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
-------
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
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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.
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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
-------
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
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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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i;
•4
N
jf
M
jf
j»
:>
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GL
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r*
i
i
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:
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«v
i
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. ..^B...
i_
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^
i
:
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i
— . ^
1
i
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^, ......
*..^.'..«. .... ». .
'' MW-a .^?;
~\
I
i
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-
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(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-
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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
-20-
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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
-21-
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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-
-------
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-
-------
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-
-------
. 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-
-------
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
-------
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).
-28-
-------
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-
-------
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
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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-
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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
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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.
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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
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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.
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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
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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.
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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
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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
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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.
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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.
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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-
-------
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-
-------
(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.
-------
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
-------
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.
-------
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
-------
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.
-------
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.
-------
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
-------
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.
-------
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-
-------
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-
-------
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-
-------
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-
-------
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
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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
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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
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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.
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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
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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).
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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.
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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:
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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
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