Norwood
has continued on a contract basis to be an advisor to Olin and participate in the
Technical Committee and Review Panel meetings. Mr. Norwood has a Bachelor of
Science degree in Chemical Engineering from the Massachusetts Institute of
Technology and a Master of Science degree in Chemical and Metallurgical
Engineering from University of Michigan.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix D. Inspection Committee Letter
-------
AD EM
JAMES W. WARR
DIRECTOR
ALABAMA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
POST OFFICE Box 301463 » 1751 CONG. w.L DICKINSON DRIVE 36109-2608
MONTGOMERY, ALABAMA 36130-1463
WWW.ADEM.STATEAL.US
(334) 271-7700
October 2,1998
Dr. Edward S. Bender
Chair, Review Panel
U.S. EPA Headquarters
401 M Street, S.W.
Washington, DC 20460
Dear Dr. Bender:
FOB JAMES, JR.
GOVERNOR
Facsimiles: (334)
Administration: 271-7950
Air 2793044
Land: 279-3050
Water 279-3051
Groumtwater 270-5631
Field Operations: 272-8131
Laboratory: 277-6718
Education/Outreach: 213-4399
This letter summarizes the observations and findings of the Review Panel
Inspection Team for the calendar years 1991-1998. Since the last report of the
Review Panel activities, the Inspection Team and others have made on-site
reviews of the remediation site at least annually. Consistent with those reviews,
our records reflect assessments of structural integrity were also performed in
1991, 1992, 1993, 1994, 1996, and 1998.
In my capacity as leader of the Inspection Team, i have reviewed the
reports on structural integrity for the referenced years and find that a
consistently applied assessment process reflects that natural succession has and
is occurring without threatening the stability of the remedy. The area is now in
an essentially natural state and I find no cause for concern relative to the
integrity of the remediation. In fact, the most recent assessment suggests that
intrusive actions may be necessary for access if reviews are to continue on an
annual basis.
ytocerely,
James W. Warr
Director
JWW/rdg
Buroingharn Sf&ncti
UOVuteanRoad
Birmingham, Alabama 35209-4702
(205) 942-6168
(205) 941-1603 (Fax]
Deeatur Branch
400 Wen Street N.E. • P.O. Box 953
Oecatur. Alabama 35602-0953
(256)353-1713
(256) 340-9359 [fax]
Mobile Branch
2204 Perimeter Road
Mobile. Alabama 36615-1131
(334)450-3400
(334) 479-2593 (Fax]
Mobile Branch - Coastal Section
4171 Commanders Drive
Mobile. Alabama 36615-1421
(334)432-6533
(334)432-6598 Fax]
Printed en Recycled Paper
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Review Panel Activities HSBJC System DDT Remedial Action (3rd Report)
Appendix E. Olin Reports Submitted to the Review Panel
Report Title
Huntsville Quality Assurance/Method Equivalency
Report
Huntsville Quarterly Report No. 1
Huntsville Groundwater Report
Huntsville Quarterly Report No. 2
Huntsville Analytical Methods Manual
Huntsville Quarterly Report No. 3
Huntsville Quarterly Report No. 4
Huntsville Remedial Action Report
Huntsville Quarterly Report No. 5
Huntsville Quarterly Report No. 6
HSB-IC Long-Term Data Acquisition Report
Draft 404/26a Permit Application
Huntsville Quarterly Report No. 7
Huntsville Engineering Quarterly Report No. 1
Huntsville Preliminary Engineering Drawings
Second Draft 404/26a Permit Application
A Cultural Resource Survey for the
Huntsville Remedial Action Plan
Huntsville Quarterly Report No. 8
Huntsville Engineering Quarterly Report No. 2
Final Engineering Drawings and Specifications
404/26a Permit Application
Environmental Analysis for the
Huntsville Remedial Action Plan
Field and Laboratory Investigations of the HSB-IC System
Report on DDT in HSBM 4.0 to 2.4 (Lower Reach A)
HSB-IC Post Remedial Action Interim Goals
Huntsville Quarterly Report No. 9
Huntsville Engineering Quarterly Report No. 3
Huntsville Groundwater Monitoring Program
Springs Report
Huntsville Quarterly Report No. 10
Date
August l, 1983
September 1,1983
November 17, 1983
December 1, 1983
February 22,1984
March 1, 1984
June 1, 1984
June 1, 1984
September 1, 1984
December 1, 1984
February 1,1985
February 5,1985
March 1, 1985
March 1, 1985
April 1, 1985
April 19, 1985
May 13, 1985
June 1, 1985
June 1, 1985 ,
July 1, 1985
July 1, 1985
July 1, 1985
July 1, 1985
August 1, 1985
August 1, 1985
September 1,1985
September 1, 1985
November 20,1985
November 27, 1985
December 1, 1985
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Huntsville Engineering Quarterly Report No. 4 December 1, 1985
Huntsville Remedial Action Plan Policy and Procedures Manual January 6, 1986
Cultural Resources Survey Report (Oxbow Alternative) January 7, 1986
Assessment of Revegetation Needs for the Olin Corporation
Huntsville Remedial Action Plan January 15, 1986
Final Engineering Drawings (Oxbow Alternative) January 15, 1986
Huntsville Quarterly Report No. 11 March 1, 1986
Huntsville Engineering Quarterly Report No. 5 March 1, 1986
HSB-IC Long-Term Data Acquisition Report March 1, 1986
HSB-IC Substitute Fish Species Report March 1, 1986
HSB-IC DDT in Fish and Water Baseline Report March 1, 1986
Huntsville Engineering Quarterly Report No. 6 June 1,1986
404/26a Permit Modification June 26, 1986
Catastrophic Subsidence Action Plan July 30, 1986
Draft 404/26a Permit Application (Lower Reach A) August 18, 1986
Huntsville Quarterly Report No. 12 (Semiannual No. 1) September 1, 1986
Huntsville Engineering Quarterly Report No. 7 September 1, 1986
Report on DDT in Reach B and Reach C of the HSB-IC System September 1, 1986
404/26a Permit Application (Lower Reach A) September 15, 1986
Environmental Analysis for the
Huntsville Remedial Action Plan (Lower Reach A) September 15, 1986
Preliminary Engineering Drawings (Lower Reach A) October 1, 1986
Technical Specifications for the
Huntsville Remedial Action Plan (Lower Reach A) October 1, 1986
Cultural Resource Assessment (Lower Reach A) October 15, 1986
Endangered Species Monitoring Report October 20, 1986
Revised 404/26a Permit Application (Lower Reach A) October 27, 1986
Huntsville Engineering Quarterly Report No. 8 December 1, 1986
HSB-IC Long-Term Monitoring Program (Draft) February 1, 1987
Evaluation of Substitute Fish for Largemouth Bass February 6, 1987
Huntsville Semiannual Report No. 2 March 1, 1987
Huntsville Engineering Quarterly Report No. 9 March 1, 1987
HSB-IC Long-Term Monitoring Program (Draft) May 5,1987
Huntsville Engineering Quarterly Report No. 10 May 29, 1987
HSB-IC Long-Term Monitoring Program August 14, 1987
Huntsville Engineering Quarterly Report No. 11 August 27, 1987
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Review Panel Activities HSBflC System DDT Remedial Action (3rd Report)
Huntsville Semiannual Report No. 3
Huntsville Project "As Built" Drawings
Huntsville Engineering Quarterly Report No. 12
Huntsville Semiannual Report No. 4
Huntsville Semiannual Report No. 5
Huntsville Long-Term Monitoring Report No. 1
Huntsville Long-Term Monitoring Report No. 2
Huntsville Long-Term Monitoring Report No. 3
Huntsville Long-Term Monitoring Report No. 4
1992 HSB-IC Intel-laboratory Data Comparison
Huntsville Long-Term Monitoring Report No. 5
1993 HSB-IC Intel-laboratory Data Comparison
Huntsville Long-Term Monitoring Report No. 6
1994 HSB-IC Interlaboratory Data Comparison
Huntsville Long-Term Monitoring Report No. 7
Huntsville Quality Assurance Meeting
1995 HSB-IC Interlaboratory Data Comparison
Report on Interlaboratory
Quality Assurance and Quality Control
Huntsville Long-Term Monitoring Report No. 8
Post Remediation Sediment Investigation
— Reach A and Reach B
1996 HSB-IC Interlaboratory Data Comparison
Huntsville Long-Term Monitoring Report No. 9
1997 HSB-IC Interlaboratory Data Comparison
Huntsville Long-Term Monitoring Report No. 10
Long-Term Monitoring Plan for Time Extension
Interim Goals for Time Extension
Contingency Plans for Time Extension
September 1,1987
September 2, 1987
December 8, 1987
March 1, 1988
September 1,1988
April 15, 1989
April 15, 1990
April 15, 1991 ,
April 15, 1992 '
March 18,1993 '<
April 15, 1993
May 11, 1994
June 1, 1994
April 19, 1995
May 15, 1995
September 13, 1995
April 30, 1996
May 17, 1996
June 1, 1996
January 6,1997
March 17, 1997
May 15, 1997 j
March 24, 1998
May 15, 1998
February 1, 1999
February 1, 1999
February 1, 1999
E-4
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix F. Decision Document No. 8,
Groundwater Monitoring, December 6, 1990
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REVIEW PANEL DECISION DOCUMENT NUMBER 8
GROUNDWATER MONITORING
I.
Introduction
In the April 15, 1990 Long Term Monitoring Program Annual
Report Number 2, Olin proposed to discontinue groundwater sample
collection. Their proposal covers two sets of wells: a) Five
existing groundwater wells on Redstone Arsenal and five public
drinking water wells that were identified in the Technical Proposal
to the Consent Decree; and b) Thirty seven wells, arranged in five
traverses, across the filled channel of the remedial action site.
These are referred to here as the "Technical Proposal" groundwater
wells (or "Far Field wells") and the "Filled channel" groundwater
wells (or "Near Field wells") respectively.
The Consent Decree (paragraph 10) requires Olin to conduct
groundwater studies as set forth in the Technical Proposal. These
studies included monitoring water samples from prescribed wells
before construction, during construction and every two years
following construction of the remedial action. Groundwater
sampling of the Technical Proposal wells would be discontinued
after three consecutive samples confirmed no significant
concentrations of DDT in the groundwater. Olin proposed that
monitoring of the Technical Proposal wells would be discontinued
because three consecutive samplings confirmed no significant
concentratons of DDT in these wells.
