Third Report on the Remedial Action to Isolate DDT from
People and the Environment in the Huntsville Spring
Branch-Indian Creek System, in Wheeler Reservoir,
Alabama. Volume 2. Appendices
Published by
U.S. Environmental Protection Agency
Washington, B.C.
September, 2000
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Third Report
on the Remedial Action
to Isolate DDT
from People and the Environment
in the Huntsville Spring Branch-
Indian Creek System
in Wheeler Reservoir, Alabama
Volume 2. Appendices
Review Panel Activities to Administer the
United States v. Olin Corporation Consent Decree
July 1, 1990-April 23, 1999
Volume 2 of two volumes
Published by
U.S. Environmental Protection Agency
Washington, D.C.
September, 2000
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Chairman's Letter
This third report of Review Panel Activities, United States v. Olin
Corporation Consent Decree, July 1, 1990 - April 23, 1999 reflects significant
progress in reducing DDTR levels in fish, water, and sediments. Although the
performance standard has not yet been achieved for all fish, there are numerous
indicators that the Remedial Action continues to reduce DDT exposure to people
and the environment.
This report and appendices (in separate volumes) mark the transition from
planning and constructing a remedy to monitoring changes. In order to fairly
evaluate that change, this report has included all of the post-construction
monitoring (1988-1997) and summaries of earlier decisions by the Review Panel.
The report summarizes RP activities which assure that: data are valid and accurate
for use in evaluating the remedy, sampling is representative of environmental
conditions, and the remedy is operating as anticipated.
This report also marks another important transition. On November 2, 1996,
Ms. Anne Asbell, second chair of the Review Panel, lost her battle with cancer. Ms.
Asbell was more than a thoughtful and tireless leader. She was a teacher and
colleague, who challenged everyone associated with this project to apply their best
talents, collaboratively, to achieve solutions to tough problems. She also reached
out with empathy to the communities affected by this and other environmental
problems in order to understand their needs and concerns.
Again in this phase of the project, the RP has demonstrated the power of
collaboration among federal, local, and state governments and industry to achieve
environmental benefits.
As the new chair, I am heartened by our progress and the continuing
commitment of the Review Panel and Olin to achieve a successful resolution of the
DDT contamination of the Huntsville Spring Branch-Indian Creek system. I am
confident that we will succeed.
Sincerely,
Edward S. Bender, Ph.D.
Chair, Review Panel
(202) 564-6483
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Review Panel Activities HSB-IC System DDTRemedial Action (3rd Report)
Introduction to Volume 2
On May 31, 1983, U.S. District Court Judge Robert B. Propst entered,
as part of an order settling litigation against Olin Corporation, a Consent Decree
(CD) governing remedial action for DDTR contamination in the Huntsville Spring
Branch-Indian Creek (HSB-IC) system. The CD requires Olin to develop and
implement a plan consistent with the goals and objectives of the CD to meet a
performance standard of 5 parts per million (ppm) DDTR in filets of channel catfish,
largemouth bass, and smallmouth buffalo in specified reaches of the HSB-IC
system.
The CD established a Review Panel (RP) with voting members from the U.S.
Environmental Protection Agency (EPA), Tennessee Valley Authority (TVA), U.S.
Fish and Wildlife Service (FWS), Department of the Army (DOA), and Alabama
Department of Environmental Management (ADEM), and non-voting participants
from Triana, Alabama (Triana) and Olin Corporation (Olin). This volume contains
documents that are pertinent to the Review Panel activities during the period July
1990 - April 23, 1999.
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Review Panel Activities HSB-IC System DDTRemedial Action (3rd Report)
Appendices (Volume 2)
Table of Contents
Appendix A. Project Chronology A-2
Appendix B. Consent Decree and Joint Technical Proposal B-l
Appendix C. Review Panel Membership C-l
Appendix D. Inspection Committee Letter D-l
Appendix E. Olin Reports Submitted to the Review Panel E-l
Appendix F. Decision Document No. 8, Groundwater Monitoring,
December 6, 1990 F-l
Appendix G. Decision Document No. 9, Process for Review of Monitoring Data and
Olin Notification of Compliance by the Technical Committee,
January 23, 1992 G-l
Appendix H. Decision Document No. 10, Process for Review of Olin's Notifications
of Continued Attainment by the Technical Committee with three appendices
Finding Continued Attainment for Largemouth Bass for Reaches A, B, and
C, various dates H-l
Appendix I. Decision Document No. 11, Extension of Time for Meeting the
Performance Standard for Channel Catfish and Smallmouth Buffalo,
December 5, 1998 1-1
Appendix J. Joint Petition for Modification of Schedule to Meet Consent Decree
Performance Standards and Court Order Approving Schedule J-l
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix A. Project Chronology
For period May 31, 1983 through April 23, 1999
May 31, 1983 Court approved Consent Decree for US vs Olin Corp
June 14, 1983
January 26, 1984
June 1, 1984
July 14, 1984
August 31, 1984
January 2, 1985
February 5, 1985
July 1, 1985
July 17, 1985
Review Panel established.
Review Panel adopted operating procedures.
Olin submitted remedial action plan to RP.
Public Meeting, Triana, AL, to receive comments on Olin's
Proposed Remedial Action Plan.
RP issued first decision document approving Olin's
Proposed Remedial Action Plan with modifications.
USAGE Nashville District initiated Environmental
Impact Statement Public Scoping Process.
Olin submitted draft permit applications to RP and
permitting agencies (USAGE, USFWS, TVA, Alabama,
and EPA).
Olin submitted: 1) final engineering drawings and
specifications and environmental analysis report; 2)
permit applications to USAGE Nashville District, TVA,
and US FWS; and 3) report on field and laboratory
investigations of the Huntsville Spring Branch-Indian
Creek (HSB-IC) system to the RP.
USAGE Nashville District issued notice of availability of
draft EIS for permitting activities.
A-2
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
August 1, 1985
December 2, 1985
January 11, 1986
January 28, 1986
February 21, 1986
March 1, 1986
March 24, 1986
March 25, 1986
March 31, 1986
April 1, 1986
April 23, 1986
Olin submitted to the RP: 1) remedial action alternatives
report for Lower Reach A (LRA) and 2) interim goals
report.
Department of Army (DA) issued license to Olin for
remedial action construction activities on Redstone
Arsenal.
Olin submitted revised permit applications and detailed
engineering plans to RP, USAGE Nashville District, TVA,
and USFWS.
USFWS issued limited authorization to begin site
preparation and mobilization within the boundaries of
Wheeler National Wildlife Refuge (WNWR).
Final EIS issued by the USAGE Nashville District.
Olin subrnitted special reports: baseline conditions for
water and fish; substitute fish species; long-term data
acquisition program (revised); and interim goals.
Close of public comment period on final EIS.
Alabama Department of Environmental Management
(AD EM) issued 401(a) certification.
Applicable permits issued to Olin.
USFWS issued permit and construction began on Upper
Reach A (URA).
Groundbreaking Ceremony for URA.
A-3
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
July 2-8, 1986
July 16, 1986
September 15, 1986
October 1, 1986
October 2, 1986
October 21, 1986
October 28, 1986
November 18, 1986
November 21, 1986
November 28, 1986
December 1, 1986
RP approved and regulatory agencies modified permits for
relocation of the northern diversion ditch in URA.
HSB diverted to new channel in URA (salient cut opened
June 11 and oxbow cut opened July 16).
Olin submitted preliminary applications for permits on
Lower Reach A (LRA).
USAGE issued public notice of remedial action proposal
for LRA.
Olin, with RP concurrence, committed to start
construction in LRA by December 1, 1986.
Olin issued proposed engineering drawings for the
remedial action in LRA, highlighting areas where
construction activities were proposed prior to December 1.
RP held public meeting at Triana concerning the remedial
action for LRA and RP issued Decision Document 2,
baseline data, substitute species, and interim goals for
fish and water.
AD EM issued 401(a) certification for remedial action in
LRA.
USFWS issued permit for remedial action in LRA.
TVA and USAGE issued permits for remedial action in
LRA.
Construction mobilization began for remedial action in
LRA.
A-4
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
December 9, 1986
January 18, 1987
February 16, 1987
March 18, 1987
April 16, 1987
May 20, 1987
May 20, 1987
July 22, 1987
July 22, 1987
August 19, 1987
September 14, 1987
RP issued Decision Document 3, remedial action plan to
isolate DDTR in LRA and full construction began in LRA.
Construction of diversion structure No. 4 in LRA
completed to elevation 558.
Mechanical excavation of bottom sediments between
HSBM 3.4 and 4.0 in LRA completed.
HSB diverted to new channel in LRA.
RP issued Decision Document 4, report on DDTR in
Reaches B and C of the HSB-IC system.
Revised plan submitted to RP for demobilization following
completion of construction in URA and LRA.
Eight-foot alligator captured in LRA and relocated with
USFWS assistance.
Major construction activities completed; ceremony held at
remedial action site.
RP issued Decision Document 5, substitute species for
largemouth bass.
USAGE Nashville District, issued report of interagency
regulatory committee inspection conducted August 3,
1987; no major deficiencies of permit conditions identified.
RP inspection committee (including representatives of all
agencies) issued report of August 27 inspection to RP
Chair certifying the "as built" remedial action for URA
and LRA meets or exceeds requirements of the decision
documents 1 and 3, plans and specifications approved by
the RP.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
October 14, 1987
October 15, 1987
December 3, 1987
December 3, 1987
January 1, 1988
February 9, 1989
RP Chair transmitted to Olin his concurrence with the
interagency regulatory inspection committee and the RP
inspection committee certification; requested Olin to
submit for a approval a proposed date for completion of
construction and start of the long-term monitoring
program.
Olin transmitted letter to RP Chair proposing January 1,
1988 as the date for the "designated event" signifying
completion of construction and implementation of the
remedy as required by Decision Document 3 and CD,
paragraph 52(j).
RP approved January 1, 1988 as completion of
construction and start of long-term monitoring period;
issued Decision Document 6, long-term monitoring
program for the remedial action in the HSB-IC system.
Howard Zeller announced his resignation as Chair of the
RP, effective December 31, 1987; Anne Asbell appointed
RP Chair effective January 1, 1988; Anne Asbell
requested continuation of the technical committee and
inspection committee. RP adopted a semiannual meeting
schedule in lieu of the quarterly meeting schedule held
through December 3, 1987.
Anne Asbell became RP Chair. Official completion of
construction and beginning of the initial remedy as
required by the Decision Document 3 and CD, paragraph
52 (j).
Olin requested change in the due date for the long-term
monitoring reports from March 1 to April 15 of each
report year.
A-6
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
February 22, 1989
April 14, 1989
June 13, 1989
June 14, 1989
November 21, 1989
December 7, 1989
April 15, 1990
June 11, 1990
June 13, 1990
June 14, 1990
June 25, 1990
RP informally concurred with requested change in due
date for the long-term monitoring report.
Olin submitted long-term monitoring report 1.
Technical Committee, Inspection Committee, and RP
jointly inspected remedial action project.
RP requested Olin and EPA jointly propose data
validation procedures for the long-term monitoring
program.
Olin and EPA proposed long-term monitoring program
data validation; Olin proposed optimum number of fish to
be collected.
RP modified Decision Document 6 to change the due date
of long-term monitoring program reports to April 15.
Olin submitted long-term monitoring program report 2.
Inspection Committee reported on June 13, 1989
inspection of remedial action.
Inspection Committee, Technical Committee and RP
jointly inspected project.
RP issued Decision Document 7, quality assurance and
fish sample size. RP approved termination of the "far-
field" groundwater monitoring program and reduced
frequency of the "near-field" groundwater monitoring
program.
Inspection Committee reported on June 13, 1990
inspection of the remedial action project site.
A-7
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
December 6, 1990
January 23, 1992
July 15, 1993
January 19, 1995
July 20, 1995
May 17, 1996
July 24-25, 1996
March 17, 1997
May 15, 1998
July 23, 1998
Decision Document No. 8 to terminate Technical Proposal
Groundwater Monitoring until Year 10 (1997).
Decision Document No. 9, Process for Review of
Monitoring Data and Olin Notification of Compliance by
the Technical Committee .
Huntsville DDT Project Public Meeting to inform the
Public of the progress toward meeting the performance
standards.
Review Panel Decision Document No. 10, Process for
Review of Continued Attainment defined. Appendix A to
Document Number 10 found that Continued Attainment
had occurred for Largemouth Bass in Reach C.
