United States        Office of
          Environmental Protection   Emergency and
          Agency          Remedial Response
EPA/ROD/R04-93/132
February 1993
&EPA    Superfund
          Record of Decision:
          National Southwire Aluminum,
          KY

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 50272-101	

   REPORT DOCUMENTATION
           PAGE
1. REPORT NO.
EPA/ROD/R04-93/132
3. Recipient's Ace eaelnn No.
    Title and Subtitle
    SUPERFUND RECORD OF DECISION
    National Southwire Aluminum,  KY
    First Remedial Action
                                          &   Report Date
                                         	02/19/93
 7.  Aulhor(t)
                                         a   Performing Organization Rapt. No.
 8.  Performing Organization Nam* and Addrasa
                                         10  Project Task/Work UnH Ho.
                                                                    11.  Contract(C)orGrant(G)No.
                                                                    (Q

                                                                    (6)
 12  Sponsoring Organization Nama and Address
    U.S. Environmental Protection Agency
    401 M Street,  S.W.
    Washington,  D.C.  20460
                                         13. Type of Report & Period Covered

                                            800/800
                                         •M.
 1&  Supplementary Notaa

               PB94-964036
 16.  Abatraet (UmH: 200 words)

  The  1,100-acre National Southwire  Aluminum site is  an active aluminum manufacturing
  facility situated within a 100-year alluvial floodplain of the Ohio  River in Hancock
  County,  Kentucky.   Site features include several manufacturing and service buildings,
  three  former site waste disposal impoundments, an active wastewater  impoundment, three
  former waste disposal  landfills, .a spent potliner accumulation building,  and a drainage
  ditch.   Adjacent to the site are an airport, a rod  and cable mill, and a power plant.
  The  site is externally fenced; however,  the surface impoundments are not isolated by
  fencing  from other  portions of the site  such as the adjacent airfield.   There are no
  barriers to human or wildlife movement between the  surface impoundments and this public
  airfield.   Site operations began in 1969, producing primarily aluminum from alumina
  ore. This process includes the production of cyanide,  which accumulates as a residual
  in the potliners at levels up to 2,500 mg/kg.  In 1971,  National Southwire Aluminum
  (NSA) began removing spent potliners and, in 1973,  constructed the concrete Dump Pad
  for potliner removal.   During removal, water was used to soak the spent potliner and
  later this spent water accumulated in an earthen sump which is believed to have leached
  into the ground water.  Water is no longer used in the process and the sump is now
  filled in with sand and covered with concrete. Two  industrial landfills and the Taylors

  (See Attached Page)
17. Document Analysis    a Descriptors
   Record of Decision - National Southwire Aluminum, KY
   First Remedial Action
   Contaminated Medium: gw
   Key Contaminants:  metals  (arsenic, chromium,  lead), inorganics (cyanide)

   b.   Identlflers/OpetvEnded Terms
   c  COSATI Field/Group
ia Availability Statement
                         19. Security Class (This Report)
                                   None
                                                    20.  Security Qass (This Page)
                                                              None
         21.  No. of Pages
                 152
                                                                              22. Price
(SeaANSI-238.18)
                                   Se» Instruct/on* on R»
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 EPA/ROP/R04-93/132
 National  Southwire Aluminum,  KY
 First  Remedial Action

 Abstract  (Continued)

 Wash Landfill  have been utilized for onsite disposal of hazardous materials.  It is
 estimated that approximately  30,000  yd^  of industrial waste was disposed of in the Taylors
 Wash Landfill  prior to 1981.  After 1981,  it is estimated that approximately 40,000 yd^ and
 10,000 yd^ of  industrial waste was disposed of in the two industrial landfills,
 respectively.   In addition, NSA constructed the North Pond, Old South Pond, East Pond, and
 New South Pond to dispose of  industrial  waste from the facility.  In 1986, the company
 closed the North Pond and covered it with a clay and soil cover.  As a result of the
 manufacturing  process,  approximately 26,000 yd^ of spent potliner material containing
 cyanide,  fluoride,  and metals,  was disposed of in the unlined North Pond.  This material
 has contaminated onsite ground water in  the vicinity of the North Pond and the Spent
 Potliner  Accumulation Building.   Since 1986, NSA has disposed of the spent potliners
 offsite at a. hazardous waste  disposal facility. The Old South Pond is filled to capacity
 and has not been used since 1969,  and the unlined East Pond also has been closed.  The New
 South  Pond is  used now for the disposal  of calcium fluoride slurry and electrostatic
 precipitator catch.   In 1985  and 1986, the State conducted studies that revealed
 contamination  in the sediment,  and as a  result, in 1989 ordered NSA to excavate and
 dispose of 2,000 yd^ of contaminated sediment.  In 1990, NSA constructed the Spent
 Potliner  Accumulation Building to replace the Dump Pad for potliner removal and transfer
 of contaminated waste for offsite disposal.  Later in 1990, NSA excavated approximately
 4,200  yd^ of rock and soil from the  site and covered the area with asphalt to further
 reduce the potential for contaminated dust generated from the spent potliner removal
 process to enter the existing storm water ditches.  Repeated spills of heat transfer
 fluids or other PCBs containing fluids caused several areas of PCB contamination in onsite
 soil.   As a result,  in 1991,  850 yd^ of  PCB-contaminated soil was removed from a cooling
 tower  excavation and disposed of in  an approved EPA facility.  While PCBs have been
 identified in  onsite soil at  several locations, there has been only one detection of PCBs
 in onsite ground water; in a  landfill standpipe.  No PCBs have been detected in any onsite
 ground water outside of this  isolated standpipe location.  A final action ROD will address
 all additional remedial activities that  will be required to clean up the site.  This
 interim ROD addresses ground  water contamination at the site.  The primary contaminants of
 concern affecting the ground  water are metals, including arsenic, chromium, and lead; and
 other  inorganics,  including cyanide.

 The selected remedial action  for this site includes implementing a multiple-well gathering
 and pump  and treat  system to  remediate two onsite contaminant plumes; installing
 withdrawal wells in  the unconsolidated aquifer in strategic positions to recover the
 maximum amounts of  contaminated ground water; utilizing intermittent pumping on a varying
 selection of the wells  within each plume to manage the plumes and control contamination
 levels  in ground water  influent  to the treatment plant; treating ground water onsite using
 a chemical coagulation/precipitation process, which includes clarification and dewatering
 processes specifically  selected to remove cyanide, fluoride, and metals from the ground
 water  entering the  system; discharging the treated effluent water to surface water; and
 dewatering and disposing of approximately 2.5 tons of sludge resulting from the treatment
 process offsite in an approved disposal  facility.  The estimated construction cost for
 this remedial  action is $1,700,000,  which includes an estimated annual O&M cost of
 $570,000  for 0.5 years.

 PERFORMANCE STANDARDS OR GOALS:

 The interim treatment standards  will comply with the State discharge limits, but the final
 cleanup standards will  meet SDWA MCLGs and MCLs. Chemical-specific ground water cleanup
 goals  include  arsenic 0.05 mg/1;  barium  1 mg/1; cadmium 0.0039 mg/1; chromium  (III) 1.74
mg/1; chromium (IV)  0.016 mg/1;  copper 0.0177 mg/1; cyanide  (free) 0.022 mg/1; cyanide
 (total) 0.2 mg/1;  fluoride 1  mg/1; iron  4 mg/1; lead 0.0816 mg/1; mercury 0.0024 mg/1;
 nickel  1.42 mg/1; PCBs  0.0014 ug/1;  and  zinc 0.117 mg/1.

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   SOUTHWIRE ALUMINUM
 liiirsopgftFONirsiTiL
FEBRUARY 19, 1993

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                        RECORD OF DECISION

                         THE DECLARATION

SITE NAME AMD LOCATION

National  Southwire Aluminum  Company  Site,  Hawesville,  Hancock
County,  Kentucky.

STATEMENT AND BASIS OF PURPOSE

This  decision document  presents the  selected  Interim  Remedial
Action  for  the National  Southwire  Aluminum Company  (NSA)  Site,
approximately four miles northwest of Hawesville, Hancock County,
Kentucky, which was chosen in accordance with CERCLA,  as amended,
by  SARA and,  to  the  extent  practicable, the  National Oil  and
Hazardous  Substances   Pollution  Contingency  Plan  (NCP).    This
decision is based on the administrative record for this Site.  The
Commonwealth of Kentucky concurs with the selected remedy.

ASSESSMENT OF THE SITE

Actual  or  threatened  releases of hazardous  substances  from this
Site, if not  addressed by implementing the response action selected
in  this  Interim  Action Record of Decision  (ROD) , may present an
imminent and substantial endangerment to public health, welfare, or
the environment.

DESCRIPTION OF THE REMEDY

This Interim Remedial  Action  employs  the use of extraction wells
combined with a pump and treat system in order to prevent further
ground water plume  migration,  to reduce contaminants  in the Ohio
River Valley alluvial aquifer  at  the Site, and to reduce the threat
of  additional contamination of the  Ohio River.   This  action will
also initiate ground water restoration while  the Remedial Investi-
gation and Feasibility Study (RI/FS) and post RI/FS activities are
being completed.  Onsite contamination identified in the unconsol-
idated alluvial aquifer consists of cyanide,  metals, and fluoride
in  two  onsite ground water plumes.   Leachate  identified  in the
onsite  landfills  contains the  above  contaminants  as  well  as
volatile and semi-volatile organics, and polychlorinated biphenyLs
(PCBs).   These contaminated waters need to be further investigated
as part of the RI/FS, then later remediated  during the Final Site
Remedy.

The components of the Selected Interim Remedy are as follows:

•    Extraction of  contaminated  alluvial  aquifer ground water;

     Treatment of contaminated ground water;
                               -i-

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       Discharge  of  treated  ground water  to  the  Ohio  River  (in
       accordance with KPDES requirements);

  •    Proper disposal of all sludge generated via the pump and treat
       action (in accordance with RCRA requirements) .


  STATUTORY DETERMINATION

  The Interim Remedial Action is protective of human health and the
  environment in the short term and is intended to provide adequate
  protection until a final ROD is signed.  It complies with Federal
  and  State  applicable or relevant  and appropriate requirements
  (ARARs)  for  this  limited-scope action,  and  is  cost-effective.
  Although this Interim Remedial  Action  is  not intended to address
  fully the  statutory  mandate  for permanence  and treatment  to  the
  maximum  extent  practicable,  this  Interim  Remedial Action  does
  utilize  treatment  and  thus is  in  furtherance of  that statutory
  mandate.  Because this action  does not  constitute the Final Remedy
  for the  Site, the  statutory preference for  remedies  that  employ
  treatment that reduces toxicity, mobility, or volume as  a principal
  element, although  partially  addressed in this  remedy, will  be
  addressed by the final  response action.  Subsequent  actions  are
  planned to address fully the  threats posed by conditions at  this
  Site.   Because  this remedy will  result in  hazardous  substances
  remaining  on-site  above health-based  levels, a  review will  be
  conducted to ensure that the remedy continues to provide adequate
  protection of human health and  the  environment_within five years
  after commencement of the  remedial action.   Because  this is  an
  Interim Action ROD,  review  of  this Site and of  this remedy will be
  ongoing as  EPA contfpiues to develop final remedial alternatives for
  the^Site.        I"
yyJ'a'trick Tobin                                         Date
A  Acting Regional Administrator
                                 -11-

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                        RECORD OF DECISION
             NATIONAL SOUTHWIRE ALUMINUM COMPANY SITE

                        TABLE OF CONTENTS
Description                                                  Page

DECLARATION	i

LIST OF FIGURES	vi

LIST OF TABLES	.vii

1. 0  INTRODUCTION	1

2 . 0  SITE BACKGROUND	1

     2.1  Site Name, Location, and Description	1
     2 .2  Physiography and Topography	4
     2 .3  Geology	4
     2 .4  Hydrogeology	10
          2.4.1 Monitoring Well Installation Summary	12
     2 .5  Affected Population	17
     2 .6  Ecological Information	17
     2 .7  Water Usage	.17
     2 .-8  Adjacent Land Usage	-,	18
     2 .9  Climatology	17

3 . 0  SITE HISTORY AND ENFORCEMENT ACTIVITIES	17

     3 .1  Operational History	17
          3.1.1. Pptliner Removal and Disposal	18
          3.1.2. Disposal Pond Areas	19
          3.1.3. Site Landfilled Areas	19
          3.1.4. Refractory Brick Disposal Area	20
          3.1.6. PCB Handling Areas	20
     3 .2  Enforcement Summary	21
          3.2.1. RCRA Summary	22
          3.2.2. TSCA Summary	23

     4 .0  HIGHLIGHTS OF COMMUNITY PARTICIPATION	 2 3

     5.0  SCOPE AND ROLE OF RESPONSE ACTION
               WITHIN SITE STRATEGY	24

     6 . 0  SUMMARY OF SITE CHARACTERIZATIONS	25
          6.1  Nature and Extent of Contamination	25
                6.1.1. Cyanide Evaluation	25
          6.2 Disposal Ponds/Wastewater Impoundments	26
                               -111-

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     6.3 Ground Water Contamination and
               Onsite Impoundments	28
          6.3.1. North Ground Water Plume	28
          6.3.2. South Ground Water Plume	38
     6.4 Effluent/Drainage Ditch	38
     6.5 Cooling Tower Excavation	38
     6.6 Onsite Soils Contamination	42
     6.7 Onsite Landfill Contamination	42
          6.7.1. Taylors Wash Landfill	42
          6.7.2. Industrial Landfills	42
     6 .8 Onsite Production Wells	43

7 . 0 SUMMARY OF SITE RISKS	43

8 . 0  DESCRIPTION OF REMEDIAL ALTERNATIVES	44
     8.1  Alternative 1: No Action	45
     8.2  Alternative 2 :  Pump & Treat System	45

9.0  SUMMARY OF COMPARATIVE ANALYSIS OF
          ALTERNATIVES	46
     9.1  Overall Protection of Human Health and
               the Environment	46
   -  9.2  Compliance with ARARs	46
          9.2.1. Action Specific ARARs	49
          9.2.2. Location Specific ARARs	50
          9.2.3. Contaminant  Specific ARARs	50
     9.3  Long-Term Effectiveness  and Permanence	.51
     9.4  Reduction of Toxicity, Mobility, and Volume	51
     9 .5  Short-Term Effectiveness	52
     9.6  Implement ability	52
     9 .7  Cost	53
     9 .8  State Acceptance	53
     9.9  Community Acceptance	53

10 . 0 THE SELECTED REMEDY	53
     10.1 Performance Standards	55
          10.1.1. Ground Water Withdrawal Limits	55
     10 .2 System Operating Parameters	55
     10.3 ARAR Requirements	55

11.0 STATUTORY REQUIREMENTS	58
     11.1 Protection of Human Health and
               the Environment	*	 59
     11.2 Attainment of  ARARs	59
     11.3 Cost Effectiveness	59
     11.4 Utilization of Permanent Solutions and
          Alternative Treatment Technology or Resource
          Recovery Technologies to the Maximum Extent
          Practicable	59
     11.5 Preference for Treatment	59
                          -iv-

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12 . 0 RESPONSIVENESS SUMMARY	60
          12 .1 Overview	62
          12.2 Background of Community Involvement and Concerns.63
               12.2.1 Questions and Answers about the Project...64
          12.3 Summary of Major Questions Raised During
                    the Public Meeting on January 19, 1993	70
          12.4 Comments From Local Officials	79
          12.5 Written Comments Received During Public
                    Comment Period and EPA Responses	90

     Appendices:

          Appendix A: Technical Information

          A.l) Technical Memorandum  #1  (Drilling  and Monitoring
               Well Installation)
          A.2) Technical Memorandum #2 (Ground Water Sampling)
          A.3) Technical Memorandum #7 (Aquifer Pump Test)
          A.4) Technical Memorandum  #8  (Ground water  modeling &
               Treatability Study for Ground Water)
          A. 5) Analytical Data from the LSI Report
          A.6) Summary of Monitoring Well Installation at the NSA
               Site

          Appendix B: Copy of the Proposed Plan Presented at the
                 Public Meeting, January 19, 1992,
                 Hawesville,  Kentucky.

          Appendix C: Information Repository Location

          Appendix D: Letter of Concurrence
                               -v-

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Figure 1)
Figure 2)
Figure 3)
Figure 4)
Figure 5)
Figure 6)
Figure 7)
Figure 8)

Figure 9)

Figure 10)

Figure 11)

Figure 12)
Figure 13)

Figure 14)

Figure 15)

Figure 16)
Figure 17)
Figure 18)
            LIST OP FIGURES
Site Vicinity Map	2
Areas of Waste Disposal and Spill Investigation	3
Stratigraphy of the Hawesville,  Kentucky Area	5
Top of Bedrock Contour Map	6
Cross-Section Locations	7
Geologic Cross-Section  A-A'	8
Geologic Cross-Section  B-B'	9
Piezometric Surface Contour Map:
Typical Conditions . (June 1989)	11
Ground Water Levels and Piezometric Surface:
Typical Conditions  (June 1992)	13
Piezometric Surface Contour Map:
Flow Reversal  (January 1990)	14
Ground Water Levels and Estimated Piezometric
Surface: High River Stage Bank Storage (May 1992) . . .15
Cyanide Isopleth Map (January 1990)	34
Concentration of Amenable Cyanide in
Ground Water	35
Concentration of Total Cyanide  in
Ground Water	36
Schematic Cross-Section of Cyanide
Plume (January 1990)	37
Shallow PCS Contamination (in Soils)	39
Deep PCB Contamination (in Soils)	40
PCS Soil Stockpile Area	41
                               -vi-

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                          LIST OF TABLES

Table 1)  Summary of Water Quality Criteria: Hydrologic
          Assessment of the Disposal Ponds (EPM Study,  1979)	27

Table 2A) Results of Cyanide Analyses (2/27/92-4/2/92)	29

Table 2B) Results of Cyanide Analyses (4/21/92-4/28/92)	31

Table 2C) Industrial Well/EPA Monitoring Well Sampling	33

Table 3)  EPA Criteria For Evaluating Cleanup Alternatives	47

Table 4A) Summary of KPDES Effluent Discharge  Limitations
          and Monitoring Requirements	56

Table 4B) Treatment Plant Effluent Standards and
          Kentucky Water Quality Standards	57

Table 5)  Preliminary System Design and Operating Parameters	58
                               -vii-

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                INTERIM ACTION RECORD OF DECISION
            SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
               NATIONAL SOUTHWIRE ALUMINUM COMPANY
                    SITE,  HAWBSVILLB,
1.0  INTRODUCTION

The National Southwire Aluminum (NSA) Company Site (the "Site") was
proposed for the National Priorities List  (NPL) on July 29, 1991,
as defined in Section 105 of Comprehensive Environmental Response
Compensation and Liability Act of 1980  (CERCLA) , as amended by the
Superfund Amendments and Reauthorization Act of 1986  (SARA, P.L.99-
499) .  The NSA Site was ranked utilizing the Hazard Ranking System
(HRS) and scored 50.0 out of a possible 100 points.  This HRS score
was calculated as part of the Site Investigation conducted by EPA's
Region IV Field Investigation Team (FIT) which collected samples at
the Site in 1986.  This Interim Remedial Action  Record of Decision
(ROD)  has  been  prepared  to  summarize the  remedial  alternative
selection process and to present the selected remedial alternative,
in accordance with  Section  113 (k) (2) (B) (v) and Section 117 (b)  of
CERCLA as amended by SARA..   The Administrative Record file for the
National Southwire  Aluminum Company  Site  forms the  basis for the
Record of Decision herein.
2.0  SITE BACKGROUND

     2.1  Location, and Description

     This aluminum manufacturing facility is located on an 1,100-
     acre tract of land in Hancock  County, Kentucky.  This Site is
     .situated  within  the broad  alluvial  floodplain of  the  Ohio
     River of  northwestern Kentucky, approximately  thirty miles
     east of Owensboro  (Figure 1).   Much  of the Site lies within
     the 100-year floodplain of the Ohio River.

     The Site  has been  utilized  from 1969 to the present,  and is
     currently an active facility.  The operation produces primary
     aluminum from alumina ore.   Site features  include a number of
     manufacturing and  service  buildings  (Figure 2),  three (3)
     former  Site waste  disposal  impoundments,  one  (1)  active
     wastewater  impoundment,   three   (3)  former  waste  disposal
     landfills, a potliner  accumulation building,  and a drainage
     ditch.   In the central-western  portion of the Site  is the
     Hancock County Airport.  At the southeastern portion of the
     Site  is   the  Southwire Rod and Cable  Mill  (a division of
     Southwire Company  of Carrollton, Georgia).   Adjacent to the
     Site  (northwest)  is  the Big Rivers Power Plant.
                               -1-

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                                                           National Southwire Aluminum Co.
                                                                       , Hancock County. Kentucky
        SCALE IN FEET
                                FIGURE 1
                            SITE VICINITY MAP
BASE MAP SOURCE: USGS 7 1/2 minute
topographic quadrangle map. Tel City.
Indiana-Kentucky 1961. photorevaed 1980.
Quadrangle
 Location

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                                                     East Slurry Dugout
                                                     vta Ctos«oi
(Szt ana Locaoon
                                                 Industrial Waste
                                                        Landfills
                                                       PCS Soil
                                                   Stockpile Area
                                                                   Cooling
                                                                   Tower  '
                                                                     Spent Potlinar
                                                                     Accumulation
                                                                      uilding
                                                                       ;.-.	-Of/

                                      V— Drainage Ditch

                                                                                     Taylors
                                                                                     Wash
                                                                                     Landfill
                                                                     Pitch Storage Tanks
                                                                               PCS Spill
                                                                               Investigation Area

                                                                               Drum Storage Area
                                                                               and Painting Area
                                                                                       800
                                 •SCO
LEGEND:

  •  •  •   Fence

  	Railroad Spur

-*-	Drainage Ditch and Flow Direction

IHH  Waste Management Unit
                                                                           APPROXIMATE SCALE iN FEET

                                                                         BASE MAP SOURCE  Comc"«s for- s.te
                                                                         plan from NSA. Novembw '9a*  ana «en
                                                                         locations from survey aau "o^ -on<- son
                                                                         Depp & Quiftnbury. Apm • 992
   NSA A Oivwon of Soutrw* C«-oar>
 Hawesville, Hancock County
            FIGURE 2
WASTE MANAGEMENT UNITS AND
   SPILL INVESTIGATION AREAS

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2.2  Physiography, Topography, and Surface Water Drainage

The  NSA  Site  is  located in  the broad  Ohio  River Valley
floodplain  (Figure 1) .    The  geographic coordinates are  35°
56'42'N  latitude and 086  47'16"W longitude.    This  area is
within  the Central  Lowland  Physiographic  Province and is
located adjacent to the northern  boundary  of the Western Coal
Field region of  Kentucky.  The land surface is characterized
by very  low relief and  lies  approximately 40  feet above the
normal water level of the  Ohio River.  The  flood plain extends
approximately one  (1) mile west of the Site.  At  this  location
there is an escarpment approximately 100 feet in elevation.

Surface water drainage follows the low topographic relief at
the  Site.   Relatively  poor  surface  water drainage in the
northwest  and  central  portion   of   the  Site  is   strongly
influenced by  impermeable clay  and  silt  lenses.    The one
anomalous  feature  is the man-made drainage ditch  that cuts
across the Site generally from south to  north, then east into
the Ohio River.

2.3  Geology

Geologically,  there are three stratigraphic zones of  interest
at  the  Site   (Figure  3) .    The Site  is situated on  the
Quaternary aged  Ohio River  Valley  alluvial  deposits.   The
alluvium  can  be divided  into two sections:   1)  the  lower
member  of  approximately  115-foot  thickness  on   average,
characterized  by   coarse-grained  sand  and   gravel   with
occasional beds  or lenses of silt and clay,  and 2}  the upper
member with an average depth of approximately twenty-five  (25)
feet  characterized  by  fine-grained  silts and clays  with
occasional lenses  of gravel  and coarse-grained sand.   The
depth of the top of bedrock at the Site is approximately 267
feet above MSL  (Figure 4) .  Geologic cross-sections in Figures
5-7  depict the  stratigraphic nature of the alluvial aquifer
and the bedrock  aquifer.

Below the  alluvium are  two Paleozoic  groups,  the Tradewater
and Caseyville formations. The Pennsylvanian aged Tradewater
Formation  consists of numerous  members that  are  generally
composed of shale,  sandy shale, carbonaceous shale, sandstone.
limestone and coal.  The  thickness of the Pennsylvanian aged
strata ranges from about  350 to about 500 feet.

Below  the Tradewater  is the Caseyville Sandstone,  which
represents the bedrock unit at the Site.  It is divided  into
three sections.  The  uppermost Bee Springs  Sandstone member is
a massive, coarse-bedded,  medium-grained sandstone containing
quartz  pebbles,  which  laterally grades  into  shales.    The
Battery  Rock  Coal  member  contains  shale,   sandy shale.
sandstone, and thin  beds  of limestone, and coal beds.  The

                           -4-

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                                                               Figure 3

                                           STRATIGRAPHY OF THE HAWESVILLE. KENTUCKY AREA
                                                    NATIONAL SOUTHWIRE ALUMINUM
                                                HAWESVILLE. HANCOCK COUNTY. KENTUCKY
    ERA
   PERIOD
FORMATION
THICKNESS
  (FEET)
                   OESCRIPTIONS/HYOROLOGIC CHARACTERISTICS
  Cenoioic
 Quaternary
 Alluvium
  0-150
Gravel, sand, silt, and clay. Alluvium in the Ohio River Valley contains gravel at the base
composed of glacial outwash derived from igneous, metamorphic, and sedimentary rocks,
and fragments of sandstones, limestone, chert, shale, and coal bedrock material locally
cemented with iron. Yields are as much as 750 gallons per minute to wells in the Ohio River
Valley. Water is hard to very hard and may contain objectionable amounts of iron.
  Paleozoic
Pennsylvanian
Tradewater
 Formation
  350-500
Shale, sandy shale, carbonaceous shale, sandstone, limestone, and coal. Sandstone units are
medium- to coarse-grained, locally shaly, generally range in thickness from 0 to 100 feet.
and generally contain iron. Formation thickens to the west. Yields enough water for a
modern domestic supply to drilled wells that penetrate sandstone. Yields practically no
water from limestone and shale. Water is hard to very hard and low in dissolved solids near
outcrop areas and becomes increasingly mineralized but softer downdip to the west. It is
highly mineralized in western Oaviess County.  Water from the lower part of the formation
generally contains objectionable amounts of iron.
  Paleozoic
Pennsylvanian
 Caseyville
 Sandstone
  100-500
Massive cliff forming cross bedded sandstones with shale, sandy shale, sandstone, and thin
limestone and coal beds. Yields enough water for a modern domestic supply to wells drilled
into sandstone. Yields practically no water from shale. Water generally contains
objectionable amounts of iron.  Water is hard to very hard and low in dissolved solids near
outcrop area and becomes increasingly mineralized but softer downdip to the west.  At
depth, water becomes too mineralized for use.
Source: USGS Hydrologic Investigations Atlas HA 27. Sheet *3
                                                                                                              (Figure  3)

-------
                          a
                          *
                                                                                                       /

                                                                             NOTE: Top of bedrock contour
                                                                             configuration inferred  m oart Vom data on
                                                                             Hydrotogic lnv«$ogauon Alias «A- "2
                                                                                            800
                                                                                                         1600
LEGEND:
                                                                               APPROXIMATE SCALE IN FEET
                                                                            BASE MAP SOURCE  Com0rt«d Tom s.te
                                                                            plan from NSA. November '984 and well
                                                                            locations from survey data Tom .onnson.
                                                                            Depp 4 Quisinbury. Apnl • 992
     - OruwoeOiMiandnoMOirKDen

  •    WtterSuppyWMLacaofl

  A    N*»NS*Uor-or^\(VeILoeatBn(!ns»d^byO»rnw4MDo™. 30^1382)

  •    W* log from HA-72

 (272)

M —  Top of Bedrock Contour

                                                                           NSA A Division at Soutrw» C>-eanr
                                                                         Haw«svill«, Hancock County. Kentucky
                                                                                    FIGURE  U
                                                                        TOP OF BEDROCK CONTOUR MAP

-------
  Refractory Bride
   Disposal Ar»«
(Sizt ana Locanon
   Approximate)
                                                                                           MW-J01S
                                                                                         /  Industrial Waste Landfills
                                                                                          PCB Soil Stockpile Area

                                                                                          Taylors Wash Landfill
                                                                                      Spent Potliner
                                                                                      Accumulation
                                                                                      Building
                                                                                UW-2MI
                                                                                     MW-2091

                                                                                     Drum Storage Area
                                                                                     and Painting Area
                                                                                      MW4
       Fence

•	  Railroad Spur

       Drainage Ditch and Flow
       Direction

 •     Water Supply Well Location

       New NSA Monitoring Well
 A     Location (Installed by
 A     Dames & Moore, Spring
       1992)

 *)     Boring Location (Well
 w     not installed. Spring 1992)
 U. S. EPA Monitoring
 Well Location (Installed
 by NUS Corp.. November-
 December 1989)

 Existing NSA Monitoring
 Well Location (Installed
 by Kenvirons, Inc..
 October 1985)

 Existing NSA Monitoring
 Well Location (Installed by
 Greenbaum Associates,
> Inc.. May 1980)

 Cross Section Location
                                                                               APPROXIMATE SCALE IN FEET

                                                                             BASE MAP SOURCE. Compiled from site
                                                                             plan from NSA. November 1984 and well
                                                                             locations from survey data torn Jonnson.
                                                                             Depp & Quisinbury. April 1992.
                                                                           NSA A Division of Soutnwir* Comcary
                                                                         Hawesville, Hancock County. Kentucky
                                                                                    FIGURE  5
                                                                           CROSS SECTION  LOCATIONS

-------
   A
WEST
 400
 Polllner
Disposal
  Area
   East Slurry
    Disposal
 360
 320
 260
LEGEND:
           SiHy Clay
           Poorly Graded Sand
           Well Graded Sand with Intervals
           ol Poorly Graded Sand and/or
           WeH Graded Gravel

           Well Graded Gravel

           Shale Bedrock
                      Surface
           (Measured April ?1  199?)