A second groundwater monitoring program was developed by Olin
at the request of the Review Panel to study the potential for DDT
contamination and movement in the groundwater around the filled
channel (HSBM 5.4 to 4.0). This program is described in the HSB-
IC Long-Term Monitoring Program (August, 1987). Review Panel
Decision Document No. 6 approved the program and established a
schedule for monitoring each well. Initially, all thirty-seven
wells were sampled quarterly and then in years 2,4,8, and 10
following construction of the remedial action. In Olin's April
1990 Report, Olin proposed discontinuing monitoring of the Filled
Channel wells after year two.
II. Decision
A. Monitoring of the Technical Proposal ("Far Field") Wells
The decision of the Review Panel is to accept Olin's proposal
for discontinuing the monitoring of the Technical Proposal
groundwater wells. The Technical Committee of the Panel has
reviewed the results of three years of sampling from these wells
and agree that no significant DDT have been found in the public
-------
water supplies. If DDT is found in the f:.lled channel wells in the
future, the Review Panel may require further sampling of specific
Technical Proposal wells to evaluate the extent of migration.
B. Monitoring of the Filled Channel ("Near Field") Wells
The decision of the Review Panel is to discontinue monitoring
of the Filled Channel wells in years 4 and 8 but to resume
monitoring those wells for year 10 or during the year following the
initial demonstration of attainment as specified in the Consent
Decree. Olin shall also sample and analyze groundwater from all
of the filled channel wells as part of the demonstration of
continued attainment before the termination of the Consent Decree.
III. Conclusion
This decision document confirms the Review Panel's decision
from its June 14, 1990 meeting. This document consists of 2 pages
of text and comprises the Review Panel decision and is .accepted and
adopted by the representatives of the Review Panel member agencies
and concurred in by the nonvoting participants as shown by the
signatures affixed hereto.
MEMBERS
Ms. Anne L. Asbell
Chairperson, Review Panel
<^I&——_£l "^T^e^jLs^—
Dr. Edward S. Bender
EPA - Washington, D.c.
Bruce Brye
Tennessee Valley Authority
Dr.. Donald P. Schul
U.S. Fish and wildlife
Service
ol. Charles Wood, U.S.
Army, Redstone Arsenal
W. Wai
Alabama Department of
Environmental Management
NONVOTING PARTI CI PANTS
Honourable C4yde Foster
Towir of Triana, Alabama v
William G. McGlasson
Olin Corporation
DATED ^
,
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix G. Decision Document No. 9,
Process for Review of Monitoring Data and
Olin Notification of Compliance by the Technical Committee,
January 23, 1992.
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REVIEW PANEL DECISION DOCUMENT NUMBER 9
PROCESS FOR REVIEW OF MONITORING DATA
AND OLIN NOTIFICATIONS OF COMPLIANCE
BY THE TECHNICAL COMMITTEE
I.
Introduction
Pursuant to the requirements of the Consent Decree, U.S. vs.
01in Corp.. May 31, 1983, the Review Panel is authorized to
review the remedial action implemented by Olin and determine
whether the remedy has achieved compliance with the Performance
Standard consistent with the goals and objectives of the Consent
Decree. The Review Panel may review a variety of information and
data to assess the adequacy of the remedy and compliance with the
Performance Standard, including the Long-Term Monitoring Reports
(Decision Document No. 6) and the Interim Goals (Decision
Document No. 5).
The Review Panel established a Technical Committee to advise
it on technical issues related to the development and
implementation of a remedial action and the monitoring of its
efficacy. The Technical Committee has met regularly to evaluate
the data presented by Olin and has applied sound analytical and
technical principles to the task. The Technical Committee
recommended revisions to the quality assurance and quality
control (QA/QC) plan developed as part of the Joint Technical
Proposal to the Consent Decree, which were incorporated into the
QA/QC requirements through Decision Document Number 7. During
reviews of the long-term monitoring programs data, the Technical
Committee has observed instances when it would be appropriate for
them to have guidance and principles for their evaluations of the
data. As a result, the following areas will be addressed in this
Review Panel document to aid the Technical Committee in its
review of the data presented by Olin:
l. What data should be available to determine compliance with
the Performance Standard consistent with the goals of the Consent
Decree?
2. What principles should be applied to evaluate the quality of
that data?
3. What procedures should be followed to evaluate the data and
what factors should be considered to provide technical assistance
and recommendations to the Review Panel?
The purpose of this document is to provide the Review
Panel's guidance to the Technical Committee on how to address
these questions and provide recommendations to the Review Panel
-------
for its consideration and decision.
II- Decision:
The decision of the Review Panel is that both the Review
Panel and the Technical Committee will continue to receive
information and data from Olin as set forth below. Further, the
Technical Committee will continue to apply sound analytical and
technical principles to evaluate the data and advise the Review
Panel on the status of the remedial action in attaining and/or
maintaining compliance with the Consent Decree.
A.
Datato Evaluate Compliance
1. The Technical Committee and the Review Panel members
will continue to receive information and monitoring data
from Olin as part of the regular monitoring programs
(Decision Documents No. 6, 7, and 8). A partial list of the
information that Olin will be reporting in the Annual
Report starting with the report due April 15, 1992, is
presented in Appendix A. In addition, Olin has conducted
and will conduct special studies to investigate particular
aspects of the remedy (e.g., Decision Documents No. 2 on
Baseline Data, Substitute Species and Interim Goals for Fish
and Water, and No. 7 on Quality Assurance and Fish Sample
Sizes) either on its own initiative, at the request of the
Technical Committee or the Review Panel. From time to time,
the Technical Committee and Olin may recommend modifications
to the monitoring program or modifications to the analysis
and presentation of data that are consistent with the
Performance Standard, the goals and objectives of the
Consent Decree, the Joint Technica.l Proposal, and the
Decision Documents approved by the Review Panel. Additional
monitoring and data analysis by Olin will depend upon the
results of the monitoring information and the Technical
Committee's recommendations.
2. The Technical Committee, with the concurrence of the
Review Panel, has determined that detailed sediment mapping
of the HSB-IC system is needed to review the remedial
action. Sediment mapping will establish the areas of
sediment deposition and erosion which exist following
implementation of the remedial action and following major
hydrologic events. This baseline and future sediment
mapping will permit the Review Panel to make informed
decisions on the stability and long-term integrity of the
remedial action (especially in Reaches B and C). Detailed
mapping should be compared to previous transects surveyed by
Olin. Such comparisons and in conjunction with periodic
updated mapping will permit the Review Panel to determine
which areas are erosional and which are depositional. Olin
-------
has agreed to conduct such mapping during 1992 to establish
post-remedial action baseline conditions and at appropriate
intervals thereafter to account for the effects of major
flood or hydrologic events (e.g., 25 year headwater flood)
on sediment profiles. If such events do not occur, then
this data should be collected prior to the final
demonstration of continued attainment and again prior to the
termination of the Consent Decree.
B. Data EvaluationPrinciples
The following principles will be used to review
monitoring data and information submitted for the remedial
action program on the HSB-IC system.
1. The Consent Decree, the Joint Technical Proposal, and
the Review Panel Decision Documents will continue to serve
as the basis for all procedures and requirements.
2. The Review Panel is charged with the authority to
determine compliance with the provisions of the Consent
Decree. The Review Panel may exercise its authority to
modify the remedial action, develop or modify implementation
schedules, and require additional monitoring and studies
from Olin.
3. Trends in long-term monitoring are of prime importance,
in evaluating the efficacy of the remedial action.
Standardized methodologies established at the outset of the
Consent Decree will be maintained as long as monitoring is
required so that comparability with the baseline conditions
is maintained.
4. Sampling, analysis, and data interpretation will follow
standard methods and QA/QC procedures as outlined in the
reference documents or as modified by any subsequent Review
Panel decisions.
5. All monitoring data collected will be retained and
reported. Technical justification for rejection of any
monitoring data collected must be well documented.
6. The remedial action must achieve compliance with the
Performance Standard for DDT1 levels in channel catfish,
largemouth bass, and smallmouth buffalo consistent with the
goals and objectives of the Consent Decree.
1 DDT is defined in the consent decree as the sum of isomers
and degradation products of DDT; including p,p'- and o,p'- DDT,
DDD, and DDE.
-------
7. All methods of data evaluation will be considered which
are appropriate for the interpretation of the data developed
under the Consent Decree.
C. Procedures for Review and Evaluationof Monitoring Data
1. Each year, following the submission of the Long-Tenn
Monitoring Report, the Technical Committee, on behalf of the
Review Panel, will review the data and any recommendation
from Olin that compliance has been attained or continued to
be attained for any performance standard fish species. The
Technical Committee will review the data and recommendation
for completeness, quality assurance certification, and
accuracy.
2. The Technical Committee review will include
considerations of the trends in DDT levels, requirements for
additional monitoring by Olin, supplemental data from
participating agencies, and modifications to the monitoring
program or construction and implementation schedules as
approved by the Review Panel.
a. Changes in Fish DDT Levels. The Review Panel
recognizes that DDT residues are highly variable among
individual fish and, therefore, reserves the option to
focus on the long-term trend(s) of this contaminant in
the community of fish within the specified study
reaches. If the Technical Committee determines it is
appropriate, it may utilize other measures of central
tendency (e.g., geometric means, medians) or pool data
among reaches to evaluate the effect of individual fish
on the arithmetic average.
b. Partitioning of DDT among various media. A dynamic
relationship exists between the levels of DDT in
sediment, suspended sediments, water, and fish tissue.
Fish residues are also influenced by the level of DDT
in the food, percent of lipids, age, feeding behavior,
and movements in and out of contaminated areas. In
reviewing trends of DDT concentrations in fish tissue,
the Technical Committee will compare the levels of DDT
in various media with the levels of DDT in each
Performance Standard fish species. Although the level
of DDT in any one medium (water or sediment) is
expected to vary, it will be used as one indication of
the efficacy of the remedial action. The Committee
will also examine relationships between DDT residues in
fish and percent lipids in the filet, age of the fish
and the level of DDT in filets, and the percent of each
isomer in the total DDT level using data and analyses
provided by Olin.
-------
c. Use of resampling, reanalysis, or additional
studies for continued attainment. Following the
attainment of the Performance Standard, the Technical
Committee may require additional information to
evaluate changes in DDT levels. For example, it may
recommend that QA/QC split sample analysis be conducted
for all performance standard fish of concern in each
reach after the initial attainment of the Performance
Standard. It may also recommend that larger sample
sizes be collected, particular fish be reanalyzed, or
that the age of all fish be verified. After the
Performance Standard has been met for three consecutive
years (by species and reach) collection and analysis
may be discontinued but all samples collected shall be
maintained in a repository.
d. Use of data from other sources. The Technical
Committee may use monitoring data from other sources to
evaluate changes in DDT levels in the HSB-IC system;
however, analytical measurements must be supported by
evidence of strict protocols and QA/QC must be
demonstrated to be equivalent to that required of Olin.