Finding of Continued Attainment Largemouth Bass,
Reach A and Reach B (Appendices B and C to Decision
Document Number 10).
Report on Interlaboratory Quality Assurance and Quality
Control
Detailed Review of long term monitoring program results
with the Review Panel and Technical Committee
Post Remediation Sediment Investigation - Reach A and
Reach B
Olin proposes a time extension for meeting the
performance standard for channel catfish and smallmouth
buffalo.
Review Panel reviews Olin's proposal for a time extension.
A-8
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
September 15, 1998
October 2, 1998
December 21, 1998
February 3, 1999
February 25, 1999
April 23, 1999
Public meeting on Olin's proposal to extend time to meet
the performance standard for channel catfish and
smallmouth buffalo.
Letter of Inspection Committee on vegetation and
stability of Remedial Action Site through monitoring
period.
RP Decision Document Number 11, to Extend Time for
Meeting the Performance Standard for Channel Catfish
and Smallmouth Buffalo.
Olin submitted interim goals and contingency plans for
Extension Period.
U.S. Department of Justice and Olin jointly petitioned the
court to modify the schedule to attain the performance
standard.
Court Order modified schedule to meet performance
standards.
A-14
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix B. Consent Decree and Joint Technical Proposal
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I
tJ
IN THE UNITED STATES DISTRICT
NORTHERN DISTRICT OF AI
NORTHEASTERN DIVISION
DEC U 19S1
J
UNITED STATES OF AMERICA,
Plaintiff,
v.
OLIN CORPORATION, A Virginia
Corporation
Defendant,
TOWN OF TRIANA
Intervenor. jglj
STATE OF ALABAMA, ex rel.
CHARLES A. GRADDICK, Attor:
General, et al.,
Plaintiffs,
v.
OLIN MATHIESON CHEMICAL
CORPORATION, a Virginia
Corporation,
Defendant. ••
CIVIL ACTION
.NO. CV80-PT-5300-NE
FI
MAY 3 i 1933
UNITED STATES DISTRICT CO'Jr»T
NORTHERN DISTRICT OF ALABAMA v
JAMES L VANDEGHIFT, CLERK
CIVIL ACTION
NO. CV79-PT-5174-NE
CONSENT DECREE
The undersigned have agreed and stipulated that a
judgment can be entered in these actions incorporating a settlement
agreement Containing terms and conditions which include those set
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forth in this Consent Decree. The parties to this Consent Decree
have agreed to its terms conditional upon the filing and-approval by
the Court of.the overall settlement of this case and related cases.
The Court has reviewed such terms and conditions and has determined
that they are reasonable and adequate to resolve the issues raised
in these actions arid constitute appropriate relief, including:
development and implementation of remedial action to achieve the
performance standard and to isolate DDT from people and the
environment in the area of the Huntsville Spring Branch ("HSB") -
» , •
Indian Creek ("1C") tributary system of the Tennessee River ("TR")
("HSB-IC System"); provision of health care and monitoring to
Claimants; and mitigation of adverse environmental effects. The
Court, having subject matter jurisdiction in these actions,
NOW, THEREFORE, ORDERS, ADJUDGES, AND DECREES AS FOLLOWS:
INTRODUCTION
••"••-. • 1'.- -•••;rThe.;pajrties- to •'this'Consent- Decree are:
(a) United States of America, on behalf of all federal
agencies, departments and other: entities-thereof (all collectively
referred to as the "United States");
. (b) Olin Corporation, a corporation organized and
existing under- the laws of the Commonwealth of Virginia with its
principal place of business in Stamford, Connecticut ( "Olin"); and
(c) State of Alabama, on behalf of all branches
agencies, departments, establishments, instrumentalities, bureaus,
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subsidiaries/ boards or commissions and any other entity of the
Government of the State of Alabama (all collectively referred to as
the "State")..
The terms of this Consent Decree shall bind the parties hereto and
their successors and assigns.
2. The HS3 enters Redstone Arsenal ("RSA") from the City of
Huntsville, Alabama. It flows through RSA and the Wheeler National
I
Wildlife Refuge and converges with 1C at HSB Mile ("M") O.O. 1C
flows into the TR near Triana at TRM 321 (ICM 0.0). For purposes of
this Consent Decree, the HSB-1C System is defined as that portion of
HSB beginning at HSBM 5.4 to HSBM 0.0, and that portion of 1C from
ICM 5.6 to ICM 0.0. The HSB-IC System is depicted on the Figure
attached hereto as Exhibit"A.n In the "Engineering and
Environmental, Study of DDT Contamination of Huntsville Spring
Branch/ Indian Creek and Adjacent Lands and Waters/ Wheeler
Reservoir/ •Alabama"' Vols.' 1-3",1'"November, 1980,' by Water and Air
Research, Inc. ("W.A.R. Report")/ the HSB-IC System is divided into
three reaches: Reach A-/ Reach B, and Reach C. Reaches A/ B/ and C
are defined in the W.A.R. Report as follows:
Reach A - Begins at HSBM 5.4 and extends to HSBM 2.4;
Reach B - Begins at HSBM 2.4 and extends to HSBM 0.0; and
Reach C - Begins at ICM 5.6 and extends to ICM 0.0.
For the purposes of this Consent Decree/ Reaches A/ B and C are
defined as they are in the W.A.R. Report.
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3. DDT is defined for purposes of this Consent Decree as:
1,1,l-trichloro-2,2-bis-(p-chlorophenyl) ethane, including - its
isomers, and the degradation products and metabolites DDD or TDE
(I/l-dichloro-2,2r-bis (p-chlorophenyl) ethane), and DDE (1,1-
dichloro-2,2-bis (p-chlorophenyl) ethylene), and the isomers
thereof..
*
4. The United States filed a Complaint on December 4, 1980 and
an Amended Complaint on February 5, 1982. The United States'
complaint as amended alleges an imminent and substantial
endangerment to human health and the environment as a result of
Olin's alleged discharge of DDT into the waters of the United
States, the Wheeler National Wildlife Refuge, and the environment
«
from a former manufacturing plant -located at RSA in northern
Alabama, and seeks appropriate relief ..under federal statutory law
and under common law. The State filed a complaint and amended
complaint alleging-thesre'aamd-facts and seeks relief similar to that
requested by the United States. Olin filed answers and motions to
dismiss and denied liability in these actions.
5. To resolve this matter constructively, to avoid prolonged"
litigation, to permit efficient implementation of the remedies to be
performed pursuant to this Consent Decree, to provide health care
and monitoring to Claimants, and to further the public interest, the
United States, Olin, and tha State, have agreed to forego their
respective claims, allegations, responses and defenses to these
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actions and to enter into this Consent Decree. This Consent Decree
is part of an overall settlement of the following claims and
actions:
a. James Cloud/ et al. v. Olin Corporation,
In the United States District Court for
the Northern District of Alabama,
Northeastern Division, Civil Action File
No. CV79-PT-5128-NE;
*
b. Marvelene T. Freeman, et al. v. Olin
Corporation, In the United States
District Court for the Northern District
of Alabama, Northeastern Division, Civil
Action File No. CV80-FT-5057-NE;
«
c. , Erskine Parcus, et al. v. Olin
Corporation, In the United States
District Court for the Northern District
of Alabama, Northeastern Division, Civil
Action File No. CV80-PT-5098-NE;
d. State of Alabama ex rel Charles A.
Graddick, Attorney General, Charles A.
Graddick, Attorney General v. Olin
Corporation, a Virginia Corporation, In
the United States District Court for the
Northern. '.District . of Alabama,
.-"•«• *-•* Northeastern Divisiotr;;C±vir Action File
No. CV79-PT-5174-NE;
e. United States of America v. Olin
Corporation, ji Virginia Corporation, In
the United States District Court for the
Northern District of Alabama,
Northeastern Division, Civil Action File
No. CV80-PT-5300-NE;
f. Annie Mae Char eat, et al. v. Olin
Corporation, a Virginia Corporation, et
aJL., In the United States District Court
for th« Northern District of Alabama,
Northeastern Division, Civil Action. File
No. CV81-PT-5367-NE; and
g. Administrative tort claims filed against
the United States relating to, among other
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things, DDT, allegedly discharged into
the waters of the United States, the
Wheeler National Wildlife Refuge, and the
environment in the vicinity of RSA in
northern Alabama.
6. The parties to this Consent Decree have agreed to its terms
conditional on the filing with and approval by the Court of the
overall settlement, including this Consent Decree. The public
• .
notice requirements of 28 C.F.R.§50.7 will be complied with/ and
this Consent Decree is to be entered only after the provisions of
that regulation have been met. , '.
PURPOSE OF THE- CONSENT DECREE
7. The purpose of the remedy(ies), monitoring and other
actions which Olin is required to perform under this Consent Decree
is to isolate DDT in the HSB-IC System from people and the
environment 'and to minimize transport of DDT out of the HSB-IC
System to. protect human health and the environment.
REMEDIAL ACTIONS
8. Olin shall implement remedial actions required by this
Consent Decree and consistent with the "Joint Technical Proposal to
Implement Remedial Activities Pursuant to Consent Decree" (the
"Proposal", Exhibit "B" hereto).
9. Olin shall develop remedy(ies) pursuant to the requirements
of this Consent Decree to achieve and continue to achieve the
performance standard under the terms of this Consent Decree.
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10. Olin shall conduct monitoring studies of fish, water,
sediment, and sediment transport, as set forth in the Proposal and
pursuant to this Consent Decree, to obtain baseline data and ,to
evaluate the effectiveness of the remedy(ies). Olin shall also
conduct studies of groundwater as set forth in the Proposal.
Selected monitoring activities will continue beyond the time for
*
attainment of the performance standard.
11. The baseline monitoring program is to begin no later than
the date of entry of this Consent Decree.
PERFORMANCE STANDARD
12. The performance standard is a DDT level of 5 parts per
million ("ppm") in the fillets of channel catfish/ largemouth bass
and smallmouth buffalo, in Reaches A/ B, "arid C. "Methods for
measuring DDT. levels in..fish-are set forth in. the Proposal. In the
event that one of the three fish species identified above cannot be
obtained in any'one'of" the'Reaches r Olin and-the'RP shall agree upon
one or more substitute fish species for that Reach. In the event of
a disagreement/ the RP shall designate such substitute fish species.
GOALS AND OBJECTIVES
13. The performance standard shall be achieved consistent with
the following Goals and Objectives: • '
a. Isolate DDT from people and the environment in
order to prevent further exposure;
b. Minimize further transport of DDT out of the
HSB-IC System;
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c. Minimize adverse environmental impact of
remedial actions;
d. Mitigate effect of DDT on wildlife habitats in
the Wheeler National Wildlife Refuge;
e. Minimize adverse effects on operations at RSA,
Wheeler Reservoir, and Wheeler National
Wildlife Refuge;
f. No increase in flooding, particularly at City
of Huntsville and RSA, except those increases
in water levels which can be reasonably
expected in connection with the implementation
of remedial action, provided Olih takes all
reasonable steps to minimize or prevent such
increase; and
«
g. Minimize effect on loss of storage capacity for •
power generation, in - accordance with the
Tennessee Valley Authority Act ( "TVA Act").
REVIEW PANEL
14. A Review Panel -("RP"-)- ±s~to- be established' promptly
consisting of members designated by each of: United States Fish and
Wildlife Service, TVA, EPA, the United States Army, and the State.
The Town of •Trianay''Alabama' ancT Olin" shall'serve as non-voting
participants on the RP. An EPA representative 'shall be the
chairperson of the RP. .The RP shall meet semi annually and may hold
special meetings as appropriate. The decisions of the RP shall be by
majority vote of the members, and the RP shall establish its own
operating procedures. The members of the RP shall have the right to
deliberate in sessions restricted to members only. Each entity
appointing a member to the RP shall be responsible for its own
expenses in connection with its respective member's service on the
RP.
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15. The RP shall review the data collected pursuant to the
Proposal and this Consent Decree and Olin's proposed remedy(ies).
In proposing and reviewing the initial remedy pursuant to the
Consent Decree, Olin and the RP shall act in good faith, shall fully
cooperate/ and shall use their best efforts to agree upon an initial
remedy consistent with this Consent Decree. Pursuant to the
schedule in this Consent Decree, the RP shall either approve Olin's
proposed initial remedy, monitoring plan, and construction and
implementation schedule, subject to compliance with applicable law;
« . ,
disapprove the proposed initial remedy and monitoring plan, and,
pursuant to a designated schedule, require submission of a modified
remedy and monitoring plan with a schedule for construction and
implementation; •or 'designate a substitute remedy and monitoring
plan with a. schedule for construction and implementation.