           Munilunitg Wull

           Si IHUIIIH) Inluival
                   0             400
                   SCALE IN FEET
           VERTICAL EXAGGERATION - lOx

NOIbS
•  I ho duplh and ihicknuss ol tliu strata indicated on Ihe subsutlacu
bin nun wuiu obiarnud by inlufpolutrng tiutwv«n lutl bonngs
Inluirnalrun un actual < undniurii  nxists only al lha locations ol Iho
mil iiuriny-. and it is possiblti lhal the conditions may vaiy liorn
Ihosu rndicalud
> for location ol cross suclio    tu Figure
                                                                                                                           A Division ol Souihwuu Company
                                                                                                                  Hawesvtlle. Hancock County, Kentucky
                                                                                            FIGUnt 6
                                                                                 GtOLOGlC CROSS SECTION A A'

-------
       Wall Gradod Sand with
       Intervals o( Poorly Graded
       Sand and/or Well Graded
       Gravel

       Well Graded Gravel

       Shale  Bedrock
^-
                   Suftace
                  Apnl 
-------
lower conglomerate member is a massive, cross-bedded, medium-
grained sandstone veined with quartz,  which grades into shale
laterally.

2.4  Hydrogaology

Groundwater at and near the Site is available  from two aquifer
sources:  the alluvial  aquifer that spans  laterally across the
Ohio River Plain, and the aquifer found in  the Paleozoic rock
formation.    The  alluvial  aquifer  is  by  far  the  most
productive.   The hydrologic  system is interconnected and is
recharged  primarily  by  percolation of  precipitation,  with
water  exchange  both  vertically  and  laterally between  the
Paleozoic and alluvial  aquifers.  Ground water flow at the NSA
Site  has   been  modeled  using   MODFLOW   [Modular  Three-
Dimensional,  Finite  Difference  Ground  Water  Flow  Model
(McDonald  and Harbaugh,  1988)].   A thorough description of
this modeling effort is described in Technical Memorandum #8
(Treatability   Study   for   Ground  Water  (Appendix  A.4)].
Additional information  concerning drilling and monitoring well
installation  is found  in Technical Memorandum  #1  (Appendix
A.I) ] .  This technical memorandum summarizes both drilling and
monitoring well installation as well as ground water sampling.
Well installation  (as summarized by Tech. Mem. #1)  indicates
that wells were installed to delineate the extent of the plume
and water  samples  were taken  for  total  cyanide analysis in
NSA's onsite laboratory.  The results are  generally lower than
other  analyses  conducted  by  either  the  -U.S.   EPA or  the
Commonwealth of Kentucky, however,  the results still indicate
that levels of  cyanide are orders of magnitude above the MCL
in the North Plume,  and  significantly elevated  in  the South
Plume.     Additional   information  is  found  in  Technical
Memorandum #2 which summarizes Ground Water  Sampling (Appendix
A.2),   and in  Technical  Memorandum #7  which summarizes  an
Aquifer Pump Test  (Appendix A.3).

Groundwater  flow,  as determined by recent  well  data and the
MODFLOW model in the area is generally toward the Ohio River
(Figure 8).   Also, water levels from  cluster wells indicate
there is an upward trend of ground water discharge towards the
Ohio River.  This information indicates that once contaminants
enter the ground water at the disposal  pond  area, contaminants
likely  reside and flow  within the unconsolidated alluvial
aquifer towards the Ohio  River where discharge occurs.  At the
present time, there is  no reason to believe  that ground waters
with cyanide, metals, and fluoride would preferentially flow
far downward into the bedrock aquifer.  Also, at the base of
the unconsolidated alluvial  aquifer there is a dense shale
layer that was  identified in recently installed Well MW-204D
(total  depth 130  feet).   This  shale  layer,  if  laterally
continuous would further  retard flow into the  bedrock aquifer.
                          -10-

-------
                                „372-6
                               //  105
              372.5106
              372^112
                 NSA-1
              372.7107
                                         MW-5
                                        , MW-6
                                 NSA-5371.7
                                                           NSA-3
                                                           MW-4
                                                           102 375.8
                                                           110 375.8
                                                       Dump Pad

                                                         369.0 3
                                                                                       12368.0

                                                                                       MW-7

                                                                                       2 369 6

                                                                                       MW-8

                                                                                       4 369.4
                                                                                   800
                                                                      1600
                                                                       APPROXIMATE SCALE IN FEET
            STATE ROUTE 271
LEGEND:

 •: •     Ftnc*

	~*- Drainage Ditch

 - • • • •  Railroad Spur

   •    Watar Supply Wall
                                            BASE MAP SOURCE
                                            aerial photograph from Fuii«r. Mossbarger,
                                            Scott i May Civil EngmOTS Inc July
                                            1966. *» plan from NUS Corptxanon.
                                            April 1991. and well location map* from
                                            National Souftw** Aluminum. Jun« 1 991 .
 369.8
U.S. EPA Monitoring Wall
Location

Piazomathc Surface Laval.
Paatmsl
        NSA Monitoring Wad
        Location
_ -_.  Piazomatric Surface, Faat. msl
  374  (Dashad Where Inferred)

•• fc  Ground Water Row Direction
                                  National Southwire Aluminum Co.
                                      Hawetvilla, Hancock County. Kentucky
                                          FIGURE  8
                            PIEZOMETRIC SURFACE CONTOUR MAP
                                          JUNE 1989
                                    (TYPICAL CONDITIONS)

-------
Information   concerning  high-flood   stage   suggests  chat
highwaters will back up  and recharge  the  alluvial aquifer
adjacent  to  the River  (Figure 9) .   Similar conditions were
identified during 1989 for typical conditions  and  in 1990 for
flow reversal (Figures 10  and 11) .  However, the significance
of this effect  is  dependent  upon the length and severity of
the flooding event. Also,  due to  the  significant accumulation
of silts  and clays adjacent  to the  River,  it is  not likely
that the  high-stage  flooding events  would cause reversal of
such  magnitude  that  ground  water   flow  would   occur  at
significant distances through the unconsolidated aquifer, then
be forced 150 feet downward into the lower bedrock  aquifer.

The measured hydraulic gradient is  approximately one foot per
1,000 horizontal feet  (0.001).   The  estimated flow velocity
for the Site  is  approximately 2 feet per day  (Given an assumed
porosity for sand and gravel of 30%) .  The piezometric surface
contour map  (Figure  11) also indicates ground waters mound
around the wastewater impoundment area.  This may cause some
radial flow from the wastewater impoundment areas.  However,
present and past ground water flow  information  indicates that
flow to the southwest, south, or west appears to be minor.

     2.4.1  Monitoring Hell Installation Summary

     In 1979,  NSA installed  12  monitoring wells  along the
     perimeter of the North Pond and adjacent to the berm of
     the impoundment to determine if hazardous substances in
     the .pond  were   leaching  into  the  ground  water.    A
     Hydrologic Assessment of the Disposal Ponds at the Site
     was  performed in  1979   and 1980  by NSA's  contractor
     Environmental Resource Management, Inc (ERM) .  This study
     concluded  that significant  levels of cyanide,  fluoride
     and metals  were  leaching from the North  Pond into the
     adjacent ground  water.   During this  investigation,  an
     additional 14 wells were installed around both  the North
     and South Ponds.

     In May of 1980,  5 wells  were installed by NSA  (NSA wells
     1-5) .    In October/November  of  1985,   12  wells  were
     installed by Fuller,  Mossbarger, Scott, and May  [(FMSM)
     wells 102-112) .  In November/December of 1985  12 in-plant
     monitoring wells were installed by Kenvirons  (wells 1-
     12) .   These wells have been used for continuous sampling
     by NSA since 1986.  However, one of these wells was not
     utilized and  is not  included  in the  well count  (well #
     10).   During the LSI  10  additional wells were  installed
     (wells  MW1-10).     Recently,   NSA  has   installed  15
     additional ground water monitoring wells at the Site in
     an   attempt  to   obtain  additional  data    regarding
     groundwater contamination (wells 201-214).
                          -12-

-------
                                                    MW-»10(361 27)

                                                    MW-201l(36i -6)

                                                    MW-201S36












M'*.! :y
.EGEND:
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1


(
         ^'"•?.L? ?o:-i~E i~^
                                        APPROXIMATE SCALE IN FEET
       Location
382.01
Nw NSA MentenigWollLoetton


Sorng Uxaoen (W« not inttiM. Spnng
1902)

U. S. EMMDntonnoJ^ILoalDn(lns{iM



EnMlMM Momomj Wrt Locanon
                                            lfK..Miyl9aO)

                                     Orouna MMr LIM (MMwrad
                                     June 16. 1902)

                                   B inttrpoMaa Pazonwx Conmur,
BASE MAP SOURCE  Comoro »om s.te
plan from NSA. NOVOTMT -9M and -en
locations from survey data from -c
Oepp A Ousinbury. April • 992
       Acpmnt Ground Water Ho*
       Dream
                                    NSA A OiVMOT of Soutrw* Cor
-------
                                                        103  365.0
                                                        NSA-3   I
                                                                                      MW-7
                                                                                      2 367 3
                                                                                      Mw-8
                                                                                      4 367 9
                                                                                      5 366.6
                                                                                  800
                                                                    1600
LEGEND:

	  Fanca

	*• Drainage Ditch

  	Railroad Spur

   •    Watar Supply WaH

   A    NSA Monitoring WaH
        Location
                                                                      APPROXIMATE SCALE M FEET

                                                                     BASE MAP SOURCE  CornpriMlrem
                                                                     Mri4 photograph (ram Futar Mo«*6arg*r.
                                                                     Soosi May Civil EnonMrvinc. JJy
                                                                     1966. Si» ptan frem MUS Corporwon.
                                                                     Aprt 1991. and •«• IOCMOR mac* fham
                                                                     ^4•ttonal Soutfwra AJurwwti AP* 1991
    9  U.S. EPA Monitoring Wall
       Location

       Contour of Piazometric
—365 Surfaca.1-Foot Intarval Excapt
       Whara r4otad (Dashed Whara
       Infarrad)

 ^     Infarrad Direction of
       Groundwatar Row
National Southwire Aluminum Co.
     HawaaviDa, Hancock County. K«r*u»y
               FIGURE  ..)
 PIEZOMETRIC SURFACE CONTOUR
,             JANUARY 1990
           (FLOW REVERSAL

-------
                                                                                      W.J010U61 27;

                                                                                     MW-»1I(361 -6)
  .«'-*• ?
   : IVfv
*IIV
LEGEND:
                                           Exswg NSA Monioma W*
                                           Lacauon (insuiM by GnMneium
                              362 01
       W«lr Step* WM LOCUM!

       Nw NSA Menttfig «M LaettMi (taHM
                                           Ground Waur u«v« (Mtnund
                                           JUM16. 19K)
                                     inurpttM Pitzonww Contour.
                                  •"
                                                                    APPROXIMATE SCALE IN FEET
                                                                  BASE MAP SOURCE Comp*«a Tom sue
                                                                  plan from NSA. Novemow '9»« »na «en
                                                                  locations from survey oau iron-
                                                                  D«pp & Ousintoury. Apnl '992
Boflno I.UBBMH (Wei not nsatad. Spring
MV

U. S. EPAMoMonnf WWI Loctton (tataM.
by '*SCom, NeMmtar-Owimer 198*)
                                           AppirM Ground Wttr Row
                                           Oirtaon
             by Kwwmrn inc.. Oaotar I9a5)
                                                               NSA A Division of Soutrw* Carw,
                                                              Hawesville. Hancock County
                                                                         FIGURE  9
                                                                GROUND WATER LEVELS AND
                                                           PIEZOMETRIC SURFACE  JUNE • 6
                                                                    TYPICAL CONDITIONS
                                                                                                    992

-------
     The total number of wells installed at the NSA Site since
     1978 is 79.  A summary of wells installed at  the NSA Site
     is included  in Appendix A.6.

2.5  Affected Population

The  NSA facility  is  located in  a sparsely  populated area
approximately four miles  northwest of Hawesville, Kentucky.
Human  population  near  the  Site  is  estimated  as  follows:
within a .25-mile radius,  274; within the zone .25 to .50 mile
from the Site,  603; within  .5 to 1 mile,  432; within  1 to 2
miles, 4,146; 2  to 3  miles,  2,568; and 3  to 4 miles,  3,788.
The majority of the population within  these  ranges is located
across the Ohio River in the State of Indiana.

2.6  Ecological Information

A complete ecological assessment  will  be performed as part of
the  RI/FS.   There has  not  been a characterization  of  the
domestic, livestock  or  wildlife animal population  near  the
Site, but the Ohio River  floodplain is generally populated by
muskrats,    beavers,    various     small    vertebrates   and
invertebrates,  songbirds  and waterfowl.    The River  itself
provides habitat  for  a number of fish and other vertebrates
and invertebrates. The bullhead mussel, a  species of concern,
has been found in  the Ohio River less than one mile from the
Site.

2.7  Water Usage

Releases have contaminated the unconsolidated alluvial aquifer
at the Site, which is used  for  industrial processes and was
previously  used for  drinking  water  for  about  1,000 plant
employees.   NSA  found one  of the three   (3)  on-site water
supply wells  to be contaminated with metals  and cyanide at
levels just below  the Maximum Contaminant Levels  (MCLs),  and
that well is no longer utilized as  a source  of potable water.
The three wells are currently being used only for industrial
purposes and pump  approximately 790,000 gallons per day (550
gallons per minute).   Municipal water  is now utilized  for all
potable water at the NSA Site.

The closest residential well is approximately  1/2 mile south-
southeast of the Site.  According to the resident,  the private
well has a  total depth  of approximately  65 feet.   Within a
four-mile radius  of  the  Site,  six municipal water companies
and  several private  wells  obtain  water  from the  alluvial
aquifer, and more  than 16,000 people obtain water from these
sources.  Most of  these water consumers live across the Ohio
River from the Site.   According to the Kentucky Division of
Waste Management Site Investigation Report  (1986), there are
approximately' 1,523  persons utilizing the  ground water for

                          -16-

-------
     drinking  purposes within  three miles  of the  Site.   These
     people are not served by the municipal water supply.  Within
     the  four-mile  radius the alluvial aquifer  is  also used for
     industrial processes,  cattle watering,  and commercial food
     processing.  Contaminants  in concentrations above MCLs have
     been  detected  in  one  of  three onsite  water  supply wells.
     Contaminants have been detected  above MCLs in many of the
     onsite monitoring wells.

     2.8  Adjacent Land Uaage

     Prior to 1990,  fields at the northern portion of the Site were
     planted annually in soybeans and possibly corn.   NSA recently
     informed  EPA that  agricultural  use of these fields ended in
     1989.  Some of  the adjacent residences to the west of  the Site
     utilize   small  portions   of  their  property   for  limited
     agricultural purposes.   A assessment  of current land usage
     adjacent  to the Site will be conducted in the RI/FS.

     2.9  Climatology

     The climate in this  area of Kentucky  is described as being
     temperate  with  warm,   humid  summers   and  moderately  cold
     winters.  The normal annual total precipitation  for the area
     is approximately 44 inches, and the net  annual precipitation
     is  approximately  8  inches.    The  highest  mean  monthly
     precipitation  is  in the  spring,  and  the lowest  is  in the
     autumn.  The annual prevailing  wind direction at the facility
     is almost evenly  distributed between north to northeast and
     east to southeast.  Percentages of wind  direction are broken
     down as follows:  north and northeast 27.8, east  and southeast
     26.7, south and southwest  18.4,  and West to northwest 18.8.
     The remaining 8.3 percent of the year is  calm, and the annual
     average wind velocity is 10 miles per hour.


3.0  SITS HISTORY AND gHTORCBMENT ACTIVITIES

     3.1  Operational History

     The facility produces elemental aluminum from aluminum ore.
     The ore is delivered  to the site by barge (via the Ohio River)
     and transferred to the production areas by a conveyer system.
     Elemental aluminum is  produced  by placing the alumina ore
     (A12O3)  in carbon-lined  metal  vessels"  called  pots.   Also
     contained in the ore  are  trace elemental  impurities including
     but not limited to copper  (Cu)  and nickel (Ni).  In order to
     facilitate the process,  a sodium fluoride  bath (Na3AlF6)  is
     added to the pots.  High amperage, low voltage, direct current
     (DC)  is run through the pots, reducing the aluminum in the ore
     to its elemental state.  Elemental impurities likely contained
     in the ore and/or bath include  but are  not limited to: copper

                               -17-

-------
 (Cu), iron (Fe),  manganese (Mn), magnesium (Mg) , nickel (Ni),
zinc (Zn), beryllium (Be), titanium (Ti),  vanadium  (V), sodium
 (Na) /  gallium  (Ga) ,  and  cadmium  (Cd) .   Molten  aluminum
collects in the bottom of the pots where it is siphoned off.
The  molten aluminum  is  then  transported  in crucibles  to
adjoining buildings,  where  it  is cast into  ingots.   Molten
aluminum is also  supplied to Southwire Rod and Cable, adjacent
to the south of the plant.

Cyanide  (CN) is  produced  and incorporated Into the potliner
where the carbon-lined pots  react  with atmospheric nitrogen
during this process.   Appreciable amounts of  total cyanide
reside in the potliners  at levels  up- to 2,500  ppm.   The
facility  has  448 active  carbon-lined pots.    The aluminum-
reducing pots are operated continuously until the carbon liner
begins to burn through.   This takes approximately 5-10 years
to occur. Once a pot begins to  experience burn-through, it is
taken out of service  and  replaced  with a reconditioned pot.
The decommissioned pot is prepared for use again by removing
and replacing the carbon liner (potliner).

     3.1.1.    Potliner Removal and Disposal

     In 1971, NSA began potliner removal by removing the spent
     potliners from  the  pots in the  pot rooms.   In 1973  a
     concrete pad (the Dump  Pad) was constructed for potliner
     removal.   At this location potliners were removed from
     the pots utilizing water  to soak the 'spent  potliner to
     assist in the removal.  Spent waters accumulated in an
     earthen sump where the  Region believes much of the water
     leached into  the subsurface.    NSA disposed  of  spent
     potliners onsite until  July  25,  1986, after which  NSA
     disposed of them offsite  at a hazardous  waste disposal
     facility.   According to NSA,  approximately 26,000 cubic
     yards of  spent  potliners were disposed in the North Pond
     (now referred to as part of the Potliner Disposal Area)  .
     At present,  NSA generates approximately 250 tons  of spent
     potliner each month (3,000 tons/year).

     Activities continued at the Dump Pad until  1990 when a
     building  was  constructed over  the  location.    This
     building  is   referred   to   as   the   Spent  Potliner
     Accumulation Building which is utilized for removing the
     potliners from the pots and transferring the wastes to
     trucks for transport and disposal offsite.  Water is no
     longer utilized  in the  spent  potliner removal process.
     The previous location of the spent potliner removal water
     sump  is   now  filled  in  with  sand  and covered  with
     concrete.  Dust generated from the spent potliner removal
     procedure is captured  and contained  in  drums  prior to
     removal to a hazardous waste disposal facility.
                          -18-

-------
3.1.2.    Disposal Pond Areas

Two  clay-lined  ponds  (North and Old  South Ponds),  one
unlined pond  (East Pond),  and one pond lined with a 60-
mil  synthetic  liner  (New  South  Pond),   each covering
approximately six acres, were constructed for disposal of
industrial wastes from the facility.  Wastes disposed in
the  North  Pond  included  spent  potliners  containing
cyanide from the aluminum reduction process and calcium
fluoride  slurry from the  air quality  control system.
Calcium fluoride  slurry was disposed in  the  Old South
Pond, East Pond and New South Pond.   NSA closed the North
Pond in 1986  and  covered  it with a  synthetic  cap and a
1.5 foot layer of clay and soil.  The area is currently
densely vegetated. The Old South Pond has  been filled to
capacity,  and its use  ceased in  1989.  The East Pond has
also been closed.   The New South Pond is now used for
disposal of the calcium fluoride slurry and electrostatic
precipitater (EP)  catch, as  approved by the Commonwealth
of Kentucky Division of Waste Management.  Approximately
15-30 tons  of  EP  dust are generated per  day.   EP dust
primarily consists of  aluminum oxide, aluminum fluoride,
sodium fluoride, and sodium aluminum fluoride, with minor
amounts of iron  (Fe), silicon (Si), vanadium (V), calcium
(Ca) , manganese  (Mn), nickel  (Ni),  potassium   (K),  zinc
(Zn), chromium  (Cr),  and  gallium  (Ga) .   It is probable
that  EP dusts  also  contain  traces  of   cadmium  (Cd) ,
berillium (Be), lead  (Pb), and magnesium  (Mg).

3.1.3     Sit* Laadfilled Areas

Three onsite  areas  have been utilized for  disposal  of
hazardous  materials.    These  are  referred  to  a  two
industrial waste landfills and the Taylors Wash Landfill
(Figure 2).  According to  NSA, solid and hazardous waste
disposal activies in  the  landfilled  areas was not well
documented.  In the case  of disposal activities at the
Taylors Wash Landfill, NSA has informed EPA  that  no
records exist.  This area was formerly a  ravine and was
filled in with various Site generated wastes  including an
unknown amount of  spent potliner material.   In 1981,  a
clay barrier was  installed at a narrow point  in  the
ravine near the Ohio  River  to prevent seepage of wacer
from the filled area to the bank of the river.  Barrier
construction consisted of a minimum 4-foot  wide compacted
clay core keyed approximately 2  feet into the original
grade.  A drainage tile  was  constructed along the length
of  the  barrier  just  inside  the barrier core on  the
landfill side to collect leachate.   The drainage system
is  accessed by  a  standpipe.    It  is  estimated  chat
approximately 30,000  cubic  yards of  industrial wastes
were disposed in Taylors Wash Landfill prior to 1981

                    -19-

-------
The other  two  industrial  waste landfills were built in
November of  1981 by excavating approximately  10  to 15
feet below grade over an area of approximately 200 feet
by 500 feet.  It is estimated that approximately 40,000
cubic yards of industrial wastes were disposed into the
larger landfill, while approximately 10,000 cubic yards
of industrial  wastes were  disposed  of  in  the smaller
landfill.   According to  NSA,  no spent  potliners  were
disposed into the two industrial landfills.

3.1.4     Refractory Brick Disposal Area

In addition to the industrial waste landfills there is a
separate disposal area  for  refractory  brick waste from
the carbon flues  and other sources. The Refractory Brick
Disposal Area is located west of State route 334 at the
north  end  of  the  main brick  plant property.   It  is
presently estimated to cover an area of approximately 2
acres. "No information exists on disposal activities in
this area;  therefore,  during the RI/FS  the Refractory
Brick Disposal Area will be characterized.

3.1.5     Effluent/Drainage Ditch

The effluent/drainage ditch that runs through the central
portion of  the  Site  drains the majority of the south,
central,  and northern  part  of the Site.   The drainage
ditch discharges from the Site into the Ohio  River within
1/4 mile of the Site.  This ditch also has drained excess
runoff from around the disposal ponds. Contaminants that
include but are not limited to fluoride and metals were
identified  during  previous   investigations   EPA  and
Kentucky  at  this   location.   In  1991,  NSA  removed
approximately 2,000 cubic  yards of contaminated sediment
from  4,800  feet of  drainage  ditch.    The  excavated
material  was  disposed   in   the   south  slurry  pond.
Resampling of the drainage ditch was  performed by NSA in
1992.    Preliminary  results  of  this  sampling  effort
indicate that contaminant  levels have been reduced in the
drainage ditch.   This information will  be reevaluated
during the RI/FS and  during  the preparation  of the Final
Site Remedy Strategy to insure that  all drainage ditch
remedial efforts have reduced the  levels  of contaminants
to acceptable levels.

3.1.6     PCS Handling Area*

It  presently  appears   that repeated  spills  of  heat
transfer fluids or other polychlorinated biphenyls (PCBs)
containing   fluids  caused   several   areas   of   PCB
contamination in onsite soils  (see section  6.5).  These
areas  include, but may not be limited  to:  1)  the area

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     surrounding  the  new  cooling  tower  footing,   2)  the
     vicinity  of the  pitch heater  building,   3)  the pitch
     storage tanks, 4)  in the vicinity of the fire station, 5)
     the  new  press building,   6)  the  PCB  stockpile area
     utilized  during the 1992  PCB contaminated soil  removal
     activity, and 7) adjacent and north of the Spent Potliner
     Accumulation Building.  The contamination was discovered
     in  1991  during  excavation  of a  small  cooling tower
     foundation.  Dames & Moore investigated the contamination
     for  NSA   by  collecting   and  analyzing  surface  and
     subsurface soil samples.  Soil excavated for the  cooling
     tower  foundation  was  stockpiled (in part) over  the two
     (2)  Industrial Landfills  prior  to  offsite disposal.
     Eight-hundred fifty (850) cubic yards of PCB contaminated
     soils were transported by Chemical Waste Management, Inc.
     for  disposal  at  the  Emelle,  Alabama  hazardous waste
     facility  in February 1992.

3.2  Enforcement Summary

In  September  1992, NSA signed  an Administrative  Order  on
Consent  (AOC)   to  perform  an  RI/FS.    NSA  through their
contractors  will  perform  the  studies  while  EPA and  the
Commonwealth of Kentucky will  oversee all RI/FS  and  related
Site study  activities  to be performed  to ensure compliance
with all applicable laws and regulations  and to ensure the
work  proceeds  in  a   timely manner.     The  Baseline Risk
Assessment which is also part of  the study-will be initiated
by EPA once the analytical data  from the  RI  sampling has been
quality assured/quality  controlled (QA/QC)  and submitted by
NSA's RI contractor.

Previous enforcement activities were initiated  in  1985.   A
Preliminary Assessment  (PA)  was completed on February 25, 1986
by the  Kentucky Division of Waste Management, under the CERCLA
EPA PA/SI Cooperative  Agreement  with EPA.   This assessment
indicated that the NSA  Site had significant  contamination,
further  studies were  warranted,  and  the  Site  was  a good
candidate for  the NPL.   As a  result, a  high priority Site
investigation was conducted.  A Site visit was  made at NSA on
May 8,   1986,  and an investigation was performed on May 12,
1986 by the  Commonwealth  of  Kentucky  Division of Waste
Management.

On July 26,  1989, a Notice of  Violation (NOV)  was issued to
NSA by  the Division of Water with  respect to contaminated
sediment that  existed  in  the  onsite drainage  ditch which
drained active industrial areas of the Site.   The inspection
report indicated that EP dust from the air pollution  control
system (APC) had entered the ditch,  and it  called  for  removal
of the dust  and any blackened  sediment.   In response  to the
NOV, NSA removed sediment from approximately 4,800 feet of che

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drainage ditch.  Approximately 2,000 cubic yards of material
was excavated from the drainage ditch and disposed in the New
South Pond.

Other NOVs were issued in November of 1990 and February 1992
respectively.  The 1990 NOV was issued due to excessive total
recoverable zinc and copper concentrations in discharge from
storm water  outfall  006.   As a result,  NSA  modified Che EP
hopper and excavated approximately 4,200  square yards of rock
and soil from the area of the scrubbers to the New South Pond.
The area was then covered with asphalt to further reduce the
potential  for  EP  dust  to enter storm water  ditches.   These
construction activities  were completed  on August  22,  1991.
Activities  initiated to comply with the February  1992  NOV
included a compliance  and proposed  sampling schedule.   Any
proposed  activities  concerning  this  NOV  have  not  been
finalized.

In the late 1980's,  the Commonwealth  of Kentucky referred the
Site to  EPA for ranking under  the HRS.   In 1990  and 1991,
surface  soil,   subsurface  soil,   sediment,  surface  water,
monitoring  well,  industrial  well,  and  some  private  well
samples  were  collected  during  the  EPA Preliminary  Field
Investigation as reported  in  the  Interim Final  Listing Site
Inspection Report (LSI) by NUS Corporation (April 1991).  The
HRS Score  generated  for  the NSA Site was 50.0.   Conclusions
from the LSI indicated that onsite ground water,  soils,  and
drainage  ditch  sediments  contain  significant  levels  of
cyanide, fluoride,  and metals.  NSA has stated to EPA that it
has cleaned out a drainage/effluent  ditch that  was found to
contain significant  concentrations of fluoride and metals.  In
anticipation of the  Site being listed as final on the NPL, NSA
(through its consultants) has also collected additional data
regarding the environmental condition of the property.

The  NSA Site  was  proposed for  inclusion  on  the  National
Prioriti«« Liat (MPL),  as defined in Section 105 of CERCLA, as
amended by SARA (P.L. 99-499), in  July 29, 1991.  At present,
this Site has not been listed as final on the NPL.

     3.2.1 RCRA Summary

     NSA  generates  spent  pot liners•  from their  primary
     aluminum  reduction  process.   NSA also  generates paint
     filters from spray paint booths. These wastes have been
     disposed  in  the  Potliner  Disposal  Area  (North Pond).
     Spent  potliners (K088)  and  paint  filters  (F017)  were
     listed as hazardous  wastes, in Interim Final Regulation,
     in  the  Federal  Register  dated  July  16,  1980.    In
     anticipation of final listing of these wastes, NSA filed
     a RCRA Part A  application in November 1980,  and gained
     interim status. K088 and F017 were temporarily suspended

                          -22-

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          as listed hazardous wastes in the Federal Register dated
          January 16, 1981.  Subsequently, NSA requested withdrawal
          of their Part A application and received approval in July
          1982,  from Kentucky and  EPA.    Interim  status  was not
          taken from the facility, however, RCRA regulations have
          not been applied to NSA.  The K088 waste at  the  time of
          disposal was not listed or regulated under RCRA.

          Currently,  NSA  holds  the  following  permits:  KPDES
          #KY0001821 for the discharge of  storm water, noncontact
          cooling water,  and sanitary waste  water  into  the Ohio
          River, Air  (Operating)  #0-82-25 for air emissions, and
          also a Certificate  of  Registration for Hazardous Waste
          Activity under EPA KYD049062375.

          3.2.2.  TSCA Summary

          In  1991  during  the  excavation  of  a  cooling tower
          foundation near the eastern portion of the Site PCBs were
          encountered at approximately 12 feet below land surface.
          NSA  coordinated   an  investigative  effort  on  this
          contamination with the U.S.  EPA Toxic Substances  Control
          Act section (TSCA).  Sampling and analysis was conducted
          in order to  characterize  contaminant  levels within the
          cooling  tower  foundation.     Sheet   pilings   at  the
          excavation were grouted to  prevent further  PCB oils to
          enter the excavation.  Forty two  (42)  composite  samples
          were  subsequent  taken  of  the  PCB contaminated soils
          temporarily stored at an onsite staging area.  NSA  removed
          approximately 850 cubic yards of PCB-contaminated soils
          at the  excavation  for  a cooling  tower footing.   One
          hundred thirty (130)  truck  loads of  PCB contaminated
          soils were transported and disposed at  the Chemical waste
          Management  facility in Emelle,  Alabama.    During  this
          sampling event, PCB levels were detected in  these soils
          from below 1 ppm to approximately 8,940 ppm.