Any discrepancies in collection of samples, preparation
of tissues for extraction, or analytical procedures
must be justified to the Technical Committee.
e. Data analysis and presentation. The Technical
Committee may consider other statistical analyses of
the Olin data sets (e.g., geometric means, medians),
pooling of the reach data, and testing the means for
sensitivity to individual data points to determine
trends and patterns of the monitoring results.
D. Evaluation of the Remedial Action
1. The Technical Committee will advise the Review Panel
if, based on their review of the data and the notification
of compliance, they believe that the Performance Standard
was attained and/or continued to be attained in a manner
consistent with the goals and objectives of the Consent
Decree.
a. If the Technical Committee finds that the
Performance Standard has been attained consistent with
the goals and objectives of the Consent Decree, the
Technical Committee may advise the Review Panel whether
or not they believe the Performance Standard will
continue to be met consistent with the requirements of
the Consent Decree as well as document the basis for
such determination.
-------
b. If the Technical Committee finds that the
Performance Standard is not being attained, but that
the remedial action is consistent with the goals and
objectives of the Consent Decree, they will advise the
Review Panel whether or not they believe the remedial
action can attain the Performance Standard over a
longer period of time and whether or not further
remedies are necessary.
c. If the Technical Committee finds that the end of
the compliance period is reached without DDT levels in
fish having reached the Performance standard for all of
the required species within all study reaches as
specified in the consent decree, it may recommend:
extending the compliance period, further sampling to
define/refine any trends, or other options, consistent
with the procedures set forth in the Consent Decree.
2. Following a determination oi: compliance with the .
Performance Standard for channel catfish, largemouth bass,
and smallmouth buffalo, consistent with the goals and
objectives of the Consent Decree discussed in paragraph D.I
of this document, Olin shall submit to the Review Panel a
proposed list of future monitoring activities, DDT
measurements, studies, and other information by which Olin
would demonstrate that the remedy has provided, is providing
and will continue to provide achievement of the Performance
Standard once the Consent Decree terminates.
a. The Technical Committee will review the proposal
of monitoring activities and advise the Review Panel on
its adequacy and/or recommend modifications to the
proposal. The proposal should explain how the future
monitoring activities, studies, and information will be
integrated with existing data.
b. The Technical Committee will seek to coordinate
the monitoring activities of DDT in HSB-IC among the
members, agencies and Olin to minimize duplicative
requirements.
3. Following the approval and implementation of the
monitoring activities and data collection discussed under
paragraph D.2 of this document, the Review Panel and the
Technical Committee will review this information for
compliance with paragraph 54 of the Consent Decree.
-------
III. Conclusion
This decision document is the Review Panel's decision from
its January 23, 1992 meeting. This document consists of 7 pages
of text and one appendix of three pages and comprises the Review
Panel decision. It is accepted and adopted by the representatives
of the Review Panel member agencies and concurred in by the
nonvoting participants as shown by the signatures affixed hereto.
MEMBERS
Anne L.
Chairperson, Review Panel
R. Mark Wilson
U.S. Fish and Wildlife
Service
Dr. Edward S. Bender
"^Washington, D.C.
seph M. Mab
Army, Redstone Ars
Tennessee Valley Authority
James W. Warr
Alabama Department of
Environmental Management
S^ NONVOTING PARTICIPANTS
«0/r -T&-4&L
Honorable Clyde Foster
Town Mf Triana, Alabama
William G. McGlasson
Olin Corporation
DATED: ^ 2 3 1992
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Review Panel Decision Document NO. 9
Appendix A
Long Term Monitoring Data Reporting
Review Panel Decision Document No. 6, as amended, requires
the submission of an annual report describing the previous year's
activities and the data collected. The types of information and
environmental data which are reported are described in the
following sections. Some additional data which are being
reported for the first time in 1992 and they are marked with an
asterisk.
1. Fish Monitoring Program
The fish monitoring program consists of the collection of
performance standard fish, substitute fish, and other fish
species in the spring and a collection of young-of-year
performance standard fish in the fall. General data to be
reported includes species of fish, numbers of fish collected,
field observations and water quality data (pH, dissolved oxygen
and water temperature).
a. Individual fish data to be reported include:
-length
-weight
-filet weight
-total DDT in filet
-DDT isomers in filet
-lipids in filet
-location of capture
-date of capture
b. Additional data on the performance standard fish
collected in the spring include:
-age(either using standard aging techniques or
length-weight relationships)*
-condition factor*
2. Surface Water Monitoring Program
The surface water monitoring program consists of semi-annual
water sampling and velocity-discharge measurements. General data
to be reported include stage elevation, water quality (pH,
dissolved oxygen and water temperature), flowrate, flow velocity
and direction, and field observations.
Individual sample data to be reported include:
-sample location
-------
-sample date and time
-total DDT
-filterable DDT
-total suspended solids
-total organic carbon (3 sampling locations only)
3. Other Environmental Studies
Other monitoring studies may be conducted. These may
include daily water sampling, macroinvertebrate studies and
sediment sampling. Data to be reported will vary from study to
study but will generally include:
-samples collected
-measurements made
-sample/measurement location
-time and date of sampling/measurements
-analytical data (DDT, noisture, etc. as
applicable)
4. Quality Assurance/Quality Control Data
All field sampling and laboratory analyses include a quality
assurance program. Data generated for quality assurance purposes
will also be reported. These data include field, intralaboratory
and interlaboratory data such as:
-split sample results
-spike sample results
-duplicate sample results
-SRM sample results
5. Data Evaluation
Data evaluation will utilize statistical analysis to
describe the data collected for fish, water and other media.
a. Analysis of Fish Data
Analysis of fish data will include the following:
-DDT by reach by species
-DDT by system by species
-DDT by age class by species *
-DDT by lipid content by species*
b. Statistics and Comparisons
Various statistical parameters will be determined and
presented where appropriate for fish and other data. These
ii
-------
include:
-arithmetic mean
-geometric mean*
-median*
-standard deviation
-range
-sample size
-statistical distribution
-other evaluations to describe the data
Comparisons of data to baseline values and previous sampling
years will be presented. Trends in data will be evaluated by
reach and by species for fish data. Trends in water and sediment
data will also be compared where appropriate.
c. Water Data Evaluation
Evaluation of water data will include:
-DDT concentrations by site
-DDT transport by site
-total suspended sediment concentrations by site
-suspended sediment transport by site
Trends and comparisons of water quality data including DDT
concentrations to past data and baseline data will be presented.
d. Quality Assurance Evaluations
Evaluation of the quality assurance data will also be
presented. Both intralaboratory and interlaboratory data will be
evaluated for accuracy and precision. The referee laboratory's
certification will also be included.
iii
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix H. Decision Document No. 10,
Process for Review of Olin's Notifications of Continued Attainment
by the Technical Committee
Decision Document 10-Appendix A , Finding of Continued
Attainment, Largemouth Bass, Reach C, January 19,
1995.
Decision Document 10-Appendix B, Fin«iing of Continued
Attainment Largemouth Bass, Reach A, July 20, 1995.
Decision Document 10-Appendix C, Fimiing of Continued
Attainment Largemouth Bass, Reach B, July 20, 1995
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REVIEW PANEL DECISION DOCDHENT NUMBER 10
PROCESS FOR REVIEW OF OLIN'S NOTIFICATIONS OF CONTINUED
ATTAINMENT BY THE TECHNICAL COMMITTEE
I. Introduction.
Pursuant to the requirements of the Consent Decree,
U.S. vs. Olin Corp.. May 31, 1983, the Review Panel .is authorized
to review the remedial action implemented by Olin and determine
whether the remedy has achieved compliance with the performance
standard consistent with the goals and objectives of the Consent
Decree. The Review Panel may review all significant information
and supporting data to assess the adequacy of the remedy and
compliance with the performance standard, including the Long-Term
Monitoring Reports (Decision Document No. 6), the Interim Goals
(Decision Document No. 5), and advice and data evaluations from
the Technical Committee (Decision Document No. 9).
Pursuant to the Consent .Decree and Decision Documents No. 6
and No. 9, Olin will notify the Review Panel and the Technical ~"
Committee when Olin determines that it has attained the
performance standard and when it has demonstrated continued
attainment of the performance standard. The Joint Technical
Proposal to Implement Remedial Activities Pursuant to Consent
Decree at Section 7.3.2, Measurement of Performance Standard,
defines Attainment and Continued Attainment as follows:
The performance standard is a DDT level of 5 ppm
. in fillets of channel catfish, larcfemouth bass and
smallmouth buffalo in Reaches A, B] and C. Olin
shall be deemed to "attain the performance standard*
when the average DDT concentration in the fillets of
each of the aforementioned fish species is five ppm
(or less) in Reaches A, B, and C. "Continued attainment
of the performance standard* occurs: when the average
DDT concentration in the fillets of each of the
aforementioned.fish species is five ppm (or less) ...
for three (3) consecutive years (including year
of Attainment) in Reaches A, B, and. C.
On behalf of the Review Panel, the Technical Committee will
evaluate Olin's notification of attainment and continued
attainment of the performance standard for each species in each
Reach and determine if attainment and continued attainment of the
Performance Standard have been satisfactorily demonstrated for
purposes of compliance with the Consent Decree and will make
recommendations to the Review Panel. The process for the
Technical Committee review of the monitoring data, other
appropriate factors, and recommendations to the Review Panel is
described in Decision Document No. 9.
-------
The purpose of this document is to establish procedures for
recording the Decisions of the Review Panel relative to
attainment and continued attainment of the performance standard.
The procedures are intended to provide guidance for consistent
reviews and to document the rationale for the decisions in one
easily accessible location. In that spirit, all future
"continued attainment* Decisions will be added as appendices to
Decision Document No. 10.
II. Decision .The decision of the Review Panel is:
A. The Technical Committee will review Olin's notification
of attainment and continued attainment of the performance
standard and supporting data. Through the application of sound
analytical and technical principles, the Technical Committee will
evaluate the data and advise the Review Panel on the status of
the remedial action in attaining and/or demonstrating continued
attainment with the performance standard. Following this
evaluation, the Technical Committee will make recommendations tor
the Review Panel on the continued attainment demonstration for
each species in each Reach and recommend preparation of an
appendix to Decision Document No. 10.