16. If the RP determines, pursuant to paragraph 20 below, that
a'modification to" the"'remedy 'implemented by Qlin is necessary, it
•
shall specify a schedule for Olin's submission of such modification.
Olin shall submit such modifications in accordance with the
schedule, and thereafter the RP shall follow the procedure specified
in paragraph-15.
17. Olin must implement the remedy(ies) approved or designated
by the RP pursuant, to the schedule for. construction and
implementation of the remedy (ies) or seek relief from the Court
pursuant to paragraph 22 below.
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18. Olin shall submit quarterly reports of its monitoring data
to the RP- and reports relating to the development of significant
information in a format to be agreed upon by the RP and Olin. The
quarterly reports .shall include, at a minimum, a summary of the data
collected and the raw data. Olin shall also submit a quarterly
report of its progress in meeting the schedule for construction and
*
implementation of the remedy(ies) undertaken pursuant to this
Consent Decree.
19. Interim goals to indicate progress toward attainment of
« ' t
the performance standard will be set pursuant to paragraph 29 below,
after selection of the initial remedy.
20. The RP'shall, semiannualIy7 review the monitoring data
gathered pur suan.t_to~the-. Proposal and this Consent Decree and the
remedy(ies) implemented, shall compare the data to the interim
goals, and shall determine whether Olin is making appropriate
progress.-in :meeting- the-performance standard. The RP shall
determine whether .a. remedy (ies) or remedy implementation is
inadequate and if it determines that a modification of the remedy is
(
necessary, it shall act in accordance with paragraph 16 above.
21. In determining whether remedial actions are appropriate,
•
the RP shall consider the following factors:
\
(a) The nature of the endangerment to human health and
the environment which the remedial action is
designed to address;
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(b) The extent to which implementation of the remedial
action would reduce or increase endangerment to
human health or the environment, or would otherwise
affect human health or the environment;
(c) Whether implementation of such remedies is
unnecessary to satisfy or is inconsistent with the
Coals and Objectives set forth in paragraph 13
herein, and the performance standard; and
(d) Whether the remedy chosen is the most cost-effective
means of accomplishing the performance standard.
JUDICIAL REVIEW
22. Olin shall be required to implement the remedial actions
required-by-the RP unless, upon petition by Olin, the Court
determines,.,upon the evidence; .. . . . ..
(a) That implementation of such remedy(ies)
••-'"•• "-' •••'••"• Is •'" unnecessary'' to"" satisfy or is
inconsistent with the Goals and
f
Objectives set 'forth in paragraph 13
herein, and the performance standard; or
(b) that considering: .
(i) The nature of the endangerment to
human health, or the environment which the
remedial action is designed to address;
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(ii) The e-xtent to which implementation
of the remedial action would reduce or
increase endangerment to human health or
the environment, or would otherwise
affect human health or the environment;
and
•
(iii) Whether the remedy(ies) chosen is
the most cost-effective means of
accomplishing the performance standard,
«
it would be arbitrary or capricious to require Olin to implement the
remedy(ies).
•
SCHEDULE FOR REMEDIAL ACTION DEVELOPMENT
23. By June 1, 1984, Olin shall complete the necessary
monitoring, studies outlined in the Proposal, shall submit the data
gathered pursuant thereto, and shall specify an initial remedy to
the RP. Olin* ai proposal for an initial remedy shall include a
• •
schedule for implementation, a monitoring plan, and the other
information required in paragraph 52 below.
24. By September 1, 1984, the RP shall take action in
accordance with paragraph 15.
25. Olin shall complete construction and implementation- of the
•
initial remedy and any subsequent remedies.required under this
Consent Decree pursuant to the schedule established under
paragraph 15.
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26. Within 10 years from the date of "completion" of the
construction and implementation of the initial remedy (as that event
is determined pursuant to paragraphs 15 and 52(j)), Olin shall
attain the performance standard in Reaches A, B, and C. The
definition of "attain the performance standard" is set forth in the
Proposal in Section 7.0.
27. After attainment of the performance standard, Olin shall
demonstrate "continued attainment of the performance standard".
'The definition of "continued attainment of the performance
•• *
standard" is set forth in the Proposal in Section 7.0.
t 28. Once Olin attains the performance standard, it shall
operate or maintain, as necessary-, any remedy(ies) (including bird
repelling• devices) implemented pursuant to this Consent Decree
until termination; of. the- Consent Pecree pursuant to paragraph 54
below.
29.' To" evaluate Oiin's progress toward attaining the
performance standard within the schedule set forth'in paragraph 26,
interim performance .goals shall be established. Interim
performance goals will be agreed upon by Olin and the RP; .in the
unlikely event that. Olin and" the RP cannot agree on" interim
«
performance goals, the RP shall set such goals after selection, and
approval of the initial remedy. The interim performance goals shall
be expressed in terms of reductions of DDT levels or particular
ranges of DDT levels'in fish fillets, as specified in paragraph 12
above, for certain time periods,.
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FINANCIAL SECURITY
30. If at any time prior to the completion of construction and
implementation of the initial remedy and any subsequent remedy(ies)
required under this Consent Decree, (i) the consolidated net worth
of Olin declines by fifteen percent (15%) or more in any one fiscal
quarter, or (ii) over a period of three consecutive fiscal quarters
•
the consolidated net worth of Olin declines by a total of fifteen
percent (15%) or more as compared with the consolidated net worth of
Olin as of the beginning of the first of such quarters, or (iii) if
the consolidated net worth of Olin declines by fifteen percent (15%)
or more in any one fiscal year, or (iv) if the consolidated net worth
••
of Olin declines at any time to five hundred million dollars
• .
($500,000,000) or below, Olin shall immediately notify the United
States and shall promptly provide security in an amount equal to one
hundred and twenty-five percent (125%) of the estimated cost to
complete- such construction-and. 'implementation-. If- such event occurs
prior to the identification and estimation of the cost of the
initial remedy (ies), the amount of such security shall be twenty
million dollars ($20,000,000). Such security shall take the form of
a first lien on.valuable assets, a performance bond, a surety bond, a
•
letter of credit or a cash bond. The parties may hereafter agree
upon other forma of similar security. If at any time the United
States believes the foregoing "net worth" test is insufficient
security for- Olin*s performance under the Consent Decree, it may
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petition the Court to order Olin to produce the. security set forth
above.
INSURANCE
31. .Olin agrees to be responsible for-the'liability arising
from its acts and omissions occuring during the term of this Consent
Decree. Olin agrees that it, and independent contractors employed by
it to perform any work pursuant tp. this Consent Decree, shall
maintain for the duration of this Consent Decree general liability
and automobile insurance with limits of ten million dollars
($10,000,000) combined single limit, with no sudden and accidental
+
pollution exclusion clause, and Alabama Statutory Workmans
Compensation Insurance. Olin and independent contractors employed
by it further -agree to perform all work pursuant to this Consent
Decree in-a workmanlike manner.-.": ' v; ' : -: ....'-.-
. DELAY OR PREVENTION OF PERFORMANCE
32. Olin shall take all reasonable measures to minimize or
avoid any delay or prevention of the performance of its obligations
pursuant to this Consent Decree. If any event occurs, or if Olin
anticipates that an event will occur, which would delay or prevent
the performance.of Olin1s obligations pursuant to this Consent
Decree ("Delaying Event"), Olin shall notify the United States
Program Coordinator in writing as soon thereafter as possible, but
in no event later than 20 days after becoming aware of such Delaying
Event. The written notice shall fully describe the actual or
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anticipated length and cause of such Delaying Event, the actions
Olin has taken, and proposes to take, to prevent and to minimize the
impact of the Delaying Event, and the schedules for taking such
actions.
33. To the extent that Delaying Events have been or will be
caused by force majeure, i.e., acts of God, strikes, fires, war, or
*
other causes beyond Olin's control, the time for performance
hereunder shall be extended as appropriate. Increased costs or
expenses associated with the implementation of actions required by
this Consent Decree shall not alone be considered a force majeure
evervt.
34. If the United States and Olin agree on the occurrence and
length of a Delaying Event, they shall file with this Court, a
stipulation and'proposed ; order "-extending the time for Olin to
perform the activit:y(ies) affected, by the Delaying Event. If,
however, Olin and the United States do not so stipulate or the United
States advises Olin in writing that it does not agree that a Delaying
Event occurred or to the extension of time sought by Olin, either
Olin or the United States may submit the matter to the Court for
resolution. Olin shall have the burden of proof, based upon a
preponderance of the evidence, (i) that the Delaying Event excused
or extended the time for Olin's performance under the terms of this
paragraph and (ii) that the time extension sought is appropriate.
Any extension of the schedule for performance of an intermediate
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requirement agreed or ordered pursuant to this paragraph shall not
result in the automatic extension of a subsequent requirement.
35. If a Delaying Event is not excusable under the terms of
this Consent Decree or if after an excusable Delaying Event occurs/
the time extension sought by Olin is unjustified, Olin shall be
subject only to the following stipulated penalties for such
unexcused failure to comply with the following paragraphs of this
Consent Decree:
A. Paragraphs 16 and 18
4 ,
(i) Fifty dollars ($50) per day for the
first fifteen days; and
(ii) Two hundred fifty dollars ($250) per day thereafter.
*
B. Paragraphs 23', 25, 27, 28, and 41
• (i) Five hundred dollars ($500)
•-..-• ... - ...•••. 'per day- for the•.•.-.first fifteen
days;
(ii) Seven hundred fifty dollars .($750)
per day for the sixteenth to
ninetieth days; and
(iii) Up to twenty five hundred dollars
($2500) per day thereafter.
C. Paragraph 26 ...
(i) One thousand dollars ($1000) per day
for the first sixty days; and
(ii) Up to five thousand dollars ($5000)
per day thereafter.
36. In determining the amount of any penalty which the United
States seeks to assess under subparagraphs 35.B. (iii) andC.(ii),
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the United States shall consider the economic savings, if any, to
Olin for its delay or failure to comply with such paragraphs, the
degree or seriousness of the delay or non-compliance, the duration
~s'
of the delay or non-compliance, the degree of endangerment to human
health or the environment, if any, resulting from the delay or non-
compliance, and other relevant factors. Provided, however, that no
•
payment shall be assessed for each day that compliance is delayed or
excused pursuant to this Consent Decree, or by order of the Court.
37. If the United States seeks to assess penalties pursuant to
paragraph 35 of this Consent Decree, it shall give written notice to
Olin.of the requirement with which Olin has not timely complied or
has failed to comply, the amount of the proposed penalty and, in the
case of penalties to be assessed pursuant to subparagraphs
35;B. (ill) and C.(ii-)i .-thar basis for. such, amount, taking into
account the factors set forth.in paragraph. 36. Such notice from the
United States shall be a condition precedent to the United States'
right to seek enforcement of such penalty assessment under paragraph
-I
38 of this Consent Decree. Within ten (10) days of its receipt of
such notice, Olin shall notify the United States whether it agrees
to pay such proposed penalty. If Olin agrees to pay such penalty, it
shall do so within twenty (20) days from receipt of such notice by
check payable to the Treasurer of the United .States and sent to the
Assistant Attorney General at the address specified in paragraph 51.
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38. If the United States and Olin do not agree to the amount of
the penalty which the United States seeks to assess against Olin,
the United States may petition the Court to enter judgment against
Olin for the amount of the penalties it seeks" hereunder. The
foregoing petition by the United States shall set forth the
requirement with which Olin has failed to comply, shall propose
*
amounts to be paid and, in the case of penalties sought pursuant to
subparagraphs 35.B..(iii) and C.(ii), the basis for such proposed
amounts, taking account of the factors set forth in paragraph 36 of
this Cons'ent Decree. The United States shall have the burden of
•*>
proof, by a preponderance of the evidence, that the amounts of money
it seeks under subparagraphs"35.B.(iii) andC.(ii) are justified;
the United States shall have no burden-of-proof with respect to the
stipulated penalties set forth in subparagraphs 35.A., 35.B.(i),
(ii), and35.C.(i).
39. Any penalty •payments made or collected pursuant to
paragraphs 35 through 38 shall be payable only to the United States
and shall be in full satisfaction of all civil claims by any party or
the Town of Triana, Alabama for fines, penalties, or other monetary
assessments arising out of Olin's failure to comply with this .