          This  initial  remedial  effort  was funded  by  NSA  and
          coordinated with TSCA Program.  With the Site expected to
          be listed  as final on  the NPL,  the  Superfund  Program
          began to review the TSCA PCB data for this  Site in April,
          1992.    Present   plans   under  CERCLA  include  final
          assessment and cleanup  of PCB  contaminated areas  as a
          coordinated  effort, through  the  Superfund  Remedial
          Program.

4.0  HIGHLIGHTS OF COMMUNITY PARTICIPATION

The Proposed Plan for Interim Remedial Action at the NSA Site was
presented at the  Public Meeting held on  January  19,  1993 at the
Hancock County Middle School.  This  document was made available -. ^
the public  in  the information  repository maintained  at  the EFA

                               -23-

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Docket Room in Region IV, and at the Hawesville Library.  Notice of
the availability of this document and notice of the Public Meeting
was published in the Hancock Clarion on January 7,  1993,  and  in the
Perry County News on January 11, 1993.  The  Public Comment  Period
was held from January 7, 1993 through February 7, 1993.

At the Public Meeting,  representatives from EPA answered questions
concerning the proposed Interim Remedial Action to pump and creat
the  two  onsite  ground water  plumes.    Other   questions  asked
included:   the  types  of   contaminants   onsite,   could  these
contaminants get offsite,  will  the Hawesville Municipal  wells need
to be sampled, what areas of the Site have been investigated, and
is it safe  to  raise livestock  and produce, on nearby agricultural
lands?

5.0  SCOPE AMP ROLB OF RESPONSE ACTION WITHIN
          SITE STRATEGY

The  Interim Remedial  Action  involves  the  implementation  of  a
multiple-well gathering and pump  and treat system to control and
contain the  two onsite ground  water plumes, to  initiate ground
water restoration activities prior to final Site remediation, and
to  obtain  information  on   the  aquifers   response  to  pumping.
Previous investigative efforts suggest contamination resides  in the
North and South Plumes are located onsite within the unconsolidated
(upper)  aquifer.   The exact number  of withdrawal wells  will  be
evaluated and determined during the Remedial Design.  This aquifer
is classified  in the Guidelines  for Ground-Water Classification
Under  the  EPA Ground-Water  Protection  Strategy.  Final  Draft,
December 1986, as a Class IIA aquifer that is a current source of
drinking water.  Although this interim remedy does not constitute
a final remedy for the site,  these activities will: 1) reduce the
levels of contaminants within the unconsolidated alluvial aquifer,
2) prevent  further migration  of  contaminants (presently in the
plumes)   toward  the Ohio River,   and 3)   prevent any  potential
migration  of  contaminants into several  stratigraphically  lower
Class IIB aquifers  that are  classified as "a potential source of
drinking water*.  Previously  acquired information  is supportive of
these "interim" measures while a more thorough site investigation
is conducted.  Following the approval of this Interim Action ROD,
the RD/RA for the  "interim"  remedy is expected to commence.  The
RD/RA for "interim" measures  is expected to be completed in  a much
shorter  time  frame  since  much  of  the  engineering,  design,
specifications,  and treatability studies have been  completed as
part of an expedited site remediation approach.  A standard RD/RA
will take approximately 14 to 18 months to complete, however, the
RD/RA for "interim" measures  is  expected to take  less than  6
months.

On September 30, 1992,  NSA entered into  an Administrative Order on
Consent  (AOC)   with EPA  to  perform  a Remedial  Investigation,
Feasibility  Study  (RI/FS).     This   investigation  was formally

                               -24-

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initiated  at  the  Public  Meeting  on January  19,  1993.   Upon
completion of the RI/FS, the groundwater pump and treat system as
discussed in this Interim Remedial Action, may be incorporated into
the Site Remedial Design specified  in the.Final Action ROD.  The
Final  Action  ROD  will  outline  all  other  additional   remedial
activities that will be  required to clean up the Site.

A typical RI/FS  takes  approximately 18 to 24 months to complete.
However, previous onsite  investigative work including 64 previously
installed wells and 15 wells recently installed by NSA's contractor
Dames & Moore,  should significantly  reduce the time  for this final
investigation.   Once  the  RI/FS is completed, work will begin on the
Remedial Design/Remedial Action  for  the Final Action. Again, since
much of  the  'interim"  measure work will  likely aid in the Final
Action, the RD/RA for the Final Remedy will likely take between 8
and 12 months to complete.   It is expected that this will also be
completed in an expedited manner.

6.0  SUMMARY OF SITE CHARACTERIZATIONS

     6.1  Nature and Extent of Contamination

     Contaminants have been released at the Site as  a result of the
     facility's  operation  and  onsite disposal of  wastes.   The
     primary contaminants   identified  in  onsite   soils,  ground
     waters,  surface  waters, drainage ditch sediments, and  leachate
     streams include but are not limited to CN (refers to  "total",
     and "amenable"  which is often utilized as a measure  of "free
     cyanide",  see discussion in  Section 6.1.1. below),  F,  PCBs,
     As, Pb, Ni, Be, Cd, Co, Cr, Zn,  V, and Mn.   Also,  several
     volatile  or semivolatile  compounds  were  identified in  the
     leachate  at the  Taylors  Wash  Landfill.   The contaminants
     identified  above  both background, MCLs, and/or Preliminary
     Remediation Goals   (PRGs)   are:  1,2-Dichloroethane and 2,4-
     Dimethylphenol.   A ground water sample from MW-09 to the south
     of the onsite production areas  revealed 1,1,1-Trichloroethane
     (TCA) ,   however,  the  level  of  TCA  was  below  the  MCL.
     Additional information will need  to be obtained on the area
     near MW-9  during the RI/FS since  this area  has not  been
     previously characterized.   PCBs have also been detected at the
     Site.    It is likely  that spillage of  PCB containing heat
     transfer fluids is  responsible for the PCB contamination in
     the soils  in the vicinity of the cooling tower.  Very little
     information exists concerning potential PCB contamination in
     the ground water.  Additional ground water information will be
     obtained during  the  RI/FS at locations where PCB contamination
     has been identified in the soil.

          6.1.1  Cyanide Evaluation

          Concerning ground water, an MCL of 0.2 ppm which applies
          to "free cyanide "(40 CFR Parts  141  and 142;  National

                               -25-

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   .  Primary Drinking Water Regulations; Vol 57,  No. 138, July
     1992).  This guidance further states,  "EPA is specifying
     the use of  the  "cyanide  amenable to chlorination" test
     for determining the "free cyanide" concentrations, while
     the "total cyanide" analytical technique is being allowed
     to screen samples".

     Previous analytical results at the NSA Site for cyanide
     (total, and amenable  - as  a  measure of "free cyanide")
     have all  indicated that cyanide levels in  the  ground
     water plumes are orders of  magnitude above  the MCL.  The
     previous analytical results for "total cyanide" have been
     very consistent  while  the previous analytical results for
     "amenable cyanide  " as a measure of the "free cyanide"
     have been variable  (even though  results were variable,
     all analyses for the main portion of the North Plume were
     consistently orders of magnitude  above the MCL while the
     levels for the South Plume were noted to-be significantly
     elevated).  In response to  the previous variable results
     for  "amenable cyanide"  at  the  NSA  Site,  it will  be
     necessary during the Remedial Design for  the  Interim
     Remedial  Action   to  utilize  different   or  enhanced
     analytical techniques  to consistently identify the amount
     of  "free  cyanide".     If  consistent  procedures  or
     analytical techniques cannot be successfully determined
     as part of the  Remedial  Design,  then the cleanup level
     (0.2 ppm) for effluent or waters discharged to the Ohio
     River should be  applied to  "total  cyanide*.  This cleanup
     level would be justified since the  "free cyanide" would
     be a variable portion of the "total cyanide".

     Within  this  Interim  Action  ROD,  the term  "amenable
     cyanide" is used since much  of the previous analytical
     data utilized this terminology,  and it should be noted
     that this was utilized in  order  to determine the "free
     cyanide".

6.2 Disposal Ponds/Waatewater Impoundmenta

NSA  has  utilized   four   (4)   disposal  ponds  (wastewater
impoundments) since plant operations commenced in 1969.  These
ponds are designated  as the North Pond, South Pond, East Pond,
and New South Pond.  In 1980,  ERM determined that leaching was
occurring beneath  the North  Pond  (Table 1) .   The  1980  ERM
Investigation determined  significant  levels of  cyanide  and
fluoride were present in the ground waters in the area of the
disposal ponds.    In 1986, the Kentucky Division of  Waste
Management investigated conditions in this area, and recovered
samples and data for cyanide and metals.  A  surface water
sample in the North Pond (prior to covering) indicated total
cyanide levels up to 165 ppm  (as also reported in the
                          -26-

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WkWUi 1 SUMMARY OF WATER QUALITY CRITERIA
BYDRbZiOQIC ASSBSSMENT OF THE DISPOSAL PONDS AT
. THE NSA SITE (BRM, 1979)
Well #
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
Soluble F
(5-14) (6-4)
(ppm)
2.48 3.33
0.44 1.18
0.73 27.40
0.48 0.52
0.35 0.37
1770.0 1300.00
21.80 13.20
2.67 2.55
1.28 1.20
13.10 15.10
2.35 3.05
0.28 1.37
6.55 	
0.65 1.23
4.96 	
1.85 	
1.84 15.60
11.00 	
0.97 0.92
19.20 	
3.64 1.77
12.30 	
7.37 	
4.98 	
8.50 	
4.27 	
Soluble CN
(5-14) (6-4)
(ppm)
0.05 <0.30
0.01 <0.30
0.96 <0.30
0.36 <0.30
0.11 <0.30
7.25 3:00
0.52 <0.30
0.55 <0.30
0.16 <0.30
0.08 <0.30
1.35 <0.30
4.25 <0.30
0.50 ----
0.24 <0.30
0.17 	
0.08 	
0.08 <0.30
1.18 	
0.19 <0.30
0.08 	
0.06 <0.30
0.03 	
0.01 	
0.04 <0.30
0.04 	
0.03 	
Total CN
(5-14) (6-4)
(ppm)
	 	
	 	
	 6.80
	 	
	 	
115.80 97.50
	 	

	 	
	 	
	 	
	 32.20
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	
	 	

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Hydro-geological Investigation Report, ERM, 1980),  and amenable
cyanide up to 101 ppm.  Highest levels of metals reported from
the KDWM report are as follows:  arsenic  (532 ppb), barium  (76
ppb), chromium  (19  ppb)  and mercury (0.3 ppb).   Significant
concentrations  of contaminants  in the  North  Pond area have
provided a  significant sources has  of  cyanide,  metals,  and
fluoride to the onsite ground water from the impoundment area
to the Ohio River  (approximately 1/2 mile east).

6.3 Ground Water Contamination and Onsite Impoundments

The  two  (2)   cyanide  groundwater  plumes  that  have  been
identified  thus  far  are  located  in  the  vicinity  of  the
disposal ponds,  also referred to as the wastewater impoundment
area (North Plume) and under and near the present location of
the  Spent  Potliner  Accumulation  Building   (South  Plume).
Ground water sampling  data in the 1991 Listing  Site Inspection
Report are presented  in  Appendix A.5.   Recent  confirmatory
sampling  (Tables 2A-2C)  conducted  in  1992  indicates  that
significant concentrations of cyanide and metals continue to
reside  in  the  two  onsite  ground  water  plumes.     This
confirmatory sampling also included samples of leachate from
the Taylors Wash Landfill.   Levels of 1,1,1-Trichloroethane,
2,4-Dimethylphenol, and  PCBs in the leachate were elevated
above background.  The Taylors Wash Landfill is located north
of the main Site complex approximately 1/4 mile.  Contaminated
ground waters from this landfill fall within the boundaries of
the North Plume  (See Section 6.1.6)

     6.3.1.  North Qround Water Plume

     Within the North  Plume,  cyanide concentrations have been
     identified  up to  56   ppm  [(Figure  12)  Interim  Final
     Listing Site Inspection Report, NUS,  1991].   Recently,
     concentrations of total cyanide have been reported up to
     30 ppm.   Sampling results from well 103 in December 1992
     reported amenable cyanide  concentrations at  24  ppm,  or
     120 times  the  MCL  [The MCL is 0.2  ppm for (i.e.- "free
     cyanide" or  cyanide amenable to chlorination),  revised
     Federal Register, July 17, 1992, see section 6.1.1. and
     9.2 for  details]  (Figures  12-14) .  Highest  levels  of
     metals reported during the 1991 EPA LSI are as follows:
     barium (580 ppb),  cobalt (260 ppb),  copper (51 ppb), lead
     (73 ppb), magnesium (69,000 ppb), manganese  (8,400 ppb),
     and nickel  (170  ppb).   The  highest amount  of fluoride
     detected during the 1991 EPA LSI was 220 ppb.  Fluoride
     levels up  to  1,770 ppm were detected  in  one of  the
     monitoring wells near North Pond in 1980.  The plume is
     elongated in the  predominant  ground water flow direction
     toward the Ohio  River which  is approximately 1/2 mile
     away (Figure 15).
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TABLE 2 A
RESULTS OF CYANIDE ANALYSES,
2/27/92 - 4/2/92 GROUND WATER SAMPLING1
SAMPLING DATS
2/27/92
2/28/92
2/29/92
2/29/92
3/2/92
3/24/92
3/24/92
3/1/92
3/1/92
3/1/92
3/1/92
3/1/92
3/2/92
3/24/92
3/3/92
3/3/92
3/3/92
3/3/92
3/3/92
3/4/92
3/4/92
3/4/92
3/5/92
3/5/92
3/5/92
TOLL *
201 D
201 D
201 D
201 D
201 D
201 S
201 I
201 D
202 D
202 D
202 D
202 D
202 D
202 I
203 D
203 D
203 D
203 D
203 D
203 D
204 D
204 D
204 0
204 D
204 D
SAMPLE DEPTH
(Feet)
40
60
80
120
CW2 (107-117)
CW2 (35-45)
CW2 (80-90)
50
70
90
110
130
CW2 (119-129)
CW2 (70-80)
40
60
80
100
120
CW2 (112-122)
50
70
90
110
130
CYANIDE
(ppb)
39
390
1,380
1,460
38
590
1,900
54
2,220
1,150-
680
460
52
540
1,100
22,700
19,760
16,820
13,880
21,930
206
4,640
11,220
6,190
5,420
-29-

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TABLE 2 A CONT.
RESULTS OF CYANIDE ANALYSES,
2/27/92 - 4/2/92 GROUND WATER SAMPLING
SAMPLING DATE
3/6/92
3/10/92
3/10/92
3/11/92
3/11/92
3/11/92
3/20/92
3/12/92
3/12/92
3/17/92
3/18/92
3/18/92
3/23/92
3/19/92
3/20/92
3/24/92
4/2/92
4/2/92
WELL *
204 D
205 I
205 I
206 I
206 I
206 I
207 S
208 I
208 I
208 I
209 I
209 I
209 I
210 I
210 I
210 I
211 I
212
SAMPLE DEPTH
(feet)
CW2 (119-129)
50
80
40
60
90
CW2 (40-50)
50
80
CW2 (70-80)
55
85
CW2 (70-85)
50
90
CW2 (75-90)
CW2 (75-90)
CW2 (80-95)
CYANIDE
(ppb)
181
21
420
60
230
280
190
27
160
330
36
140
160
230
860
1,030
8
11
1)  - Samples collected by NSA contractor during drilling
2)  - Completed Well (interval)
                          -30-

-------
                 TABLE 2B

      RESULTS OF CYANIDE  ANALYSES,
4/21/92 - 4/28/92  GROUND  WATER SAMPLING1
WELL *
NSA-1
NSA-5
2
3
4
5
8
11
12
102
103
104
105
106
107
109
110
111
112
MW-201 S
MW-201 I
MW-201 D
MW-202 I
MW-202 D
MW-203 S
TOTAL CYANIDE
(ppb)
31.4
5.0 U
435.0
324.0
217.0
426.0
5.4 U
1,080.0
148.0
4,310.0
22,900.0
740.0
80.4
73.9
69.8
5.0 U
5.0 U
5.0 U
5.0 U
289.0
235.0
7.2
553.0
13.8
11,300.0
AMENABLE CYANIDE
(ppb)
18.5
5.0 U
61.0 U
185.0
50.0
426.0
5.4 U
250.0 U
50.0 U
500.0 U
- 2,660.0 U
250.0 U
5.0 U
25.0 U
69.8
5.0 U
5.0 U
5.0 U
5.0 U
142.0 U
25.0 U
7.2
130.0
13.8
9,330.0
                   -31-

-------
TABLE 2B CONT.
RESULTS OF CYANIDE ANALYSES,
4/21/92 - 4/28/92 GROUND WATER SAMPLING1
WELL *
MW-203 I
MW-203 D
MW-204 D
MW-207
MW-208 I
MW-209 I
MW-210 I
MW-210 I2
MW-211 I
MW-212 I
MW-213 I
MW-213
MW-214 S
TOTAL CYANIDE
(ppb)
10,700.0
26,100.0
67.8
196.0
24.4
149.0
336.0
719.0
5.7
6.3
1,110.0
1,100.0
232.0
AMENABLE CYANIDE
(ppb)
2,500.0 U
5,000.0 U
13.0
187.0
6.8 U
31.2 U
55.6 U
663.0
5.7
6.3
250.0 U
U
U
1)   Analyses by Wadsworth/Alert Labs., North Canton, Ohio,
2)   Sample taken on June 17, 1992
U  =  Not detected above method detection limit
                          -32-

-------
TABLE 2C
INDUSTRIAL WELL /EPA MONITORING
WELL SAMPLING1
INDUSTRIAL WBLL* *
IW-1
IW-2
IW-3
EPA WELL3 *
MW-1
MW-3
MW-4
MW-5
MW-7
MW-8
MW-9
MW-10
MW-24
MW-24 (Duplicate)
MW-6*
TOTAL CYANIDE
(ppb)
193.0
35.8
5.0 U
TOTAL CYANIDE
(ppb)
5.0 U
18.1
339.0
948.0
1,210.0
41.1
6.9 U
5.6 U
28,900.0
28,000.0
9,220.0
AMENABLE CYANIDE
(ppb)
85
5 U
5 U
AMENABLE CYANIDE
(ppb)
5.0 U
18.1
54.3 U
152.0
20.0
35.3
6.9 U
5.6 U
12,000.0
18,400.0
5.0 U
1) Analyses by Wadsworth/Alert Labs., North Canton, Ohio.
2) Industrial Well samples taken 4/21/92 - 4/28/92.
3) Wells sampled May 15, 1992
4) Wells sampled July 28, 1992
U = Not detected above method detection limit
                          -33-

-------
                                                                                MW-5  1.1

                                                                                MW-6  6

                                                                                NSA-5 2.84
                                             ^   i    i
                                           MW-9
                                            NO        '

                                         \        ^
                                                                                          MW-7 0.51
                                                                                          2 0.4
                                                                                          MW-8 0.04
                                                                                          4 0.45
                                                                                          5 07
                                                          300
                                    1600
            STATE ROUTE 271  If
                                              APPROXIMATE SCALE IN FEET

                                             BASE MAP SOURCC Co«
-------
                                                     (Now Pona)
                          105

                      MW-2030
                      MW-J03I

                      MW-203S 9 33

                            MW-20400013

                            MW.S01S2
                            MW4
   Sz» ana LOCIOOO
      Apofojuma»)
                                                                                         .MW-2111
                                                                                          0006
                                                                                          WW-2010

                                                                                          UW-2011
                                                                                          MW-2013

                                                                                          Industrial Waste Larafals


                                                                                         PCB Soil Stockoiie Area
                                                                                       Taylors Wash Lanofill
MW-10
                                                                                     Spent Potlmer
                                                                                     Accumulation
                                                                                     Building
                                                                                    30.185
                                                                                    MW.202IO.13


                                                                                    MW*202D00138

                                                                                    MW-7002
                                                                                    UW-20W

                                                                                    Drum Storage Area
                                                                                    and Painting Area

                                                                                    MW-4 0 0353
 LEGEND:
              STATE ROUT£ 27"!

	  Fence

	  Railroad Spur

	Drainage Ditch and Row
      Direction

 •    Water Supply Watt Location

      New NSA Monitoring Well
 ^    Location (Installed by Dames &
      Moore.  Spring 1992J

 *    Boring Location (Well not
      instaifed, Spring 1992)

      U.S. EPA Monitoring Well
 <&    Location (Installed by NUS Corp.
 *    November-December 1989)
                                                                                           800
                                                                                                         •5CO
                                      0.542
Existing NSA Monitoring
Well Location (Installed by
Kenvirons. Inc.. October
1985)

Existing NSA Monitoring
Well Location (Installed by
Greenbaum Associates,
Inc. May 1980)

Amenable Cyanide
Concentration. mg/L,
Measured May  1992
                                                                              APPROXIMATE SCALE IN FEET

                                                                             BASE MAP SOURCE  Compiled "z- -, :a
                                                                             plan from NSA. November i
                                            Amenable Cyanide
                                       * •" Concentration Contour,
                                            mg/L

                                       NO   Not Detected
                                                                           NSA AOw*on of Soutrwt C
                                                                         Hawesville, Hancock County.
            FIGURE  L3
CONCENTRATIONS OF AMENABLE
   CYANIDE.IN GROUND WAT£3

-------
                       0.0004108


                      0.0181 UW4
    PoSirwr DijpOMl ATM	
          (Norm Porxn^-^    .^ y^^ 0_073fl^

  Refractory Brick -^    J   //
    Disposal Area  /    uW.,'
Size and Location  [     oasis'
    Approximate)  >•—^ '  ,-/r
                   0.0698107
                                                                                          Industrial Waste Landfills
 NO
MW-10
                                                                                         A MW-2111
                                                                                           0.0057
                                                                     AMW-211100063

                                                                East Slurry Ouooul ACM (CtoMd)

                                                                             •01
                                                                   UW.203026.1
                                                                   yW-3031107
                                                                   MW-203311 3
                                                       MW-5
                                                  NSA-3 0.948
                                                      MW-4
                                                      0.399
                                                                                           MW-201000072

                                                                                           MW-201I023S

                                                                                           MW-201S0289
                                                                             JAMW-2140232

                                                                                         PCS Soil Stockpile Area

                                                                                        Taylors Wash Landfill
                                                                              A MW-2MI 0.0244
                                    :  Sp«nt Potliner
                             /      ;  iAccumulation
                               	{IUUMKP
                                                                                     MW-202D 00138
                                                                                     MW-71 21
                                                                                     20.435

                                                                                     Drum Storage Area and
                                                                                     Painting Area

                                                                                     MW-209IO.:i9

                                                                                     MW-4 0.0411
                                        V— Drainage Ditch
 LEGEND:
	 Fenc»
        Railroad Spur
     Drainage Ditch and Flow
     Direction

•   Water Supply Well Location

     New NSA Monitoring Well
A   Location (Installed by Dames
     & Moore. Spring 1992)

A   Boring«Location (Well not
w   installed. Spring 1992)

^   U. S. EPA Monitoring Well
®   Location (Installed by NUS
     Corp., November-December
     1989)
                                   0.553



                                   100 ~


                                    NO
                                         Existing NSA Monitoring Well
                                         Location (Installed by
                                         Kenvirons, Inc.. October
                                         1985)

                                         Existing NSA Monitoring Well
                                         Location (Installed by
                                         Greenbaum Associates. Inc.
                                         May 1980)

                                         Total Cyanide Concentration,
                                         mg/L. Measured May 1992

                                         Total Cyanide Concentration
                                         Contour. mg/L

                                         Not Detected
                                                                                                           •'600-
                                                                               APPROXIMATE SCALE IN FEET

                                                                             BASS MAP SOURCE. Comp.ied from site
                                                                             plan from NSA. November <984
                                                                           NSA A Civilian of Soutrwi Cor-oao
                                                                         Hawesville. Hancock County.
                                                                                     FIGURE  u
                                                                       CONCENTRATION OF TOTAL CVANICE
                                                                                IN GROUND WATER

-------
SOUTHWEST

     North Pond / South Pond
    400
                                                                                                                  NORTHEAST
                                                          East Pond
    350
                                                                                                                OHIO
                                                                                                                KIVKJt
I
UJ
   250


feEGEND:

 _ 7_   Piezometric Surface

         Cyanide Isopteth. Logarithmic
  " 10°  Interval (Except where noted)

    H    Monitoring WeH Location

    I     Screened Interval

  o OS    Cyanide Concentration, pom
                                              Bedrock
                                                          50 -|
                                                            o            soo
                                                            SCALE IN FEET
                                                     VERTICAL EXAGGERATION - 10x
 NOTE This cross sttdion was generated using lh« limilad data available
 and is inl*nd«»d to show on« possibta pan«rn ol contaminant migration
      th« aquitar n doas not n«c«ssarily d«ptd actual condrtions
                                                                                                                        400
                                                                                                                        390
                                                                                                                         300
                                                                                                                             I
                                                                                                                        250
                                                                                           National Soulhwire Aluminum Co.
                                                                                                Hawesvill*. Hancock County. Kentucky
                                                                                                         FIGURE 15
                                                                                               SCHEMATIC CROSS SECTION OF
                                                                                               CYANIDE PLUME. JANUARY 1990

-------
     6.3.2 South, around water Plume

     The South Plume is located beneath and around the Spent
     Potliner Accumulation Building  (previously known as the
     Dump Pad).   The South Plume is more diffuse in shape than
     the North  Plume,  possibly  because of  variable ground
     water  flow  directions  during  high  river stage  flow
     reversals.    This  also may  be due to  the influence of
     pumping from the Site production wells  to  the southwest.
     Cyanide  has  been identified in  the  South  Plume  at
     concentrations up to 4.4 ppm for total cyanide (Kenvirons
     Ground Water  Monitoring, well #12,  10/24/91,  p. 7)  and
     more recently at 1.21 ppm for total cyanide, and  0.54 ppm
     for amenable cyanide.    The  highest  levels of metals
     identified  in the south plune  are:  barium  (180  ppb) ,
     chromium (21 ppb), cobalt (82 ppb), copper (63 ppb), lead
     (41 ppb), magnesium (130,000 ppb),  manganese (2,400 ppb),
     and nickel  (95 ppb).   The  highest  level of   fluoride
     identified within the south plume was 740 ppb.

6.4 Effluent/Drainage Ditch

The drainage ditch sediments at  the  Site  contain cyanide at
levels ranging up to 7.7 ppm, nickel  up to 1,400 ppm,  arsenic
up to  160  ppm,  and lead up  to  170 ppm.  Fluoride has been
detected at levels ranging from trace to up to 6-1,000 ppm in
drainage ditch sediments.  Samples of the surface soils at the
Site have exhibited contamination ranging from trace levels up
to 64,000  ppm for fluoride,  20  ppm  for arsenic, 12  ppm for
lead, and 20 ppm for nickel.   Subsurface soil samples at the
Site indicate fluoride at levels  ranging from trace levels up
to 88 ppm,  4.4 ppm for arsenic,  20 ppm for nickel, and 5.3 ppm
for lead.

6.5 Cooling Tower Excavation

During  recent  construction  activities,  NSA  discovered  and
removed soils contaminated with PCBs at  concentrations ranging
from below 1 ppm to approximately 8,940 ppm in an excavation
for  a  cooling  tower  footing.    It  presently  appears  that
repeated  spills  of  heat  transfer  fluids  or  other  PCB
containing fluids caused several areas of PCB contamination in
onsite soils. These areas include, but may not be limited to:
1) the area surrounding the new cooling  tower footing  (Figures
16 & 17), 2)  the vicinity of the pitch heater building, 3) the
pitch storage tanks, 4) in the vicinity of the fire  staticn,
5) the new press building,  6) the PCB stockpile area (Figure
18) utilized during the 1992 PCB  contaminated soil  removal
activity,  and 7)  adjacent and north of the  Spent   Potliner
Accumulation Building.  The  contamination was discovered in
1991 during  excavation of a  small cooling tower foundation
Dames & Moore investigated the contamination for NSA by

                         -38-

-------
h.


a
»•




	

(" ;,; >;, w;
^ tX •" ""
•• *j>- • -


DM-? a pSS' n
NO (2-2.5) HOJ ?<=
                                               OM-1
                                             NO (2-2.5)
                                             NO (6-6 5)
                                             NO !9-'OS)
•4
"\\V
ft
X-
js.

DM-2
1.7 (2-2S)
NO J4-4.S)
NO COS-'-:
3.4 (14- '6)

DM-S
NO (2.5-45)
NO (75*
NO (9-11)
3200 (14-16)

MW-207
NO (19-211 •
NO (44-45) .
                                                              NO (2.S-3)
                                                              NO (4.5-5)
                                                            2600 (6.S-7)
                                                              NO (9-95)
                                                              NO (15-iSS)
        Railroad Tracks

  •    Soil Boring Location

  ®    Monitoring Well Location

 3200   PCB Concentration (mg/Kg)

  /VO    Not Detected

n A  i fi^  Sampling Depth Below
   •TO)  Ground Surface (Feet)

        Approximate Extent of PCB
        Contamination Shallower than 2.5 Feet
                                                                      0100200


                                                                        APPROXIMATE SCALE IN
                                           BASE MAP SOURCE:
                                           Modrfted from NSA.
                                           General Plant Layout
                                           Drawing No.
                                           500-0000-201. Revision
                                           5. August3. 1979.
                                                                        NSA A DiviMn of Sowrv* :.y-Mr>
                                                                      Haw*svill«, Hancock
           FIGURE   . •>
SHALLOW PCB CONTAMiNA' CN

-------
                                                               MW-207

                                                               NO (19-2H
                                                               NO (44-45)
                                                                   DM-3

                                                                 NO (2.5-3)
                                                                 NO (45-5)
                                                                2600 (6.5-7)
                                                                 NO (9-95)
                                                                 NO (15-15 S)
                                                                             IK.!
                                  SiSl^   •
                                 \ .  ,-	f--	
V.--'



,'""N
                                        DM-16

                                       TO  (1-1.5)
                                       NO  (4-4.5)
                                       NO  (10.5-11!
                                                                DM-17
                                                               NO (2-2.5)
                                                                                      fp]
                                                                                V~J
LEGEND:
   NO


 (14-16)
Railroad Tracks

Soil Boring Location

Monitoring Wall Location

PCB Concentration (mg/Kg)

Not Oatactad

Sampling  Oapth Below Ground
Surface (Feet)

Approximate Extant of PCB
                                                                     0	100	200


                                                                       APPROXIMATE SCALE IN FEET
BASE MAP SOURCE:
Modified from NSA. General
Plant Layout. Drawing No.
500-0000-201. Revision 5.
         Contamination Deeper than 2.5 Feet  August 3.1979
                                                                       NSA A Oivwon of Soutrwr* C2.S FEET) PCB CONTAMINATION

-------
             126
              40
        • 5.8
   >34
11
16
             '2.5
        • 16
STOCKPILE LOCATION MAP
         NOT IO SCALE
        • 4.4
         i9.5
                                                          
                                                           I
                                               10
                                                                325 leal
• 6.7
                                                                 11
                                                   LEGEND:

                                                   .	 Approximate Limils of PCB Soil
                                                           Stockpile Area

                                                   —	• Sampling Grid Quadrant Boundary

                                                      •    Stockpile Sampling Location

                                                     9 5    PCB Concentration, ppm
                                                                                  148
                                                                                                i 2.3
                                                                                       7.7
                                               «
                                               I
                                              »J
                                                I
                                               I
                                               I
                                               I
 *

r5.5
                                                                         NO A A Division ol Soulliwiiti Company
                                                                       Hawesvillu. Hancock County. Kentucky
                                                                                FIGURE  18
                                                                         PCB SOIL STOCKPILE AHEA
                                                                        RESIDUAL CONCENFRATIONS

-------
collecting and analyzing surface and subsurface soil samples.
Soil excavated for the cooling tower foundation was stockpiled
(in  part)  over  the  two  (2)  Industrial Landfills  prior to
offsite disposal.  Eight-hundred and fifty (850)  cubic yards
of PCB contaminated soils were transported by Chemical Waste
Management,  Inc.  to  the  Emelle,   Alabama hazardous  Waste
Facility for disposal.  The extent of PCB contamination at the
Site will be further evaluated during the RI/FS.   No further
remediation of this area  will  take place during  the Interim
Remedial Action.