B. The Review Panel will review the recommendations of the
Technical Committee and make a decision as to the demonstration
of continued attainment of the performance standard.
C. The Review Panel will acknowledge the notification of
the attainment of the performance standard for a species in the
Minutes of the Review Panel, meeting.
D. Decisions related to continued attainment of the
performance standard will be documented in signed appendices to
this Decision Document. Each appendix will identify the
notification, the supporting data from.Olin including the EPA
Certification of the data set, and any recommendations of the.
Review Panel fo*r additional mpnitoring or modifications to the
remedial action plan.
E. Once the Review Panel determines that continued
attainment has been achieved for a performance standard species
in a particular Reach, compliance for that species in that Reach
will not be reevaluated until the seventh year of the seven year
period prior to termination o± the Consent Decree. Olin may
continue to monitor that species in that Reach for informational
purposes and will report the results of any informational
monitoring to the Review Panel in the Annual Report.
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III. Conclusion
This Decision Document confirms the Review Panel decision at
its July 21, 1994 meeting. This document consists of three pages
of text and Appendix A with four Attachments and comprises the
Review Panel decision. Appendices for subsequent determinations
of continued attainment of the performance standard will be
attached and incorporated herein as they are developed, approved,
and signed by the Review Panel. Acceptance and adoption of this
document by the representatives of the Review Panel member
agencies and concurrence by the nonvoting participants are shown
by the signatures affixed hereto. .
MEMBERS rs.
Anne L. Asbe11
Chairperson, Review Panel
Dr. W. Allen Robison
U.S. Fish and Wildlife
Service
Dr. Edward S. Bender
EPA - Washington, D.C
Col. Stephen P. Moeller
U.S. Army, Redstone Arsenal.
Robert
Tennessee Valley Authority
James W. Warr
Alabama Department of
Environmental Management
NONVOTING PARTICIPANTS
Honorable Clyde* Poster
Triana, Alabama
William G. McGlasson
01in Corporation
DATED: JAK H IMS
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Review Panel Decision Document No. 10
Appendix A
Finding of Continued Attainment:
Largemouth Bass, Reach C
I. Introduction
Pursuant to the requirements of the Consent Decree, U.S. vs.
Olin Corp.. May 31, 1983, the Review Panel is authorized to
review the remedial action implemented by Olin and determine
whether the remedy has achieved compliance with the performance
standard consistent with the goals and objectives of the Consent
Decree. This Appendix documents the Decision of the Review Panel
regarding Olin's demonstration of continued attainment of the
performance standard for Largemouth bass in Reach C.
II. Findings of the Review Panel
A. Notification* Olin provided notification that Largemouth
bass had demonstrated continued attainment of the performance
standard of 5 ppm DDT in Reach C on June 1, 1994 in Annual Report
Number 6 for the Huntsville Spring Branch Indian Creek Long-Term
Monitoring Program. The data showing DOT concentrations in
Largemouth bass by Tear are presented on Table 22 of the June 1,
1994 Report (copy of Table 22 is attached hereto and incorporated
herein). .
B. Datas The Technical Committee reviewed the data and
determined that the average DDT concentrations in fillets of
Largemouth bass in Reach C have been lens than 5 parts per.
million for four consecutive years, based on data from annual
fish collections from 1990 through 1993.,
C. Quality Assurance Evaluations: The EPA referee
laboratory Certifications -for each set of .data are attached to
this Appendix A and confirm that ,the data are acceptable for use
in determining achievement, of the performance standard set forth
in the Consent Decree. . .
D. RQConTmen.dati.ons for Further Studies or Analysis* There
are no recommendations for further study or analysis by Olin at
this time.
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III. Decision
The Review Panel has evaluated the recommendation of the
Technical.Committee and determined that the data provided by Olin
for Largemouth bass for DDT concentrations in fillets demonstrate
.continued attainment with the performance standard of 5 parts per
million for Largemouth bass in Reach C.
IV..Conclusion
This decision document confirms the Review Panel decision at
its July 21, 1994 meeting. This document consists of two pages
of text and four attachments and comprises the Review Panel
decision. Acceptance and adoption of this document by the
representatives of the Review Panel member agencies and
concurrence by the nonvoting participants are shown by the
signatures affixed hereto.
• MEMBERS s*\
Anne L. As bell
Chairperson, Review Panel
Dr. W. Allen Robison
U.S. Fish and Wildlife
Service
Bender
EPA - Washington, D.C.
Col. Stephen P. Moeller
Army, Redstone Arsenal
Robert J.~ Pryor
Tennessee Valley Authority
is W. Warr
Alabama Department of
Environmental Management
NONVOTING PARTICIPANTS
Honorable Clyde Foster
Town of Triana, Alabama
William 6. McGlasson
Olin Corporation
DATED:
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TABLE 22
AVERAGE DDT CONCENTRATIONS IN FISH BY YEAR
LARGEMOUTH BASS
Parameter piling* Year 1 Year2 Year 3 Year 4 Year5 Year6
128S 1282 122Q 1991 1992 1993
B
n
ave
s.d.
min
max
n
ave
s.d.
min
max
n
ave
s.d.
min
max
21
7.1
7.8
1.2
28
3
37
11
28
49
34
8.2
6.0
1.2
24
10
5.6
5.5
.7
16
'9
5.0
8.5
0.4
27
17
2.7
4.8
0.2
16
17
4.9
4.1
0.2U
15
13
2.2
2.4
0.2U
8.8
26
6.4
13
0.2U
56
18
4.3
4.2
0.11J
16
14
3.7
4.0
0.45
16
A
(&7
1.4
0.64
5.0
14
9.7
6.8
2.0
23
10
9.5
5.6
2.3
21
A
@
3.7
0.03U
12
11
1.5
2.4
0.27
8.0
18
1.3
1.4
0.03U
5.6
Tfi,
c^?
OT89
0.03U
4.0
to
1.2
1.3
0.13
3.8
15-
3.SL'
3.5
0.08
14
•12
&d
1.7
0.50
6.8
* Dedson Document No. 2 [1982-1985 Fish Collection (Year Group H-V)]
DDT concentrations are ppm (mg/kg) in filets
** • • .
n is number of samples analyzed
ave is average DDT concentration (ppm) of samples analyzed
s.d. is standard deviation of the DDT concentrations (ppm)
min is the minimum DDT concentration (ppm) analyzed
max is the maximum DDT concentration (ppm) analyzed
C:HSVTAB6AJX)C
6/1/94
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ENVIRONMeKTAI. SERVICES DCVIStON
ATHENS. GEORGIA 3OO13
May 25, 1994
4ES-AS-LES
SUBJECT:
FROM:
TO:
Huntsville- DDT Project
H. Lavon Revells
Senior Staff Specialist
Analytical Support Branch
O.tcice of Regional Counsel
I have reviewed the fish inter-laboratory comparison data
for the 1993 Huntsville DDT Project and find it acceptable.
There were 38 fish samples split with EPA as the Referee
laboratory and Olin-Charleston as the Primary laboratory. The
average % RSD was 18.8, which is well within the required % RSD
of 30. However, a data bias check performed by Keith Roberts
determined that there was bias between laboratories. Of the 38
split samples, Olin's results were less than EPA's for 32 of
them. Keith Roberts and I have begun studies to determine the
cause of this difference.
cc: Dr. Edward Bender (14OOF, HDQTR)
Mr. Keith Roberts (Olin-Charleston)
•James Finger (ESD)
Wade Knight (ESD)
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U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ENVIRONMENTAL SERVICES DIVISION
ATHENS, GEORGIA
AUGUST 17, 1994
4ES-AS-LES..
MEMORANDUM
SUBJECT: OLIN'S 1991 AND 1992 FISH MONITORING DATA
FROM:
TO:
Lavon Revells, Chemist
Senior Staff Specialist
. chairperson, Review Panel
As you know, Olin's 1991 and 1992 fish monitoring, data were
flagged because the percent relative standard deviation (%RSD) of
split fish sample results between Olin and EPA Region IV Labora-
tories was greater than the target goal of 30. Since the
reporting of the 1991 fish data, representatives from our EPA
laboratory and Olin's primary and secondary laboratories had
several.meetings and discussions in an effort to determine the
cause of the high %RSD. As a result of these discussions, a
series of studies were designed and conducted to identify the
problem areas. While all laboratories were using the same
analytical method, the studies indicated that slight variations
in laboratory procedures could give different results. For this
reason, the procedures were standardized and incorporated into
the method, subsequently, thirty fish samples representing the
1991 and 1992 fish collection were split between the three
laboratories and analyzed according to the standardized pro-
cedures. All samples that had results greater than 5 PPM DDT met
the goal of 30% RSD between Olin's primary and EPA Laboratories.
The Technical committee in it's July 0.993 meeting recommend-
ed that other**QC parameters in addition to %RSD be used in .
evaluating fish monitoring data. The Committee agreed that 30%
RSD is not as important, if the sample results from the Olin and
.EPA laboratories are below 5 PPM DDT.
After reviewing the analytical data and the conclusions of
the Technical Committee, I concur with the recommendation of the
Technical Committee and the decision of the Review Panel to
remove the asterisk from the 1991 and 1992 fish data. The data
are appropriate for use by the Review Panel in making decisions
regarding compliance with the performance standard of 5 PPM DDT
in fillets of performance standard fish.
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FIGURE 3
EPA QUALJTY ASSURANCE DATA CERTIFICATION
UNfTED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION (V
CNVWOMMCNTAL SERVICES DIVISION
ATHENS. GEOflWA 3O61 9
March 11, 1991
Anne Asbell
US Environmental Protection Agency
Office of Regional Counsel
345 Court land St. NE
Atlanta, GA 30365
Dear Anne,
I have reviewed the fieh inter-laboratory comparison data for the
1990. Huntsville DOT Project and find it acceptable. There were 26
fish samples, split with EPA as the Referee lab and Olin-Charleston
as .the Primary lab. The average %RSD was 25%, which is quite
acceptable for fish tissue split samples. Also, a data biae check
performed by Keith Roberts determined that there was no bias
between labs. .
Sincerely yours,.
E. William Loy, Jr.,
Analytical Support Branch
cc: Keith Roberts, Olin-Charleeton
-------
-------
Review Panel Decision Document No. 10
Appendix B
-/
Finding of Continued Attainment
Largemouth Bass, Reach A
I. Introduction
Pursuant to the requirements of the Consent Decree, U.S. vs.