Consent Decree, except those.specific monetary obligations imposed
pursuant to paragraphs 41, 42 and 43. Olin shall be subject to civil
fines, penalties; or other monetary assessments arising out of its
i
failure to comply with 'this Consent Decree only as provided in
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paragraph 35. Notwithstanding anything in this Consent Decree to
the contrary, the provisions of paragraphs 35 through 39 shall not
be construed.to limit any equitable or other non-monetary relief
which may'be available to the United States for violations of this
Consent Decree or bar the United States from seeking any appropriate
relief, equitable, monetary or otherwise, which may be available to
the United States for violations of law arising during and in
connection with Olin1 s performance under this Consent Decree.
40. If Olin and the United States agree that Olin has acted in
« ,
good faith consistent with the schedule set forth in this -Consent
Decree but has failed to meet the performance standard within the
time set forth herein, Olin and the United States shall agree to an
extension of time for meeting the performance standard, shall
jointly petition the Court for a modification of the schedule and
Olin shall not be liable for penalties set forth in paragraph 35
•.*"* "•'• ^ ' ' - "
based solely on its failure to meet'the performance standard within
the time required during such extended period. In the event of a
disagreement concerning whether Olin has acted in good faith, Olin
shall have the burden of proof, by a preponderance of the evidence,
that it has acted in good faith.
REMEDIAL ACTION MITIGATION MEASURES
41. Olin agrees to install and maintain bird repelling
measures or bird repelling devices'as required by remedial actions
undertaken pursuant to this Consent Decree. Olin further agrees
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upon entry of this Consent Decree to pay into a trust fund the sura of
$375,000 fo-r the purpose of funding mitigation measures (such as
studies or structures) to be selected by the United States in
furtherance of the goals of the statutes cited in the first amended
complaint of the United States in the above-styled action.
EXPENSES
•
42. Olin shall bear the reasonable expenses incurred by the
United States for contracts to monitor Olin's activities, including
data collection and analysis, in connection with this Consent
Decree. From and after the date.of entry of this Consent Decree,
Olin shall bear, without its prior approval, such expenses in an
amount not to exceed $10,000 per year until it demonstrates
continued attainment of" the performance standard as provided for
herein with. prior:notice of such expenditures to be given to Olin.
Upon request of Olin, the United States shall provide a brief
description of the work to be performed under contracts entered into
pursuant to this paragraph and substantiation for the expenses
thereof. In any event,' if the Government does not expend the sum of
$10,000 in any one year, the Government may not carry over such
unused sums in any subsequent' year, it being expressly understood
that Olin's obligations under this paragraph are limited to a total
of $10,000 per year. Olin shall reimburse such expenses in excess of
$10,000 per calendar year only if ii: has given prior approval to such
expenditures. .
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43. In addition, Olin agrees to pay for the cost of developing
any environmental impact statements or environmental assessments •
which nay be required pursuant to NEPA in order to implement any
remedies under this Consent Decree.
EMPLOYMENT PREFERENCE
44. Olin agrees to give employment preference (consistent with
*
applicable law) for all work related to development and
implementation of this settlement including, but not limited to,
construction work, to "Claimants," as-the term i-s defined in the
"Comprehensive Agreement Regarding Compromise of Claims" and to
anyone else who resides in the immediate area of Triana, Alabama who
agrees to sign a release and waiver of any liability against the
United St"atesF~and Olin, arising from- the presence of DDT in the HS3-
IC System. The parties hereto do not intend this paragraph to create
and the provisions, .of this paragraph shall not create any
enforceable rights of action or any remedies on behalf of either the
parties to.this Consent Decree or individuals or entities who are
not parties to this Consent Decree.
INSPECTION
45. The United States, the State, and their agencies and
authorized representatives, including contractors and consultants,
shall, upon notice, be provided reasonable access at all times to
the site of any actions taken within the HSB-IC System pursuant to
this Consent Decree to observe and monitor the work performed by
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Olin, to collect samples, to inspect records and for any other
lawful purpose relating to assuring compliance by Olin with the
terms of this Consent Decree. Nothing in this paragraph is intended
to limit any other lawful rights of Access or inspection which the
United States or the State of Alabama may have with respect to the
site or to affect the right of the United States Army to restrict
access as necessary. •.
EFFECT OF CONSENT DECREE
46. Nothing contained in this Consent Decree shall constitute
an admission of law or fact or may be introduced into evidence as
proof of same, or constitute proof of the violation of any law or
regulation. The parties hereto may rely upon this Consent Decree
-only-in- this" action or-in'any of the other actions listed in
paragraph .5, above. The parties hereto may not rely upon this
Consent Decree in any other action or proceeding, and neither this
Consent Decree nor any part hereof may be introduced into evidence
in any other action or proceeding. Except for the'right of the Town
of Triana, Alabama to enforce this Consent Decree, as provided in an
order entered contemporaneously herewith, it is intended that this
Consent Decree shall neither create nor have any effect upon rights
of persons or entities not parties to this Consent Decree.
PROGRAM COORDINATOR.
•47. The United States and Olin. shall each designate a program
coordinator and an alternate within 15 days following the date of
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entry of this Consent Decree. -At any time, Olin and the United
States may appoint new coordinators, alternates or both, and notice
thereof shall be given in writing.
48. Olin and the United States intend that communications
between them to carry out the terms and conditions of this Consent
Decree shall be by and between the program coordinators or
* ,
alternates. The -coordinators designated by the parties shall be
deemed agents for purposes of receiving proposals, reports and
notifications from other parties, except that the coordinators
« f
shall not constitute agents for the purpose of receiving service of
process, subpoenas, or other judicial or administrative process,
and each coordinator shall be responsible for assuring that all
communications from the other are appropriately disseminated and
processed.. :••.>• . v- •" "• •..••'.-.. .:'. • -,:- -.-..-• • . • .
COMPLIANCE WITH ALL LAWS
49. All work undertaken pursuant to this Consent Decree is to
be performed, in accordance with all applicable federal, state and
local statutes, regulations, ordinances and permits, including, but
not limited to the following statutes which may be applicable to the
work undertaken pursuant to this Consent Decree: the National
Environmental Policy Act, 42 U.S.C. §§4371, et seq., the Fish and
Wildlife Coordination Act, 16 U.S.C. §§661-666c, the Endangered
Species Act, Pub. L. No. 93-205, 87 Stat. 884. (codified as amended in
scattered sections of 7 and 16 U.S.C. ), the National Wildlife Refuge
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System Administration Act, 16 U.S.C. §§668dd-668ee> the Tennessee
Valley Authority Act, 16 U.S.C. §831 as amended by Pub. L. No. 96-97,
93 Stat. 730, the Clean Water Act, 33 U.S.C. §§1251 et seq., the
Resource Conservation and Recovery Act, 42 U.S.C. §§6901 et seer..
the Comprehensive Environmental Response, Compensation and
Liability Act, ("CERCLA"), 42 U.S.C. §§9601 et seq., the
•
Occupational Safety and Health Act, 29 U.S.C. §§651 et seo;., the
Hazardous Waste Management Act of 1978, Code of Ala. 1975, §§22-30-1
et sea;. (1982 cum. suppi), the Alabama Water Pollution Control Act,
• « •
Code of Ala. 1975 §§22.22-1 et sea. (1982 cum. supp.), and all
applicable regulations promulgated thereunder, including without
limitation, the revised National Contingency Plan, 40 C.F.R. Part
300 et seo;., as published in 47 Fed. Reg. 31180 (July 16, 1982).
Olin. shall.apply for. and use .its best.efforts to obtain any permits
or authorizations required by applicable federal, state or local law
in carrying out the work required of Olin under this Consent Decree.
EXPENSES UNDER CERCLA
50. In consideration of the entry of this Consent Decree, Olin
agrees not to make any claims pursuant to Section 112 of CERCLA, 42
U.S.C. §9612, against the Fund established by that Act for expenses
related to this case and this Consent Decree.
NOTICES
51. All notices and documents required to be provided to the
United States, Olin and the State pursuant to this Consent Decree,
i
unless otherwise stated, shall be addressed as follows:
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Assistant Attorney General
Land and Natural Resources Division
Department of Justice
9th & Pennsylvania Avenue, N.W.
Washington, D.C. 20530
United States Environmental Protection Agency
Regional Administrator
Region 4
Atlanta, CA 30309
State of Alabama
Attorney General
250 Administrative Building
Montgomery, Alabama 36130
Olin Corporation
120 Long Ridge Road
Stamford, CT 06904
DOCUMENTS
52. In submitting its initial proposed remedy and any
subsequent or modified remedies to the RP, Olin shall submit, in
addition to the other information required by this Consent Decree,
at-a minimum the following information:
(a) References to all scientific and/or technical
literature used in preparation of the remedy;
(b) Engineering diagrams, chemical analyses, and all
other technical data used in proposing the remedy;
(c) Names, titles and disciplines of 'all professionals
engaged in preparation of the remedy;
(d) A description of all analytical techniques and
protocols used in preparing the remedy;
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(e) Anticipated effects-on people and the environment of
any actions to be implemented under the remedy, including, as
applicable, the information described in section 8 of the Proposal;
(f) Cost and time to implement the proposed remedy(ies);
(g) A discussion of all alternative remedies examined but
rejected including, where developed, cost, time to implement, and
•
other data and the reasons for concluding that each alternative
remedy is not necessary or appropriate to attain the performance
standard;
(h) A specific monitoring plan for determining the
•
efficacy of the remedial action implemented, including monitoring
activities continuing beyond the time for attainment of the
performance standard;
...-•/.: V: C'i-X-- Any. heiltlx-and:; safety'plans required by law to
implement the remedy (ies);
'•-"..»•.
(J) Construction and implementation schedules, including
a schedule for the development and submission of detailed
engineering specifications and a designation of the event which
signifies "completion" of construction and implementation of the
initial remedy; and
(k) The assumptions on which the remedy (ies) are based.
RETENTION OF JURISDICTION
t
53. This Court retains jurisdiction over the parties to this
Consent Decree to enforce compliance with its terms, to construe the
-27-
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Consent Decree, and to resolve disputes in accordance with its
provisions.
TERMINATION OF CONSENT DECREE
54. After Olin (1) demonstrates to the RP continued attainment
of the performance standard and (2) demonstrates to the reasonable
satisfaction of the RP that the remedy(ies) implemented pursuant to
this Consent Decree has provided, is providing and will continue to
provide achievement of the performance standard once this Consent
Decree terminates, Olin shall operate or maintain such remedy(ies),
as set forth in paragraph 28, for a period of seven additional
years. At the conclusion of this seven year period, if Olin is in
compliance with the provisions of this Consent Decree and the
performance standard, Olin shall be deemed to have completely
fulfilled all of its obligations hereunder, and this Consent Decree
shall terminate.' " .
'• ' • ' . '- MISCELLANEOUS PROVISIONS
55. All information and documents submitted by Olin to the
United States, State or RF pursuant to this Consent .Decree shall be
i
subject to public.inspection.
56. The terms and conditions of this Conse_nt Decree shall
include the terms and conditions contained in the Proposal attached
hereto, which are incorporated herein by reference.
57v^--ln""the event^ef'changed matej
environmental or/health standards^ arising^af^er the ent£y-tf£ this
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57. In the event of changed .material circumstances of law or
environmental or health standards, arising after the entry of this
Consent Decree, the United States or Olin may petition the Court for
a modification of the Consent Decree.
58. Each party shall bear its own costs, disbursements and
attorneys' fees of this action.
59. The parties represent to the Court that their respective
undersigned counsel and the other signatories have full authority to
approve the terms and conditions of this Consent Decree and to
execute and legally bind the respective parties- to this Consent
Decree.