6.6 Onsite Soils Contamination

Samples of surface soils at the Site have exhibited fluoride
contamination up to 64,000 ppm,  arsenic  up  to  20 ppm, lead up
to 12 ppm, and nickel up to 20 ppm.  Subsurface soil samples
have exhibited fluoride contamination up to 88  ppm, arsenic up
to 4.4 ppm, nickel up  to  20 ppm,  and lead up to 5.3 ppm.  The
extent  of  surface and   subsurface contamination  will  be
investigated during the RI/FS.  No  remediation of these areas
will occur during this Interim Remedial Action.

6.7 Onsite Landfill Contamination

     6.7.1 Taylors Wash Landfill

     The  Taylors  Wash Landfill  occupies  what used to  be  a
     ravine adjacent to  the Ohio  River.   No-records exist for
     this  landfilled  area, however,  sampling and  analyses
     conducted by Dames  & Moore  in 1992  indicate that  a
     variety of industrial wastes were disposed of within the
     ravine.  It  is estimated that  approximately 30,000 cubic
     yards of industrial  wastes were disposed  in Taylors Wash
     Landfill prior to 1981.   NSA has. indicated that unknown
     quantities of potliner have  also been  disposed of in the
     Taylors Wash Landfill, but they believe that the quantity
     is small.  Preliminary results of sampling at MW-210I at
     this location revealed the following contaminants: total
     cyanide (62,900 ppb),  amenable cyanide (663 ppb), barium
     (3,750 ppb), lead (89 ppb),  manganese (48,600 ppb), and
     nickel (320  ppb).   Leachate from the standpipe (MW-1000)
     within  Taylors  Wash  Landfill  revealed  the  following
     contaminants: manganese  (280  ppb),  2,4-Dimethylphenol
     (1,100  ppb),  1,2-Dichloroethane   (17 ppb),  and  PCBs:
     Arochlor-1242 (7.3  ppb).

     6.7.2 Industrial Landfills

     The other two (2) Industrial Waste Landfills were built
     in November of 1981  by excavating approximately 10 to 15
     feet below grade over an area of approximately 200 feet
     by 500 feet.  It is estimated that approximately 40.000

                          -42-

-------
          cubic yards  of  industrial wastes were disposed of into
          the  larger landfill, while  approximately 10,000 cubic
          yards  of  industrial wastes  were  disposed  of  in  the
          smaller  landfill.  According  to NSA, no spent potliners
          were  disposed  into  the  two  Industrial   Landfills.   A
          sample  was  obtained from MW-214 downgradient  of  the
          industrial landfills.   Preliminary analyses identified
          the following contaminants: chromium (144 ppb) ,  lead (220
          ppb), manganese  (21,300 ppb), and nickel  (652 ppb).

     6.8 Onsite Production Walla

     In  1985,  NSA detected cyanide in one of  its  three on-site
     water  wells.    This  well provided drinking water  to plant
     employees.  Results  from the  analyses  indicated  that  NSA
     Production Well #1 contained a total  of 0.133 ppm of cyanide.
     This significantly elevated level  is still below the Maximum
     Contaminant   Level   (MCL)  of  0.2  ppm  as  established  by
     regulation pursuant  to the Safe Drinking Water Act.  Cyanide
     that is  amenable  to  chlorination  was detected at 0.020 ppm.
     Barium, chromium,  and mercury,  were also detected.  Production
     Well #2 contained 0.051 ppm of total  cyanide and 0.006 ppm of
     cyanide  amenable  to  chlorination.    Production  Well  #3
     contained 0.020 ppm of total cyanide  and 0.010  ppm of cyanide
     amenable to chlorination.  The contaminated on-site drinking
     water  (Production Well #1) was no  longer utilized as a source
     of potable water.  The well is still utilized  as a source of
     industrial water  for the  facility.  At present, NSA utilizes
     the municipal water supply for all potable water.

7.0  SUMMARY OP SITB RISKS

A formal Baseline  Risk Assessment  has  not been conducted for the
NSA Site, but will be conducted during the'RI/FS.   The Agency's
decision to initiate Interim Remedial Action at  this Site is based
on  data collected during  previous Site  investigations.    This
information indicates that hazardous substance releases from this
Site are migrating in onsite  ground water  through the unconsol-
idated alluvial aquifer toward the Ohio River less than 3/4 mile
away.  Primary contaminants of concern  in  both the North and South
Plumes  are:  (but   are  not  limited  to)   cyanide,  arsenic,  barium,
manganese,   lead,   nickel,   and fluoride.    This  Interim Remedial
Action  will  be  conducted  to  address  the most  imminent  and
substantial problem  identified thus far  at the NSA Site.   This
Interim Remedial Action will prevent ground water contamination in
the North and South Plumes from spreading  and also to begin ground
water restoration activities.   Ground water  restoration activities
as described  in this  ROD,  will  not include  leachate  within the
landfilled areas.   Preliminary  sampling in this area  has identified
PCBs, volatile and semi-volatile  organic  compounds (VOCs)  in the
leachate of. the Taylors Wash  Landfill.   Further information will
need to be  obtained during the RI/FS for the Taylors Wash Landfill

                               -43-

-------
and  other landfilled areas  prior to  initiating  future remedial
activities.

Concentrations  of  cyanide  in  onsite  ground  waters  have  been
identified up to 56 ppm  (24 ppm amenable cyanide) with  the MCL at
0.2 ppm.  Fluoride was identified at levels up to 1770  ppm with the
MCL at 4.0 ppm.  Nickel was identified at levels up to  170 ppb with
the MCL at 100 ppb.  Manganese was detected at levels up to 8,400
ppb and the  SMCL  is  50 ppb.   Lead was identified at levels up to
110 ppb with the action level at 15 ppb.  Levels for these specific
contaminants of concern  in the  ground water are far above levels
allowed by  either the EPA or  the Commonwealth of  Kentucky.   In
response to the well documented contamination of the unconsolidaced
alluvial  aquifer   near  the  Potliner  Disposal Area  and  in  the
vicinity  of  the Spent Potliner  Accumulation Building, the Agency
has decided that containment  of  the contaminant plumes and initial
cleanup activities should be initiated.

Hazardous substances have been or  are being  released from the Site
in other  than a controlled  manner.   Some  of  these contaminants
found at  the Site are acutely toxic at extremely low levels,  and,
at  sublethal  levels,   they tend  to  bioconcentrate.    These
contaminants, other than  PCBs, are readily soluble and have leached
or migrated from soils into the groundwater.  Cyanide that is a by-
product of primary aluminum  production is  extremely toxic at low
levels.   Exposure  to cyanide can cause  a wide variety of health
problems  including:  central  nervous,  respiratory,  and cardio-
vascular  system problems.     Fluoride  is  a  by-product  of  the
ionization of cryolite,  and is concentrated as a waste product as
a result  of  the air  emissions filtration system at the Site.   In
the environment,  fluorides are soluble and can  result  in a variety
of toxicological effects, including fluorosis, a syndrome resulting
from chronic exposure and characterized by bone and tooth damage.
PCBs are  oil-based contaminants that are not readily soluble,  can
be carcinogenic and  tend to  bioconcentrate.   Calcium fluoride is
present at the Site in most media.

The .manufacturing facility  is  externally  fenced; however,  the
surface  impoundments are  not  isolated  by  fencing   from  other
portions  of the Site such as the adjacent airfield.  There are no
barriers  to  human  or   wildlife   movement  between the surface
impoundments and this public airfield.

8.0  DESCRIPTION OF REMEDIAL ALTERNATIVES

     The  following  alternatives were evaluated by  EPA using the
     nine evaluation criteria.

     1.   No Action;

     2.   Implementation of a multiple-well  gathering  and pump ar.d
          treat system to  remediate  two onsite plumes  conta:r.:.~. 3

                              -44-

-------
     cyanide and metals  contamination  in the unconsolidaced
     aquifer.  The exact number of withdrawal wells for each
     plume will be fully evaluated and determined during che
     Remedial Design phase of the Superfund process.

8.1  Alternative 1: No Action

   •  The EPA requires that this  alternative be evaluated at
     every site to  serve as a baseline  for comparison for all
     other alternatives considered.  Under this alternative,
     no groundwater remediation would  take  place.   The only
     reduction of contaminant levels that  could potentially
     occur would be via natural  processes such as dispersion
     or attenuation.   There would be no associated costs with
     this alternative.

8.2  Alternative 2: Pump and Treat System

   •  Implementation of a multiple-well  gathering and pump and
     treat system to remediate two onsite  plumes which contain
     cyanide and metals  contamination  in the unconsolidated
     aquifer.

   •  The  withdrawal   wells   will   be  installed   in   the
     unconsolidated aquifer in strategic  positions to recover
     the  maximum  amounts  of  contaminated  ground  water.
     Intermittent pumping on a varying  selection of the wells
     within each plume will  be utilized to manage the plumes
     and  control  cyanide concentrations   in  ground  water
     influent to the treatment plant.

   •  The treated effluent water will be  discharged into the
     Ohio River. Cleanup attainment levels are presented in
     Tables  4A &  4B  (Refer  to  Section 10.1,  Performance
     Standards).   System Operating Parameters are  shown  on
     Table 5 (Refer to Section 10.1, Performance Standards).

   •  Approximately  2.5 tons of sludge will be generated daily
     by the process,  which will be handled and disposed of in
     an EPA approved disposal  facility.

     Construction cost                         $ 1.7 million
     Annual operation and maintenance costs      $ 570,000
     Months to implement                           6 months

   The  extraction well and pump and  treat  system will limit
   the  offsite  spread of contaminated ground water  in  the
   unconsolidated aquifer.  The volume and amount of hazardous
   contaminants within the aquifer will  also be reduced.  This
   action will achieve significant risk  reduction early in -he
   Superfund process.
                          -45-

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9.0  SUMMARY OP COMPARATIVE ANALYSIS OF ALTERNATIVES

This section provides the basis for determining which alternative
for  this limited  scope Interim  Remedial Action:  1)  meets  the
threshold  for  overall  protection   of   human  health  and  the
environment  and compliance  with  ARARs,  2)  provides  the  "best
balance" between effectiveness and reduction of toxicity, mobility,
or volume through  treatment,  implementability, and  cost,  and 3)
demonstrates state  and  community  acceptance.  A  glossary  of  the
evaluation criteria is provided in Table 3.

     9.1  Overall Protection of Human Health and the Environment

     The only alternative that would sufficiently be protective of
     human health  and the environment for  this  Interim Remedial
     Action would be Alternative 2.  The "No Action" Alternative is
     not  protective  because  it  does   not  address   the  most
     significant threats  from the ground' water plumes  to  human
     health and the environment at the NSA Site.   Therefore,  the
     "No Action" Alternative will not be considered further in this
     analysis  as   an  option  for   the Site.   Alternative  2  is
     protective of human  health  and the  environment  since  it
     reduces or controls significant and immediate threats from cwo
     onsite ground water plumes containing significant levels of
     cyanide.  The extraction well and pump and treat system will
     also limit the potential spread of contamination onsite.

     9.2  Compliance with Applicable  or  Relevant  and Appropriate
          Requirement*

     Alternative 2  will meet all State and Federal ARARs concerning
    . the implementation of the extraction well and pump and treat
     system.  The ground water treatment  plant will meet all ARARs
     discharged  to surface  water.    All activities  concerning
     handling  and   disposal  of  the  sludge  generated  from  the
     operation will be  disposed of  at an EPA approved  disposal
     facility.

     Resource Conservation and Recovery  Act  (RCRA)  [42 U.S.C.  §§
     6921-39  {§§ 3001-19),  40 CFR Parts -260-270],  and  Kentucky
     solid hazardous waste regulations (401 KAR 30-35,  37, 47,  and
     48),  regulate  the  treatment,   storage,  and  disposal  of
     hazardous waste  from generation  through  ultimate disposal.
     All activities concerning handling and disposal of the sludge
     generated from the operation will be in  compliance with State
     and Federal ARARs.  Waste sludge  (2.5 tons per day  ) will be
     disposed of at an EPA approved disposal facility.

     All manifesting and generator requirements  cited  in CFR 262
     and 264 will be met during this CERCLA response action.  Under
     RCRA policies  and regulations (derived from rule)  (Contained


                              -46-

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                          TABLE 3

         EPA CRITERIA FOR  EVALUATING
              CLEANUP  ALTERNATIVES
Overall Protection of Public Health and Environment:  Degree to which
each alternative eliminates, reduces, or controls  threats to public
health and environment through treatment,  engineering methods,  or
institutional controls  (e.g., deed, land use or other restrictions).

Compliance with State  and  Federal Requirementa:  Degree  to which
each alternative meets environmental regulations  determined to  be
applicable or relevant  and  appropriate to Site conditions.

Short-Term Effectiveness:  Length of  time needed to  implement each
alternative and  the  risks  posed  to workers  and  nearby residents
during implementation.

Long-Term Bffectivenee*t  Ability  to maintain reliable protection
after implementation.

Reduction  of  Toxicity,  Mobility,  and  Volume:  Degree to  which
alternative reduces  (1) ability of contaminants to move through the
environment,  (2)  harmful nature of contaminants, and  (3) amount  of
contamination.

Implementability:      Technical   feasibility   (difficulty   of
constructing,  operating,  or maintaining)  and administrative ease
(e.g.,  amount of coordination with other governmental agencies  or
relocation  or   residents)  of   implementing  remedy,   including
availability of  goods or services.

Cost: Benefits of alternative weighed against cost.

State Acceptancet EPA requests State comments on the Proposed Plan
and concurrence  on final remedy selection.

Community Acceptancei EPA holds a public comment period to get input
from the  affected community and  considers  and  responds to  all
comments received prior to the final  selection of  a  remedial (long-
term cleanup)  action.
                           -47-

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in policy) the groundwater is considered to be a hazardous
waste because it  contains constituents derived from the listed
hazardous waste,  K088, spent aluminum potliners.  Normally 40
CFR Part 264, Subpart I, Tanks, would be applicable  to  storage
of  hazardous wastes;  however,  it  is  not  applicable here
because the pump  and treat system is a contained system and is
therefore  exempt  under §  264.10(g)(6)  as  a waste water
treatment unit.   Disposal  of waste  water  from the pump and
treat system will also not  be regulated under  RCRA  because it
will be disposed of  under a KPDES permit.

RCRA Land Disposal Restrictions (LDRs)  will not be  applicable
or relevant and appropriate for this  Interim Remedial  Action.
However, it  is anticipated  that the treatment residual will
contain the K088  listed waste for spent potliners from  primary
aluminum  reduction  (which  contains  cyanide),  and disposal
facilities receiving the treatment residuals  (sludge)  should
handle of the sludges  in compliance with RCRA LDRs.

RCRA  requirements  may  include  LDR  and  waste  generator
requirements set forth in 40 CFR Part 268.7 and Part 262.  Any
offsite facility receiving  the  hazardous waste for disposal
will meet the requirements  set  forth in 268.41. Because the
Commonwealth of Kentucky may be authorized for some or all of
the RCRA  provisions, the applicable  regulations  are  hereby
incorporated by reference.

While MCLs are relevant and appropriate for-final groundwater
cleanup  at   this  Site, this  remedy  is  primarily  a   source
control  remedy for  containment of  two  contaminated water
plumes and  does  not address  the  final cleanup.   The final
cleanup levels for the ground water are not addressed  in this
Interim Remedial Action ROD because such goals are  beyond the
limited scope of this  action.   The final cleanup levels will
be addressed and will be met  by  the Final Remedial  Action ROD
for the  Site.  Thus,  to the extent that  this Interim  Action
remedy addresses  remediation of the  groundwater  an  interim
action waiver  pursuant to  CERCLA Section  121(d)(4)(A) ,  42
U.S.C. 9621(d)(4)(A),  for the final cleanup ARARs, including
MCLs  and  other relevant cleanup  levels  is  hereby invoked.
However, it  is expected that continued implementation of the
extraction well and pump and treat system will specifically
reduce levels of cyanide to the MCL of 0.2 ppm which  applies
to 'free cyanide' (40 CFR Parts 141 and 142; National  Primary
Drinking Water Regulations;  Vol  57, No. 138, July 1992) . Th:s
guidance further  states,  'EPA  is  specifying  the  use  of zne
"cyanide amenable  to chlorination* test for determining :r.e
"free  cyanide"  concentrations, while  the  "total cyanide'
analytical technique is being allowed  to screen samples'.

Previous  analytical  results  at  the NSA  Site  for  cyar.: :e
(total, and  amenable - as  a measure of  "free cyanide") r.^-.e

                          -48-

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all indicated  that  cyanide levels in  the  ground water plumes
are  orders  of  magnitude  above  the  MCL.    The  previous
analytical  results  for   "total  cyanide"  have  been  very
consistent while the previous analytical results for  "amenable
cyanide* as a measure of the "free cyanide" have been variable
(even though results were variable,  all analyses for the main
portion  of  the  North Plume  were  consistently orders  of
magnitude above the MCL, while levels for the South Plume were
noted  to be significantly elevated)-.   In response  to the
previous variable results  for  "amenable cyanide"  at the NSA
Site, it will be necessary during the Remedial  Design for the
Interim  Remedial Action  to utilize different or  enhanced
analytical techniques  to consistently identify the  amount of
"free  cyanide".    If consistent procedures  or  analytical
techniques cannot be successfully be determined as  part of the
Remedial Design, then the cleanup level (0.2 ppm) for effluenc
or waters discharged  to the Ohio River should be applied co
"total cyanide".  This cleanup level would be justified since
the "free cyanide*  would be a variable portion of the "total
cyanide*.

Within this Interim  Action ROD,  the term "amenable  cyanide" is
used since much of the previous analytical  data utilized this
terminology, and it  should be noted  that  this was  utilized in
order to determine  the "free cyanide*.

Concerning  KPDES   standards  (Table  4A),  Treatment  Plant
Effluent Standards  and the Kentucky Water "Quality  Standards
(Table 4B) , these levels  will  be attained prior  to treated
waters being discharged into the  Ohio River (refer to Section
10.1,  Performance Standards).  A  list  of the major ARARs that
pertain to the NSA  Site Interim Action is presented below.

  9.2.1  Action Specific ARARs

  Pertain  to  performance,  design,  or  other  similar action-
  specific  requirements  that  impact  particular  remedial
  activities.

  •  Kentucky   Pollutant    Discharge   Elimination   System
     FKPDESUOl KAR  5.  specifically Parts 031.  065. and 075) 1 .
     Kentucky Water  Quality Regulations are applicable to rhis
     response action  because they regulate the point-source
     discharge of treated ground water  to the Ohio  River by
     setting    discharge    limitations    and   monitoring
     requirements.  This response action  shall abide  by tr.e
     substantive  requirements  of   regulations set by  tr.e
     Commonwealth of  Kentucky,  which has  been authorized to
     implement the  National Pollutant Discharge  Elimination
     System program under  authority of the Clean Water Art
     (CWA  §  402) .    Section  402  of  the CWA incorporates
     sections 301,  302, 306,  and 307.

                         -49-

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•  KRS 151.140 is applicable to this response action because
   it regulates  the withdrawal of  water from public waters
   within the  Commonwealth of  Kentucky.   This  response
   action will  comply with all substantive requirements  of
   this regulation.

•  401 KAR 5:005:  Kentucky's  Waste Water  Treatment  Plant
   Design Criteria  are  applicable requirements  for  the
   design of  the treatment system  to be used at  the Site.

•  KRS224.01-400 : Hazardous Substance Remediation Provisions
   are applicable when a release or threatened release of a
   hazardous  substance occurs.

9.2.2  Location  Specific ARARs

Complications  or  additional  problems  may  develop  when
hazardous  waste cleanup occurs  in  specific  locations.
Location  Specific  ARARs  are  restrictions  placed on  the
concentration of hazardous substances  or the conduct  of
activities  solely  because  these  activities  are  being
conducted in a  specific location.

•  40 CFR §264.18(b),  Floodplain Management,  mandates that
   hazardous waste treatment, storage or disposal facilities
   located within a 100-year floodplain must  be  designed,
   constructed,  operated and maintained to  avoid washout.
   This regulation  is applicable because -a large portion  of
   the Site is located within the 100-year floodplain of the
   Ohio River.

•  40  CFR  6.302.  Floodplain Management  Executive  Act,
   (Executive Order  11988):  Actions  in  floodplains are
   required  to  avoid  adverse  effects,  minimize  potential
   harm,  and restore  and preserve natural  and  beneficial
   values.

9.2.3 Contaminant Specific ARARs

These ARARs are health or risk-based concentration limits
or  ranges in  various  environmental  media  for  specific
hazardous substances, pollutants,  or contaminants.   These
ARARs set protective cleanup levels for the contaminants of
concern in the designated media  or indicate and acceptable
level  of discharge  into  a  particular medium  during  a
remedial activity.

For  this  Interim  Remedial  Action,  Maximum  Contaminant
Levels  (MCLs) [Safe Drinking Water Act  (40  CFR  Part  141)]
are  not  relevant and  appropriate requirements  since  the
"interim* cleanup is  intended to  implement  source control
measures for onsite  ground water  plumes.  MCLs  are  HOC  a

                       -50-

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   contaminant specific ARAR since no final cleanup measures
   will be implemented as part  of this "interim"  remedy.

   •  Clean Water  Act  (40 CFR  Part  122) :  National Pollutant
     Discharge  Elimination System  (NPDES) .    This  ARAR is
     applicable concerning point source discharges.

   •  Clean Water Act (40  CFR Part 125) : Criteria and Standards
     for the National  Pollutant Discharge  Elimination System
     (NPDES) are applicable to point source discharges.

   •  Clean Water Act  (40 CFR  Part 133):  Secondary Treatment
     Regulation is applicable because  hazardous waste derived
     from  industrial waste will  be discharged  into United
     States navigable waters.

   •  402 KAR  5:  029 and  5:031;  Water Quality Standards are
     applicable  because  they  pertain   to   point   source
     discharges at the Site.

9.3  Ziong-Term Effectiveness and Permanence

Interim measures (Alternative 2) as described in this document
will  not  provide  any  degree  of  long-term effectiveness
concerning  remediation  of  source  waste   at  the  NSA  Site.
However, the  extraction  well and pump and treat system will
permanently eliminate contaminants from extraction well waters
prior  to  treated water  discharge in  the" Ohio River.   The
primary goal of the Interim Remedial Action is to address the
most imminent and substantial problems at the Site.  This will
occur  while  the RI/FS and  Post RI/FS activities  are  being
completed.   Alternative  2  is  consistent  with the Agency's
long-term goal of restoration of Site and adjacent area ground
water.   In  addition,  the two  onsite  cyanide  plumes  will be
hydraulically controlled to reduce the possibility  of offsite
migration.   This will offer   significant  advantages during
implementation of the  Final Remedy for the Site.

Additional data will be generated during implementation of the
Interim  Remedial   Action.     This   information   concerning
hydraulic conductivity and  aquifer  response  will be used in
conjunction  with  RI/FS  data   to  facilitate Final  Remedy
selection.   Long-term effectiveness  and  permanence  will be
more thoroughly evaluated at that time.

9.4  Reduction of Toxicity, Mobility, and Volume

Alternative 2 will effectively  reduce toxicity and mobility of
contaminants (specifically cyanide)  in the ground water plumes
at: 1)   the  waste water  impoundment areas, and 2)  under and
near the Spent  Potliner  Accumulation Building (formerly tr.e
Dump Pad).  Contaminants withdrawn from the extraction we*is

                          -51-

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will  be  permanently  eliminated.   . It  is  expected  that
contaminant levels within the two onsite ground water plumes
will be significantly  reduced through implementation of the
ground water  extraction pump  and treat system.   Continued
implementation of the system may potentially reduce the volume
of contaminated  waters in  the alluvial  aquifer.   During the
RI/FS,  the  onsite source  will  be thoroughly  evaluated and
appropriate action will be taken as part of the Final Remedy
to insure  continued ground water contamination does not occur.

9.5  Short-Term Effectiveness

Significant   short-term   effectiveness   will   result   from
implementation of Alternative 2.   The  Interim Remedial Action
is effective in the short-term because it would significantly
reduce the  potential threats  from contaminants  in  the two
onsite ground water plumes.  However,  short-term risks will be
slightly  elevated during  transfer of  sludge  from  the:  1)
sludge holding  tank,  2)   sludge  transfer  area,   3)  solids
collection area, or 4)  the  filter  press  area to transport and
disposal facilities.   These 4 system areas will be routinely
maintained and associated risks are expected to be minimal.

9.6  Implementability

The implementability of Alternative  2 is  based on technical
feasibility, administrative feasibility, and availability of
services  and  materials.     Alternative-  2  is  readily
implementable since the ground water extraction pump and treat
system is a prepackaged system  that  has been implemented at
numerous  sites with metals/inorganic contamination in the
ground  water   (information  is  included  as  part  of  the
Administrative Record for the Site).  A treatability study was
performed on  samples of  the contaminated ground water  to
determine  the  optimum conditions  to  remove  the  metals,
cyanide,  and fluoride.  The study determined that the chemical
coagulation/precipitation process  would be a viable technology
for treating  contaminated  ground  water  at  the NSA facility.
Test samples of contaminated ground water were run through 8
separate runs  to  confirm the  effectiveness of this process.
Treatability  testing results  indicated  that "total cyanide'
and  'amenable cyanide' (free cyanide)  will  be  effectively
reduced to  the 0.2 mg/1 MCL.    [It should  be noted that the
treatability  testing  indicated  that  cyanide amenable  to
chlorination was not  effective in reducing cyanides. However,
as  was previously  stated  in  Section 9.2,  a   consistent
analytical technique to identify  'free  cyanide" will have to
be demonstrated during the  Remedial Design,  otherwise the
cleanup level to be attained for effluent or waters discharged
to the Ohio  River will be 0.2  for "total  cyanide"].   Other
metals and  fluoride will also  be  effectively  reduced  to
Federal and State of Kentucky regulatory limits.

                          -52-

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     There are no expected difficulties concerning administrative
     feasibility or availability of services or materials  for the
     implementation of Alternative 2.

     9.7  Cost

     Alternative 2 has a present worth cost of $1.7 million.  The
     annual  operation  and maintenance  cost  will be  $570,000.
     Additional  areas of  contamination  that  are  not  addressed
     during this Interim Remedial Action will be evaluated during
     the RI/FS.  The associated cleanup  costs  for these areas will
     be evaluated after this information is obtained during these
     investigations.

     9.8  State Acceptance

     The Commonwealth of  Kentucky has  assisted  in the Superfund
     process  through review   of   documents   and  submittal  of
     significant comments.   The State  has  reviewed the Proposed
     Plan  and Interim  Remedial Action Record  of Decision  and
     concurs  with  the  selection   of   these   "Interim"  Remedial
     Actions.

     9.9  Community Acceptance

     A Public  Meeting to present  the  Proposed Plan was  held on
     1/19/93 at the Hancock County Middle School near Hawesville,
     Kentucky. Comments  from  the public during- the meeting were
     supportive of the Interim Remedial Action proposed for  the NSA
     Site.   The Public  Comment Period was  held  from  1/7/93  to
     2/7/93.  No extension to the comment period was requested.

10.0 THE SELECTED RgMBDY

Based  upon  consideration  of  the  requirements of CERCLA,  the
detailed analysis of the alternative, and public comments, EPA has
determined  that  the  activities as  described  in  Alternative  2
(Section 8.2, p.  41)  constitute an  appropriate  Interim Remedial
Action until a  Final Action   for  the Site  is  determined.    A
prepackaged pump and  treat system utilizing  extraction  wells is
being  proposed  to  limit   the  spread  of  contaminants   in  the
unconsolidated alluvial aquifer and to begin ground water cleanup
activities.  This  system,  as  investigated by  NSA,  offers  a wide
range of treatment features and appears cost  effective.   Cleanup
attainment levels are  presented in Tables 4A &  4B (Refer to Section
10.1,  Performance  Standards).The   major  goal  of  this  Interim
Remedial Action is to reduce risks  at  the Site by eliminating cr
controlling  the  most  imminent  and substantial threats  to hunvan
health and  the environment.    Additional  goals of  this  Interim
Remedial Action  are  to derive valuable information  concernir.5
aquifer  characteristics   that  would   potentially   assisc   : r.
implementing the Final Remedy.

                               -53-

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A Treatability  Study was  performed on contaminated ground waters
from  the  NSA   Site.     This  study  determined  that  Alkaline
Chlorination would  not  be an effective method for elimination of
cyanide, metals, and fluoride from the ground water.  However, the
study  did determine that  a  Chemical Coagulation/Precipitation
process did effectively remove contaminants  to acceptable levels.
Since a successful Treatability Study has already been performed on
contaminated ground water samples,  significant  modifications to
either  the procedure or  apparatus  are  not expected  during the
Remedial  Design and  Remedial Action  (RD/RA).    However,  normal
modifications  may   be  implemented  in  order   co  enhance  the
performance of the pump & treat apparatus.