Olin Corp., May 31, 1983, the Review Panel is authorized to
review the remedial action implemented by Olin and determine
whether the remedy has achieved compliance with the performance
standard consistent, with the goals and objectives of the Consent
Decree. This Appendix documents the Decision of the Review Panel
regarding Olin's demonstration of continued attainment of the
performance standard for Largemouth bass in Reach A.
II. Findings of the Review Panel
A. Notificationr Olin provided notification that Largemouth
bass had demonstrated continued attainment of the performance
standard of 5 ppm DDT in Reach A on May 15, 1995 in Annual Report
Number 7 for the Huntsville Spring Branch Indian Creek Long-Term
Monitoring Program. The data showing DDT concentrations in
Largemouth bass by Year are presented on Table 22 of the May 15,
1995 Report (copy of Table 22 is attached hereto and incorporated
herein).
B. Data; The Technical Committee reviewed the data and
determined that the average DDT concentrations in fillets of
Largemouth bass in Reach A have been less than 5 parts per
million for three consecutive years, based on data from annual
fish collections from 1992 through 1994.
C. Quality Assurance Evaluations; The EPA referee
laboratory Certifications for each set of data are attached to
this Appendix B and confirm that the data are acceptable for use
in determining achievement of the performance standard set forth
in the Consent Decree.
D. Recommendations for Further Studies or .Analysis^ There
are no recommendations for further .study or analysis by Olin at
this time.
-------
III. Decision
The Review Panel has evaluated the recommendation of the
Technical Committee and determined', that the data provided by Olin
for Largemouth bass for DDT concentrations in fillets demonstrate
continued attainment with the performance; standard of 5 parts per
million for Largemouth bass.in Reach A.
IV. Conclusion
This decision document confirms the Review Panel decision at
its July 20, 1995 meeting. This document, consists of two pages
of text and four attachments and comprises the Review Panel
decision. Acceptance and adoption of this document by the
representatives of the Review Panel member agencies and
concurrence by the nonvoting participants are shown by the
signatures affixed hereto.
MEMBERS
_
Anne L. Asbell
Chairperson, Review Panel
Dr. W. Allen Robison
U.S. Fish and Wildlife
Service
Dr. Edward S. Bender
EPA - Washington, D.C
Col. Stephen P. Moeller
U.S., Army, Redstone Arsenal
Robert: .J>Pryor
Tennessee Valley Authority
&=-
fames W. Warr
Alabama Department of
Environmental Management
NONVOTING PARTICIPANTS
Honorafcfle 6lyde Foster
Town/of Triana, Alabama
DATED:
William G. McGlasson
Olin Corporation
JUL 20 1955
-------
TABLE22
AVERAGE DDT CONCENTRATIONS IN HSH BY YEAR
LARGEMOUJH BASS
Begsh Parameter Baseline* Year! Year2 YearS Year4 YearS
12SS 19J2 1220. 1221 1222
B
Year 6 Year?
1222 1994
n
ave
s.d.
min
max
n
ave
s.d.
min
max
i
n
ave
s.d.
min
max
21
7.1
7.8
1.2
28
3
37
11
28
49
34
8.2
6.0
1.2
24
10
5.6
5.5
.7
16
9
5.0
8.5
0.4
27
17
2.7
4.8
0.2
16
17
4.9
4.1
0.2U
15
13
23
2.4
_ \
OL2U
8.8
26
6.4
13
0.2U
56
18
4.3
4.2
0.11J
16
14
3.7
4.0
0.45
16
14
2.4
1.4
0.64
5.0
14
9.7
6.8
2.0
23
10
9.5
5.6
2.3
21
13
4.9
3.7
0.03U
12
11
1.5
2.4
0.27
8.0
18
1.3
1.4
0.03U
5.6
26
0.78
0.89
0.03U
4.0
10
1.2
1.3
0.13
3.8
15
3.8
3.5
0.08
14
12
1.4
1.7
0.50
6.8
17
1.6
1.7
0.03U
5.6
* '
'12
1.9
2.3
0.03U
8.2
15
1.1
1.1
0.03U
3.8
DDT concentrations are ppm (mg/kg) in fillets
* Decison Document No. 2 [1982-1985 Fish Collection (Year Group E-V)]
n is number of samples analyzed
ave is average DDT concentration (mg/kg) of samples analyzed
s.d. is standard deviation of the DDT concentrations (mg/kg)
min is the minimum DDT concentration (mg/kg) analyzed
max is the maximum DDT concentration (mg/kg) analyzed
-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ENVIRONMENTAL SERVICES DtVISfON
ATHENS. GEORGIA 3O613
MAY G 8 895
4ES-AS-OCS
MEMORANDUM.
SUBJECT: Huntsville DDT Project, 1994
FROM:
TO:
H. Lavon Revells
Senior Staff Specialist
Analytical Support Branch
of Regional Counsel
I have reviewed the fish inter-laboratory comparison data
for the 1994 Huntsville DDT project and find it acceptable.
There were. 37 fish samples split with EPA as the Referee
laboratory and Olih-Charleston as .the Primary laboratory. The
average % RSD was 18.1, which is veil within the required 30%
RSD. Also; a data bias check performed by Keith Roberts
determined that there was bias between laboratories. However,
this appears to be a minor problem at this time.
cc: Dr. Edward Bender (140OF, HDQTR}
Mr. Keith Roberts (Olin-Charleston)
Mr. Russell Wright (ESD)
Mr. Charles Hooper (BSD)
-------
-------
\ . _-
? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
'•'£*''-. • • REGION-IV
eNVKONMCNTAl. SERVICES (XVtStON
. *'-'" - ATHENS, GEORGIA 3O013
May 25, 1994
4ES-AS-LES .'
SUBJECT: Huntsvill6-DDT Project
FROM: . H. Lavon Revells
Senior staff Specialist
Analytical flupport Branch;
• • ^<
TO: Anne/Asbelil
Of/face of Regional Counsel
I have reviewed the fish. inter-laboratory comparison data
for the 1993 Huntsville DDT Projec.t ,and -find it acceptable.
There were 3& fish samples split with EPA as the Referee
laboratory .and .blin-Charleston as 'the Primary laboratory. The
average. %.RSD was .18.8, which is well within the required % RSD
of 30. ' However, a data bias check performed by Keith Roberts
determined.that there was bias.between laboratories. Of the 38
split samples, Olin's results were less than EPA's for 32 of
them. Keith Roberts and I have begun studies to determine the
cause of this difference.
cc: Dr. Edward; Bender (1400F, HDQTR)
Mr. Keith Roberts (Olin-Charleston)
James Finger (ESD)
Wade Knight (ESD)
-------
-------
U. S. ENVIRONMENTAI, PROTECTION AGENCY
REGION IV
ENVIRONMENTAL SERVICES DIVISION
ATHENS, GEORGIA
AUGUST 17, 1994
MEMORANDUM
Lavon Revells, Chemist
Senior Staff Specialist
Aiinfe LrAsbell
Chairperson, Review Panel
SUBJECT: OLIN'S 1991 AND 1992 FISH MONITORING DATA
FROM:
TO:
.As you know, Olin's 1991 and 1992 fish monitoring, data were
flagged because the percent relative standard deviation (%RSD)* of'
split fish sample results between Olin and EPA Region IV Labora- '
tories was greater than the target goal of 30. Since the . ir
reporting of the 1991 fish data, representatives from our EPA "-
laboratory and oiin's primary and ,secondary laboratories had •-•
several .meetings and discussions,-iti an effort to determine the
cause of the high %RSD. As a result of these discussions, a
series, of-studies were designed and conducted to identify the-
problem areas. While all laboratories were using the same
analytical method, the studies indicated that slight variations
in laboratory procedures could give different results. For this
reason, the procedures were standardized and incorporated into
the method. Subsequently, thirty fish samples.representing the
1991 and. 1992 fish collection were split between the three
laboratories and analyzed according to the standardized pro-
cedures. All samples that had results greater than 5 PPM DDT met
the goal of 30% RSD between Olin's primary and EPA laboratories.
The-Technical Committee in it's July 1993 meeting recommend-
ed that other**QC parameters in addition to %RSD be used in. •
evaluating fish monitoring 'data. The Committee agreed that 30%
RSD is not as important, if the sample results from the Olin and
,EPA laboratories are below 5 PPM DDT.
After reviewing the analytical data and the conclusions of
the Technical Committee, I concur with the recommendation of the
Technical Committee and the decision of the Review Panel to
remove the asterisk from the 1991 and 1992 fish data. The data
are appropriate for use by the Review Panel in making decisions
regarding compliance with the performance standard of 5 PPM DDT
in fillets of performance standard fish.
-------
-------
Review Panel Decision Document No. 10
Appendix C
Finding of Continued Attainment
Largemouth Bass, Reach B
I. Introduction
Pursuant to the requirements of the Consent Decree, U.S. vs.
Olin Corp., May 31, 1983, the Review Panel is authorized to
review the remedial action implemented by Olin and determine
whether the remedy has achieved compliance with the performance
standard consistent with the goals and objectives of the Consent
Decree. This Appendix documents the Decision of the Review Panel
regarding Olin's demonstration of continued attainment of the
performance standard for Largemouth bass in Reach B.
II. Findings of the Review Panel
A. Notification: Olin provided notification that Largemouth
bass had demonstrated continued attainment of the performance
standard of 5 ppm DDT in Reach B on May 15, 1995 in Annual Report
Number 7 for the Huntsville Spring Branch Indian Creek Long-Term
Monitoring Program. The data showing DDT concentrations in
Largemouth bass by Year are presented on Table 22 of the May 15,
1995 Report (copy of Table 22 is attached hereto and incorporated
herein).
B. Datat The Technical Committee reviewed the data .and
determined that the average DDT concentrations in fillets of
Largemouth bass in Reach B have been less than 5 parts per
million for three consecutive years, based on data from annual
fish collections from 1992 through 1994.
C. Quality Assurance Evaluations; The EPA referee
laboratory Certifications for each set of data are attached to
this Appendix C and confirm that the data are acceptable for use
in determining achievement of the performance standard set forth
in the Consent Decree.
D. Recommendations for Further Studies or Analysis; There
are no recommendations for further study or analysis by Olin at
this time.
-------
III. Decision
The Review Panel has evaluated the recommendation of the
Technical Committee and determined that the data provided by Olin
for Largemouth bass for DDT concentrations in fillets demonstrate
continued .attainment with the performance standard of 5 parts per
million for Largemouth bass, in Reach B.