UNITED STATES OF AMERICA
Deputy Assistant Attorney General
Land and Natural Resources Division
United States Department of Justice
DATED:
DONALDSON
Usu-ted States Attorney
>rthera District of Alabama
DATED
-29-
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HENRY FROSH1N
Firsje^Ass/istant United States
Attot
3D CAMPBELL
:ant United States Attorney
:TH A. REICH
Attorney
United States Department of Justice
DATED:
DATED:
DATED:
/' /
LOIS
Attorney
United States Department of Justice
.DAVID BATSON
Attorney
United States Environmental
Protection Agency
DATED:
DATED:
ARTHUR RAY
Attorney
United.States Environmental
Protection Agency
DATED:
-30-
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ELIZABETH TODD CAMPBELL
'Assistant United States Attorney DATED:
KENNETH A-. REICH
Attorney
United States Department of Justice DATED:
LOIS J. SCHIFFER
Attorney
United States Department of Justice DATED:
DAVID BATSON
Attorney
United'States Environmental '
Protection Agency DATED:
ARTHUR RAY
Attorney
United States Environmental
Protection Agency DATED:
ANNE L. ASBELL x
Assistant Regional Counsel
United States Environmental
Protection Agency
Region IV DATED:
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ANNE L. ASBELL
Assistant Regional Counsel
United States Environmental
Protection Agency
Region IV
DATED:
STATE OF ALABAMA
By
CHARLES A. GRADDICK
Attorney General of the
State of Alabama
R. CRAIG
Assistant Attorney General
State of Alabama
DATED
.4/14&
DATED:
I
OLIN CORPORATION
By:
E. MCINTOSH COVER.,
Group Counsel
Olin Chemicals Group
DATED:
MYRON B. SOKOLOWSKI
Counsel
Olin Chemicals Group
-31-
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STATE OF ALABAMA
By:
CHARLES A. CRADDICK
Attorney Cener&l of the
State of Alabama
DATED:
R. CRAIG KNEISEL
Interim General Counsel
Department of Environmental
Management
DATED:
OLIN CORPORATION
By
£
E. MCI
Group Counsel
Olin Chemicals Group
MYRCNVS. SOKOLOWSKI
Counsel
Olin Chemicals 'Group
''/
/
STUART NX ROTH
Associate Counsel
Olin Chemicals Group
DATED:
-31-
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G. LEE GARRETT/ JR.
Hansel1 & Pps1
Attorneys for Olin Corporation
DATED:
7
Entered in accordance with the foregoing Consent De
11TED STATES DISTRICT
DATED:
-32-
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5 It. top - Hunts,!)).
BMnch. Mttn
U.I ARMY CORK OF ENQINCIM. MOBltC OinfllCT
Inflow*Inf Mid tnvlfoiunMtal Study of DOT Co«t«mln«ll«i
M|| *ml WniMi.
-------
JOINT TECHNICAL
PROPOSAL TO IMPLEMENT
REMEDIAL ACTIVITIES
PURSUANT TO
CONSENT DECREE
-------
TABLE OF CONTENTS
1.0 SUMMARY 1-1
1.1 Background .1-1
1.2 Objectives of This Proposal 1-3
1.3 Proposal Approach 1-4
1.4 Organization of Proposal .* 1-6
2 . 0 NEED FOR REMEDIAL ACTION ALTERNATIVES 2-1
2.1 The W.A.R. Alternatives 2-1
2.2 Environmental Impacts of F* 2-4
2.3 Other Remedial Actions 2-8
3.0 QUALITY "ASSURANCE PROGRAM 3-1
3.1 Introduction .* 3-1
3.1.1 Program 3-1
3.2 Participating Laboratories . ._. . . .3-2.
3.2.1 Primary Laboratory 3-2
/
3.2.2 Secondary Laboratory 3-2
3.2.3 Referee Laboratory 3-3
3.3 Analytical Parameters., 3-3
3.3.1 Biological Samples .-3-3
'3.3.2 Sediment Samples. 3-4
3.3.3 Water Samples. .' 3-5
-------
3.4 Analytical Methodologies. 3-5
3.4.1 Biological Samples 3-6
3.4.2 Sediment Samples 3-6
3.4.3 Water Samples 3-7
3 .5 Intralaboratory Quality Control Plan 3-9
3.5.1 Facilities 3-9
3.5.2 Chain-of-Custody and Sample Handling
and Storage 3-10
3.5.3 Laboratory Personnel and Equipment 3-12
3.5.4 Data Quality Assurance 3-13
3.5.4.1 Precision ,...3-13
3.5.4.2 Accuracy 3-14
3.5.4.3 Sampling Blinding..... 3-15
3.5.4.4 Additional Control Measures;. .. .3-16
3.6 Interlaboratory Quality Control Plan 3-18
^
3.6.1 General Requirements 3-18
3.6.2 Method Equivalency 3-18
/
4.0 FISH STUDIES 4-1
4.1 Introduction 4-1
4.2 Program Objectives 4-3
4.3 Utilization of W.A.R. Data ...4-3
4.4 Program Design 4-4
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4.4.1 Sampling Locations 4-5
4.4.2 Sampling Frequency 4-8
4.4.3 Sampling Protocol 4-9
4.4.4 Analytical Parameters 4-15
4.5 Mechanism of Fish Contamination 4-15
4.6 Utilization of Data Base 4-20
5.0 IN SITU SEDIMENT SAMPLING PROGRAM. . : 5-1
5.1 Introduction 5-1
5.2 Specific Objectives 5-3
5.3 Utilization of W.A.R. Data 5-4
5.4 Program Design 5-6
5.4.1 Sampling Locations 5-6
5.4.2 Sampling Frequency 5-7
5.4.3 Sampling Protocol..A 5-7
5.4.4 Analytical Parameters 5-10
5.5 Utilization of Proposed Data Base 5-11
6.0 SUSPENDED SEDIMENT TRANSPORT/WATER SAMPLING PROGRAM 6-1
6.1 Introduction 6-1
6.2 Specific Objectives 6-3
6.3 Program Design 6-5
. 6.3.1 Sampling Locations " 6-5
6.3.2 Sampling Frequency 6-6
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6.3.3 Sampling Protocol 6-7
6.3.4 Analytical Parameters 6-10
6.4 Utilization of Proposed Data Base 6-10
6.4.1 Computer Modeling of HSB-IC 6-11
7.0 REMEDIAL ACTION APPROACHES 7-1
7.1 Introduction 7-1
7.2 Overview of Action Considerations 7-1
7.3 Long-Term Environmental Monitoring Program 7-3
7.3.1 Groundwater Monitoring 7-5
7.3.2 Measurement of Peformance Standard 7-6
8.0 ENVIRONMENTAL ASSESSMENT OF REMEDIAL ACTIONS 8-1
9 . 0 PROPOSAL TIME FRAME 9-1
10.0 REFERENCES 10-1
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1.0 SUMMARY
1.1 Background
Since 1977, the United States Army, The Tennessee Valley
Authority (TVA), the Environmental Protection Agency (EPA), and
other federal agencies have reported DDT residues* in the Huntsville
Spring Branch-Indian Creek (HSB-IC) tributary system of the
Tennessee River (TR). Reports have described the existence of DDT
within the boundaries of the Wheeler National Wildlife Refuge (WNWR)
and the Redstone Arsenal (RSA) near Huntsville, Alabama.
In 1980, Water and Air Research, Inc. (W.A.R.) completed a
report entitled "Engineering and Environmental Study of DDT
Contamination of Huntsville Spring Branch, Indian Creek and
Adjacent Lands and Waters, Wheeler Reservoir, Alabama" (W.A.R.
* DDT is defined _as 1,1, l-trichloro-2,2-bis-.(p-chlorophenyl)
ethane including its isomers, and the degradation products and
metabolites DDD or TDE (1,l-dichloro-2,2-bis (p-chlorophenyl)
ethane), and DDE (1,l-dichloro-2, 2-bis (p-chlorophenyl)
ethylene), and the isomers thereof.
1-1
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Report) .* W.A.R. links the DDT to the discharge of effluent from the
manufacture of DDT by the Olin Corporation (Olin). The DDT
manufacturing plant operated from 1947 to 1970 on RSA facilities
leased from the United States. W.A.R. states that DDT, discharged
into the drainage ditch, entered the HSB-IC system. W.A.R. now
estimates that 475 tons of DDT presently exist within that system
and estimates that 97.8 percent of the resulting in situ DDT is
contained within HSB miles (HSBM) 5.4-2.4 (Reach A), 1.4 percent
within HSBM 2.4 and its confluence with 1C (Reach B) and the
remaining 0.8 percent within 1C (Reach C).
W.A.R. also states that fish within the HSB-IC-TR system have
exhibited levels of DDT greater than the Food and Drug
Administration action level of 5 parts per'million in the fillet.
DDT in channel catfish, a food source for local residents, has
prompted particular concern.
* 'That report consists of three volumes, viz., an Executive
Summary, App.endices I-JJI, and IV-V-I* References herein-• to
pages in the Executive Summary will appear as "S- ";
references to pages in the appendices will give the appendix
number followed by the page, e.g., "11-77" means page 77 in
Appendix II.
1-2
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1.2 Objectives of This Proposal
The primary objective of the remedy (ies), monitoring and other
actions which Olin is required to perform under this Consent Decree
is to isolate DDT in the HSB-IC System from people and the
environment and to minimize transport of DDT out of the HSB-IC
System to protect human health and the environment. This objective
is met under the terms of the Consent Decree when DDT levels in the
fillets of channel catfish, largemouth bass, and smallmouth buffalo
in Reaches A, B, and C are reduced to 5 ppm, i.e., the performance
standard of the Consent Decree, and the other terms of the Consent
Decree are fulfilled. The overall goals and objectives set forth in
the Consent Decree are as follows:
1. Isolate DDT from people and the environment in order to
prevent further exposure.
2. Minimize further transport of DDT out of the HSB-IC
system.
3. 'Minimize adverse environmental impact of remedial
actions.
4. Mitigate effect of DDT on wildlife habitats in the Wheeler
National Wildlife Refuge.
5. Minimize adverse effects on operations at Redstone
Arsenal, Wheeler Reservoir, and Wheeler National Wildlife
Refuge.
6. No increase in flooding, particularly at City of
Huntsville and Redstone Arsenal, except those increases
in water levels which can be reasonably expected in
connection with the implementation of remedial action,
provided Olin takes all reasonable steps to minimize or
prevent such increase.
7. Minimize effect on loss of storage capacity for power
generation, in accordance with the Tennessee Valley
Authority Act ( "TVA Act" ).
1-3
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The Proposal contemplates use, to the extent possible, of data
collected by W.A.R. Although the W.A.R. Report contains extensive
regional data and can be used to determine certain background
environmental conditions, the environmental characteristics of the
various segments of the HSB-IC system must be defined more
specifically before any remedial action alternative can be
developed. Likewise, the evaluation of the short and long-term
environmental impacts associated with proposed remedial actions
requires a more extensive data base. These studies, combined with
data from the W.A.R. Report, will provide that data base.
1.3 Proposal Approach
This Proposal will investigate the pathways that DDT takes to
enter the water and biota in HSB-IC. The findings of this study will
identify the critical point(s) in the pathways which can be blocked
via specific -remediaj actions applied to the HSB-IC system. In
addition, 'the study will provide the bas,ic design information for
remedial actions (i.e. flow rates, particle size/DDT relationships,
etc.).
. The Proposal has four primary areas of investigation:
suspended sediment transport, in situ sediment sampling, fish
sampling and fish uptake studies. The purpose of each study is to
answer several basic questions concerning the movement of DDT into
the water and the biota. The main questions to be answered are as
follows:
• What is the source of DDT that is available to
contaminate fish or other biota? Is it in the
channel and/or overbank areas? Is it from
Reach A, B, and/or C? Under what conditions is
1-4
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this DDT available (i.e., high or low water
elevations, flow rates, etc.)?
• What is the source of DDT to the water column?
What are the contributions of each reach (A, B,
and C) of the HSB-IC system? Under what
conditions does DDT enter the water column?
Are storms more significant than normal day-to-
day transport?
• Why and how are fish becoming contaminated? Is
it caused by suspended, dissolved or deposited
DDT? What is the effect of siltation and
covering on these sources?
The in situ sediment sampling and suspended sediment transport
(water sampling) studies are designed to address the first two sets
of questions. The fish sampling and fish uptake studies are
designed to answer the third ser of questions.
The data evaluation phase of the project is just as critical as
the data collection phase. The data evaluation phase will utilize
two main tools in addition to normal engineering analysis to aid in
_the decision process for selecting -and development remedial
«f-
actions. The two tools are (1) computer modeling of the system and
(2) the display of significant field data on a topographical map or
aerial..photograph. .... - — •
The computer model will simulate the transport of sediment
through the HSB-IC system. The first step in the modeling process
will be the selection of a computer model which best simulates the
sediment transport process that is occurring in HSB-IC. Data
collected during the in situ sediment and water sampling programs
will be utilized in the computer model and used to verify the model.