This treatment system as proposed to EPA by NSA, utilizes ferrous
precipitation and settling  to remove cyanide  from ground water
entering the system. The process will also lower incidental levels
of  multivalent  metals.    The  treatment  process consists  of the
following  five levels:

     1)    Cyanide Precipitation

     2)    First Stage Clarification

     3)    Chemical Coagulation/Precipitation Process

     4)    Second Stage Clarification

     5)    Solids Dewatering

In level 1, Cyanide Precipitation,  excess ferrous chloride  (FeCl2)
or ferrous sulfate (FeS04) is added to the ground water  in order to
precipitate ferricyanide  (Fe(CN)6"3).   The solids in the effluent
are then  separated  from the liquid phase by  gravity  settling in
level 2, First  Stage Clarification.   The clarified effluent from
level 2 then enters  level 3 where the residual soluble ferrous iron
(Fe2*)  is  removed  from  the  liquid phase.   Removal  is  achieved
through  air  oxidation  and  precipitation  as   ferric  hydroxide
(Fe(OH)3).   Additional  solids are  removed  by  settling  from the
level  3  treated  ground   water  during  level   4,  Second  Stage
Clarification.  The clarified effluent is then discharged from _he
system.  In level 5, Solids Dewatering, the liquid phases remaining
in the sludges produced during previous levels,  are collected and
re-routed  to  level  1.    The  treated  effluent  water  will  be
discharged into the Ohio River.  The discharge will be treated to
meet  the  standards  shown on  Table 4A  (Refer  to  Section  10.1.
Performance Standards).   Approximately 2.5 tons of sludge will be
generated  daily by the process, which will be handled and disposed
of in an EPA approved disposal facility.

In appendix  A.4,  additional preliminary information on the design
of the gathering system and treatment plant  are presented together
with  a  technical  memorandum  on preliminary  ground  water   t.

                               -54-

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modeling of the effects of  the  pumping system.   Also in Appendix
A.4 are  the conclusions of  a  treatability study  for  the ground
water.

At the end of  the  five-year  period  following this Interim Remedial
Action,  a  review will be   conducted.    If   subsequent  remedial
activities are initiated prior to the close of  the five-year period
following the Interim Remedial Action, a review will be conducted
prior to any  initiation of  additional  work at the  NSA Site.   The
review will be  conducted  to insure that  the  extraction  well and
pump and treat system are,  and  have been functioning as  designed
and that the  "interim" activities are, and have been effective in
reducing the threat to human health and the environment.

     10.1 Performance Standards

     Performance  Standards  for  the ground water pump and  treat
     system are presented in Tables 4A & 4B.   Emissions  from the
     system would meet Treatment Plant Effluent Standards for: 1)
     the Ohio River Valley Water Sanitation Commission (ORSANCO),
     2) warm water aquatic habitat  acute  criteria (Commonwealth of
     Kentucky),  and 3) warm  water aquatic habitat chronic criteria
     (Commonwealth of Kentucky).  These performance standards are
     not MCLs  (refer to Section 9.2, p. 46-47 for a discussion of
     sludge disposal standards).

     The discharge limits contained in Table 4A are those currently
     proposed by  the Commonwealth  of  Kentucky Division of. Water.
     The permit with which these discharge limits shall comply is
     currently  subject  to  public   comment,   therefore,   these
     discharge  limits  may   be  amended.    If  the  final  KPDES
     requirements vary from those listed in this table, the final
     discharge limits are hereby incorporated  by reference and will
     replace those listed in Table 4A.

       10.1.1 Ground Water withdrawal Limits

       Ground water withdrawal limits will be evaluated during the
       Remedial Design.  The ground water withdrawal criteria to
       be  evaluated include:  1)  availability,  2)  reasonable use,
       and 3)  impact  on   other  users  of  the resource.    The
       Commonwealth of  Kentucky  Water  Resources  Branch  have
       performed    a   preliminary    review   concerning    the
       implementation of the pump &. treat system and believe that
       ground water availability will  not be a problem.  However,
       they have  suggested that  the  impact on  other users  be
       further evaluated during the Remedial  Design.
                               -55-

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(TABLE 4A)
cBMUkcrnmrxc*

PARAMTO
Flow (MGD)
Arsenic (T.R.*)
Barium (T.R.)
Cadmium (T.R.)
PCBs*
1,2 DCA
Chromium (III)
Lead (T.R.)
Zinc (T.R.)
Chromium (IV)
Copper (T.R.)
Iron (T.R.)
Mercury (T.R.)
Nickel (T.R.)
Fluoride
Cyanide*
Cyanide5
Manganese (T.R. )
2,4-DMP
1,1.1-TCA
Aluminum T.R.
SUMMARY
AN]
DXI
MLT/OLT
KVWA/n
(kff/d)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
' OF KPDBS
t> MONITOR:
"'HftfTT TiTHTT*
UTUU OMZTI
KLT. AVI.
0.72
0.05 mg/1
1.0 mg/1
0.0039 mg/1
0.0014 ug/1
Report11
1.74 mg/1
0.0816 mg/1
0.117 mg/1
0.016 mg/1
0.0177 mg/1
4.0 mg/1
0.0024 mg/1
1.42 mg/1
1.0 mg/1
0.20 mg/1
0.022 mg/1
Report
Report
Report
Report
EFFLUENT
CNQ REQUIJ
rxora
3 (SPIGOT)
DLT. AVI.
0.72
0.05 mg/1
1.0 mg/1
0.0039 mg/1
0.0014 ug/1
Report
1.74 mg/1
0.0816 mg/1
0.117 mg/1
0.016 mg/1
0.0177 mg/1
4.0 mg/1
0.0024 mg/1
1.42 mg/1
1.0 mg/1
0.20 mg/1
0.022 mg/1
Report
Report
Report
Report
DISCHARGE
IEMENTS
MOVXTOK.

PUQOTOCT
I/week
I/ week
I/ Week
I/Week
I/ week
I/week
I/ Week
I/week
I/week
I/ Week
I/Week
I/week
I/Week
I/Week
I/ Week
I/Week
I/Week
I/ Week
I/Week
I/ Week
I/Week
t LIMITATIONS
DM KEQOXRXXKNTS

TYPS
Instantaneous
24-Hr. Composite
24-Hr. Composite
24-Hr. Composite
Grab
Grab
24-Hr. Composite
24-Hr. Composite
24-Hr. Composite
24-Hr. Composite
24-Hr. Composite
24-Hr. Composite
24 -Hr. Compos :~-S
24-Hr. Composite
24-Hr. Composite
Grab
Grab
24-Hr. Composite
Grab
Grab
24-Hr. Composite
a)      T.R.  = Total Recoverable
b)      Value is for Total cyanide
c)      Value 1* Cor Amenable Cyanide
d)      Report = Analyses will be performed Cor contaminant, however, there  is  no KPDES lirr.i
        this  contaminant.
Additional
                      • i
    Compliance with the PCS limitation of 0.0014 ug/1  shall be achieved by demonstrating that :
    is no  detectable  discharge of PCBs at any  time.  An  instantaneous maximum detection  1:-:
    0.065 ug/1 in water shall  be  utilized.

    The pH of the effluent shall not be less than 6.0 standard units nor greater than 9.0  scar
    units and shall be monitored  I/week by grab sample.

    There shall be no discharge of floating solids or visible foam  in other than trace amour.-. 5

    Samples taken in compliance with the monitoring requirements specified above shall be  -i-
    the following locations(s): nearest accessible point after final treatment but prior  :
    discharge to or mixing with receiving waters.

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TABLE 4B
TREATMENT PLANT EFFLUENT STANDARDS AND
KENTUCKY WATER QUALITY STANDARDS
PARAMETER
ARSENIC
BARIUM
CADMIUM3
CHROMIUM
(III)3
CHROMIUM
(IV)
COPPER
IRON
LEAD3
MERCURY
NICKEL3
ZINC
FLUORIDE
CYANIDE (t)
CYANIDE1"
TREATMENT
PERF . STANDARDS
(mg/1)
0.050
1.000
0.0039
1.74
0.016
0.0177
4.0
0.0816
0.0024
1.42
0.117
1.0
0.204
0.022
ORSANCO1
(mg/1)
0.050
1.000
0.0039
1.74
0.016
0.0177
NA
0.0816
0.0024
NA
0.117'
1.0
NA
0.022
WARM WATER AQUATIC
HABITAT CRITERIA2
(mg/1)
ACUTE CHRONIC
NA
NA
0.0039
NA
0.016
0.0177
4.0
0.0816
0.0024
1.42
0.117
NA
NA
0.022
0.05
1
0.010
33
0.011
1
NA
0.05
0.000012
0.610
NA
1.0
NA
0.005
1  401  KAR 5:  029  §  8
2  401  KAR 5:  029  §  4  Table 2
3  Hardness-Dependent  (assumes  hardness  of  100  mg/1)
4  Design Standard
t = Total Cyanide
f = Free Cyanide
NA = Not Available

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 10.2    System Operating Parameters

 The operating parameters.under which the ground water  pump  and  treat
 system shall operate are presented in Table  5.
                           TABLE 5
PRELIMINARY'SYSTEM DESIGN AMD OPERATING PARAMETERS
                       SYSTEM FLOW RATE
  Treatment System
500 GPM (720,000  GPD)
                  CHEMICAL CONSUMPTION RATE
Ferrous Chloride (39 wt%)
Caustic Soda (50 wt%)
Polymer
409 gallons/day
259 gallons /day
8.64 gallons/day
                    SLUDQE GENERATION RATE
  Cake  (30% solids)
     71.3 cu.ft./day
     2.49  tons/day
                     UTILITY REQUIREMENTS
Air
Electricity
100 SCFM @ TOO PSIG
20 HP
  *  Preliminary operating parameters may vary slightly from
     the final  operating parameters to be developed and
     submitted  during the Remedial Design.
      10.3 ARAR Requirements

    The  following  major  ARARs shall be  met  for the ground  water
    contaminants of concern for this Interim Remedial Action.

    Treated ground water discharged to  the Ohio River  shall  comply
    with applicable  KPDES  limits.   State ground water  withdrawal
    requirements  shall  be  observed.    Solid  wastes  and sludges
    generated from the pump and treat  system will be  regulated  as
    K088  listed  hazardous  wastes  (wastes   derived   from   spent
    potliners).   Applicable manifest and generator  requirements  as
    cited in  CRF §262 and  §268 shall  be  met  during this  CERCLA
    response action.

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11.0 Statutory Requirements

The U.S.  EPA and the  Commonwealth  of Kentucky believe  that the
activities included  in the  Interim Remedial Action  satisfy the
statutory requirements of providing  protection of human health and
the environment,  attain ARARs directly associated with this action
and will be cost- effective.   Sections 11.1 through 11.6 summarize
the statutory requirements for che Site.

   11.1    Protection of Human Health and the Environment

   The  activities previously  described  concerning  this "interim"
   action  will   provide  protection  of  human  health  and  the
   environment  through  extraction  and treatment of  contaminated
   ground water at the  NSA Site.    Implementation of  the Interim
   Remedial Action activities will  not  pose unacceptable short-term
   risks or cross-media impacts.

   11.2    Attainment of ARARs

   Although this  is an Interim Remedial Action, it is expected that
   the   cleanup  levels  attained  for  the  treated  ground  waters
   discharged to the  Ohio  River  will be  consistent,  and  in
   compliance with Federal and State ARARs as  identified in Section
   9.2   of  this  document.    Treatability   Study   results  and
   preliminary  test sampling  indicate that  performance standards
   for  the ground water pump  and treat  system will  attain ARARs.
   The  final  cleanup  levels for the ground water are not formally
   addressed  as part of this Interim Remedial  Action.  However, che
   final cleanup  goals for the Site are  expected to be consistent
   with  those cited in the Safe Drinking Water Standards Current,
   and Proposed MCLs,  MCLGs,  and SMCLs.

   11.3    Cost  Effectiveness

   This  Interim Remedial Action employs  proven  technologies that
   will  be applied to  contaminated ground waters  that presently
   reside on  the NSA  Site.   The selected remedy affords overall
   effectiveness  concerning  remediation  of cyanide,  metals,  and
   fluoride  from ground  water.     Considering  the  toxicity  of
   cyanide, and the effectiveness  of  the system as  indicated by
   Treatability Testing, Alternative 2 provides a sufficient margin
   of protection  proportional to its cost.

   11.4    Utilisation  of  Permanent  Solutions  and  Alternative
          Treatment Technology or Resource Recovery Technologies to
          the Maximum Extent Practicable

   Although this  Interim Remedial Action  is not intended to utilize
   permanent  solutions  for the NSA Site,  pump and treat activities
   will  permanently  remediate ground waters extracted  from the
   alluvial aquifer that are discharged to the Ohio River.  The EPA

                               -59-

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will continue to evaluate long-term effectiveness and permanence
as part  of the development of  the  final  action for the Site.
Subsequent  actions will  provide a  final resolution  to Site
conditions,  the majority of which  will  be controlled through
implementation of this Interim Remedial Action.   This action is
limited  in  scope and  not  expected to be final.  However, this
remedial activity does represent  the best balance of tradeoffs
among alternatives with respect to pertinent criteria.

11.5   Preference for Treatment

The  CERCLA statutory preference  for  treatment  requires that
waste treatment be thoroughly evaluated and if possible, treated
to reduce  or eliminate  the threats from  hazardous wastes or
materials.  This interim remedy satisfies  this CERCLA statutory
requirement through treatment of  contaminated ground water via
a ground water  extraction pump  and treat system.  This Interim
Remedial Action will not necessarily be the  final solution for
Site  contamination,  but  through  chemical coagulation/precip-
itation  it  will effectively reduce  levels of cyanide,  metals,
and  fluoride  in extracted  ground waters  to levels at or below
promulgated standards.
                            -60-

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                         APPKNTICBS

Appendix A: Technical Information

  A.I) Technical  Memorandum #1  (Drilling  and Monitoring Well
       Installation)
  A.2) Technical  Memorandum #2  (Ground Water  Sampling)
  A.3) Technical  Memorandum #7  (Aquifer  Pump  Test)
  A.4) Technical   Memorandum  #8  (Ground  water  modeling   &
       Treatability Study  for Ground Water)
  A.5) Analytical Analyses  from LSI Report  (11/89-1/90).
  A.6) Summary  of Monitoring Wells Installed at the NSA  Site.

Appendix B:  Copy of the Proposed Plan Presented at the
         Public Meeting, January 19, 1992,
         Hawesville, Kentucky.

Appendix C:  Information Repository Location

Appendix D:  Letters of Concurrence

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               APPENDIX A.I
          TECHNICAL MEMORANDUM #1
DRILLING AND MONITORING WELL INSTALLATION

-------
                   TECHNICAL MEMORANDUM  NO. 1

SITE:  NSA a Division of Southwirc Company
LOCATION: Hawesville, Kentucky
JOB NO.  22784-005-121
CLIENT:   NSA

         DRILLING AND  MONITORING WELL  INSTALLATION

       Drilling and installation of the new monitoring wells (MW-201D, MW-201I,
MW-201S, MW-202D,  MW-202I,  MW-203D,  MW-203I,  MW-203S, MW-204D.
MW-207,  MW-208I, MW-209I,  MW-210I,  MW-211I. MW-212I,  MW-213I, and
MW-214S) was conducted by Fugro-McClelland, Inc. (Fugro-McClelland) of St. Louis,
Missouri under the technical supervision of a Dames & Moore geologist A Central Mine
Equipment Company Model 750 rotary drill rig, mounted on an all terrain vehicle (ATV),
equipped with 4-1/4-inch inside diameter (ED) hollow-stem augers was used for the drilling
and well installation. The  well  installation was completed between February 26 and
April 7, 1992

       All drilling and sampling equipment and tools were steam-cleaned and inspected for
signs of contamination prior to the onset of drilling activities at each drilling site. Split
spoons were steam-cleaned or cleaned in a detergent wash and double rinsed with potable
water between each sample.

       Boreholes were advanced through unconsolidated sediments using hollow-stem
augers.  Hollow-stem augering advances the borehole by rotating and pressing the augers
into the soil. As this occurs, soil cuttings are rotated upward by the auger flights to the
ground surface.

       Split-spoon soil samples were obtained from each borehole, at 5-foot intervals as
drilling progressed, A 2-inch outside diameter (OD) split spoon, driven by a 140-pound
hammer falling 30 inches was used. The samples were examined and classified according
to the Unified Soil Classification System (USCS) and logged on Dames & Moore boring
log forms.  In locations where monitoring well clusters were installed, only the deep well
was sampled and logged.  Also recorded on the boring logs were sample time, sample
interval, and blow counts for the Standard Penetration Test (SPT).

-------
       Ground water samples were collected from the deep monitoring wells and selected
intermediate wells during drilling using a Grunfos RediFlo 2 submersible sampling pump.
Samples were collected at 20-foot depth intervals, with the first sample collected at the top
of the water table. The pump and discharge hose were decontaminated by steam cleaning
the exterior and flushing the interior with potable water. The volume of water standing in
the augers  was calculated and purged by initially pumping from  the top of the water
column.  After one volume of water was removed from inside the augers the pump was
lowered to  the sampling depth and at least one more volume of water was purged. The
water sample was then collected, preserved with sodium hydroxide, stored on ice in a
cooler, and delivered to NSA's onsite laboratory for total cyanide analysis.  Results are
shown on the attached Table TMl-1.

       The total cyanide results from water samples taken while  drilling the deep  wells
were used to determine the depth of maximum cyanide concentration.  The intermediate
wells  were drilled to the depths determined.  Test results from the water samples  taken
from the intermediate wells during drilling were used to ensure the wells were delineating
the lateral limits of the cyanide plume. In borings 20SI and 2061 cyanide contamination
was above the Maximum Contamination Limit (MCL). These borings were backfilled with
grout and new wells were located and drilled to better define the extent of contamination.

       All  the wells were constructed of 2-inch-ID stainless-steel  casing equipped with a
10-foot secdon of 10-slot stainless-steel screen.  A commercial filter pack consisting of No.
5 silica sand was placed along the entire length of and 5 feet above the well screen. The
remaining annulus was filled with thick Volclay® bentonite sealer extending  up to just
below the frost line.  The annulus from below the frost line to the surface was filled with
concrete, which blended to a 3 feet diameter, 4-inch-thick pad on the surface. A lockable
protective steel casing was set in the concrete pad and 4-inch diameter steel posts  set m
concrete were placed around the wells to protect them.  The protective casing and steel
posts were painted high-visibility yellow.

       On  April 22,  1992  the locations of the new and existing wells  were  surveyed by
Johnson, Depp, and Quisinbury, of Owensboro, Kentucky.  The top of inner casing
elevations were also surveyed to within 0.01 foot above msl.

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      The wells were developed and sampled following installation using the Grundfos
pump. A minimum of 15 well volumes of water were removed during development. The
well screens were surged with the pump during development.  Development water was
contained and then added to the makeup water of the air control system.

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                          TABLE  TM-M

                  RESULTS OF CYANIDE ANALYSES
                     GROUND WATER SAMPLES
                   COLLECTED DURING DRILLING

                 NATIONAL SOUTHWIRE ALUMINUM
                     HAWESVILLE, KENTUCKY


Sampling Date
2/27/92
2/28/92
2/29/92
2/29/92
2/29/92
3/2/92
3/24/92
3/24/92
3/1/92
3/1/92
3/1/92
3/1/92
3/1/92
3/2/92
3/24/92
3/3/92
3/3/92
3/3/92
3/3/92
3/3/92
3/4/92
3/4/92
3/4/92
3/5/92
3/5/92
3/5/92
3/6/92
3/10/92
3/10/92
3/11/92
3/11/92
3/11/92


Weil Number
201 D
201 D
201 D
201 D
201 D
201 D
201 S
2011
202 D
202 D
202 D
202 D
202 D
202 D
2021
203 D
203 D
203 D
203 D
203 D
203 D
204 D
204 D
204 D
204 D
204 D
2040
2051
2051
2061
2061
2061
Sample Depth Below
Ground Surface
(feet)
40
60
80
too
120
completed well (107- 11 7)
completed well (35-45)
completed well (80-90)
50
70
90
110
130
completed well (119- 129) '
completed well (70-80)
40
60
80
100
120
completed well (112-122)
50
70
90
110
130
completed well (1 19- 129)
50
80
40
60
90

Cyanide
(ppb)
39
390
1.380
1.460
1.290
38
590
1,900
54
2.220
1.150
680
460
52
540
1.100
22,700
19.760
16.820
13.880
21.930
206
4,640
11.220
6.190
5,420
181
21
420
60
230
280
ppb = pans pet billion

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                             TABLE  TM-1-1 (Continued)
   Sampling  Date

       3/20/92

       3/12/92
       3/12/92
       3/17/92

       3/18/92
       3/18/92
       3/23/92

       3/19/92
       3/20/92
       3/24/92

       4/2/92

       4/2/92
                    Sample  Depth  Below
                       Ground Surface          Cyanide
Well  Number               (feet)                (ppb)

    207 S            completed well (40-50)           190

    208 I                    50                    27
    208 I                    80                    160
    2081            completed well (70-80)           330

    209 I                    55                    36
    2091                    85                    140
    2091            completed well (70-85)           160

    2101                    50                    230
    2101                    90                    860
    2101            completed well (75-90)          1,030

    2111            completed well (75-90)           8

    212 I            completed well (80-95)           11
ppb = pans per billion

-------
     APPENDIX A.2
TECHNICAL MEMORANDUM #2
 GROUND WATER SAMPLING

-------
                  TECHNICAL MEMORANDUM  NO.  2

SITE: NSA a Division of Southwire Company
LOCATION: Hawesville, Kentucky
JOB NO.  22784-005-121
CLIENT: NSA

                      GROUND WATER SAMPLING

      NSA  monitoring wells  (MW-201D,  MW-201I,  MW-201S,  MW-202D.
MW-202I,  MW-203D, MW-203I,  MW-203S,  MW-204D,  MW-207, MW-208I.
MW-209I, MW-210I, MW-211I, MW-212I, MW-213I, IW-1, IW-2, IW-3. NSA-l.
NSA-5,  102, 103,  104, 105, 106, 107, 109, 110,  111, 112,  2, 3, 4, 5, 8, 11. 12) and
United States Environmental Protection Agency (U.S. EPA)  monitoring wells (MW-1,
MW-3, MW-4, MW-5, MW-7, MW-8, MW-9, MW-10) were sampled from April 21 to
28, 1992 and on May  13, 1992, respectively, as pan of the cyanide investigation. The
U. S. EPA wells were sampled under the supervision of a  U.S. EPA representative.
Samples collected from all the wells were analyzed for total and amenable cyanide. In
addition, wells  MW-207, 3, l'l,  13, and IW-1  were sampled as part  of the PCB
investigation and analyzed for PCB concentration

      The sampling team coordinated sampling activities prior to the sampling events.
Wadsworth/ALERT Laboratories, Inc. (Wadsworth) of North Canton, Ohio was selected
as the analytical laboratory for the cyanide analyses.  Technical Testing Laboratories (TTL)
was selected as the analytical laboratory for the PCB analyses.  Sample containers and
appropriate preservatives were shipped in coolers by Wadsworth and TTL to the NSA sue.
Upon arrival the contents of the coolers were inspected to confirm that the appropriate type
and number of sample containers and preservatives had been sent.  The contents were also
inspected for damage or tampering that may have occurred during shipment.

      All reusable equipment was collected and decontaminated before traveling to the
field. All disposable equipment (bailers, bailer cord, distilled water, etc.) was compiled
prior to arriving onsite. Immediately prior to use, the pH meter was calibrated with pH 7 0
and pH 10.0 standard buffer solution.

      The sampling event was initiated by measuring the depth to water and total well
depth with an electronic water level indictor.  This information was recorded on the

-------
"Measurement of Ground Water Levels" form.  The depth information was  transferred to
"Well Data Sheet" form and the volume of standing water in the well was calculated.  In
addition, the wells were checked for aboveground condition.

       All wells were purged with stainless-steel bailers, except MW-207, 3, 11. and 12.
where  disposable polyethylene bailers were employed.  The bailers  were raised and
lowered in the wells using a new length of plastic-coated nylon cord for each well.  As the
bailer was withdrawn the cord was coiled to prevent contact with the ground and cross
contamination.  All wells were purged until at least three well volumes were removed.
Physiochemical parameters (temperature, pH,  and  specific  conductance) were then
monitored and purging  continued until all parameters were stable over three consecutive
readings. The sample was then obtained from the bailer in use.  The bottles were filled
without splashing or otherwise aerating the sample.

       The sample  containers were then  labeled with site name, well I.D., samplers
initials, time, date, analytic parameters, and preservatives were added to the samples. The
samples were then placed in coolers with blue ice and recorded on a chain-of-custody form.
The samples were shipped via overnight courier to Wadswonh and TTL under proper
chain-of-custody procedures.

       All reusable sampling equipment was thoroughly decontaminated prior to use. The
water level indicator and pH-conductiviry meter were  rinsed with distilled water between
wells.  Stainless-steel bailers were decontaminated prior to the initiation of field work by a
laboratory grade detergent wash, tap water rinse, and a triple distilled water rinse. They
were then wrapped in aluminum foil and rinsed again with distilled water immediately prior
to use  in the field.   Bailers that were reused in the field were washed with a laboratory
grade detergent solution and triple rinsed with distilled water. Disposable bailers were
sealed in plastic from the manufacturer. They were triple rinsed with distilled water prior to
use.

       The monitoring wells surrounding the dump pad were sampled first and the wells
associated with the disposal ponds  were sampled second.  The U.S.  EPA wells were
sampled 2 weeks later because an U.S. EPA representative had to be present to gain access
to the wells. In total, 46 wells at NSA were sampled.

-------
       Five wells were not sampled due to conditions of the well. N"SA-3 and NSA-4
were dry.  The protective steel casing for 108 srill exists but the well appeared to be
plugged. An obstruction that could not be passed by a bailer was present at 36:3  feet
below the top of casing of MW-2. Some unknown piece of heavy equipment has damaged
MW-6 and  knocked flat two of the three protective steel posts surrounding the well.  The
concrete well pad appeared to have moved slightly. A bailer would not pass below 5.3 feet
below the top of casing.

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     APPENDIX A.3
TECHNICAL MEMORANDUM #7
   AQUIFER PUMP TEST

-------
                   TECHNICAL  MEMORANDUM  NO.  7
SITE: NSA a Division of Southwire Company
LOCATION: Hawesville. Kentucky
JOB  NO.:  22784-005-121
CLIENT: NSA
                        AQUIFER  PUMPING TEST

       Site-specific estimates of aquifer characteristics were obtained through performance
of an aquifer pumping test in June  1992.  The test was conducted by observing and
recording the aquifer response to changes in pumping of NSA production well 1. NSA
uses three onsite pumping wells to supply water for various uses onsite, one of which was
shut down for approximately 2.5 days in June.  This provided the opportunity to observe
the aquifer's response to first the stopping of pumping, then the renewed pumping.  Details
of the activities involved in the collection and evaluation of the test data and the results of
the effort are presented below.

       Preparations for the aquifer test  began  on June 5, 1992 with the inspection and
installation of the data collection and logging equipment. This equipment consisted of two
HERMIT Model SE1000C data loggers and three model PTX-161/D pressure transducers.
Together, this equipment monitored the water level response to instantaneous changes in
head. Prior  to installation, the HERMITs and transducers were examined for shipping
damage and a check test was set up and run to insure the electronic loggers were
functioning properly.

       Pressure transducers were placed in piezometers P-l and P-2, and well 8 with the
transducer lines secured to the wellhead with duct tape to ensure stable positioning in the
well. The monitored well/piezometers were chosen based on their location relatively close
to the pumping well (see attached site layout diagram).

       The transducer in well 8 was connected to one HERMIT data logger,  and the
transducers in P-l  and P-2 were connected to the second HERMIT. The HERMITs were
pre-set to record displacement in feet taking readings at a logarithmic rate for the first 15
minutes of the tests. The internal clocks  of the HERMITS were synchronized so that they
would run identical, simultaneous tests.
                                       1

-------
       The first test, run to record background changes in water levels during normal
pumping operations at NSA production well I, was started on the evening of June 5.  1992
and stopped manually on the morning of June 8, 1992. The HERMJTs were then zeroed
and reset, and the second test started when the production  well was shut down June 8.
This test was run for approximately 2.5 days in order to record the aquifer's recovery from
the pumping stress.

       On June 10, 1992, the second test was stopped and the HERMJTs were zeroed and
reset to record a third test.  The third and final test was started at the same moment the
production well was re-activated, and recorded the aquifer response to resumed pumping
stress.  This test was stopped on June 15, 1992 after approximately 5 days.

       Data from the loggers were downloaded to spreadsheet and graphing computer
programs  for evaluation of the aquifer characteristics of transmissivity and storativity as
discussed below.

       As mentioned above, changes in piezometric levels were measured and recorded at
one well  and two  piezometers during three  time  periods: background, recovery test
(production  well I shut down),  and  drawdown  test (well 1 pumping  resumed).  The
background data were used to evaluate what ambient ground water fluctuations would have
persisted through the test. The test data were used in the calculation of aquifer parameters.

       The background data indicate sharp fluctuations of ground water levels of a much
as 0.1  to 0.2 feet at the observation points (well 8, P-l, and P-2;  see attached graphs).
These fluctuations are attributable to the pumping pattern of the test well (production well
1). The well is used in part for non-contact cooling of the  pigging wheel. The cooling
system is often bypassed (potentially 2 to 3 times a day), creating a change in pressure on
the system.  As a result, the wells production rate changes, and ground water levels
fluctuate accordingly.  Because of the strength and irregularity of the fluctuations produced
by this bypassing, no other trends in the background data were identified.  The fluctuations
ceased when production was stopped and did not interfere with the recovery test

-------
       The recovery data were evaluated using the Theis recovery method (see attached
graphs).  The early portion of the test data appear to have been skewed by the effects of
elastic storage and potentially by increased pumping from production wells 2 and 3.  The
later data for P-l, which were found to conform most readily to the requirements of the
evaluation,  yielded a  hydraulic conductivity estimate of approximately 500 ft/day
(approximately 0.2 cm/s).

       The drawdown test data  were evaluated using the Theis curve-fitting method and
the Jacob's straight-line methods (time-drawdown and distance-drawdown methods; see
attached graphs). The  evaluations yielded values of hydraulic conductivity in the range of
0.14 to 0.85 cm/s as indicated on Table B-l. By discarding the values derived from well
8, which, being the furthest data point from the pumped well is most likely to be influenced
by background noise, the agreement becomes even better (0.15 to 0.4 cm/s).  The average
hydraulic conductivity  value produced by these evaluations is 0.25 cm/s (approximately
700 ft/day).

       Storage coefficient is a unitless measure of the ability of the aquifer, to release water
from storage. The higher the storage coefficient, the more readily the aquifer will  yield
water to a well.  The  estimated values of storage coefficient range from 0.01 to 0.3
(excluding values derived from well 8 data), which are similar to the range of values
observed in  other unconfmed aquifers.  The storage coefficient values are more variable
than the values of hydraulic conductivity obtained through these evaluations. This may be
partially influenced by changes in the pumping of production wells 2 and 3 during the  early
pan of the tests. In general, a representative storage coefficient for the aquifer should be on
the order of the average value listed  on Table B-1 (0.11).