IV. Conclusion
This decision document confirms the Review Panel decision at
its July 20, 1995 meeting. This document consists of two pages
of text and four attachments and comprises the Review Panel
decision. Acceptance and .adoption of this document by the
representatives of the Review Panel member agencies and
concurrence by the nonvoting participants are shown by the
signatures affixed hereto.
MEMBERS
Anne L. Asbell
Chairperson, Review Panel
Dr. W. Allen Robison
U.S.. Fish and Wildlife
Seirvice
Dr. Edward S. Bender
EPA - Washington, D.C.
Cfol. Stephen P. Moellez-
U.S. Army, Redstone Arsenal
Tennessee Valley Authority
James W. Warr
Alabama Department of
Environmental Management
NONVOTING PARTICIPANTS
ie Foster
Town/of Triana, Alabama
William G. McGlasson
Olin Corporation
DATED :
-------
TABLE 22
AVERAGE DDT CONCENTRATIONS IN FISH BY YEAR
/'
LARGEMOUTH BASS
Reach
B
arameter
n
ave
s.d.
min
max
n
ave
s.d.
min
max
n
ave
s.d.
min
max
Baseline* Year 1
21
7.1
7.8
1.2
28
3
37
11
28
49
34
8.2
6.0
1.2
24
J988
10
5,6
5.5
.7
16
9
5.0
8.5
0.4
27
17
2.7
4.8
0.2
16
Year 2
1989
17
4.9
4.1
0.2U
15
13
2,2
2,4
0:217
8.8
26
6.4
13
0.2U
56
Year 3
1990
18
4.3
4.2
0.11J
16
14
3.7
4.0
0.45
16
14
2.4
1.4
0.64
5.0
Year 4
1991
14
9.7
6.8
2.0
23
10
9.5
5.6
2.3
21
13
4.9
3.7
0.03U
12
Year5
1992
11
1.5
2.4
0.27
8.0
18
1.3
1.4
0.03U
5.6
26
0.78
0.89
0.03U
4.0
Year 6
1993
10
1.2
1.3
0,13
3.8
15
3.8
3.5
0.08
14
12
1.4
1.7
0.50
6.8
Year 7
1994
17
1.6
1.7
0.03U
5.6
*
12
. 1.9
2.3
0.03U
8.2
15
1.1
1.1
0.03U
3.8
DDT concentrations are ppm (mg/kg) in fillets
* Decison Document No. 2 [1982-1985 Fish Collection (Year Group H-V)]
n is number of samples analyzed
ave is average DDT concentration (mg/kg) of samples analyzed
s.d. is standard deviation of the DDT concentrations (mg/kg)
min is the minimum DDT concentration (mg/kg) analyzed
max is the maximum DDT concentration (mg/kg) analyzed
C-.HSVTAB7A.DOC
-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
4ES-AS-OCS
REGION IV
ENVIRONMENTAL SERVICES DIVISION
ATHENS. GEORGIA 3O613
•1 AY C SU995
. /
MEMORANDUM
SUBJECT:
FROM:
TO:
Huntsville DDT Project, 1994
H. Lavon Revells
Senior Staff Specialist
f cal Support Branch
ell1
of Regional Counsel
I have reviewed the fish inter-laboratory comparison data
for the 1994 Huntsville DDT project and find it acceptable.
There were 37 fish samples split with EPA as the Referee
laboratory and Olin-Charleston as the Primary laboratory. The
average % RSD was 18.1, which is well within the required 30%
RSD. Also, a data bias check performed by Keith Roberts
determined that there was bias between laboratories. However,
this appears to be a minor problem at this time.
cc: Dr. Edward Bender (14OOF, HDQTR)
Mr. Keith Roberts {Olin-Charleston)
Mr. Russell Wright (BSD)
Mr. Charles Hooper (BSD)
-------
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ENVtRONMGNTAL. SERVICES DIVISION
ATHENS. GEORGIA 3O613
May 25, 1994.
4ES-AS-LES
SUBJECT: Huntsville- DDT Project
FROM: . H. Lavon Revells H^t
Senior Staff Specialist
Ahalytical ftupport Branch:
TO:
Office of Regional Counsel
I have reviewed the fish inter-laboratory comparison data
for the 1993 Huntsville DDT Project and find it acceptable.
There were 38- fish samples split with EPA as the Referee
laboratory and .Olin-Charleston as 'the Primary laboratory. The
average %.RSD was 18.8, which is well within the required % RSD
of 30. However, a data bias check performed by Keith Roberts
determined.that there was bias between laboratories. Of the 38
split samples, Olin's results were less than EPA's for 32 of
them. Keith Roberts and I have begun studies to determine the
cause of this difference.
cc: Dr. Edward Bender (14OOF, HDQTR)
Mr. Keith Roberts (Olin-Charleston)
James Finger (ESD)
Wade Knight (ESD)
-------
-------
4ES-AS-LES..
MEMORANDUM
S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ENVIRONMENTAL SERVICES DIVISION
ATHENS, GEORGIA
AUGUST 17, 1994
SUBJECT: OLIN'S 1991 AND 1992 FISH MONITORING DATA
FROM:
TO:
Lavon Revells, Chemist
Senior Staff Specialist
X
Aimfe L.VAsbel
Chairperson, Review Panel
As you know, olin's 1991 and 1992 fish monitoring, data were
flagged because the percent relative standard deviation (%RSD) of•
split fish sample results between Olin and EPA Region IV Labora- •
tories was greater than the target goal of 30. Since the t~
reporting of the 1991 fish data, representatives from our EPA =
laboratory and oiin's primary and secondary laboratories had ---
several .meetings and discussions, in an effort to determine the
cause of the high %RSD. As a result of these discussions, a
series of .studies were designed and conducted to identify the
problem areas. While all laboratories were using the same
analytical method, the studies indicated that slight variations
in laboratory procedures could give different results. For this
reason, the procedures were standardized and incorporated into
the method. Subsequently, thirty fish samples representing the
1991 and. 1992 fish collection were split between the three
laboratories and analyzed according to the standardized pro-
cedures. All samples that had results greater than 5 PPM DDT met
the goal of 30% RSD between Olin's primary and EPA Laboratories.
The Technical Committee in it's July 1993 meeting recommend-
ed that pther**QC parameters in addition to %RSD be used in.
evaluating fish monitoring data. The committee agreed that 30%
RSD is not as important,' if the sample results from the Olin and
EPA laboratories are below 5 PPM DDT.
After reviewing the analytical data and the conclusions of
the Technical Committee, I concur with the recommendation of the
Technical Committee and the decision of the Review Panel to
remove the asterisk from the 1991 and 1992 fish data. The data
are appropriate for use by the Review Panel in making decisions
regarding compliance with the performance standard of 5 PPM DDT
in fillets of performance standard fish.
-------
Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix I. Decision Document No. 11,
Extension of Time for Meeting the Performance Standard
for Channel Catfish and Smallmouth Buffalo,
December 3, 1998.
-------
REVIEW PANEL DECISION DOCUMENT NUMBER 11
EXTENSION OF TIME FOR MEETING THE PERFORMANCE STANDARD FOR
CHANNEL CATFISH AND SMALLMOUTH BUFFALO
INTRODUCTION
On May 31,1983, the United States District Court for the Northern District of
Alabama (Northeastern Division, the Honorable Robert B. Propst presiding) entered, as part of
an overall order settling litigation between the United States of America, the state of Alabama,
and four sets of private parties against Olin Corporation (Olin), a Consent Decree (CD) that
governs development and implementation of remedial action for DDTR1 contamination in the
Huntsville Spring Branch-Indian Creek (HSB-IC) system.
The CD requires Olin to develop and implement a Remedial Action to meet the
performance standard of 5 parts per million (ppm) of DDTR in filets of channel catfish,
largemouth bass, and smallmouth buffalo in specified reaches of the HSB-IC system:
Reach A-Huntsville Spring Branch mile (HSBM) 5.4-2.4
Reach B-HSBM 2.4-0.0, and
Reach C-Indian Creek mile (ICM) 5.6-0.0.
The purpose of the remedy, monitoring, and other actions that Olin is required to perform
under the CD is to isolate DDTR in the HSB-IC system from people and the environment, to
minimize transport of DDTR out of the HSB-IC system, and to protect human health and the
environment. The performance standard is to be achieved by a remedy consistent with the goals
and objectives of the CD, which are summarized below:
1. Isolate DDTR from people and the environment;
2. Minimize the transport of DDTR out of the HSB-IC system;
3. Minimize adverse environmental impacts of remedial actions;
4. Mitigate effect of DDTR on wildlife habitats in Wheeler National Wildlife Refuge
(WNWR);
1 For purposes of the CD and as used in this report, DDTR is defined as 1,1 ,l-trichloro-2,2-
bis- (p-chlorophenyl) ethane, including its isomers, and the degradation products and metabolites
ODD or TDE (l,l-dichloro-2,2-bis (p-chlorophenyl) ethane), and DDE (l,l-dichloro-2,2-bis (p-
chlorophenyl) ethylene), and the isomers thereof.
Page 1 of 10
-------
5. Minimize adverse effects on operations at Redstone Arsenal (RSA), Wheeler
Reservoir, and WNWR;
6. Avoid any increase in flooding, especially at the city of Huntsville and RSA, except
those increases in water level that can reasonably be expected in connection with
implementation of remedial action, provided Olin takes all reasonable steps to minimize
or prevent such increases; and
7. Minimize the effect of loss of storage capacity for power generation, in accordance
with the TVA Act.
The Review Panel reviewed and approved the proposed remedy for Reach A (Decision
Documents Numbers 1 and 3) and a Long Term Monitoring Program (Decision Document
Number 6) for evaluating progress toward meeting the perfoimance standard.
The performance standard must be achieved within ten years after completion of
construction of the remedial action. The remedial action plan, the long-term monitoring
program, and the attainment of the performance standard are all subject to the review and
approval of the Review Panel.
Paragraph 40 of the Consent Decree provides "If Olin and the United States agree that
Olin has acted in good faith consistent with the schedule set forth in this Consent Decree but has
failed to meet the performance standard within the time set forth herein, Olin and the United
States shall agree to an extension of time for meeting the performance standard...".
DATA
Olin implemented the remedial action plan for Reach A as approved by the Review
Panel. Construction was completed in January 1, 1988. Beginning January 1,1988, Olin
implemented the Long-term Monitoring Program which was approved by the Review Panel in
Decision Document Number 6.