Once a computer model has been developed which simulates the HSB-IC
1-5
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system, the model can be modified to include one or more potential
remedial actions. Thus, the effects of potential remedial actions
on sediment and DDT transport can be estimated. Various
combinations of remedial actions can be evaluated by computer
modeling in order to determine the optimum set of remedial actions.
The computer modeling is discussed further in Section 6.0.
; The topographical map or aerial photograph will be used to
provide a visual overview of the HSB-IC system. Areas of DDT which
are available for transport or biological uptake will • be
highlighted. Significant findings of the field data collections
will be illustrated. The locations of potential remedial actions
will also be shown. This map will be a valuable tool in the
development of the remedial actions.
1. 4 Organization of Proposal
This Proposal will discuss the technically-feasible and
environmentally-sound approaches towards resolution of the
following:
• identifying the pathways of DDT contamination
in the given environmental" setiring/"
• evaluating timely, cost-effective remedial
solution(s),
• predicting the environmental effects resulting
from those remedial solutions, and
• proposing a long-term environmental monitoring
program to monitor the effectiveness of future
remedial actions.
Each section will describe the specific objectives of each task
.relative to and associated with the proposal objectives and the
1-6
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methodology utilized "to achieve the proposal objectives. Changes
(with proper approval) may be necessary as the project progresses.
The proposed fish studies are described in Section 4.0.
Proposed sampling locations, scheduling, equipment to be utilized,
fish species to be collected, sample protocol and analytical
procedures are outlined.
The in situ sediment sampling study is set forth in Section 5.0
of the Proposal. This study will provide the more complete and
precise data on the areal and vertical distribution of DDT necessary
to determine types and locations of appropriate remedial actions.
The suspended sediment transport and water sampling study
parameters are set forth in Section 6.0. The results of this study
will provide data on, and permit the prediction of the effectiveness
of, in situ burial/isclation of DDT sediments, as well as quantify
the transport *of DDT through and out of the system.
An extensive quality assurance program has been developed for
both analytical laboratory facilities and field sampling programs.
The major aspects of the laboratory quality assurance^ program will
be the use of a primary laboratory, two secondary laboratories for
split sampling, and a referee laboratory. Approved testing
methodologies, blinding of samples and standard chain-of-custody
procedures will be employed at all times. These procedures are
described in Section 3.0 of the Proposal.
In summary, the Proposal provides for the attainment of the
following:
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(a) Development, of data to define more precisely the
environmental characteristics of the HSB-IC system;
(b) Determination of the biological and geotechnical
characteristics of the HSB-IC system with respect to DDT
(DDT pathways) to design remedial alternatives;
(c) Development of a data base to predict the environmental
and related impacts of the selected remedial
alternatives;
(d) Development of baseline data from which to assess the
effectiveness of the remedial actions selected;
(e) Development and proposal by Olin of specific remedial
actions for all three reaches (A, B, and C); and
(f) Development of a long-term environmental monitoring
program to ascertain the effectiveness of remedial
actions.
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2.0 NEED FOR REMEDIAL ACTION ALTERNATIVES
2.1 The W.A.R. Alternatives
W.A.R. presented seven alternatives (including F*) for
addressing DDT in the HSB-IC system. The no-action alternative
involves natural restoration processes. This alternative requires
** no remedial operations but includes an extensive monitoring program
to evaluate the progress of the natural restoration processes. All
remaining alternatives would involve removal or isolation of
essentially 100 percent of the DDT in the HSB-IC system. These
alternatives, B through F*, include:
• Dredging the entire area and disposing of the
dredged material off-site; or
• Variations of dredging a substantial portion of
the area and diversion of the HSB from its
present basin to the TR (out-of-basin
diversion); or
• Variations of dredging a substantial portion of
the area and diversion of the HSB around much of
Reach A (within-basin diversion).
For both the out-of-basin_and within-basin diversion alternatives..,.
W.A.R. considered removing the DDT sediments or providing in-place
containment of these sediments. The major features of these various
alternatives are outlined in Table 2.1 (taken from the Executive
Summary of the W.A.R. Report). Detailed discussions of these
alternatives are presented in the Summary and Appendix III of the
W.A.R. Report.
2-1
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Table 2;i'-" Alternatives for Mitigation of DDT Contamination
Alternative
Major Actions Implemented
A. Natural Restoration
o let natural processes mitigate contamina-
tion
o extensive monitoring to determine whether
system is improving, remaining stable, or
deteriorating
E. Dredging and Disposal
o construct dredged material disposal area
o dredge channel sediments from HSB Mile 5.6
to 1C Mile 0.0 and 260 acres of overbank
sediments between Dodd and Patton Roads
to a depth of 3 feet
Out-of-Basin Diversion and
Removal of Contaminated
Sediments
o divert HSB upstream from contaminated area
directly to the TR
o implement all actions listed for Alterna-
tive B under reduced flow conditions
Out-of-Basin Diversion
and Containment of Contam-
inated Sediments
o divert HSB upstream from contaminated
area directly to the TR
o construct dikes to isolate contaminated
sediments upstream of Dodd Road from
surface water flow
o construct dredged material disposal area
o dredge channel sediments from Dodd Road
to 1C Mile a.O-to a depth of 3 feet
o cover and stabilize channel sediments
and 250 acres of overbank sediments
upstream of Dodd Road
E. Within-Basin Diversion
and Removal of Contaminated
Sediments
o divert HSB around the highly contaminated
area between HSB Miles 3.9 and 5.6
o construct dike around the highly contamin-
ated area
o implement all actions listed under Alterna-
tive B. Highly, contaminated sediments
would be removed under zero flow or dry
conditions.
F. Within-Basin Diversion
and Containment of Contamin-
ated Sediments
Alternate: Use Containment Area
for Disposal of Dredged Material
o divert HSB around the highly contaminated
area between HSB Miles 3.9 and 5.6
o construct dike around the highly contamin-
ated area
o construct dredged material disposal area
o dredge channel sediments from HSB Mile 3.9
to 1C Mile 0.0 to a depth of 3 feet
o cover and stabilize channel sediments
and 185 acres of overbank sediments within
diked area
o Same as above except dredged material
would be disposed of within the diked highly
contaminated area.
2-2
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The remedial action alternative originally recommended by a
Government/Citizen Advisory Committee was F*. Like Alternative F,
F* involves a within-basin diversion of the HSB between HSBM 5.6 and
3.9 and the containment of DDT sediments located therein. In F*, the
containment area will be used for the disposal of material dredged
from the area between HSBM 3.9 and ICM 0.0.
Table 2.2 (taken from the Executive Summary of the W.A.R.
Report) provides an overview of the predicted effectiveness of the
various alternatives and estimated costs of implementation.
Although W.A.R. predicts that F* would be 99.7 percent effective in
"mitigation" of the DDT, W.A.R. notes there are numerous problems
associated with alternatives which include removing and disposing
of DDT-containing sediments. These problems include (S-51):
Some D3T will remain'aftef dredging,
An undetermined amount of DDT* transport will
occur for an unknown distance during dredging,
and
The potential exists for DDT-containing
materials 'to be "spilled or" leak~e~d~~;du"ring~
removal.
W.A.R. concludes by stating, "dredging and removal can be assumed
somewhat less effective than in-place containment" (S-53). Another
problem with F* and similar alternatives is that the time required
for implementation is long. W.A.R. estimates that 2.5 years would
be required for the engineering and design phase of F* (or similar
alternatives) prior to the initiation of field construction
2-3
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activities. An additional six to nine years would be required for
completion of the work. The implementation timeline for Alternative
F is provided in Figure 2.1 (excerpted from III-124) as a typical
example.
The remedial alternatives proposed by W.A.R. are expensive.
W.A.R. estimates the cost for F* (one of the less expensive
alternatives examined by W.A.R. ) to be $88.9 million. This estimate
may be low considering the implementation timeframe and the extent
of work required.
2 .2 Environmental Impacts of F*
Implementation of any of the action alternatives presented by
W.A.R. would have significant adverse environmental impacts. Table
2.2 provides a W.A.R. overview of predicted adverse environmental
impacts posed by the alternatives it examined.
2-4
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Table 2.2 Estimated Level of Mitigation, Predicted Impacts, and Estimated Costs Associated WHh
Proposed Alternatives.
Alter-
native
A
B
C
D
Estimated % DDTR
Remove
0
99.3
99.3
4.4
Cover
0
0
0
94.9
Total
0
99.3 .
i
99.3
99.3
Predicted Adverse Environmental
. Impacts
(lj ODTR continues, to move down MSB to 1C and the TR
(2) Fish and other biota continue to have elevated ,
DDTR levels
(1) Significantly alter 313 acres wetland, 228 acres-
aquatic habitat
(2| Lose "edge" habitat along dredged stream
(.3) Lose Aufwuch communities and snag habitats In
dredged stream
(.4) Some short-term water quality loss
(1) Significantly alter 684 acres wetland, 495 acres
upland, and 313 acres aquatic habitat
(2) Dredging Impacts (2)-(4) listed under Alternative B
(.3) Increase 1n suspended solids and nutrients loading
to the TR via the diversion channel
(.1) Significantly alter 701 acr.es wetland, 521 acres
upland, and 313 acres aquatic habitat
(2) Dredging Impacts (2)-(4) listed under Alternative B
for dredging downstream from Dodd Road
(3) Increase 1n suspended solids and nutrient loading
to the TR via the diversion channel
(4) Drier habitat in MSB between Patton and Dodd Roads
Est. Cost
millions
0.6/yr
. 86.8
*
137
130
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fable 2.2 Estimated Level of Mitigation, Predicted Impacts, and Estimated Costs Associated With
Proposed Alternatives, (Continued) '
Alter-
native
E
F
F*
Estimated % DDTR
Remove
99.3
8.3
8.3
Cover
0
91.0
91.4
Total ;
i
99. 3'
99.3
99.7
• i
Predicted Adverse Environmental
Impacts
(1) Significantly alter 619 acres wetland, 348 acres
upland, and 338 acres aquatic habitat
(2) .Dredging impacts (2)-(4) listed under Alternative B
for dredging. downstream from HSB Mile 3.9
(3) Increase in suspended solids and nutrient loading "
to 1C via the diversion channel
(1) Significantly alter 612 acres wetland, 348 acres
upland, and 338 acres aquatic habitat
(2) Dredging impacts (2)- (4) listed under Alternative B
for dredging downstream from HSB Mile 3.9
' (.3) Increase in suspended solids, nutrlerit loading
to 1C via the diversion channel
(4) Drier habitat in HSB between Miles 3.9 and 5.6
. (1) Significantly alter 612 acres wetland, 161 acres
upland, and 338 acres aquatic habitat
(2) Dredging impacts (.2)- (4) listed under Alternative B
for dredging downstream from HSB Mile 3.9
(3) Increase in suspended solids and nutrient loading
to 1C via the diversion channel
(4). Drier habitat in HSB between Miles 3.9 and 5.6
Est. Cost
millions
106
93.0
/
.
-
88.9
.
*
* Alternative F with option to us? diked contaminated area for disposal of dredged material.
N)
I
tn
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Estimated Implementation Timeline • Alternative F, Withjn-Basin Diversion and Containments
Sediments (Using Diversion Containment Area for Disposal of Dredged Material)
»__^^_ ___
of Contaminated
Long-Term Monitoring .
and Maintenance '
* «.
l TDMDA Operation, Dewatering v .
| | Powerline Installation
Sun Time Assume*: . _ _, channc|.
• Project Is Authoriied ' '
• Implementing Aganct it . , _ „ ' .
• Identified 1 -i Treatment System Set-up
• Funding Is Approprieted
Advanced Engineering and Design
• Soil Testing § ,
• Surveying *~ 1 Access Road Construction
• Detailed Design Analysis .
• Review of Plans and Spec* ' . ' Lonstruction ot U.verslon and Dike
• Contra*! Adventeement
• Contractor Lead Time *
1
)~Ao«ncy L«»d Tim§
* i ( i i it i
o i a|a 4 s 6 7
B.J.n : ELAPSED TIME (YEARS)
Conitruction '
inagging
i i i ^j
§ 9 10 11
FIGURE 2.1 Estimated Implementation Timeline, U.S. ARMY CORPS OF ENGINEERS,
Alternative F . MOBILE DISTRICT
Engineering and Environmental Study of DDT Contamination of
Huntsville Spring Branch, Indian Creok, and Adjacent Lands an,d Wajers
SOURCE: WATER AND AIR RESEARCH, INC., 1980 Whofllar Reservoir, Alabama
-------
The W.A.R. alternatives would necessitate significant amounts
of appurtenant construction and destroy the major portion of the
existing natural habitat of HSB and much of 1C. Aquatic habitats and
wetlands, which cover hundreds of acres, would be destroyed or
drastically altered. Depending upon the alternative chosen, almost
72 acres of stream bank (S-29) would be converted to access roads,
over 12 miles of pipelines with 11 booster pumps (S-27) would be
installed for transporting dredged material, 187 acres of upland
habitat (S-30) would be converted into disposal areas, and a two to
three million gallon per day (MGD) water treatment plant and/or a
four MGD pumping station would have to be constructed. In all, 1000
acres or more of upland and water habitat would be destroyed or
significantly degraded.