       Using the average hydraulic conductivity value described above and more recent
ground water flow gradient information, a more representative ground water flow velocity
can be calculated. An estimate of ground water flow rate for the dominant flow condition
can be derived by multiplying the measured hydraulic  gradient (0.001) by the estimated
hydraulic conductivity  (700 feet/day as discu^ ,ed above) and dividing the  product by an
assumed porosity for  sand  and gravel aquifer (30 percent).   The resultant value is
approximately 2 feet per day.

-------
                                   TABLE TM-7-1

                        AQUIFER  PUMPING TEST  RESULTS
                             CYANIDE INVESTIGATION

                    NSA  A DIVISION  OF  SOUTHWIRE COMPANY
                             HAWESVILLE, KENTUCKY

Evaluation
Method
Theis


Jacob
(time-drawdown)



Datapoint
P-l
P-2
Weil 8
P-l
P-2
WeU8

Storage
Coefficient
0.13
0.06
NA*
0.01
0.04
0.002*
Hydraulic
Conductivity
(ft/d:cm/s)
400/0.15
700 / 0.25
1,400/0.5'
1.100/0.4
1,100/0.4
2,400 / 0.85*
Jacob
 (distance drawdown)
                      0.3
                  600 / 0.2
Recovery
P-l
NA
500 / 0.2
               Average
                     0.11'
                 700/0.25'
Well 8 results discarded in averaging process because of the greater potential for
  background interference further from the pumped well.

-------
                                                                NSA 6 (nod)
                    Laboratory
                   Second Street
                                                        0>


                                                        0)
                                                       03
P-2O
                                                                P-1O
                                                                          Pump House
                                                                              Production Well «1
                                                                                                                             True*
                                                                                                                            North  Plant
                                                                                                                                   North
                                                LEGEND:

                                                   O   Observation Well
                                                        Location

                                                   ,,   Tusl Production Water
                                                   u   Well Location
                        Office 44 2
                                         Well 8 O
MAC SUUIU.l.
                                                                                                            0              50             100


                                                                                                              APPROXIMATE SCALE IN FEET
                                                                                                         No A A Division ul Soulhwiitt Coiry>dny
                                                                                                       Hawasvillo. Hancock County, KunluoKy
                                                                                                                I IGUIU  IM7  1
                                                                                                       SIIL I AYOUT l-Olt AQUII 1 I) I LSI
                                                                                                   JOI1NO  X'/B4 (K)l> l?l
                                                                                                                                       MIM.I,

-------
     p-l
c
$
o
•3
                                       5=0 '3 ft

                                    '.•3 0»!0'-4 days
      P-2
T=(Q(ff3/d)* (w/u3.r))/4*-!*s(ft
 =(59,679*1 )/(4*3.l4*0.l3)
 = 36.550 ff2/d
K=T(fr2/d)/b(m
 = 365.5 ft/d (0.13 cm/sec)
S»(4*T*t*ua)/r'2
 =(4*36,550*(3.0*IO"-4)»!
 =0.12
!9'2
 5
 n
 Q
                                                      ',00
                                     time (min)
                                                     T=(Q(ff3/d)* (w/ua.D)/4»-r*v"
                                                      =(59,679*1 )/(4«3.!4»0 0"2:
                                         s-00?2ft     =65,993 ff2/d
                                         1 9»'0'-3 days K»T(ff2/d)/b(ft)
                                                      =659.9 rt/d (023 cm/sec)
                                                     S-(4*T*t*ua)/r2
                                                      =(4*65,993*(I.8*tO-3)»! )• ?? :
                                                      =0.06

-------
   MW-3
o
-3  I
  01








• •*
.

•


1








• *t


•











•














k














•














1





























1














«**"nrf
•




I








•













»












Tl














*












7













•






















































I*













v













•
<













«l







•o
time (min)






r













• •• •*













•v*v














^













ft.













h













^







100






V
















: 000
                                              S-0035 ft
T=(Q(ft"3/d)* (w/ua.D)/4»n»s(ft)
 -(59,679* I )/(4*3.1 4*0.035)
 -135,757 ft'2/d
K-T(ff2/d)/D(ft)
 = 1,3576 ft/d (0.48 cm/sec)

-------
               PW-2  RECOVERY (1  YEAR  PUMPING)
 «

 e
 o»
_e

"5.
o
o
u

ac
  =352.000 gpd/ft

K.T((t*2/d)/b(lt)

  =470  (Vd (0.17 cnv$«c)
          10
                                t/t '

-------
                         P-1   Drawdown  vs.  Time
e
3
o
T»
9
a
                                I         I
                       T.<284'Q(gom))/At(ft)
                         . 818.400 gpd/tt
                       K.T(ft»2/d)/b(M)
                         • 1,094  ft/d (0.39  crrvsac)
                       S-(T(gpd/ft)'  t.(mln))/(4790*r*2(ft*2))
                         -0.01
                              t.-0.022  (min)
                                        10
                                                 100
1000     10000
                                   Time  (min)
                         P-2  Drawdown  vs.  Time
          0.8
o
•o

0
O
          0.6-
          0.4-
          0.2-
                        T.(264'Q(gpm))/As(lt)
                          .818.400 gpd/tt
                        K.T((t»2/d)/b(lt)
                          • 1.094  ft/d (0.39 crrvsvc)
                        S«(T(gpd/lt)'t.(min))/(4790T*2(ff 2))
                         •0.04
                                                 100
                                                          1000     10000
                                    TIm»  (min)

-------
                         MW  8  Drawdown  vs.  Time
e
e
•o
                        T.(264'Q(gpm))/as(ft)
                          •1.818.667 gpd/tl
                        K-T(M«2/d)/b(lt)
                          •2.431 fvd (0.86 cm/sac)
                        S«(T(gpd/ft)M.(mln))/(4790  * r*2(ft*2))
                          =0.002
                           t.-0.13 (min)
          0.0
                       .1
10
100
1000     10000
                                    Tim*  (min)

-------
                         Distance  vs.   Drawdown
e
>
«
M

C
E
o
c


o
•o

<9
         -0.4
•0.5 -
                              AS-0.171



                              t.»1000 (min)
                                              T.(2S4'O(gpm))/A»(lt)

                                                .481,412 gpd/nl

                                              K«T(ff2/d)/b(ft)|

                                                .€44  tt/d (0.23 cm/*«c)

                                              S-(T(gpd/lt)'t.(min))/(4790V'2(lf2))

                                                .0.3
         -0.6
                                        100
                                                          1000
                                  Distance  (ft)

-------
                        APPENDIX A.4
                  TECHNICAL MEMORANDUM f8
GROUND WATER MODELING & TRBATABILITY STUDY FOR GROUND WATER

-------
                   TECHNICAL MEMORANDUM  NO.8
SITE:  NSA, a Division of Southwire Company
LOCATION:  Hawesville, Kentucky
JOB NUMBER:  22784-005-121
CLIENT:  NSA
                  PRELIMINARY  DESIGN EVALUATION
                GROUND  WATER EXTRACTION SYSTEM
      The proposed ground  water extraction  system design was evaluated on a
preliminary basis using ground water flow modeling to project the zones of influence likely
to be achieved by the system. The proposed system consists of 12 extraction wells, nine in
the  northern plume and three in  the southern. Each well was designed for a yield of
approximately 80 gallons per minute (gpm) for a total production capacity of approximately
1,000 gpm. This capacity would be managed by selective use of wells and/or valving of
production to fine tune the capture of cyanide-contaminated ground water while staying
below the treatment plant capacity of 500 gpm.

      The ground water flow  modeling effort utilized MODFLOW, a modular, three-
dimensional, finite difference ground water flow model developed "by the U.S. Geological
Survey (McDonald and Harbaugh, 1988). The model was constructed using a 4,000 by
6,000-foot grid of  100-foot by  100-foot block-centered cells, with the Ohio River
constituting the easternmost column of cells. The eastern and western columns were
established as general head boundaries with head values of 367 and 365 feet msl
respectively to simulate a gradient of 0.005 across the site. Simplifying assumptions of the
model include that the aquifer is homogeneous and isotropic, and that the base of the
aquifer is located uniformly at elevation 300 feet msl (likely base of the pumped zone).

      A series of pumping scenarios were tested, one of which is illustrated on the
attached figure. Under this scenario, seven wells located in the center to the two plumes
are pumped near their capacity.  The impact of the pumping on piezometric conditions can
be seen as a deflection of piezometric contours around the wells. The projected zones of
capture  for the two areas of pumping suggest that operation of this scenario would
effectively capture ground water having reported concentrations in excess of 0.1 mg/L of
both total and amenable cyanide.

-------
       6000.00-1     i    $
                     *> '   <•»
                                                                         GENERAL
                                                          HEAD BOUNDARY =. 365.0
                                                                       (FEET, MSL)
                      GENERAL    I      '
                      HEAD BOUNDARY = 367.0
                      (FEET, MSL)
                       ^      W     *H      t^      rt
LEGEND:
                       600.00    1200.00    1800.00   2400.00    3000.00    3600.00    420000

                                    GROUND WATER MODEL MODPLOW
36Sa	 Simulated Ground Water Level             Extraction Well Capture
         Contour (Fort, msi)           	Zon« Limit
         Amenable Cyanide Above 0.1
         mg/IUrnl
®    Exiraaion Well Location
	Total Cyanida Abov«0.1mg/1
         Umit

ASSUMPTIONS:
•Gerwral head bounoaries set al 367 teet and 365 feel.
• Weite 2.3.5.6,8.10, and 11 pumpmg at 80 gpm.
• Aouitor hydraulic conductivity 700 it Jday.
• Aquiftr thickntss •
      Ground Water Flow
      Direction
NSA A Division ol Sov-S"*"* Co>-o*-»
     ille, Hancock Coor:v Ke"!.c«y
                           GROUND WATER FLOW SIMLLAT CN ?O
                                 EXTRACTION WELL
                                                               JOB NO. 22784-005-121

-------
                      APPENDIX A.4 CONTINUED

              CONCLUSIONS OF THE  TREATABILITY STUDY
Information within  this  appendix is taken from the "Ground Water
Treatability Study  Report  (October 28,1991)"  prepared by Dames &
Moore.

Due to  the marginal removal efficiencies  for total cyanide,  and
very  low  removal   efficiencies   for   free   cyanide,  alkaline
chlorination,  for  the evaluated,  was  judged  not to  be a viable
treatment  technology for removing cyanide from  ground water at
NSA's Hawesville facility.

The process  of chemical coagulation/precipitation  using ferrous
sulfate with lime as the coagulant provided removal efficiencies
for cyanide in  the range  of  94-99  percent  for  the  conditions
evaluated.  These removal efficiencies indicated that the chemical
coagulation/precipitation  process  is  a  viable technology  for
treating  cyanide  contaminated. ground water  at  NSA's  Hawesville
facility.   Applying these  removal efficiencies  to the expected
total cyanide influent concentration of 2.5 ml/g, it appears that
the process can meet expected performance requirements  for effluent
standards  of 1.20  mg/1 for  total  cyanide,  0.86  mg/1 amenable
cyanide, and 0.022 mg/1 free cyanide.

The treatability study procedures for chemical coagulation/precip-
itation examined different  Fe/CN dose rations and operating pH's
while maintaining the lime dosage at 500 mg/1.  Process performance
was acceptable  over the  entire  range  of  Fe/CN  ratios (15:1 to
35:1)-.   For the dilute samples  evaluated,  removal efficiencies
appeared  slightly  better at  higher  pH.    As evaluated  in  this
treatability study,   the range of operating conditions that proved
successful are summarized below:

   •  lime dosage*  of 500 mg/1

   •  Fe/CN dose ratio of 15:1 to 35:1

   •  reaction pH of  6 to 8

*  It  should be noted that the chemical coagulation/precipitation
   process utilized lime during the treatability study.  However,
   the pump and treat  apparatus  information submitted by Dair.es i
   Moore on behalf of NSA does not utilize lime.   This apparatus by
   Unocal  utilizes   the  following  chemicals:   Nalclear  ""63
   Flocculant (acrylamide/acrylate polymer in hydrocarbon solvent) ,
   ferrous  chloride or  ferrous   sulfate,  and  sodium  hydroxide.
   Information submitted by the manufacturer  indicates that  -he
   omission  of  lime  in the  process will  not  impact apparatus
   efficiency in the removal of contaminants from extracted gr-^r.-i
   waters.

-------
It is expected that acceptable cyanide removal efficiencies can be
realized at  Fe/CN dose ratios of less than 15:1.   Based on this
expectation and an evaluation of the process chemistry, it is also
likely  that  the required  lime dosage  rate may  be significantly
reduced from the 500 mg/1 fixed during the treatability study.

The sizing of the rapid mixer,  flocculator, and clarifier is based
predominantly on hydraulic considerations,  and as such, is defined
by the expected flow rate of 500 gpm.  The process feed systems can
be  designed based on  available data  without  significant  cost
impacts caused by potentially varied ferrous sulfate or lime feed
rates.   Based  on a  Fe/CN  dose ratio  of 15:1 and  optimized lime
addition, a  preliminary estimate of dewatered  sludge production
would  be  on the  order of 1.5  to  2  tons  per  day  at  full  scale
operation.

-------
         APPENDIX A.5
ANALYTICAL DATA FROM LSI REPORT
          11/89-1/90

-------
                 Analytical Data Summaries and Sample Location Maps
               for Listing Site Inspection at National Southwire Aluminum

                     Samples Collected by NUS Corporation. FIT 4
                           November 1989 • January 1990
All samples analyzed for complete target compound list. In addition,
all groundwater samples (Table 14) analyzed (SAS) for Free Cyanida.

-------
                                                      TABLE 1
                                     SUMMARY OF ORGANIC ANALYTICAL RESULTS
                                               SURFACE SOIL SAMPLES
                                          NATIONAL SOUTHWIRE ALUMINUM
                                     HAWESVILLE. HANCOCK COUNTY. KENTUCKY

PARAMETERS (uoAg)
•UR6EA1U COMPOUNDS
CARtONDttULHDE
1.1.1-TRlCHlOROETMANE
rETRACHLOROETHENE
EXTRACT ABLE COMPOUNDS
FLUORENE
PHENANTHRENE
ANTHRACENE
FLUORANTHENE
PVRENE
BEN2O
-------
                                                                 TABLE 1
                                                SUMMARY OF ORGANIC ANALYTICAL RESULTS
                                                          SURFACE SOIL SAMPLES
                                                     NATIONAL SOUTHWIRE ALUMINUM
                                                HAWESVILLE. HANCOCK COUNTY, KENTUCKY
,-,.y.- r
PARAMETER* (u0ftfl)
NOENO(1.2.9-CO)PYftENE
DMEN2O(A.H)AMTHRACENE
BENZO(GHUMRYLENE
4EXADECANOIC ACH>0)
BENZOCHRYSENEO)
JNINOC NTIf IE D COMPOUNDS
4EXANEDIOIC ACU>0)
BEN2OPYRENE«)
HSTIOOf WCt COMPOUNDS
M* DOT (P.P1 DOT)
!>CI-124t(ANOaOR 124C)
•Mkgf«wnd
NW-SS41
4JOJ
840UI
4001
800JN
700JN
4000J/2



96
1MO
North Pood AIM
NWSS42
-
•
•


-





NW-SS-4)
-
-



3000J/S
3001N



•
South
Pond Area
NWSS44
-
-
-


-



•
-
Ai ca B«tvw««n
WatUPondt
and Ohio Wvcf
N«VSS4>S
-
-
-


4000 J/7
600JN



-
NWSS4M
-
-
-


-



-

Dump Pad
Atea
NW-SS07
670)
-
590)

400JN
5000 J/3

1000JN


1100
Oium
Slofag*
Aica
NtM-SS-OI

-



600J/I





South End
of Facility
NWSS-0*
-
-
•


-

i



I
IN)
                  Material analyzed for but not detected above minimum quantitation limit (MQL). (MQls for non-detected parameters can be
                  found in Reference 7A).
           J      Estimated value.
           N     Presumptive evidence of presence of material
           U     Material was analyted for but not detected. The number given is the MQL.
           (')     Tentatively identified compound This compound is not on Target Compound List and is reported only as detected in individual
                  samples. MQL not determined

-------
                                               TABLE 2
                               SUMMARY OF ORGANIC ANALYTICAL RESULTS
                                        SURFACE SOIL SAMPLES
                                   NATIONAL SOUTHWIRE ALUMINUM
                               HAWESVILLE. HANCOCK COUNTY. KENTUCKY
PARAMETERS (119*0)
NMGf AM.E COMPOUNDS
CAMONDiSULFIDC
1.1.1-TRICHLOROETHANE
TETRACHtOROETHENE
EXTRACTAM.I COMPOUNDS
FLUORENE
WENANTHRENE
ANTHRACENE
FLUORANTHENE
PYRENE
»ENZCXA)ANTHRACENE
CHRYSENE
lENKXt AMD/OR KPLUOHANTHENE
Dump Pad Ar*a
NW-SS-11


•
•

-
•
•
430
410
250)
340J
480)
NWSSU

-
-
•

•
•
-
1200
1200
960
1100
17001
D< urn Storage Ace*
NW-SS-11

-

-

-
•

•
-
-
-
•
NW-SS-14



-

-


790
770
S30J
740
11001
North of
Dump Pad
NW-SS-1S

201
22)
-

160)
3200)
110)
1700
1200
-
270)
100)
AIM IWttl
•etvwecn
North and South
Pond
NW-SS-1*






240)

910
140)

730
300)
      Material analyzed for but not detected above minimum quantitation limit (MQL). (MQLs for non-detected
      parameters can be found in Reference 7A.)
j     Estimated value
N     Presumptive evidence of presence of material
(')    Tentatively identified compound. This compound is not on Target Compound List and is reported only as detected
      in individual samples; MQL not determined

-------
                                               TABLE 2
                               SUMMARY OF ORGANIC ANALYTICAL RESULTS
                                        SURFACE SOIL SAMPLES
                                   NATIONAL SOUTHWIRE ALUMINUM
                               HAWESVILLE, HANCOCK COUNTY, KENTUCKY
PAHAMfTEM(u0*c)
BEN2O-A PYftENC
INDENO ( \ .2. J-CD) PVRENE
[MIENZO
-------
                                                                 TABLE 3
i
en
                                                SUMMARY OF INORGANIC ANALYTICAL RESULTS
                                                          SURFACE SOIL SAMPLES
                                                     NATIONAL SOUTHWIRE ALUMINUM
                                                 HAWESVILLE. HANCOCK COUNTY, KENTUCKY

PARAMETERS (m?>g)
ALUMINUM
ANTIMONY
ARSENIC
IARIUM
BERVtllUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
RON
EAD
MAGNESIUM
MANGANESE
MERCURY
4ICKEL
POTASSIUM
KUNIUM
•ack pound
NtM-SS-OI
7100
9UJ
201
68)
IU
OSUi
3900U
20U
73
20U
22.000)
SOU)
1400
3SOJ
0 UU)
14
970
0 71)
North Pond Aiea
NWSS02
8000

42J
591


-

82

21.000)

1600
410)

14
860

NWSS03
16.000

IOJ
721

-


II

32.000)
i
2900
S)0)

20
1900

South
Pond
Aiea
NWS* 04
8100

J )l
99J

•


84

16.000)
-
1200
6101

14
710

•
Aiea Between
Watt* Pond< and
Ohio River
NWSS-OS
11.000
381
84J
841




79
18.000)


1SOO
7 JO)

14
1100

NWSS06
12.000

861
911




99

19.0001

ISOO
770)

IS
MOO

tfump Pad
Are*
f)wSS07
S3.000


491
) )
4 41
47.000

52

13.0001

3000
2601

i;
/bO

Oium
Storage
Aie*
NW SS 08
3500

6 it





85

1 i.OOOl

iaoo
)OUI

IS
400

South End
of Facility
NWSS-09
8400

10
56


1500
II i
10
IS
19.000
12
1700
410

17
810

                    Mdlenal analysed for but not delected above minimum quantiiaiion limit (MQl) (MQls lor non delected parameter can
                    be found in Reference 7A )
U
N/A
                    Material was analy/ed lor but not delected Ihe number given is the MQL
                    Material not analyzed for

-------
                                                                 TABLE J
i
o»
                                                SUMMARY OF INORGANIC ANALYTICAL RESULTS
                                                          SURFACE SOIL SAMPLES
                                                     NATIONAL SOUTHWIRE ALUMINUM
                                                 HAWESVILLE. HANCOCK COUNTY, KENTUCKY
PAMAMETIMSiMg/kg)
SILVER
SODIUM
I/ANADIUM
{INC
IUORIDE
STRONTIUM
TITANIUM
WRIUM
CYANIOC TOTAL
•ackgtound
NW-SS-CI
1U
I40U
20
SSI
82
N/A
N/A
N/A
12U
North Pond Area
NWSS-02
-
•
21
21
87
N/A
N/A
N/A
•
NWSSO]


36
62
83
N/A
N/A
N/A
-
South
fond
Af«a
NWSS04
•

17
411
29
N/A
N/A
N/A
-
Ate* tetween
Watte Ponds and
OhioMivei
NWSSOS


24
49)
110
N/A
N/A
N/A

NWSSOt
-
-
27
S2)
91
N/A
N/A
N/A

Dump Pad
Area
NWSS07
-
-
23
320J
2900
N/A
N/A
N/A

0«um
Slot age
Aiea
NW-SJ08


10
4IJ
93
N/A
N/A
N/A

South fnd
of Facility
NIMSSM


19
47

86
140
9 i

                    Material analyzed for but not detected above minimum quantitation limit (MQL)  (MQLs for non-detecled parameters can
                    be found in Reference 7A)
             J      Estimated value.                             <
             U     Material was analyzed for but not detected The number given is the MQL.
             N/A    Material not analyzed for.

-------
                                                    TABLE 4
                                   SUMMARY OF INORGANIC ANALYTICAL RESULTS
                                             SURFACE SOIL SAMPLES
                                        NATIONAL SOUTHWIRE ALUMINUM
                                    HAWESVILLE. HANCOCK COUNTY. KENTUCKY

PAftAMfTfMSImeftg)
M.UMINUM
ANTIMONV
MSI NIC
lAHIUM
iERYUIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
RON
.CAD
MAGNESIUM
MANGANESE
MERCURY
VICKIl
WTASSIUM
11 II Nil JM
Dump Pad AIM
MVtf-SS-11
M.ooo
•
84)
4JJ
•
-
21.000

91

18.000)

2100
}60I

IB
1000

NWSS -II
48.000

6)1
461
61
1 21
67.000
-
6

10.0001

1)00
1801

19
1000

Oium Storage A»e*
NWSS 13
68.000


24)
38
28)
100.000

52

66000J

5400
1601

28
bOO

NWSS 14
17.000

6 Si



2/0.000

64

110 000 J
2SOI
8000
7101

14
no

Noilh ol
Dump Pad
NWSS IS
84.000


ISO)
78
3 71
J 3.000
26
54
120
13.000)

2600
240)
0 10)
1)0
1 100

AieaCatt
Between North
iftd South Pond
NWSS 16
130.000

11 IN
811
2 UN
1 41
49.000
i
II

10.000)

1600
3101

260
1800

J
N
N/A
M«ieiMl analysed lot but nut detected above minimum quaniilalion limit (MQL)  (MQLs lor nun-detected parameters
found m Reference 7A )
I tlimaied value
Piesumplive evidence of pretence ol niaienul
Material not analyzed lor
                                                                                                        con be

-------
                                                                TABLE 4
i
oo
i
                                               SUMMARY OF INORGANIC ANALYTICAL RESULTS
                                                          SURFACE SOIL SAMPLES
                                                     NATIONAL SOUTMWIHE ALUMINUM
                                                 HAWESVILLE. HANCOCK COUNTY. KENTUCKY
PANAMfHNSdwg/kg)
ill VI «
iOOIUM
k/ANADIUM
fINC
1UORIOE
UftONTIUM
riTANIUM
ITTTRIUM
CYANIDE TOTAL
Dump Pad Area
NW-SSIt
-
-
20
5?J
690
N/A
N/A
N/A
-
NWSS 12


2J
69)
4000
N/A
N/A
N/A

Oium Storage Area
NWSS 1)
19

16
not
910
N/A
N/A
N/A

NWSS 14


ii
6bOI
860
N/A
N/A
N/A

North of
Dump Pad
NWSS IS

58.000
300)
1 1
64.000
N/A
N/A
N/A

Area Eatl
Between North
and South Pond
NWSS 16

11.000
ISO
761
SO.OOO
N/A
N/A
N/A i

                   Material analyted for but not detected above minimum quantitalion limit (MQL) (MQLi lor non delected pjrameiers can be
                   found in Reference 7A )
             J      Estimated value.                              >
             N     Presumptive evidence of presence of material
             N/A   Material not analyzed for

-------
                                                        TABLE 9
                                       SUMMARY Of ORGANIC ANALYTICAL RESULTS
                                                  SEDIMENT SAMPLES
                                            NATIONAL SOUTHWIRE ALUMINUM
                                       HAWESVILLE. HANCOCK COUNTY. KENTUCKY

PARAMETENS(u«/kg)
•URGf AM.I COMPOUNDS
TOTAL XVIENES
DIHVDROINDENE«>
(METHVlHHVDBINZtNfO
EXTRACT ABlf COMPOUNDS
DlBENZOfURAN
PHENANTHRENE
FlUORANIHENE
PyftCNE
BE N2O
-------
                                                                 TABLE 9
                                                SUMMARY OF ORGANIC ANALYTICAL RESULTS
                                                            SEDIMENT SAMPLES
                                                     NATIONAL SOUTHvVIRE ALUMINUM
                                                 HAWESVILLE. HANCOCK COUNTY. KENTUCKY
PARAMETERS (ug/kg)
lENKXGHUPtNVLfNE
BENZYL BUTYL PHTHALAU
UNIDENTIFIED COMPOUNDS
ANTHftACENEDtONEO)
NEXAOECANOIC ACID«>
PENTAMETHYIBEN7ENEO
DIM YORODIME TH VLINDE NE < < >
ME IN YLPROPYliE N7E NE < ' )
ETHYLDIMETHYLIENZENEO)
METHYL(METHYLETHVL)BEN2ENEO>
lETRAMEIHYlBEN/ENCO)
DKTH VLME THYLM N2ENE< ' )
•ackground
MWSO41
UOOUJ
uoou
IO.OOOi/5


2000/N
1000JN
JoeojN
10.000JN
6000JN
0000 JN
2000JN
Drainage
Dilch
(South End)
NW-SO-02
-

-









OiainagvOiUh
(Wctl of facilily)
NWSDOi
190)
S20J
4000J/1

6001N







NW-SO-04


1 0.000 J/4
700)N








Drainage
Ditch (East
ol Watte
Pondi)
NWSDOS












Oiamage
Dilih(8eloce
I nlciing Ohio
8ivei)
NM/-SD04


4000 Hi

400 IN







South Pond
NIMSO07


IOOOJ/1









NMr-SDM




700/N

I





U1
                Material analyzed for but not detected above minimum quantitalion limit (MQL) (MQLs for non-delected parameters can be found
                in Reference 7A.)
          J      Estimated value
          N     Presumptive evidence of presence of material
          U     Material was analyzed for but not delected The number given is the MQL
          (')     Tentatively identified compound This compound is not on Target Compound List and is reported only as delected in individual
                samples. MQL not determined

-------
                                                    TABLE 10
                                   SUMMARY OF INORGANIC ANALYTICAL RESULTS
                                               SEDIMENT SAMPLES
                                        NATIONAL SOUTHWIRE ALUMINUM
                                    HAWESVILLE. HANCOCK COUNTY. KENTUCKY
PARAMETE MS (mgkg)
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
CO! AIT
RON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SELENIUM
•achgfamtd
NWSO-01
10.000
7U)
12)
72)
1U
06SUJ
2700U
02
99
22.000J
691
2000
1401
16
1200
1U)
DtaiMg*
Ditch
(South End)
NW SO 02
9700

I2J
681

•
•
-
10
22.0001

2SOO
2901
IB
1100

Oiainagc Ditch
(Wen ot f acMly)
NWSDO)
270.000
4 71
)51N
SSJ
11 IU
))
31.000

16
61001
971
1400
671 '
560
110

NWSD-04
2)0.000

160JN
871
4S1N
I9J
22.000

4)
15.0001
I70J
1800
741
1400
1600

Drainage
Ditch
(fill Ol
Wane Pondil
NW-SO-OS
67.000

Til
901
16

80.000

IB
IJ.OOUI

2700
1201
420
noo

Drainage Ditch
(flefoie f nleiing
OhioRiwci)
NW-SO-06
17.000
-
79)
ISOI
29

9)00

22
JJOOO)

5300
17001
4S
)500

South Pond
NMIS007
170.000

160 IN
)/i
49 IN
) )!
190.000
24
10
55001
1201
)400

1000
550
4 MN
NW-SD08
170.000
751
I201N
)8l
S7IN
181
170.000
))
)7
8)001
1601
)000

1)00
740

      Material analyied for bui not detected above minimum quantitation limit (MQL) (MQLs (or non detected parameters can be
      found in Reference 7A )
J      f iiim*t*d value
N     Presumptive evidence ol pretence of material
U     Material wat analyied for but not detected  The number given is the MQL

-------
                                                   TABLE 10
                                   SUMMARY OF INORGANIC ANALYTICAL RESULTS
                                              SEDIMENT SAMPLES
                                        NATIONAL SOUTHWIRE ALUMINUM
                                    HAWESVILLE. HANCOCK COUNTV. KENTUCKY
•v



PARAMETERS (Mft/fcg)
ML VCR
SODIUM
VANADIUM
riNC
FLUORIDE
CYANIDE TOTAL



Background
NW-SO4I
1.3U
120U
25
240)
54
77

Drainage
Ditch
(South End)
MWSO-02

-
23
84)
76
"U


Drainage Ditch
(Wetl ol facility)
NWSD01

20.000
1200
520)
61.000
61
NWSO-M

10.000
2900
270
40.000
27
Drainage
Ditch
(fait of
Watte Pondt)
NWSOOS

6700
6)0

62.000
1 7

Drainage Ditch
(lefore Entering
Ohio River)
MW-SD4*
-

44

20
" U
'


South Pond
NWSD07
2
21.000
ISOO
11 OJ
16.000
29
NW-SD4M

J 1.000
2000
110
15.000
48
      Material analyzed for but not detected above minimum quantitation limit (MQL) (MQLs for non-detected parameters can be
      found in Reference 7A.)
j     Estimated value
N     Presumptive evidence of presence of material.
U     Material was analyzed for but not detected  The number given is the MQL