The long-term monitoring plan measured DDTR concentrations in surface water, ground
water, sediments, and fish tissue as an indicator of effectiveness of the remedy in meeting the
goals of the CD. A baseline of conditions for surface water and DDTR concentrations in
performance standard species and other species offish was established before the remedial
action. Other biota were also monitored periodically by Olin and other agencies to measure
DDTR concentrations and assess trends.
Olin submits annual monitoring reports to the Review Panel. Results for 1997
(representing the 10th year after completion of the remedial action) were received in 1998.
Baseline vs. 1997 fish sampling results are as follows:
Page 2 of 10
-------
DDTR in Performance Standard Fish Over Time
Species
Reach DDTR Concentration (ppm) in Fish Filets
% Reduction
from Baseline
Baseline
1988
1997
Channel Catfish
Largemouth Bass
Smallmouth Buffalo
A
B
C
A
B
C
A
B
C
95
69
66
7.1
37
8.2
140
180
110
33
45
36
5.6
5
2.7
31 (1989)
82
89
5.0
6.9
5.5
1.5(1996)
I.I (1996)
0.5 (1996)
12
21
9.4
95
90
92
79
97
94
91
88
92
Largemouth bass have met the performance standard and continued attainment has been
demonstrated in all three reaches for this species in 1994. Channel catfish in Reach A also met
the performance standard in 1997. Channel catfish in Reaches B and C and smailmouth buffalo
in Reaches A, B, and C have not yet met the performance standard. Channel catfish are very
close to.the standard and smailmouth buffalo are approaching it. All three (3) species have
shown a 90%. reduction in DDTR overall and the trend appears to be continuing toward further
reductions.
DDTR concentrations in the water column are believed to be an important route of exposure for
fish in HSB-IC. Baseline vs. 1997 water sampling results are as follows:
Page 3 of 10
-------
DDTR in HSB-IC Water Over Time
Sample
Location
Reach
Total DDTR Concentration (ppb) in Water
Baseline
1988
1997
% Reduction
from
Baseline
HSBM 9.75 Upstream of A
HSBM4.85
HSBM 3.9
HSBM 2.4
ICM4.6
ICM 0.38
ICM 8.2
A
A
A
C
C
Upstream of C
0.77
3.4
12
13
4.3
1.7
0.6
0.0*
0.0*
0.35
1.23
1.51
0.54
0.0*
0.0*
0.0*
0.0*
0.05
0.11
0.0*
0.0*
>98
>98
>98
>97
>98
* Below quantitation limit of the analytical method.
As shown in the above table, average DDTR concentrations in the water column are
reduced by 97% or greater below the baseline conditions (pre-remedial action) throughout the
entire HSB-IC system. Water column concentrations are affected by sediment DDTR
concentrations within the HSB-IC system. The remedial action in Reach A isolated significant
quantities of DDTR in sediments.
The Remedial Action Plan developed by Olin, reviewed and approved by the Review
Panel, has been implemented consistent with all of the goals and objectives of the CD. Even
though the ten year monitoring period has expired, Olin has continued, in good faith, the
monitoring to evaluate changes in DDTR concentrations in performance standard species. The
results for 1998 should be available by the summer of 1999.
Although significant reductions in DDTR concentrations for channel catfish and
smallmouth buffalo have occurred, these species have not achieved the performance standard in
each of the stream reaches. In anticipation of this situation, the Review Panel requested that Olin
provide an evaluation of the progress achieved through the initial ten years and an analysis of
when the performance standard would be achieved. In Olin's. HSB-IC Long-Term Monitoring
Program, Annual Report No. 10, May 15,1998, Olin included extensive trend and statistical
evaluation of the results and projections of when performance standards would be achieved.
Results of this evaluation conclude that channel catfish and smallmouth buffalo would achieve
the performance standard in all three reaches within 5 and 10 years respectively. Based on these
results, Olin made the following recommendations:
Page 4 of 10
-------
1. The attainment period for the channel catfish be extended by five (5) years to
December 31,2002.
2. The attainment period for the smallmouth buffalo be extended by ten (10) years to
December 31,2007.
PUBLIC INVOLVEMENT
On September 15,1998, the Review Panel held a public information meeting at the
Triana Youth Center to inform the public on: a) the progress that had been achieved through
1997 and b) the Review Panel proposal to extend the time to attain the performance standard for
channel catfish and smallmouth buffalo.
At the meeting, members of the Review Panel and other agency representatives discussed
the background of the problem, the design and implementation of the remedy, and the progress
toward meeting the performance standard which is summarized here. Questions were answered
in one-on-one discussions with members of the public. One hundred and fourteen people
attended the sessions. Oral and written comments at the meeting supported the recommendation
of the Review Panel to extend the time to attain compliance with the performance standards,
while requiring monitoring, interim goals, and contingency plans. However, questions from the
public also reflected their concerns about the permanence of the remedy, the necessity for the
time extension, groundwater or water supply contamination, and the risks of eating fish today.
Many individuals said that the monitoring results were very encouraging, they believed that the
remedy would work, and they were pleased with the commitment of all involved.
. After, the public meeting the record remained open for the receipt of written comments
until October 9,1998. Comments offered at the meeting or in writing were consolidated by topic
and are presented with Review Panel responses in Appendix A to this decision document.
RATIONALE FOR THIS DECISION
The Review Panel members recognized the following points in developing this decision:
1. DDTR concentrations in the HSB-IC system have declined significantly in fish, sediments,
and surface water following the construction of the remedial action. Analysis of existing
data predict that further reductions should occur in the future.
2. There is no evidence of contamination of groundwater. Extensive monitoring supports the
conclusion that DDTR does not move in groundwater at this site.
3. DDTR concentrations are expected to continue to gradually decline in sediments and water
due to natural processes, including hydrologic mixing with clean sediments, burial from
Page 5 of 10
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deposition, microbial degradation and irietabolism to other compounds, binding with
organic particles, and photolysis. There is no evidence that additional sources of DDTR
are contributing to the HSB-IC system loadings.
4. The remedial action structures containing the known sources, i.e., DDTR in sediments, have
continued to maintain their integrity and isolate DDTR. Engineering inspections by the
Review Panel's Inspection Committee (comprised of staff from all represented agencies)
confirm that the remedy has been stable and has not required repair or maintenance.
5. The HSB-IC system is a valuable resource, water quality is improving, and desirable species
offish and wildlife are increasing in abundance and diversity. Independent studies and
evaluations by Fish and Wildlife Service, Tennessee Valley Authority, Department of the
Army (both USAGE and Redstone Arsenal), the Environmental Protection Agency, and
Alabama support these conclusions.
6. The DDTR concentrations of fish in Wheeler reservoir have decreased to levels sufficient
that the Alabama Department of Public Health removed its fish consumption advisory
from the Tennessee River in 1996.
7. The Review Panel has reviewed Olin Annual Report No. 10 and concurs that the predictions
of time to achieve the performance standard for channel catfish and smallmouth buffalo
are reasonable estimates based on current data.
8. At this time, it is unclear whether further remedial action would decrease the time to attain
the performance standard.
9. The Review Panel will monitor progress and require action as needed.
DECISION
Based on consideration of achievements to date and public comments, the decision of the
Review Panel is that Olin has acted in good faith with the provisions of the Consent Decree.
Monitoring data verifies that DDTR levels in fish have declined significantly. Concentrations hi
fish, sediment and water have all decreased. Analysis of existing data on fish, water and
distribution of DDTR in sediments support the conclusion that this trend will continue.
Largemouth Bass have met the performance standard in all three reaches since 1992 (with
continued attainment since 1994) and concentrations in channel catfish and smallmouth buffalo
have declined significantly toward the performance standard. Furthermore, all of the goals and
objectives of the CD have been achieved.
The Review Panel concludes that an extension of the time to attain the performance
standard for channel catfish of 5 years (until December 31, 2002) and for smallmouth buffalo of
10 years (until December 31, 2007) should be granted. These extensions are subject to the
conditions that Olin:
Page 6 of 10
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a) monitor to evaluate attainment of the performance standard for these fish species and
the effectiveness of the remedy during the period of the extension;
b) establish interim goals to evaluate progress toward compliance; and
c) develop contingency plans if the interim goals are not achieved, the performance
standard(s) is not attained, or the performance standard(s) cannot be maintained as
defined by the CD.
Within 60 days following the date of this decision document, Olin shall submit to the
Review Panel for review and approval, proposals for:
1) a monitoring program for the balance of the time extension;
2) interim goals for the time extension; and
3) contingency plans in the event that the interim goals or performance standards are not
achieved within the period of this time extension, or the performance standard cannot be
maintained.
Olin shall submit this information to the Review Panel for approval. The current
monitoring program will remain in effect until the Review Panel approves a modification.
Page 7 of 10
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CONCURRENCE
This Decision Document, consisting of text (including this concurrence section) and
appendix A, comprises the Review Panel decision and is accepted and adopted by the
representatives of the Review Panel member agencies and concurred in by the nonvoting
participants as shown below by the signatures affixed hereto.
MEMBERS
Edward S. Bender, Ph.D.
Chairman, Review Panel
W. Allen Robison, Ph.D.
U.S. Fish and Wildlife Service
•Alan Yarbrou
Environmem
£7
rotection Agency
Colonel Steven C. riamilton
U.S. Army, Redstone Arsenal
RobertPryor
Tennessee Valley Authority
James W. Warr
Alabama Department of
Environmental Management
NONVOTING PARTICIPANTS
Honoj>«r&le'Clyde Foster
Town of Triana, Alabama
Dated:
Laura B. Tew
Olin Corporation
DEC 2 1 1998
Page 8 of 10
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Appendix A.
Review Panel Responses to Public Comments
Comments2 listed here are a consolidation of oral and written public comments and
questions on the Review Panel proposed decision to extend the time for meeting the performance
standard for channel catfish and smallmouth buffalo under the terms and conditions of the
Consent Decree, U.S. v. Olin Corporation.
Comment: The remedy has been given ten years to reach the performance standard, why should
more time be granted?
Response: The remedial action for the Huntsville Spring Branch-Indian Creek System
has been very effective in reducing DDTR concentrations in fish, water and sediments.
Concentrations in some fish are declining more slowly than expected when the Consent
Decree was signed. However, monitoring data show that concentrations continue to
decline.
There is convincing evidence that the remedy is working and, given additional time, will
fully comply with the Consent Decree. People and the environment would experience
fewer additional adverse effects by extending the time to allow the trends to continue
declining than by undertaking additional remedial actions that probably would release
additional DDTR into the environment temporarily.