2.3 Other Remedial Actions
This Proposal is intended to develop remedial measures that
will achieve the performance standard and the goals and objectives
of the Consent Decree. The studies set forth in this Proposal are
necessary for the adequate development and assessment of new
alternatives.
2-8
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3.0 QUALITY ASSURANCE PROGRAM
3 .1 Introduction
The primary' and secondary laboratories described below will
provide quantitative data (analytical test results) for use in
decision making processes relative to any final remedial action to
be implemented for the HSB-IC system. To be valuable, sampling
protocols and laboratory analytical methods must be appropriate to
assure (i) the samples are representative, and (ii)-the laboratory
data accurately describe the characteristics and constituents of
samples submitted. To this end, the following quality assurance
program wj.ll be followed.
3 .1.1 Program
The quality assurance program will include the use of primary,
secondary and referee laboratories; specific parameters for
analysis; standardization of analytical-methods, instrumentation,
and laboratory operations and techniques; and the blinding of
analytical samples prior to analysis. Additionally, there wil_l_be a
defined intra- and interlaboratory control program.*
* Whenever a determination of equivalency of methods, procedures
or equipment is required, Olin and EPA shall agree upon such
determination.
3-1
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3 .2 Participating Laboratories
3.2.1 Primary Laboratory
The primary analytical facility will be provided by Recra
Environmental Laboratories. This laboratory is based in Tonawanda,
New York and is a New York State certified environmental laboratory
for various analyses performed on drinking water. It will be the
responsibility of. the Recra laboratory to maintain its own
laboratory controls and to coordinate interlaboratory activities
"with secondary laboratories and the referee laboratory. All samples
will be analyzed by the staff of the primary laboratory.
3.2.2 Secondary Laboratory
The role of a secondary laboratory is to provide verification
of the results generated by the primary laboratory. Split sampi.es
prepared by the primary laboratory "and blinded by an independent
organization will be shipped under appropriate custody to the
secondary laboratories. Additionally, reference samples provided
by the referee laboratory via the primary laboratory will also
require analysis.
Two secondary laboratories are planned for this project. The
first is the laboratory of the Olin Corporation in Charleston,
Tennessee. The second is the Olin laboratory at its research center
in Connecticut.
3-2
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3.2.3 Referee Laboratory
The referee laboratory for this program is the Region IV,
Athens, Georgia laboratory of the EPA. The referee laboratory will
provide evaluation samples for the primary and .secondary
laboratories, review split reference samples, evaluate each
laboratory's performance, and assist in the identification and
solution of any analytical discrepancies and/or problems that arise
over the course of the analytical phase of the project. The referee
laboratory will also be involved in selecting and using each
analytical procedure (especially those concerning DDT) to insure
the validity of the analytical data.
The referee laboratory will analyze 5% of all DDT samples. The
primary laboratory will provide these samples in duplicate after
blinding by an outside firm. -For those samples sent to the referee
laboratory (EPA), a total of five (5)* blinded aliquots will be
prepared with 2 subsamples sent to EPA and one (1) subsample sent to
each of the secondary and primary laboratories. The analytical
results of these samples will be compared to determine laboratory
equivalency.
3.3 Analytical Parameters
3.3.1 Biological Samples
The only biological samples to be collected, at least during
the initial phase of this project, are fish from the HSB-IC system.
Other fauna, including waterfowl, have been collected and analyzed
3-3
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as a part of past projects. Other aquatic biota samples such as
algae, benthic macroinvertebrates and zooplankton also have been
collected in previous studies. It is not this Proposal's intent to
duplicate these efforts but rather to use> wherever possible, the
results available from the W.A.R. Report.
Both fish fillet and the offal will be analyzed as a part of
this program. The offal analysis is included to determine the whole
body concentration and to address the concern of biomagnification.
Both fillet and offal results may also be compared to the analyses
performed during other studies by previous investigators. Offal
represents the remainder of the carcass after the fillets have been
removed and skinned. The skin is included as part of the offal.
Analysis of both fillets and offal will permit construction of whole
body residue concentrations.
Analysis will include qualification and quantification of DDT
v
and lipid (% fat) content in both the fillet and offal samples.
• 3.3.2 Sediment Samples
The collected sediment samples, as further described in
Section 5 of this proposed scope of work, will be analyzed for the
following:
• wer weight, dry weight and moisture content
• grain size distribution
• total organic content (total volatile solids)
DDT
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3.3.3 Water Samples
Water samples collected as a part of this project will be
analyzed to determine DDT content in both the dissolved and
suspended phases. Whole (total) water samples will be analyzed for
total suspended solids and DDT content. Suspended particulates
(after separation by filtration) will also be analyzed for DDT.
Additionally, at the time of water sample collection, the following
measurements will also be made and provided to the secondary and/or
referee laboratories:
pH
• specific conductance
• temperature
• dissolved oxygen
• alkalinity
3.4 Analytical Methodologies
"One of the major factors in a successful interlaboratory
quality control program is standardization of analytical
methodologies. Although numerous methodologies from various
/
sources are available for the above parameters of interest, the
following methods will be used in this project. All of the following
methods are consistent with "accepted" state-of-the-art analytical
techniques, have been used in past studies, and are available to the
primary, secondary, and referee laboratories.-
3-5
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3.4.1 Biological Samples*
Both the fish fillet and the offal will be analyzed as a part of
this program. Filets will be skinned and the skin will be included as
part of the offal during sample preparation and subsegv it analysis.
Fish samples (both fillet and offal) will be analyzed for lipid
(% fat) content and DDT according to the "Interim Method for the
Sampling and Analysis of Priority Pollutants in Sediment and Fish
Tissue" as presented by EPA in August 1977-(revised October 1980).
This document presents two procedures for the analysis of
chlorinated pesticides in fish. For consistency with past studies,
Method A (the blender method) will be employed, except that an ultra
sonic probe (or Brinkman Polytron) will be used during the
extraction procedure in lieu of a blender to reduce the possibility
of cross contamination. Past work has shown that the homogeneity of
the sample is"critical to the reliabili-ty of the analytical data.
Therefore, the fish fillets and offals will be put through the meat
grinder three times to assure homogeneity of the sample.
3.4.2 Sediment Samples
After removal of twigs, rocks and/or other debris and thorough
homogenization, DDT content of collected sediment samples will be
determined by EPA methods. Specifically, the procedure outlined in
"Organochlorine and Organophosphorus Insecticide in Bottom
Sediment" (Section 11B) from the Manual of Analytical Methods for
the Analysis of Pesticides in Human and Environmental Samples (EPA-
3-6
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600/8-80-038, June 1980) "will be used with the exception that the
Soxhlet extraction procedure will be substituted for the column
extraction procedure. The determination of moisture content of the
sediment is also addressed in the above referenced procedure.
Grain size analysis of collected sediment will be completed
using methods consistent with or equivalent to those procedures
employed by TVA and reported by W.A.R. Specifically, an electronic
particle size procedure (Welch et al., and" Micrometric Instrument
Corp.) utilizing a Sedigraph Model 5000D particle size analyzer (or
equivalent) will be used.
The association between DDT and particle size will be
ascertained by direct analysis of the sand and silt plus clay size
fractions and by regression/correlation analysis for the specific
silt and clay fractions as identified by the Sedigraph 5000D (or
equivalent).
3.4.3 Water Samples
At the time of sample collection, field measurements of pK,
temperature, specific conductance and dissolved oxygen will be
made. The methods to be used for determining these parameters are
contained in EPA manual of Methods for Chemical Analysis of Water
and Wastes (EPA-600/4-79-020, March 1979). Actual procedures are as
follows:
3-7
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• pH Method 150.1
• specific conductance Method 120.1
• temperature Method 170.1
• dissolved oxygen Method 360.1
Laboratory analysis of water samples for total suspended solids
(non-filterable residue) will be done according to Method 160.2, set
forth in the above reference. Alkalinity of water samples will be
determined according to Method 310.1.
The DDT of the whole (total) water sample (usually 1 liter)
will be determined via EPA Method 617 (EPA, July 1982). This method,
although not specifically referenced in past studies, is equivalent
to the previously used methods. This equivalency will be
demonstrated.
Suspended solids/particulate DDT determinations will employ
the Soxhlet extraction procedures (Section 11A from the Manual of
V
Analytical Methods for the Analysis of Pesticides in Human and
Environmental Samples). Suspended particulates will be .separated
from the whole (total) water sample via large volume water
filtration through pre-extracted glass fiber filters [U.S. EPA,
Test Methods for Evaluating Solids;- Physical and Chemical Methods
SW-846, Method 7.2 (1980)]. Due to the low concentration (5 to 50
mg/£) of suspended solids in the water samples, five to eight liters
of water must be filtered to provide sufficient quantity of sediment
for DDT analysis. The glass fiber filters and filtered materials,
3-8
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after being dessicant-dried to a control weight, will be extracted
directly and subjected to DDT quantification. The filtrate (water
phase) will be analyzed for DDT using the procedure specified above
for whole water.
In the past, difficulty has arisen during the analysis for
total and suspended DDT of water samples. The sum of the quantity of
DDT in the water phase and the DDT in the sediment phase did not
equal the DDT found in the total sample. This error generally arises
because very large volumes of water with very small concentrations
of sediment have to be analyzed.
Present plans call for the analysis of total water and both the
dissolved and the suspended fractions as previously defined. After
completion of the analysis the sum of the fractions(dissolved and
suspended) will be compared to the separately determined total water
sample DDT content. It is anticipated tJtat differences will exist
between these two values. On a case-by-case basis, the extent of the
relative error will be assessed. Based upon the techniques employed
and as long as the total suspended solids remain relatively low, the
total water sample analytical result will be considered to be most
reliable. " All three DDT analyses will be reported.
3 .5 Intralaboratory Quality Control Plans
3.5.1 Facilities
All participating laboratories will be of sufficient size and
capability " to assure the necessary amount of work-space,
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ventilation, separation of analytical activities, heating or
cooling, solvent storage, sample storage, etc., to assure the
successful completion of the analytical programs.
3.5.2 Chain-of-Custody and Sample Handling and Storage
Water and sediment samples will be placed in pre-cleaned glass
bottles with TEFLON-lined lids. Fish samples will be wrapped in
aluminum foil. All samples will be preserved in accordance with EPA
recommendations. All samples will be handled under chain-of-
custody procedures which will apply to all laboratories used in this
study. An example custody form is attached as Figure 3.1.
Upon receipt of samples and after appropriate inventory
activities (logging, labelling, etc.) are completed, water and
sediment samples will be stored in Recra's secured 800 ftj walk-in
* •
-cooler which is maintained at 4°C. ' Special cooling system
+
modifications have been implemented to guarantee against loss of
samples due to freezing. Storage time prior to analyses will not
exceed r'e"commendations in the above-referenced procedures, i.e. ,
water samples must be extracted within seven days and completely
analyzed within 30 days of collection. Holding time criteria will
apply to all participating laboratories. Fish samples, after
inventory, will be'maintained in a locked freezer until analysis.
Custody of samples will be maintained during analysis using
permanently bound separation-laboratory and analysis-laboratory
notebooks. All chromatographs, preparation sheets and forms,
3-10
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FIGURE. 3.1
RECRA RESEARCH, INC
CHAIN OF CUSTODY RECORD
PROJECT* .
STUDY AREA:
PROJECT NAME:.
.SAMPLERS SIGNATURE:.
STATION*
•
•
-
.
DATE
'
Relinquished By:
Relinquished By:
Method of Shipment
TIME
•
~~
Date/Time:
Date/Time
Shipped By:
SUBSAMPLE
CODES
-
... .1
Received By:
Received By:
Received By:
TOTAL #OF
SAMPLES
REMARKS
-
-----
Comments:
Comments:
Comments:
Recieved for Laboratory:
Job ft:
Authori/uiion
for Disposal: •
Date/Time.