-------
                                                                 TABLE 14
                                                SUMMARY OF INORGANIC ANALYTICAL RESULTS
                                                         GROUNDWATER SAMPLES
                                                     NATIONAL SOUTHWIRE ALUMINUM
                                                 HAWESVILLE. HANCOCK COUNTY. KENTUCKY
PARAMETERS (091)
ALUMINUM
ARSENIC
IAMUM
CAICIUM
CHROMIUM
COBAll
COPPED
RON
EAO
MAGNESIUM
MANGANESE
MERCURY
4KKEL
•OTASSIUM
SODIUM
Background
MWMW4I
490
1U
16
92.000
SU
4U
SU
890
S
11.000
07
02UR
7U
ISOO
11.000
Area
Wcttof
Pioptity
NWMW10
21.000
14
720
59.000
19
110
48
19.000
110
20.000
8600
-
120
5600
7900
North Pond Aiea
NWM1M02
9500
29
560
59.000

260
1)
48.000
4]
15.000
8400
-
ISO
6400
5 70.000
NW-MW-01
5200

290
59.000

13
11
12.000
19
11.000
4400

45
4300
26.000
*
South
Pood
Atea
NWMW04
1600

98
150.000

21
II
5400
12
51.000
1100

28
1000
440.000
A«ea Between
Watle Pond*
and Ohio Mivei
NWMWOS
9200

290
190.000

130
SI
20.000
73
69.000
6800

170
1200
8700
NWMW06
730

bb
100.000

25

2900

21.000
240
-

3300
85.000
Dump Pad
Aiej
NWMW07
4400

IOU
1 70 000

HI
17
1 1 .000
26
63.000
1300

42
3700
60.000
Oium
Stoiage
Aiea
NWMWOS
16.000
II
IUO
2>>O.OQO
21
82
63
16000
41
1 30.000
2400

95
/soo
IS 000
South Ind
of facility
NW-MW-M
9100

130
1 70.000
12
35
30
19.000
17
5700
1800

53
3100
8000
ro
ro
i
                  Material analysed for but not delected above minimum quantitation limii (MQL)  (MQLs for non deiecied parameters can be
                  found in Reference 7A ) •
            J      Estimated value
            U     Material was analyzed (or but not delected  The number given is the MQL
            R     Quality Control indicates that data unusable Compound may or may'not be present

-------
                                                               TABLE 14
                                              SUMMARY OF INORGANIC ANALYTICAL RESULTS
                                                        GROUNOWATER SAMPLES
                                                    NATIONAL SOUTHWIRE ALUMINUM
                                                HAvVESVIUE. HANCOCK COUNTY. KENTUCKY
FAN AMI TENS (u«1)
i/ANACNUM
HNC
IOORIDE
CYANIDE. (NEE
CYANIDE TOTAL
•MkgrwMid
NW-MMf-01
2U
60UJ
100J
IOU
IOU
Aiea
West of
Property
NW-MWMO
49
-
-


North Pond Area
NMV-MW02


200
170
S6.000J
NMMMtM-OJ


110

JSOJ
South
Pond
Aiea
NW-MW-04
-



I?OJ
Are* Between
Waste Pond*
and Ohio Rivei
NWMW05


110
10
1100
NWMW06



100
fcOOO
Dump Pad
Aiea
NWMWV-07


740

SIO
Oium
Storage
Aiea
NW-MW-08




40
South End
of Facility
NWMW49


160


I
ro
                 Material analyzed for but not detected above minimum quantilation limit (MQL) (MQLs for non-detected parameters can be
                 found in Reference 7A )
          J      Estimated value                                                                                         '
          U      Material was analyzed for but not delected  The number given is the MQL
          R      Quality Control indicates that data unusable. Compound may or may not be present

-------
                       TABLE 14

       SUMMARY OF INORGANIC ANALYTICAL RESULTS
                GROUNDWATER SAMPLES
            NATIONAL SOUTHWIRE ALUMINUM
        HAWESVILLE, HANCOCK COUNTY, KENTUCKY
PARAMETERS (ug/l)
ALUMINUM
ARSENIC
BARIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSiUM
SOOiUM
VANADIUM
ZINC
FLUORIDE
CYANIDE. fREE
CYANIDE TOTAL
Main Building Area
NW-IW-01



83.000


•
-
•
1 9.000
-
-
-
1700
22.000
•
40
3SOJ

260
NW-IW-02



68.000
•
-


•
• 6.000
2 SO

-
•200
•

•
240J
-
100
NW-IW-03
-


74.000
-

-
-

17.000
3 SO
-
- -
870
-
-
•
2SOJ
-
20
Southw«jt
of Facility
NW-PW-01


-

-




8500



'000
•
•
100
190J
-

Material analyzed for but not detected above minimum quantitation limit
(MQL). (MQLs for non-detected parameters can be found in Reference
7A.)
Estimated value.
                          -24-

-------
L
  A • *UR?ACf SOC
     •AUPtl
                                               •CAtf

                                              0 »00'«00'
SURFACE SOIL SAMPLE LOCATION MAP
NATIONAL SOUTHWIRE ALUMINUM
HAWESVILLE, HANCOCK COUNTY, KENTUCKY


FIGURE t


-------
                                      .
                              .
SEDIMENT SAMPLE LOCATION MAP
NATIONAL SOUTHWIRE ALUMINUM
HAWESVILLE, HANCOCK COUNTY, KENTUCKY
FIGURE 3
                                  PEIMUS
                                    I  CXIWHGRATOM

-------
                                          OHIO MIVIM
MONITOR WELL LOCATION MAP
NATIONAL SOUTHWIRE ALUMINUM
HAWESVILLE, HANCOCK COUNTY, KENTUCKY
                                              FIGURE £

-------
                                          ONIO MlVf H
    - OJIOUMOWATtll
GROUNDWATER SAMPLE LOCATION MAP
NATIONAL SOUTHWIRE ALUMINUM
HAWESVILLE, HANCOCK COUNTY, KENTUCKY
FIGURE-

-------
                     APPENDIX A. 6






SUMMARY OP MONITORING WELLS INSTALLED AT THE NSA SITE

-------
             Top of
                Elevation
                 (feel)
  Well ID

Pond  Monitoring Wells
 I
 2
 3
 4
 5
 6
 7
 8
 9
 10
 II
 12
 13
 14
 IS
 16
 17
 18
 19
20
21
22
23
24
25
                                                           TABLE  I

                                     SUMMARY UK MONITORING  WELL INSTALLATION

                                          NATIONAL SOUTHWIRE CORPORATION
                                                 HAWESVILLE,  KENTUCKY
            Screened
Depth       Interval
(reel)        (feet)
403.54
403.39
403.48
403.73
403.43
402.21
404.94
403.68
403.80
403.88
403.63
404.34
404.78
404.83
405.0S
403.76
397.66
404.48
395.21
404.12
403.22
404.60
397.85
40470
402 2 1
»VH 10
50.0
50.0
50.0
50.0
50.0
36.5
40.0
50.0
50.0
50.0
50.0
50.0
40.0
64.0
40.0
40.0
40.5
40.0
40.0
40.0
40.0
40.0
40.0
40.0
400
400
47-49
47-49
47-49
47-49
47-49
Unknown
Unknown
47-49
47-49
47 49
47-49
47-49
20 40
61 64
20-40
20 40
20.5 - 40.5
20 40
20-40
20-40
20-40
20-40
20 40
20 40
20 40
20 40
 Casing
Type/ID
                            2" PVC
                            2" PVC
                            2" PVC
                            2" PVC
                            2" PVC
                            2" PVC
                            2" PVC
                            2" PVC
                            2" PVC
                            2" PVC
                            2" PVC
                            2" PVC
                        2" galvinized sieel
                       1.25" galvinized steel
                        2" galvinized steel
                        2" galvinized steel
                        2" galvinized steel
                        2" galvinized steel
                        2" galvinized steel
                        2 "galvinized steel
                        2" galvinized steel
                        2" galvinized steel
                        2" galvinized steel
                       2" galvinizol sieel
                       2" giilvini/eO iioel
                       2"
                                                                            Installed by
  Date
Installed
   Date
Abandoned
                                                                                                                            Boring  Log
NSA
NSA
NSA
NSA
NSA
NSA
NSA
NSA
NSA
NSA
NSA
NSA
ERM
ERM
ERM
ERM
ERM
ERM
ERM
ERM
ERM
ERM
ERM
ERM
HKM
ERM
Fall 1978
Fall 1978
Fall 1978
Fall 1978
Fall 1978
Fall 1978
Fall 1978
Fall 1978
Fall 1978
Fall 1978
Fall 1978
Fall 1978
April 1979
April 1979
April 1979
April 1979
April 1979
April 1979
April 1979
April 1979
April 1979
April 1979
April 1979
April 1979
April 1979
April 1979
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
1980
No
No
No
No
No
No
No
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes

-------
Location of Monitot- Wells

-------
J L J I
1 1 J 1 1 1
Top of Casing

Well ID
Pond Monitoring
NSA-I
NSA-2
NSA-3
NSA-4
NSA-S
101
102
103
104
10S
106
107
108
109
110
III
112
EPA Monitoring
MW-I
MW-2
MW-3
MW-4
MW-S
MW-6
MW-7
MW-8
MVV9
MW 10
Elevation
(fe.t)
Wells (conl'd)
394.29
407.78
397.74
392.79
392.48
Unknown
402.41
403.51
395.03
398.04
395.46
398.71
Unknown
396.71
407.15
395.58
393.00
Wells
402.54
406.36
404.74
405.32
406.23
405.32
410.50
408.16
407.47
400 7 i
Depth
(reel)

37.0
34.0
36.9
23.0
41.5
50.0
52.7
54.2
50.0
52.1
50.4
51.7
50.0
50.1
54.6
45.6
52.6

57.8
57.8
53.7
55.9
57.3
102.0
58.0
57.3
56.5
56.7
i * < i ' i ' i .' i ; i ;
TABLE 1 (Continued)
Screened '
Interval
(feet)

27-37
24-34
26-36
22-32
31-41
35-50
37-52
39-54
35-50
37-52
35-50
36 51
35 50
35 50
39 54
30-45
37-52

48-58
48-58
48-58
48-58
48-58
92 - 102
48-58
48-58
47-57
47 57

Casing
Type/ID

2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC

2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC
2" PVC


Installed by

Greenbaum & Associates
Greenbaum & Associates
Greenbaum & Associates
Greenbaum & Associates
Greenbaum & Associates
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons

NUS
NUS
NUS
NUS
NUS
NUS
NUS
NUS
NUS
NUS
i : i

Date
Installed

May 1980
May 1980
May 1980
May 1980
May 1980
Oci Nov 1985
Oci Nov 1985
Oci Nov 1985
Oci Nov 1985
(kl Nov 1985
Oci Nov 1985
Oct Nov 1985
Oci Nov 1985
Oci Nov 1985
Oci Nov 1985
Oci Nov 1985
Oci Nov 1985

Nov Dec 1989
Nov Dec 1989
Nov Dec 1989
Nov Dec 1989
Nov Dec 1989
Nov- Dec 1989
Nov Dec 1989
Nov-Dec 1989
Nov Dec 1989
Nov Dec 1989
' 1 l
. 1 . 1 1 . 1

Date
Abandoned Boring Log

July 1989 Yes
Yes
Yes
Yes
Yes
April 1989 Yes
Yes
Yes
Yes
Yes
Yes
Yes
September 1989 Yes
Yes
Yes
Yes
Yes

Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes

-------
L. J    t   I    LI    II    I
                 I    l    I    I
                                                 I    l
                                                             TABLE I (Continued)
           W.ll ID
Top  of Cuing
  Elevation
    (tot)
         In Plant Monitoring WelU
           1
           2
           3
           4
           5
           6
           7
           8
           9
           10
           II
           12
Depth
(•••I)
Screened
Interval
 (feet)
 Casing
Type/ID
Unknown
407.78
405.65
406.74
405.52
Unknown
Unknown
406.56
Unknown
Unknown
407.13
407.67
Unknown
62.9
62.4
65.7
76.9
Unknown
Unknown
102.2
Unknown
Unknown
62.6
62.4
Unknown
47-62
47-62
50-65
61 -76
Unknown
Unknown
87- 102
Unknown
Unknown
47-62
47-62
2"PVC
2"PVC
2"PVC
2"PVC
2"PVC
2"PVC
2"PVC
2"PVC
2"PVC
2"PVC
2"PVC
2"PVC
Installed  by
  Date
Installed
   Dale
Abandoned
Boring Log
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Kenvirons
Nov-Dec 1985
Nov Dec 1985
Nov Dec 1985
Nov Dec 1985
Nov Dec 1985
Nov Dec 1985
Nov Dec 1985
Nov Dec 1985
Nov Dec 1985
Nov Dec 1985
Nov-Dec 1985
Nov Dec 1985
October 1986




September 1989
January 1989

September 1989
June 1986


No
No
No
No
No
No
No
No
No
No
No
No

-------
                                                       TAIII.K 5-1 (Continued)
Ground Top of Casing Screened
Elevation Elevation Depth Interval
Well ID (feel) (feel) (feel) (feel)

Casing
Type/ID


Installed by

Dale
Installed Boring Log
Dames & Moore Wells
20ID
2011
20IS
202D
2021
203D
2031
203S
204D
207
2081
2091
2101
2111
2121
2131 »
214S
397.52
397.82
397.85
408.63
408.29
394.19
394.76
394.78
402.75
406.51
404.52
414.62
406.71
392.62
400.63
407.87
NA
399.90
400.29
400.38
410.73
410.62
396.51
397.03
397.21
405.11
406.29
406.98
416.87
409.16
395.12
402.79
410.19
410.17
120.0
90.0
45.0
130.0
80.0
122.0
90.0
50.0
130.0
510
80.0
85.0
90.0
90.0
95.0
95.0
60.0
107-117
80-90
35-45
119-129
70^80
112-122
80-90
40-50
119 129
40-50
70^80
7585
80-90
80-90
85-95
85-95
49-59
2" Stainless Steel
2* Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
2" Stainless Steel
Dames & Moore
Dames &. Moore
Dames & Moore
Dames A Moore
Dames & Moore
Dames A Moore
Dames & Moore
Dames & Moore
Dames &. Moore
Dames & Moore
Dames & Moore
Dames & Moore
Dames & Moore
Dames A Moore
Dames & Moore
Dames & Moore
Dames A Moore
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feb-Mar 1992
Feo-Mar 1992
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes

-------
<
cfl
                              10S
    yw.io
                                                                                           MW-2111

                                                                                             '         &
                                                           /
                                                                                                  /
                                              •/MW-2010

                                               MW-2011

                                             •f-MW-2013
                                                                                                 *

                                                                                                2
                                                                                               I
                                                                                           800
                                                             •500
              Drainage Ditch and Row
              Direction

              Watte Supply W»ll Location

              New NSA Monitoring Well
              Location (Installed by
              Dames & Moore, Spring
              1992)

              Boring Location (WeU
              not installed. Spring 1992)
U. S. EPA Monitoring
Well Location (Installed
by NUS Corp., November-
December 1989)

Existing NSA Monitoring
Well Location (Installed
by Kenvirons. Inc.,
October 1985)

Existing NSA Monitoring
Well Location (Installed by
Qreenbaum Associates.
Inc., May 1980)
                                                                               APPROXIMATE SCALE IN FEET

                                                                              BASE MAP SOURCE: Comoro *
-------
                        APPENDIX B
COPY OF THE PROPOSED PLAN PRESENTED AT THE PUBLIC MEETING
 AT  THE  HANCOCK COUNTY MIDDLE SCHOOL,  JANUARY 19,  1993,
       NEAR  HAWBSVILLB,  HANCOCK COUNTY,  KENTUCKY.

-------
     U.S. EPA ISSUES PROPOSED PLAN FOR
    INTERIM  ACTION AND INITIATES STUDY
                  NATIONAL SOUTHWIRE
                      ALUMINUM SITE

                  HAWESVILLE, HANCOCK
                     COUNTY, KENTUCKY
      EPA
  REGION IV               January 1993
INTRODUCTION

   The U.S. Environmental Protection Agency  (EPA), in cooperation
   with  the  Commonwealth  of  Kentucky  Natural  Resources and
   Environmental Protection Cabinet (KNREPC) , has begun the Federal
   "Superfund" process to  address environmental contamination at
   the National Southwire Aluminum Company Site (the "Site") near
   Hawesville, Hancock County, Kentucky  (Figure 1) . EPA is issuing
   this fact sheet in order to provide a notice of proposed Interim
   Remedial Actions for the Site, to familiarize the public with
   those proposed actions as part of the public participation
      •  The Proposed Plan For Interim Remedial Action;
      •  The start of RI/FS activities at the Site;
      •  The Superfund Process.
         Highlighted words are defined in the Glossary at
         the end of this Fact Sheet

-------
040008000

  APPROXIMATE SCALE IN FEET
  NSA
Hawesvffle, Hancock County. Kentucky
          RGURE  1
      SITE VICINITY MAP
BASE MAP SOURCE: USGS 71/2 minute
topographic quadrangle map. TeB City,
Indiana-Kentucky 1961. photcxavised 1980.     Quadrangle
                                        Location

-------
requirements   under  section  117(a)  of   the  Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA),   as   amended  by   the  Super fund   Amendments  and
Reauthorization Act of 1986  (SARA) ,  and to  inform the public
about  the   initiation  of   the   Remedial   Investigation  and
Feasibility Study  (RI/PS) at the Site.

EPA is proposing that an Interim Remedial Action be conducted at
the Site  to:  l)  limit further ground  water  contamination,  2)
attempt to prevent migration of  contaminants,  and 3)  initiate
ground  water  restoration  while  the  RI/FS  and  post-Rl/FS
activities are being completed.  Previous investigations by EPA,
the  Commonwealth  of  Kentucky,   and  the  National  Southwire
Aluminum  Company  (NSA,  Inc.)  indicate  that the unconsolidated
alluvial aquifer beneath the  Site is  contaminated in two onsite
locations  with cyanide,  metals, and  fluoride.   The  onsite
locations identified thus far  that  contain significant ground
water  contamination are:  1)  the  spent potliner  disposal area
(North Plume) ;  and 2)  the previous  location of the  dump pad
(South Plume)(Figure 2).

This Interim Remedial Action is proposed to remove some of the
contaminants from  the ground water aquifer, provide short-term
contaminant control, and gain additional information about the
alluvial  aquifer's response  to  clean  up.    It is an interim
measure and  is not considered the Final Remedy  for  the Site.
During the RI/FS the best long-term solutions_for the Site will
be identified.  Upon conclusion of the RI/FS, EPA will present
several of  the best potential remedies for  the Site  to the
public for comment.

This  fact sheet provides background information on  the Site,
describes the  Interim  Remedial Action, provides the rationale
for  EPA's identification  of  the Preferred Alternative,  and
outlines  the  role of  the public in  helping EPA make a final
decision  on a remedy.

SITE BACKGROUND

The NSA Site consists  of approximately 1,100 acres adjacent to
the Ohio  River approximately 4 miles northwest of Hawesville,
Kentucky.   This  Site  is situated  within  the  broad alluvial
floodplain of the  Ohio River of northwestern Kentucky, approx-
imately  30  miles  east of  Owensboro.  Much of the  Site lies
within the 100-year floodplain of the Ohio  River.  The Site has
been utilized from 1969 to the present, and is still an
EPA encourages the public to review the Administrative Record
located  at the Hancock  County Public Library  and to submit
written  comments  on the Interim Remedial Action alternatives
presented  in this plan.  Public comments may influence aspects
of EPA's proposed Interim Remedial Action.

-------
    Podintr Disposal Area
           (Ntxtt Poflfl)
  Refractory Brick
    Disposal Area
(Size and Location
    Approximate)
                                                                   A yw-21210.0063

                                                             East Suny Disposal Ana (Closed)
                                                                                B-2081*
                                        Spent Potliner
                                        .Accumulation
                                                                                             : 0.0057
                                                                                             •UW-20100.0072

                                                                                              UW.201I0.23S
                                                                                              MW-201S 0.289

                                                                                             Industrial Waste Land?:
                                                                                 A MW-214 0.232

                                                                                          r PCS Soil Stockpile Area

                                                                                         •j Taylors Wasn Landfill

                                                                                     MW-2101 0.336
  NO
 MW-10
                                                                                   MW-2021 O.S53

                                                                                   MW-202000138
                                                                                   MW-71.21
                                                                                   20.435
                                                                                   Drum Storage Area and
                                                                                   Painting Area

                                                                                   UW-20910 '<9
                                                                                   UW40.04H
  LEGEND:^-
 	 Fenca

  -— -   -, Railroad Spur

     	 Drainage Ditch and Flow
         Direction

    m   Water Supply Well Location

         New NSA Monitoring Well
    A   Location (Installed by Dames
         & Moore, Spring 1992)

    A   Boring Location (Well not
    w   installed. Spring 1992)

         U. S. EPA Monitoring Well
         Location (Installed by NUS
         Corp., November-December
         1989)
                                                                                         800
                                                                  1600
                                 O.S53
                                100 —
®
Existing NSA Monitoring Well
Location (Installed by
Kenvirons, Inc.. October
1985)

Existing NSA Monitoring Well
Location (Installed by
Greenbaum Associates, Inc.
May 1980)

Total Cyanide Concentration,
mg/L. Measured May 1992

Total Cyanide Concentration
Contour, mg/L              ,
                                                                             APPROXIMATE SCALE IN FEET

                                                                           BASE MAP SOURCE  Comowa Tarn site
                                                                           plan from NSA, Novemow :93*
                                  NO  Not Detected
                                                                         NSA A Division of Souff»f» CO»-C*-Y
                                                                       Hawesville. Hancock County
              FIGURE  -
CONCENTRATION OF TOTAL
          IN GROUND WATE =

-------
active facility that engages in aluminum smelting operations.
NSA owns and operates the facility and appears to be the only
Potentially Responsible Party (PRP).   Site features include a
number of  manufacturing and service buildings,  three former
waste disposal impoundments,  an active wastewater impoundment,
three former waste disposal  landfills, a potliner accumulation
building, and a drainage ditch, and a  refractory brick disposal
area. In the central-western portion of the site is the Hancock
County Airport. At the southeastern portion of the site is the
Southwire  Rod and Cable  Mill (a  division of the  Southwire
Company  of  Carrollton,  Georgia).   Adjacent  to  the  site
(northwest) is the Big Rivers Power Plant.

SITE OPERATIONS

The  facility  produces  elemental  aluminum  from aluminum ore.
The ore is delivered to the  site by barge  (via the Ohio River)
and transferred to the production areas by a conveyer system.
Elemental  aluminum is  produced  by  placing the alumina ore
(A1203) in carbon-lined metal vessels  called pots.  In order to
facilitate  the process, a  sodium fluoride bath  (Na3AlF6)  is
added  to the pots.  Direct  current  (DC)   is  run  through the
pots, reducing the aluminum in the ore to its elemental state.
Molten aluminum collects in the bottom of  the pots where  it is
siphoned  off.   The  molten  aluminum is then transported in
crucibles to adjoining  buildings, where it is cast into ingots.
Molten aluminum is also supplied  to  Southwire Rod and Cable,
adjacent to the south of the plant.

Where  the  carbon-lined pots  are  exposed  to  air  during this
process,  cyanide  is produced  and incorporated into  the pot
liner.   The facility has 448 active carbon-lined  pots.   The
aluminum-reducing  pots are  operated continuously  until the
carbon  liner  begins  to  burn through.    This process   takes
approximately  5-10 years  to occur.   Once  a pot  begins to
experience  burn-through,  it  is   taken  out  of  service and
replaced with  a reconditioned pot.   The decommissioned pot is
prepared for use again by  removing  and replacing the carbon
liner  (potliner).   In 1971, potliner  removal began  at che
facility.   In 1973, a concrete  pad called the  dump pad was
constructed specifically for the  removal  of  potliners.   The
concrete pad was upgraded to an enclosed containment structure
in  1991.   This  building is  now referred  to  as  the  Spent
Potliner  Accumulation  Building.    Prior to  7/25/86,  the
potliners  were disposed  of  onsite  in  the potliner disposal
area.   According to NSA, approximately 26,000 cubic yards of
spent  potliners  were disposed in the North Pond.  After this
time,  the potliners were shipped offsite to an EPA  approved
disposal facility.

Two clay-lined ponds (North and Old  South Ponds), one unlir.ed


                             -5-

-------
pond (East Pond),  and one synthetically-lined pond  (New South
Pond),  each covering approximately six acres, were constructed
for disposal of industrial  wastes from the facility.  Wastes
disposed  of  in  the North  Pond  included  spent  pot linings
containing cyanide  from  the  aluminum  reduction  process  and
calcium fluoride slurry  from  the air quality control system.
Calcium fluoride slurry was disposed of  in  the Old South Pond,
East Pond, and New  South Pond.   NSA closed the North Pond in
1986 and covered it with a synthetic  cap and a layer of soil.
The area is now covered with low vegetation and grass.  The Old
South Pond has been filled to capacity, and its use ceased in
1989.   The East Pond has also  been closed.  The New South Pond
is now  used  for disposal of  the calcium fluoride slurry and
electrostatic precipitator catch, as  approved by the State of
Kentucky Division of Waste Management.

ENVIRONMENTAL SAMPLING

In  1980,  a contractor  hired  by  NSA (Environmental Resource
Management, Inc.) to  investigate the ground water determined
that leaching of cyanide  and fluoride was occurring beneath the
North Pond.   A Preliminary Assessment was  completed  by the
Kentucky Division of Waste Management on February 25, 1986.  In
the late 1980'a, the Commonwealth of Kentucky referred the site
to EPA for ranking under the Hazard  Ranking System  (HRS).  In
1990 and  1991,  samples  from surface  soils, subsurface soils,
sediments, surface waters, monitoring wells,  industrial wells,
and some  private  well samples were  collected during the EPA
Preliminary  Field Investigation  as   reported  in  the Interim
Final Listing Site Inspection Report by NUS Corporation  (April
1991).

All documents related to previous ground water investigations
are in  the administrative  record and  available  for review.
NSA, through  its consultants, has  also collected  additional
data regarding the  environmental condition of the property.
NSA has stated to  EPA  that  it  has  cleaned  out  a  drainage/
effluent   ditch  that   was   found  to  contain  significant
concentrations of fluoride  and metals.

During  onsite construction of a cooling tower foundation in
1991, NSA identified significant levels of PCBs.  In order to
finish  construction activities at this location, NSA removed
and  disposed  of   approximately  850  cubic   yards of  PCB-
contaminated  soils  at   the  excavation  for  a  cooling tower
footing.   Present information suggests  that  PCB contamination
exists  near  the foundation  of  the  cooling tower  and the
adjacent  areas.   These  areas  will  be further  investigated
during  1993 to determine the  full extent of  contamination.

The  NSA  Site  was  proposed  for  inclusion  on  the National
Priorities List (HPL), as defined in Section 105 of  CERCLA, as

                            -6-

-------
amended, 42 U.S.C. §9605, in July 29, 1991.  At present, this
Site has not been listed as final on the NPL.

RZ/FS TO BE CONDUCTED UNDER AGREEMENT WITH EPA

A Superfund  Remedial Investigation and  Feasibility  Study or
RI/FS will be conducted at the Site to determine the nature and
extent  of   contamination  and  provide   an  evaluation  of
appropriate alternatives for permanent Site cleanup.  The Site
RI/FS and associated environmental  studies will  be conducted
under the Administrative  Order on Conseat that NSA, Inc. signed
with EPA on  September 30,  1992.   EPA and the Commonwealth of
Kentucky will oversee all RI/FS and related studies performed
by  NSA to  ensure compliance  with  all  applicable  laws  and
regulations and  to ensure  that  the  work proceeds in a timely
manner.

The RI will identify all  areas of Site contamination and where
these  contaminants  might  have  migrated.   The  information
gathered  during  the RI will  then  be  used  to  develop  a
Feasibility Study (FS) which will evaluate options for cleaning
up the  Site.  The FS is  expected to be completed by December
1993.  Site field work will begin in March of 1992.  The field
work  includes:   1)  installation of additional  ground water
monitoring wells in  areas  suspected to  be  contaminated,  2)
soils and sediment sampling on and  offsite in areas suspected
to be contaminated,  3) sampling of all onsite  .wells and offsite
residential  wells,   and  4)   any  other  activities  identified
during  the  ongoing review of the RI/FS  Work Plan that would
allow  EPA,  the  Commonwealth of  Kentucky, and NSA to better
understand and cleanup the Site.

THE NEXT STEP: ONCE  THE  RI/FS IS COMPLETED

At the completion of the FS,  EPA will develop another Proposed
Plan which will  describe several alternatives under consider-
ation,  as  well  as EPA's preferred  alternative  for the Final
Remedy  for the Site.  A  copy of the proposed plan, which will
include  a brief description of  the RI/FS  results,  will be
mailed to interested parties and all persons who have requested
to be  included  on EPA's  mailing list for the Site.  EPA will
conduct a 30-day public comment period on the RI/FS Report and
the  Proposed Plan  to  provide  an  opportunity  for   public
involvement  in  the  final cleanup decision.

EPA will also conduct a public meeting at that  time to  discuss
the  RI/FS and  the  proposed plan,  and  to address  community
questions  and concerns.   After the public meeting and public
comment period,  EPA will  review  and  consider  all comments
received  from the community as part of the process  of reaching
a final decision on  the most appropriate remedial alternative,
or combination of alternatives, to address contamination found

                            -7-

-------
at  the  NSA Site.   EPA's  final  choice of  a remedy  will be
documented in the Record of Decision (ROD), which will include
a report  called a Responsiveness Summary.   A Responsiveness
Summary   is  designed   to   summarize   citizen   and  other
questions/comments and provide EPA  responses.

After the ROD is signed by the EPA Regional Administrator, EPA
will negotiate with the PRPs to design and implement the final
cleanup plan.   At  the  end of the negotiation period,  EPA and
the Commonwealth of Kentucky will  oversee the development of
engineering design plans for  implementation  of  the selected
remedial alternative.

SCOPE AMD ROLE OF  PROPOSED  INTERIM  REMEDIAL ACTION

Due  to  the  length of  time  required  to  complete  the RI/FS
(typically  18  to  24 months)  and the possibility  of  further
plume migration, EPA feels  that it  is appropriate to initiate
an Interim Remedial Action on Site ground  water.  The proposed
Interim Remedial Action (which will  be described in  the Interim
Remedial Action ROD)  would begin ground  water cleanup while
RI/FS- and  post RI/FS  activities  are being  completed.   This
proposed Interim Action would initiate a reduction  of risks to
human health and the environment  posed by  the  cyanide, metals,
and  fluoride  in onsite ground water  plumes   (North and South
Plumes).   Previous onsite investigative work,  including 36
previously  installed  wells and 15  recently  -installed wells,
provides   the  required   information  to   support  interim
activities, and will significantly  reduce the time needed for
this final  investigation.