If Olin has acted in good faith consistent with the schedule set forth hi the Consent
Decree but has failed to meet the performance standard, the Consent Decree provides that
the Review Panel shall grant an extension of time for meeting the performance standard.
The Review Panel has concluded that Olin has acted in good faith in planning,
construction, and monitoring the remedial action project. Consequently, at this point, a
time extension is prudent and consistent with the Consent Decree.
Comment: What is the basis for the time period of the extension?
Response: Monitoring data have shown that the average concentrations of DDTR are
declining in the water column and in fish filets. Analysis of this data can be used to
estimate the amount of time required to achieve the performance standard. The Review
Panel reviewed analyses supplied by Olin and concurred with predictions of the time for
channel catfish and smallmouth buffalo to reach the performance standard.
Comment: What will Olin do if they are given more time to reach the performance standard?
2 Comments received about the medical fund monies were forwarded to the Chair of the Health
Review Panel because the issues raised were outside the scope of this Review Panel.
Page 9 of 10
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Response: During the period of the extension, Olin must continue to monitor DDTR
concentration trends and maintain the remedy. Olin also must continue to report annually
to the Review Panel on progress toward achieving the performance standard. If progress
toward achieving the performance standard is not considered to be adequate by the
Review Panel, Olin must pursue contingency plans. In addition, Olin must comply with
all other provisions of the Consent Decree.
Comment: What is the current status of DDTR contamination in fish for the Triana area?
Response: In 1996, the State of Alabama lifted the fish consumption advisory in the
Tennessee River in the vicinity of Triana. Average DDTR concentrations in channel
catfish and smallmouth buffalo in Indian Creek and Huntsville Spring Branch continued
to exceed the performance standard in 1997, and the fish consumption advisory for
bottom-feeding fish (primarily channel catfish and smallmouth buffalo) in Indian Creek
and Huntsville Spring Branch remains in effect. Largemouth bass have achieved the
performance standard and are not subject to the fish consumption advisory in the HSB-IC
system or the Tennessee River.
Page 10 of 10
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix J
Joint Petition for Modification of Schedule to Meet Consent Decree Performance
Standards and Court Order
J-l
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THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF ALABAMA
NORTHEASTERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
OLIN CORPORATION,
Defendant.
CIVIL ACTION
NO. CV80-PT-5300-NE
JOINT PETITION FOR MODIFICATION OF SCHEDULE TO MEET
CONSENT DECREE PERFORMANCE STANDARDS
The United States of America, on behalf of the U.S. Environmental
Protection Agency (EPA), the U.S. Fish and Wildlife Service (FWS), the U.S.
Department of the Army (DOA), and the Tennessee Valley Authority (TVA), joins
with Olin Corporation in filing this Petition for Modification of Schedule to Meet
Performance Standards. This Petition is being filed pursuant to Paragraph 40 of
the Consent Decree entered by this Court on May 23,1983. A copy of the Consent
Decree is attached to this Petition as Attachment A
I. BACKGROUND
On December 4,1980, the United States filed a Complaint against Olin
Corporation alleging that Olin's discharge of DDT into the waters of the United
States, the Wheeler National Wildlife Refuge, and the environment from Oiin's
DDT manufacturing plant located on the Redstone Arsenal, had created an
imminent and substantial endangerment to human health and the environment.
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The United States sought relief under federal statutory law and common law.1' -
On May 31,1993, this Court entered a Consent Decree between the United
i
States and Olin Corporation under which Olin agreed to conduct cleanup activities
at its former DDT plant (also known as the Olin Superfund Site) in order to abate
the risk of harm. More specifically, the Consent Decree required Olin to develop
and implement a remedial action plan which will isolate DDT contaminated soils
and sediments from people and the environment, and reduce DDT levels in filets of
three selected indicator fish species to 5 parts per million (ppm) within ten (10)
4
years after Olin completed construction of the remedy. The Consent Decree
established a Review Panel with voting members from EPA, TVA, FWS, and DOA,
and the State of Alabama2', and non-voting members from Olin and the Town of
Triana, Alabama. The Review Panel is authorized to make decisions concerning the
selection and modification of the remedy, achievement of performance standards,
compliance with the goals and objectives of the Decree, and other activities
required under the Decree. The Review Panel approved Olin's proposed remedial
action plan. ;
Olin implemented the remedial action and completed construction on
January 1,1988. A ten-year monitoring period began on January 1,1988, and the 5
^Congress enacted the Comprehensive Environmental Response, Compensation,
and Liability Act ("CERCLA" or "Superfund") in 1980.
State of Alabama filed a separate suit (Civ. Action No. CV79-PT-5174-NE)
against Olin seeking similar relief to that requested by the United States. The
Court consolidated the cases.
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ppm performance standard was required to have been achieved by December 31
1997. During the monitoring period, Olin measured DDT concentrations in the
surface water, ground water, sediments, and fish tissue as an indicator of the
effectiveness of the remedy. Results for 1997, representing the 10th year after
construction of the remedy, were received in 1998 and indicated that while the
remedy has been successful in achieving the Goals and Objectives set out hi
paragraph 13 of the Decree, the performance standards have not yet been met in all
3 fish species in all 3 reaches of the river system.
4
Largemouth bass have met the performance standard and continued
attainment has been demonstrated in all three reaches for this species in 1996.
Channel catfish in Reach A have also met the performance standard. Channel
catfish in Reached B and C and smallmouth buffalo in Reaches A, B, and C have not
yet met the performance standard. All three species have shown a 90% reduction
in DDT overall and the trend appears to be continuing toward further reductions.
• Based on these results, the Review Panel requested Olin to provide and evaluation
of the progress achieved during the ten-year monitoring period and projection of
when the performance standard would be met for channel catfish and smallmouth
buffalo. Olin's Annual Report No. 10, dated May 15, 1998, included extensive trend
and statistical analyses of the monitoring results, and concludes that channel
catfish would achieve the performance standard within 5 years, and
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smalimouth buffalo within 10 years. Based on this report, Olin recommended that:
1. The schedule for attainment of the performance standard for channel catfish
be extended five years to December 31,2002;
2. The schedule for attainment of the performance standard for smallmouth
buffalo be extended by ten years to December 31,2007.
After extensive review and evaluation of Olin's recommendations, the
Review Panel concurs with Olin's conclusions and recommendations concerning
the attainment of the performance standard. The evidence in the record strongly
indicates that the decline in DDT levels will Continue and that the performance
standard will be met without the need for additional remedial action. The Review
Panel's findings and concurrence with Olin's recommendations are set forth in
Decision Document #11 (attached hereto as Attachment B)2'. Prior to signing the
Decision Document, the Review Panel issued a Proposed Plan which explained the
Review Panel's findings and the proposed schedule extension. A public meeting
was conducted on September 15,1998, and the public: comment period remained
open until October 9,1998. None of the comments received by the Review Panel
presented compelling facts or circumstances which demonstrated that the schedule
extension agreed to by Olin and the Review Panel Review is inappropriate, unfair or
unlawful. A summary of the public comments submitted to the Review Panel and
Decision Document, requires Olin to submit to the Review Panel, for review
and approval, proposals for a monitoring program and establishments of interim
goals to be met during the time extension, and contingency plans in the event that
the interim goals or performance standards are not achieved within the period of
the extension.
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the Review Panel's responses thereto are included in Decision Document #11.- The
review Panel members, including the non-voting members Olin Corporation and
the City of Triana, have signed Decision Document #11.
Paragraph 40 of the Consent Decree provides "If Olin and the United States
agree that Olin has acted in good faith consistent with the schedules set forth in
this Consent Decree but has failed to meet the performance standards within the
time set forth herein, Olin and the United States shall agree to an extension of
time for meeting the performance standard, shall jointly petition the Court for a
modification of the schedule and Olin shall not be liable for penalties set forth in
paragraph 35 based solely on its failure to meet the performance standard within
the time required during such extended period." The Review Panel (comprised of
4 agencies of the United States) and Olin have agreed that Olin has acted in good
faith with the Consent Decree. Therefore, under paragraph 40 of the Decree, the
parties are petitioning the Court to grant an extension of time for Olin to achieve
the performance standard. .
II. REQUEST FOR MODIFICATION OF SCHEDULE
Based on the foregoing facts and circumstances, the United States and Olin
Corporation hereby request the Court approve a modification of the schedule in
the Consent Decree for compliance with the performance standard as follows:
1. The time for attainment of the performance standard for channel
catfish shall be extended from December 31, 1997, until December 31,
2002.
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2. The time for attainment of the perfomuince standard for smallmouth
buffalo shall be extended from December 31,1997, until December 31,
2007,
Respectfully Submitted,
Cheryl L. S6fout
Trial Attorney
Environment and Natural«Resources
Division
U.S. Department of Justice
P.O. Box 7611
Washington, D.C. 20044-7611
202-514-5466
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Signature Page for Joint Petition For Modification Of Schedule To Meet Consent
Decree Performance Standards in United States v. QHn Corporation CV80-PT-5300-
NE (N.DJMa.)
ON BEHALF OF OLIN CORPORATION
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MflY-10-1999 09:54
USDC HUNTSUILLE
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OP ALABAMA
NORTHEASTERN DIVISION
JAMES CLOUD, ET AL. ,
205 551 074i P.082/003
FILED
99RPR23 P« 1*32
U.S. OiSVRiCT COURT
H.O. OF AlABAH*
PLAINTIFFS,
vs.
OI.IN CORPORATION, ET AL.,
DEFENDANTS,
CV79-S-
CV79-S-
CV80-S-
CV80-S-
CV80-S-
CVBO-S-
S128-NE
5174-NE
5057-NE
S09B-NE
5300-NE
5115-NE
ENTERE
yr\
4PR 2 3 1999
This action is before the court on the joint petition for
modification of schedule to meet consent decree - performance
standards filed February 26, 1999. The court has reviewed the
Consent Decree entered May 31, 19B3 (the "Decree"), the attachments
and submittals of the parties, particularly the Review Panel
Decision Document No. 11 dated January 5, 1999, and is of the
opinion that the petition should be granted. Accordingly, it is
ORDERED, ADJUDGED, and DECREED as follows: (1) the time for
attainment of the performance standard for channel catfish shall be •
extended from December 31. 1997, until December 31, 2002; and (2)
the time for attainment of the performance standard for smallmouth
buffalo shall be extended from December 31, 1997, until December
31. 2007.
DONE this 23 "~_ day of April, 1999.
Unitkd) States District Judge
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