This Interim  Action does not constitute the  Final Remedy for
the Site.  A Final Remedial Action  will be developed to fully
address  the  principle   threats  posed   by   Site  conditions
following the conclusion of the RI/FS.  Upon  completion of the
RI/FS,  the ground water  treatment system embodied  by  this
Interim Action may be incorporated into the Site  remedy design
specified  in the  final action  ROD.    This   Interim Remedial
Action  would  be monitored carefully to ensure that hydraulic
control  and  remediation  of  the   contaminant  plume  can be
achieved  and to  determine the  feasibility   of  incorporating
interim measures into  the Final Remedy  for the Site.

Once the  RI/FS  is completed, work  will begin on the Remedial
Design/Remedial Action for the Final Action.  Again, since  much
of  the  "interim"  measure work will  likely  aid  in the Final
Action, the'RD/RA for the Final Remedy will likely take between
8 and 12 months to complete.   This  is a significantly shorter
period  of  time  than usual.
                            -8-

-------
SUMMARY OF SITE RISKS

Cyanide, metals,  fluoride, and PCBs are contaminants of concern
at the NSA Site  and  have been  or are being released from the
Site in other than a  controlled manner.  Metals  include but may
not be limited to: lead, manganese, nickel, beryllium, cadmium,
arsenic, chromium,  and barium.   Some  of  these contaminants
found at the Site are very toxic at extremely low levels, and
they also  tend  to bioaccumulate.   These  contaminants,  other
than PCBs, are  readily soluble  and  have  leached or migrated
from soils into the groundwater.   Cyanide at  the  Site has been
reported at  levels  ranging  from traces up  to  56  parts per
million (ppm) in the  ground water  (The highest level EPA allows
in ground  water or  the Maximum Contaminant Level  (MCL)  for
cyanide is 0.2 ppm) .  Levels in North Pond surface waters prior
to covering were 165 ppm.

Fluoride is a by-product of  the ionization of cryolite, and is
concentrated as a waste product by the air emissions filtration
system at the Site.   In the  environment, fluorides are soluble
and can result in a variety of toxicological effects, including
fluorosis, a syndrome resulting  from chronic  exposure and
characterized by bone and  tooth damage. Fluoride was found in
the ground water adjacent to the North Pond  area at levels up
to 1,700 ppm  (The MCL for  fluoride is 4.0 ppm) .   PCBs are oil-
based  contaminants  that  are  not  readily  soluble,  can  be
carcinogenic and tend to bioconcentrate.  PCB'^s  were identified
during   construction  activities   for  the   cooling  tower
foundation.   Levels  of PCB's in  onsite soils ranged from less
than 1 ppm up to 8,940 ppm.  EPA cleanup levels  in soils will
be determined during the RI/FS.   These  levels are commonly 1 to
10 ppm.  PCBs do not easily leach into ground water, however,
they were identified in leachate  at one of the onsite landfills
at levels up  to  7.3  ppb.  The EPA allowable  limit for PCBs in
ground water  is  0.5  ppb.

Much  of  the  Site contamination  is  due to  the breaking up of
spent pot liners on the dump pad  and also by disposal of wastes
into surface  impoundments.  Pot  lining material, a by-product
of the  aluminum reduction process which may contain cyanide,
has been, disposed of  in  the North  Pond which was closed in
1986,   and  in  two  other  smaller   onsite  disposal   areas
immediately  north of  the main  industrial  complex.   Prior to
impoundment   or   landfill   covering,  this   material   was
transportable by wind, water,  and human activities.  Cyanide
and  other metals  have leached  into  the groundwater  at the
surface impoundments, spent  potliner accumulation building, and
the smaller landfills.  Calcium fluoride is present at the Site
in most media.  It is presently believed that groundwater  flows
generally  from  the  Site to  the Ohio River,  less  than  3/4 mile
away.  On-Site water production wells south of the impoundments
may create a cone of depression that may influence groundwater

                            -9-

-------
movement at the Site.   At the present time, risks appear to be
low  concerning  the Ohio  River.    Present  monitoring  well
information suggests that any  contaminants  that do enter the
river are diluted to the point where they are not detectable.
This will be further evaluated during the RI/FS to be certain
risks remain low for the Ohio River.

The manufacturing facility is externally fenced; however, the
surface  impoundments are not isolated by fencing  from other
portions of the Site such as  the  adjacent airfield.  There are
no barriers to human or wildlife movement between the surface
impoundments and this public airfield.

DESCRIPTION OF REMEDIAL ALTERNATIVES

The alternatives that EPA has evaluated for the  Interim Action
are described briefly below.  EPA evaluated these options using
the nine evaluation criteria listed in Table 1.

Alternative 1: No Action

Cost: $0

Time to Implement: N/A

The EPA  requires  that  this  alternative  be evaluated at every
site  to serve  as a baseline  for  comparison  for  all  other
alternatives   considered.      Under  this   alternative,   no
groundwater remediation would take place.  The  only reduction
of contaminant levels that could potentially occur would be via
natural  processes  such as dispersion or  attenuation.   There
would be no associated costs with this alternative.

Alternative 2: Pump and Treat System

Construction cost                            $ 1.7 million

Annual operation and maintenance costs       $ 570,000

Time to  implement                            6 months

This alternative would ensure that active treatment of the two
onsite  ground  water plumes  would  begin  during  the  RI/FS.
Ground water containing cyanide,  metals,  and fluoride would be
collected  (pumped)  from extraction wells placed in the North
Plume and South Plume.  The exact number of  wells utilized for
extracting  contaminated ground waters will  be determined as
part of  the Remedial Design  (RD)  for the Interim Action.  The
RD will  take place  after Consent Decree  (CD)  negotiations are
completed for  the  interim action ROD.

The extraction well pump and treat system would effectively

                            -10-

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                            TABLE 1

                EPA CRITERIA FOR EVALUATING
                     CLEANUP ALTERNATIVES


Overall Protection of Public Health and Environment:  Degree to which
each alternative eliminates,  reduces,  or  controls threats to public
health  and environment through  treatment,  engineering  methods,  or
institutional controls (e.g., deed,  land use or other restrictions).

Compliance with State and Federal Requirements:  Degree to which each
alternative meets environmental regulations determined to be applicable
or relevant and appropriate to Site conditions.

Short-Term  Effectiveness:  Length of  time needed  to  implement each
alternative and the risks posed to workers and nearby residents during
implementation.

Long-Term Effectiveness: Ability  to maintain reliable protection after
implementation.

Reduction  of  Toxicity,   Mobility,  and  Volume:  Degree  to  which
alternative reduces  (1) ability  of  contaminants to move through the
environment,  (2) harmful  nature of contaminants,  and (3)  amount of
contamination.

Implementability:  Technical feasibility (difficulty-of constructing,
operating,  or maintaining)  and administrative  ease (e.g., amount of
coordination  with  other  governmental  agencies   or  relocation  or
residents) of implementing remedy, including availability of goods or
services.

Cost: Benefits of alternative  weighed against cost.

State Acceptance: EPA requests State comments on the Proposed Plan and
concurrence on final remedy  selection.

Community  Acceptance:  EPA holds  a public  comment  period  to get input
from the affected community and considers  and responds to all comments
received prior to the final selection of a  remedial  (long-term cleanup)
action.
                               -11-

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limit the  onsite spread  of  contaminated ground water  in the
unconsolidated aquifer,  and potentially  limit any  spread of
contaminated waters offsite.  The volume and amount of hazardous
contaminants within  the  aquifer would also be reduced.   This
action would achieve significant risk  reduction  early  in the
Superfund process.  The treated waters would be discharged into
the Ohio River.   The system would be operated in compliance with
the Kentucky Pollutant Discharge Elimination System (KPDES) Ohio
River discharge limits, and with regulations that govern ground
water withdrawal from the Ohio River Valley alluvial aquifer.

In  order  to  assess  the  performance   of  the  ground  water
extraction pump and treat system, evaluation of alluvial aquifer
conditions  will  be  an  ongoing  effort  during  the  RI/FS.
Additional information obtained by this  Interim Remedial Action
will assist in determining the most appropriate cleanup measures
for the Final Site Remedy.

EVALUATION OF ALTERNATIVES

The proposed Interim Remedial Action for the  Site is presented
as Alternative 2 and involves ground water  collection and pump
and treatment  for cyanide, metals,  and fluoride contaminated
ground  waters  using  a  ferrous  precipitation  and  settling
process.   These activities  will be performed while  the Site
RI/FS is being conducted.

This  section   provides  the   basis   for  determining  which
alternative: 1)  meets  the threshold for overall protection of
human health and the environment and compliance with applicable
and relevant and appropriate requirements  (ARARs), 2) provides
the  "best  balance"  between effectiveness  and  reduction of
toxicity,    mobility,     or    volume     through    treatment,
implementability,  and  cost,   and 3)  demonstrates  state  and
community acceptance.

OVERALL PROTECTION OF  HUMAN HEALTH AND  THE  ENVIRONMENT

The only  alternative that would sufficiently  be protective of
human health and the environment would be Alternative 2.  The
"No Action" Alternative is not protective because it does not
address  the most significant  threats  to human health and the
environment  at  the NSA Site.    Therefore,   the  "No Action"
Alternative will not be  considered further  in this analysis as
an  option for  the Site.  Alternative 2 is  protective of human
health  and  the environment  since  it  reduces   or controls
significant and  immediate threats from two  onsite ground water
plumes  containing significant  levels  of cyanide, metals, and
fluoride.   The  pump  and treat  system would also  limit the
potential  spread of  contamination onsite.
                             -12-

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COMPLIANCE  WITH  APPLICABLE  OR  RELEVANT   AND  APPROPRIATE
REQUIREMENTS

Alternative 2 would meet all  State and Federal ARARs concerning
the implementation of the ground water collection and pump and
treat system.  The ground water treatment plant would meet all
ARARs for discharge to surface water.  All activities concerning
handling and disposal of the sludge generated from the operation
will be  in compliance  with  State and  Federal ARARs.   Waste
sludge  (2.5 tons  per  day)  would be  disposed  of  at  an  EPA
approved disposal facility.  Treated water will be released into
the Ohio River and all  treated water will be  in compliance with
KPDES requirements for contaminants identified.

The final cleanup levels for  the ground water are not addressed
in  this  "interim"  remedy  because such  goals are  beyond  the
limited scope of this action.   The  final cleanup levels will be
addressed  by  the final  remedial  action  ROD  for the  Site.
However,  it is expected that  continued  implementation  of  the
pump and treat system would reduce  levels of  cyanide to the MCL
of 0.2 ppm.

LONG-TERM EFFECTIVENESS AND PERMANENCE

Interim measures  (Alternative  2) as described in this document
would  not  provide  any  degree  of  long-term  effectiveness
concerning  remediation  of  source  waste   at-  the  NSA  Site.
However, the pump and treat system would permanently eliminate
contaminants from collection well  waters prior to discharging
the treated waters in  the Ohio River.   The Interim Action is
intended to address  the most imminent and substantial problems
at  the Site.   This would occur while the RI/FS and Post RI/FS
activities  are being completed.   Alternative 2 is consistent
with  the Agency's long-term  goal  of restoration  of  Site  and
adjacent  area ground  water.   In addition, the  two on-site
cyanide plumes would be hydraulically controlled to reduce the
possibility of offsite migration.   This would offer significant
advantages  during implementation of the  Final Remedy for the
Site.

Additional  data would be generated during implementation of the
Interim Remedial Action.  This information concerning hydraulic
conductivity and aquifer response would be used  in  conjunction
with RI/FS data to facilitate Final Remedy selection. Long-term
effectiveness  and permanence will be more  thoroughly evaluated
at  that  time.

REDUCTION OF TOXICITY,  MOBILITY, AND VOLUME

Alternative 2 would  effectively reduce toxicity and mobility of
contaminants  (specifically cyanide)  in the ground  water plumes
at: 1) the  waste water impoundment areas, and 2)  under and near

                             -13-

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the spent  potliner accumulation  building  (formerly  the dump
pad) .   Contaminants withdrawn from the extraction wells would be
permanently eliminated.  It is expected that contaminant levels
within the two onsite ground water plumes would be significantly
reduced through implementation  of  the ground water extraction
pump and treat system.  Continued implementation of the system
may potentially reduce the volume  of  contaminated waters  in the
alluvial aquifer.   During the RI/FS,  the onsite source will be
thoroughly evaluated  and appropriate action will  be  taken as
part  of  the  Final Remedy  to  insure  continued ground  water
contamination does not occur.

SHORT-TERM EFFECTIVENESS

Significant   short-term  effectiveness   would  result   from
implementation  of Alternative  2.   The  "interim" action  is
effective  in the  short-term because  it would significantly
reduce the potential threats from contaminants in the two onsite
ground  water plumes.    However,   short-term  risks  would  be
slightly  elevated during transfer of sludge  from the sludge
holding tank, sludge transfer area, solids collection area, and
the filter press area to transport and then disposal facilities.
These 4 system  areas  would be routinely maintained during the
Interim Action and associated risks would thus be  minimal.

IMPLEMENTABILITY

The implementability  of Alternative  2  is  based  on technical
feasibility,  administrative feasibility,  and  availability of
services and materials.  Alternative  2 is readily implementable
since the standard design and construction methods are utilized.
Also,  there are no expected difficulties concerning administra-
tive  feasibility  or availability  of  services or materials for
the implementation of Alternative 2.

COST

Alternative  2 has a present worth cost of  $1.7 million.  The
annual  operation and   maintenance   cost   will  be  $570,000.
Additional areas of contamination that are not  addressed  during
this  Interim Action will be evaluated during  the  RI/FS.  The
associated cleanup costs for these areas will be evaluated after
additional information  is  obtained.

STATE ACCEPTANCE

EPA is  currently  seeking State concurrence with this  Proposed
Interim Remedial  Action.

COMMUNITY ACCEPTANCE

Community acceptance of  the Interim Remedial  Action will be

                            -14-

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evaluated after the public comment  period and will be described
in the Record of Decision for the Site.

The public is asked to comment on the proposed Interim Remedial
Action during the Public Comment Period, which is from January
7, 1993 through February 7, 1993.

SUMMARY OP STATUTORY FINDINGS

The Preferred Alternative represents the best balance among the
criteria used to evaluate.remedies and would achieve significant
risk  reduction  through treatment  of  the  ground water  in the
alluvial  (unconsolidated)  aquifer.  Based on  the information
available at  this  time,  EPA believes  that  the  Interim Action
would be protective of human health and the environment, would
comply  with  ARARs,  and  would utilize  permanent  treatment
technologies or resource  recovery  technologies  to the maximum
extent practicable.

EPA'S PREFERRED ALTERNATIVE

The preferred Alternative  (Alternative 2)  involves the use of
ground water collection and pump and treat  system.  This system
utilizes a precipitation and settling process that will reduce
cyanide, metals,  and fluoride in  the  treated  ground water to
acceptable levels.  Treated ground water exiting the system will
be discharged to the Ohio River  under applicable KPDES require-
ments.  State requirements for ground water withdrawal will not
be exceeded.

The effectiveness of  the collection well pump and treat system
in   reducing  the  previously   mentioned   contaminants,   and
controlling  the  two ground  water  plumes  will  be  evaluated
through  an extensive monitoring program as part of the RI/FS.
The  proposed  monitoring  program  will  include  all  existing
 (usable) monitoring wells  onsite,  and  all residential wells in
adjacent off site areas that are  determined as part of  the RI, to
be potentially  affected by Site  conditions.

The Preferred Alternative would  allow EPA to initiate  cleanup of
the  contaminated  ground  water  aquifer while  the  RI/FS and
related  activities are  being  completed,  and  to expedite the
Superfund  Process.    Further migration of  contaminants in the
ground water will be reduced.

TECHNICAL ASSISTANCE GRANTS

EPA  has been authorized  by  Congress  to  provide communities
affected by  Superfund  Sites  the  opportunity  to  apply  for
Technical Assistance Grants (TAGS).  Grants range up  to $50.000
per  site and are designed to  enable community groups  to hire
 technical  advisors or consultants to  help them,  interpret  EFA

                            -15-

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findings  and  specifications  for  cleanup  activities.    The
community must provide a 20% match to the amount provided by EPA
and only one TAG is awarded per site.  Interested persons or
community groups may contact the Region IV Grants Specialist
listed below.
  Sharon Chandler
  Technical Assistance Grant Specialist
  U.S. EPA, Region IV
  345 Courtland Street., N.E.
  Atlanta, GA 30365
  (404) 347-2234
THE NEXT STEP: THE COMMUNITY'S ROLE IN THE SELECTION PROCESS

EPA solicits  input  from the community on  the cleanup methods
proposed for  each superfund response  action.   EPA has  set a
public comment period from January 7,  1993  to February 7, 1993,
to encourage public participation  in the selection process.  The
comment period includes a public meeting at which the EPA will
present the Proposed Plan and announce the startup of the Site
RI/FS,  answer questions,  and  receive both written  and oral
comments.  The public meeting is scheduled  for 7:00 PK, January
19, 1993 and will be held at the Hancock County Middle School,
near  Hawesville,  Kentucky.  Comments  will be  summarized  and
responses provided in the Responsiveness Summary section  of the
Interim Remedial Action ROD, which is the document  that presents
EPA's  interim selection for initiation of  site cleanup.  The
public  can   send written  comments  to   or  obtain  further
information from:
                      Douglas A. Bell
                  Remedial Project  Manager
                     U.S.  EPA Region IV
                 345 Courtland Street,  N.E.
                     Atlanta, GA 30365
                       (404)  347-7791
                       1-800-435-9233
The  Proposed Plan,  Supplemental Information  for the  Interim
Action, Current Site Conditions Report, and other pertinent Site
related documents have been placed in the information repository
and the Administrative Record for the Site.   The Administrative
Record includes all  documents  that were  used in developing  the
alternatives  for  the NSA Site.  These documents  are available

                            -16-

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for public review and copying at the following location:


               Hancock County Public Library
                        Court  Street
                        P.O. Box 249
                    Hawesville,  KY  42348
                       (502) 927-6760
                   Contact:  Jackie  Walter
           Copy Facilities Available:   10 cents.
MORE INFORMATION

The  public  can  send written  comments  to  or  obtain further
information  from:

  Douglas A. Bell
  Remedial Project Manager
  U.S. EPA,  Region IV
  354 Courtland St., N.E.
  Atlanta, GA 30365
  (404) 347-7791
  1-800-435-9233

  Suzanne Durham
  Community  Relations Coordinator
  U.S. EPA Region IV
  345 Courtland Street, N.E.
  Atlanta, Georgia 30365
  (404) 347-7791
  1-800-435-9233

  Eric Liebenauer
  Site Manager
  Division of Waste  Management/Commonwealth of  Kentucky
  Natural Resources  and Env. Protection  Cabinet
  Frankfort  Office Park
  14 Reilly  Road
  Frankfort, KY 40601
   (502) 564-6716

  NOTE: PLBASB SHARE THIS INFORMATION WITH OTHERS WHO MIGHT BE
  INTERESTED IN THE NATIONAL SODTHNIRB SITE.
                             -17-

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GLOSSARY

Administrative Order on Consent:  A legal document that identifies
tasks or legal requirements for the Responsible Parties to conduct
the Remedial Investigation and Feasibility Study.

Administrative Record: A file which is maintained and contains all
information used by  the lead agency to make  its decision on the
selection of a response action under CERCLA.  This file is required
to be available for public review and a copy is  to be established
at or  near the  site,  usually at  an information repository.   A
duplicate  file is maintained in a  central  location,  such  as a
regional EPA and/or state office.

Applicable or Relevant and Appropriate Requirements (ARARs) : Refers
to the Federal and State requirements that a remedy selected by EPA
must attain.  These requirements may vary from site to site.

Arsenic: A toxic  metallic substance that  is  a  by-product of the
smelting process.

Attenuation:  Contaminant  levels  may become  lower  over  very long
periods  of time due  to natural  decomposition  or chemical  break
down.  For most hazardous waste sites,  this is not viable because
significant risks associated with contaminants may last for several
lifetimes.

Barium: A toxic silver-white metallic substance  often found in raw
ores utilized  in the smelting industry.

Beryllium: A toxic metallic substance generally associated with raw
ores  utilized  in the smelting  or metals  machining  industry.
Beryllium may  also be  generated through the combustion of coal or
fuel oil.

Bioaccumulate: The escalating accumulation of toxic materials that
occurs within  the food chain of an ecosystem.

Broad Alluvial Flood Plaint   The nearly flat portion of  the Ohio
River Valley  that is  located on soft sediments that are deposited
from  repeated flooding and  migration  of the Ohio  River and  its
tributaries.

Cadmium:   A Toxic bluish-white metallic substance that is often a
by-product of the  smelting industry.  Combustion of fossil  fuels
may also result  in the release of  cadmium  to  the environment.

Carcinogenic:  Any substance  that produces  cancer.

Chromium:    In its  raw  state,  chromium  is a  toxic steel-gray
metallic substance  found  in  raw  ores commonly utilized in  the
smelting industry.   Another  common source of chromium is through

                               -18-

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the combustion of fossil fuels.

Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) i A Federal law passed in 1980  and modified in 1986 by
the Superfund Amendments and Reauthorization Act.  The Acts created
a special tax that goes into a trust fund, commonly known
as Superfund,  to investigate and clean up abandoned or uncontrolled
hazardous waste sites.  Under the program, EPA can either pay for
site cleanup when the responsible parties cannot be located or are
unwilling or unable  to perform the work, or take legal action to
force responsible parties to clean up the site or reimburse EPA the
cost of the cleanup.

Cone of Depression: Withdrawal  of ground waters from a well usually
influences, the ground  water adjacent to  the well.  This influence
if shown on a map may be circular  (similar to a cone) and generally
represents a  lower level  of ground water for a variable distance
from the well.

Consent Decree:  A legal  document that  outlines  the  actions the
Responsible  Parties  will  undertake  for the  Remedial  Design and
Remedial Action at a Superfund Site.

Cyanide: The  toxic,  colorless  solid or  substance  is incorporated
into carbon potlining material during the aluminum smelting process
at the NSA Site.

Dispersion:  As contaminants move away from their'source they tend
to be  less  concentrated since  they mix with more and more ground
waters.

Ferrous  Precipitation: A  process allows  ferrous  iron in ground
water  to combine with cyanide  and settle out of the water.  This
allows the  cyanide to  be  collected and  separated  into sludge that
can be disposed  of at  an  EPA approved disposal  facility.

Fluoride: Is a pale-yellow to green substance that at  the NSA Site
is  a  by-product  of  the  aluminum  smelting  process.    In low
concentrations  fluoride is not  hazardous.   However,  at elevated
levels  fluoride  may  have  adverse affects (see  fluorosis).

Fluorosis:  A syndrome sometimes seen following chronic exposure  to
fluoride in which subjects exhibit  symptoms  such as mottled  tooth
enamel  and  bones that  are harder and more brittle.

Ground water:  Underground water  that  fills  pores  in  soils  or
openings  in  rocks  to the point of  saturation.   Unlike  surface
water, groundwater cannot  clean  itself by exposure to sun or  rapid
aeration.   Groundwater is  often used as  a source of drinking  water
via municipal or domestic wells.
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Information  Repository:  A  file  containing  current information,
technical reports and reference documents regarding a Superfund NPL
site.  The information repository  is  usually located in a public
building that is convenient for local residents, such as a public
school, city hall, or a library.  As the site proceeds through the
Superfund Remedial Process,  the file at the information repository
is continually updated.

Interim Remedial  Actions:   Usually short-term cleanup activities
selected to reduce risks at a Superfund site while  investigations
continue.  Once additional information is obtained from studies and
also from  the  Interim Remedial  Action, then  the Final  Remedy is
proposed for the Site.

Interim Action Record of Decision:  A public document that presents
information concerning an expedited  cleanup  alternative that has
been  selected to reduce  or eliminate  problems  at a  National
Priorities List site prior to implementation of the Final Remedy.
This document also explains the reasons for choosing that cleanup
alternative over other possibilities.

Kentucky  Pollutant  Discharge  Elimination  System: See  National
Pollutant Discharge Elimination System.

Lead: A toxic bluish-gray metal that at the NSA facility is a by-
product of aluminum manufacturing processes.  Lead is also commonly
found in paint, solder, and pipes.

Manganese:  A  toxic  metallic substance that is commonly combined
with other chemicals to form manganese compounds.   These compounds
are commonly found in ores utilized in the smelting industry.

Maximum  Contaminant  Levels:  The  maximum  allowable  level  a
contaminant may be identified at before EPA can take action.

Metals: Inorganic substances including but not limited to: arsenic,
barium, beryllium, cadmium,  chromium,  lead, manganese, and nickel.

Monitoring Programs  The continued  collection of information about
the  environment  that helps gauge  the effectiveness of a cleanup
action.

National   Pollutant   Discharge   Elimination  System  (NPDES):   A
provision of the  Clean Water Act which prohibits  the  discharge of
pollutants into waters of  the United States unless a special permit
is issued by EPA  [State (where delegated), or a  tribal government
on an Indian reservation] allowing  a controlled discharge of liquid
after  it has undergone treatment.

National  Priority List: A  list  of  the  nation's  hazardous waste
sites that are eligible for  cleanup under Superfund (1980)  and  SARA
 (1986).

                               -20-

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Nickel: A toxic silver-colored metal commonly found in ores used in
the smelting industry.

PCBs (Polychlorinated biphenyls) :   These  toxic compounds have been
widely used in transformers and electrical equipment as coolants or
lubricants.

Plume Migration: Contaminants in the ground water will usually move
and spread away from the source.  The affected ground waters from
the  source   (origin)   to   the   farthest  extent   of  measurable
contamination is called a plume.

Potential Responsible Parties (PRPs):  This may be an individual, a
company or  a  group of companies who  may have  contributed to the
hazardous conditions at a site.  These parties may be held liable
for costs  of  the  remedial  activities by  the EPA  through CERCLA
laws.

Precipitation  Process:  At  the treatment  apparatus  (see  pump and
treat) , chemicals are added to the extracted ground waters  (ferrous
chloride or ferrous sulfate)  to  cause  the ferricyanide contaminant
to be effectively  separated  from the  water.

Preferred Alternative: After evaluating  and examining the various
remedial alternatives,  EPA  selects the best alternative based on
relevant cost and non-cost factors. This alternative was selected
from a list of  the most technologically  feasible_ alternatives for
a remedial  strategy.

Pump and Treat:  Ground water will  be  pumped from the aquifer and
transported via an onsite pipeline to  the treatment apparatus.  At
the treatment  apparatus the  contaminants will be removed  from the
ground water, then the treated water will be discharged to the Ohio
River.  All treated water disposed of  in the Ohio River will be in
accordance  with all  State and Federal Regulations.

Record of Decision:  A public document written by EPA that  presents
information concerning the  Final Remedy selected  to  reduce or
eliminate  problems  at a National Priorities  List  site.   This
document  also  explains the reasons  for choosing that cleanup
alternative over other possibilities.

Remedial Actions  The EPA selected  action for an NPL site.

Remedial  Design: A  set of  specifications, plans,   and procedures
that  describe how the remedial  action will proceed.

Remedial Investigation and Feasibility Study (RI/PS): Two distinct
but  related  studies,  normally  conducted  together,  intended  to
define the  nature  and extent of contamination at a site (RI)  and to
evaluate  appropriate, site-specific  remedies necessary to achieve
final cleanup at the site  (FS).

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Responsiveness Summary: A report that summarizes citizen comments
or questions and EPA responses during the public comment period.

Settling Process: A stage of activity during  the  pump and treat
process  where  contaminants  are  allowed  to  separate  from  the
solution so they may be collected and removed from the water.

Superfund Amendments and Reauthorization Act  (SARA): Modifications
to CERCLA Enacted on October 17, 1986.

Unconsolidated Alluvial Aquifer:  Soft sediments that reside below
the Ohio  River flood .plain.   These  sediments are saturated  and
sufficiently permeable to transmit economic quantities  of water to
wells and springs.

Work Plan: A report  that describes activities to be  performed in an
upcoming investigation.
                                -22-

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EPA MAILING LIST ADDITIONS

   If you know of  others that wish to be placed on the mailing list
   to receive information  on the NSA Site,  please request that they
   fill out and mail this form to:
     NATIONAL SOUTHWIKB SITE
     Suzanne Durham, Community Relations Coordinator
     U.S. Environmental Protection Agency
     Region IV
     345 Courtland Street, N.E.
     Atlanta, GA 30365
     (404) 347-7791
     1-800-435-9233
   Name:
   Address:
   Affiliation:.

   Telephone:	
                                -23-

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             APPENDIX C
  INFORMATION REPOSITORY LOCATION
   Hancock County Public Library
            Court  Street
            P.O. Box 249
        Hawesville,  KY 42348
           (502) 927-6760
      Contact: Jackie Walters
Copy Facilities Available: 10 cents

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      APPENDIX D






LETTERS OF CONCURRENCE

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PHILLIP J. SHEPHERD  •                  /s^Sv*^                     BRERETON C. JONES
    SeCR£TaBY                        ISI  m Ml                         GOVERNOR
                             COMMONWEALTH OF KENTUCKY
               NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION CABINET
                      DEPARTMENT FOR ENVIRONMENTAL PROTECTION
                                FRANKFORT OFFICE PARK
                                   14 REIU.Y ROAD
                               FRANKFORT. KENTUCKY 40601

                                February 2,  1993
     Doug Bell
     Remedial Project Manager
     U.S. Environmental Protection Agency
     345 Courtland Street, N.E.
     Atlanta, GA 30365


     Dear Mr. Bell


          This letter is written to give the Kentucky Division  of Waste
     Management's  (KDWM's)  official  approval  of  the  Interim Action
     R.O.D. at the National Southwire Aluminum site in Hancock County,
     Kentucky.

          KDWM concurs with EPA that this action is  a positive effort to
     address contaminant migration,  and  should be implemented as soon as
     possible.   Also, EPA's willingness to  incorporate KDWM's  comments
     into this deliverable is noted and appreciated.   This willingness
     to  acknowledge  the State's  concerns will  undoubtedly  be   the
     cornerstone of a good working relationship on this project.

          If you have any questions or concerns, please  call  me or  Eric
     Liebenauer  at (502) 564-6716.


                                         Sincerely,
                                         Caroline P. Haight, Director
                                         Division of Waste Management
     CPH/EL/kb
                                Printed on Recycled Paper
                         *«*  .  -  .. .-	 r	>...>. xic/u

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