Type of Disposal:.
Date of Disposal:.
3-
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etc., will be maintained and available for inspection and review by
interested parties. All written information will be retained for
five years after completion and approval of the project report.
After analysis, samples will be retained until the final report is
accepted by the United States.
3.5.3 Laboratory Personnel and Equipment
Laboratory personnel will be experienced residue or water
quality analysts or under the close supervision of such qualified
persons.
All laboratory equipment, including the 63... electron capture
gas liquid chromatographs, shall be covered by manufacturers'
service contracts, unless other arrangements for maintenance of
such equipment are provided. Instrument maintenance quality
control includes at least the following:
• determination of chromatographic column
efficiency (theoretical plates) - after-
initial packing
• daily monitoring of absolute retention a_nd,
relative (t6"aldrin) retention times - all
samples; aldrin may also be used as a'
surrogate, in the absence of other
chromatographic interferences
• daily evaluation of GC columns to ensure no
breakdown of DDT is occurring on column
• daily monitoring of response factors for DDT
and metabolite standards
• daily linearity of standard curves
• daily determination of column resolution
capabilities
3-12
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Personnel at all participating laboratories will maintain this
information in bound logs which will be available for review or
inspection.
3.5.4 Data Quality Assurance
The overall data quality assurance activities of the
participating laboratories will include a minimum of approximately
30 percent of the total work load. Quality control limits will be
established during the method equivalency period (at the initiation
of the proposed scope of work) and will be continually verified by
each laboratory throughout the life of the project. During the
method equivalency program, replicate samples will be analyzed by
each participating laboratory. Evaluation of these results will
allow for the establishment of warning and control limits. As the
project progresses, a number of additional control measures will be
completed in order to further refine these limits as necessary.
These control techniques include:
• analysis of replicate samples and spike samples .. ....
• analysis of standard reference materials
• analysis of independently blinded samples
which are analyzed by the Region IV EPA
(referee) laboratory and the primary and
secondary laboratories.
3.5.4.1 Precision
The precision (reproducibility) of analytical results will be
based upon a minimum of ten percent of the samples being analyzed in
duplicate. The results of these duplicate analyses will allow for
3-13
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the establishment of x charts specifically related to the project.
These charts, commonly called Shewhart Control Charts, will contain
both upper and lower warning and control limits, based upon the
standard deviation of the replicate analysis. Generally, or at
least initially, these limits are set at plus and minus one and two
standard deviations, respectively, of the relative standard
deviation values.
Analytical results falling outside "the control limits will
require re-analysis. If the re-analysis falls outside the control
limits, the reason will be identified (operator error, equipment
malfunction, etc. ). After the problem has been corrected, the entire
lot of samples will be re-analyzed along with the appropriate
standards and blanks.
3.5.4.2 accuracy
Accuracy limits will be determined ^ for both "absolute" and
"relative" recovery. Absolute recovery is based upon the addition
of spikes to blanks and relative recovery is based upon the addition
of spikes to samples. Experience shows that absolute recovery is
almost always within warning limits unless the problems associated
with the analysis are instrument related. Generally, absolute
recoveries are most indicative of method/control verification;
relative recovery, on the other hand, of analytical/analyst control
and/or matrix effects.
3-14
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The accuracy of analysis will be monitored • by performing
percent recovery of known constituent additions on a minimum of ten
percent of the samples. The percent recovery less 100 percent
(percent bias) will be plotted on R charts. From the individual
values of percent bias, the mean and standard deviation are
calculated. The warning limits (UWL and LWL) and control limits
(UCL and LCL) are initially set at the mean ±10% bias, and at the
mean ±20% bias, respectively. In the event that accuracy
measurements are above or below warning limits, the analyst will
examine the system/protocol to retard loss of control. If bias
values indicate greater than the mean ±20% bias, samples will be re-
analyzed. In the event that samples are not available for re-
analysis, out-of-control data will be so identifed and not used in
further evaluations for purposes of developing remedial action
alternatives.
V
3.5.4.3 Sample Blinding
One of the main quality control measures, which will be
employed in this project, is sample blinding. All samples collected
for analysis (fish, water and sediment) will be blinded. The
samples which are split and sent to all participating laboratories
for analysis will be blinded by an outside party which is not
connected with this project in any manner. The samples will be
blinded by replacing existing labels with randomly distributed
laboratory numbers. Only the blinding party will have the key which
3-15
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identifies the samples. The identity of the individual samples will
remain unknown to all analytical laboratories (Recra, Olin (2) and
EPA) until all analyses have been completed and results submitted to
the blinding agent.
The samples which are to be analyzed by only the Recra
laboratory will be blinded by Recra upon arrival at Recra. During
analysis, the sample will be identified by only a laboratory
job/control number. The identity of the sample will not be revealed
to the laboratory analysts. Blinding in this manner will minimize
the time required for the generation of analytical data and will
permit expeditious processing of samples and data while assuring a
high degree of quality assurance.
3.5.4.4 Additional Control Measures
In addition to the " above precision and accuracy
determinations, other control measures ""will also be employed to
insure intralaboratory quality control. The most important of these
is the use of standard reference materials (SRM's). .SRM's for water
analysis, including DDT and metabolites, are currently available
from EPA or commercial concerns such as Environmental Resource
Associates (ERA). SRM's for pesticides (including DDT and
metabolites) in fish are also available. The SRM for sediment DDT is
being developed by Recra. The source of the sediment for this SRM is
the overbank area near the old waste ditch.
3-16
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As an integral part of the quality control program, SRM's will
be analyzed with each lot or analytical batch of water, sediment, or
fish samples. The results of these analyses will be plotted and
reviewed relative to established control limits on a frequency of no
less than ten percent of the work-load or with each set of analysis
(if less than 10 samples). The method equivalency program which
will use the above SRM's also allows for establishment of warning
and control limits for the SRM charts.
Other quality control means to be employed include, but are not
necessarily limited to, the following:
• establishment of five point calibration curves
on a daily basis;
• analysis of a mid-range standard every tenth
sample to verify maintenance of linearity and
consistency of standard curve;
• analysis of method blanks on a'frequency of one
every ten samples or one blank- on each set of
analysis if less than ten samples in a
set/batch;
• re-injection and gas chromatograph
interpretation of samples analyzed after any
sample which exceeded 50 percent of the,
analytical range in order to guard •against
"ghosting";
• verification of the absence of contaminants
and/or -interference in extraction (or
cleaning) solvents; and
• use of field blanks to verify that samples were
not contaminated during field handling and
transportation.
3-17
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3 . 6 Inter laboratory Quality Control Plan
3.6.1 General Requirements
The proposed program as outlined above will be practiced by
both the primary and secondary laboratories. It is also anticipated
that, dependent upon the degree of involvement of the referee
laboratory (Region IV, EPA, Athens, Georgia), the above quality
control plan will be utilized by the referee laboratory. The
interlaboratory control plan will be primarily used to control
overall laboratory bias and to resolve analytical discrepancies
that may arise.
The splitting of samples will be the responsibility of the
primary laboratory. Blinding "of samples will be the responsibility
of an independent concern. In addition to reviewing the analysis of
the split sample results,it will also be the responsibility of the
4k
primary laboratory to design and implement the interlaboratory
equivalency program.
..-.-..The role of the referee.. laboratory will -be to analyze blind
samples and provide other quality control samples, as deemed
necessary, to both the primary and secondary laboratories. The
referee laboratory will be asked to play a major role if
discrepancies in the analytical results are identified.
3 .6.2 Method Ec/uivalency
Despite the standardization of procedures as addressed in the
above subsection, differences (bias) will undoubtedly exist between
3-18
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participating laboratories. If differences become significant, the.
reasons for the bias will have to be determined. To make this
determination, the primary laboratory will implement a method
equivalency program. This program will be implemented prior to the
actual analysis of any collected soil/sediment or fish samples.
This program consists of a step-by-step assessment to
establish where the bias(es) of each participating laboratory
exist. The initial sample splitting and subsequent data review will
indicate the total bias between the participating laboratories.
Areas in which differences can originate include homogenization,
splitting, extraction, clean-up, and instrumentation or data
interpretation. The method/laboratory equivalency program is based
upon the use of fish and water SRM's and is illustrated in Figure
3.2.
To directly or indirectly evaluate these various aspects of
^
bias,' the following procedure will be followed:
. • extracts or composite extracts will be
subdivided and sent by Recra to participating
• laboratories; arid"
• a set of extracts will be prepared by' the
secondary and referee laboratories and sent to
the primary laboratory.
Based upon the results of the analysis of the split extracts,
the instrumental or interpretive bias of the laboratories can be
assessed. With multiple injection of each extract and the
submission of copies of chromatographs and standard curves,
3-19
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FIGURE
METHOD/LABORATORY EQUIVALENCY PROGRAM
SRM
Primary Lab(Soil SRM Preparation)
I
Referee
Lab
I
5 Replicate
Analysis
I
L
Secondary
Labs
5 Replicate
Analysis
I
Primary
Lab
5 Replicate
Analysis
I
Initial
Extract
I
1 m£ of
€ Replicate
From each lab
returned to
Primary Lab
I
Concentrate
Florisil
Preconcentrate
I
I
1 m£ Of
I Replicate
From each lab
returned to
Primary Lab
I
Analyze each
Replicate
Multiple (3)
• injee-tiwis of
each Replicate
Distribution of SRM
materials to Referee
Secondary Laboratories
All results
including logs/
chromatographs
standards and
samples) sent to
Primary Laboratory
.-for review prior to
meeting of all
participating laboratories
3-20
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the primary laboratory will also be able to indirectly address bias
due to injection techniques and interpretation and calculation
procedures.
Additionally, if extract cleanup is generally required, the
secondary and referee laboratories will analyze the extracts after/
as well as before, cleanup to address differences that may be caused
by the use of Florisil column chromatography and subsequent re-
concentration .
Extraction procedures bias can be determined from the
analytical data of the split extract samples sent by the secondary
and referee laboratories to the primary laboratory.
Finally, but of great importance, is the review of the above
incremental differences in comparison to the total sample bias
between laboratories. This comparison will reflect the homogeneity
of the sample splitting procedures which past experiences have shown
*
to be a significant consideration in overall data quality assurance.
This method equivalency program will be implemented after the
initial split sample results are received and reviewed. The majority
of this program will be concentrated within a single relatively
short (approximately two months) time frame but will continue less
intensely over the duration of the Consent Decree.
3-21
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4.0 FISH STUDIES
4.1 Introduction
The majority of the fish studies reported by W.A.R. focused on
the Tennessee Paver. A few included the 1C but the HSB itself was
rarely sampled. For example, in the 1970 Alabama Department of
Conservation and the 1971 Alabama Department of Agriculture and
Industry surveys (11-21, 23), no HSB-IC stations were sampled. No
fish were collected from HSB-IC stations in the W.A.R.-TVA .fish
survey of June-July 1980 (11-172). In the 1977-1979 Food and Drug
Administration (FDA) surveys, the HSB and 1C were not sampled (II-
27). In the 1975-1977 FDA analyses of fish taken from area markets,
the origins of the fish were not established (S-7) . In the April-May
s
and June-October 1979 TVA project, no fish were collected from HSB.
However, channel catfish, white crappie, gizzard shad, smalimouth
*.
buffalo, white bass, and largemouth bass from 1C were analyzed (II-
167-169). Similarly, the November 1977 and June and September 1978
TVA' surveys (11-29) included fish from 1C but not the HSB. The same
was true for the Fall 1979 analysis (11-171).
Samples were collected from HSB stations in only three previous
fish monitoring projects. In 1977, TVA analyzed whole body samples
of shortnose gar, gizzard shad, white bass, black crappie,
freshwater drum and bluegills collected from HSB (11-25). The same
year, the Army Environmental Hygiene Agency analyzed HSB goldfish
and gar (11-22). In 1979, the TVA collected gizzard shad and
4-1
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bluegills from the mouth of HSB (V-Task 2). At HS3M 4.0, TVA did not
collect largemouth and smallmouth bass, smallmouth buffalo,
bluegill, white crappie, white bass, and gizzard shad for analysis
(V-Task 1), perhaps because there were no fish there at that time.
As indicated above, the information on HSB fish is very
limited. No data exist concerning three fish in the HSB, i.e.,
channel catfish, largemouth bass, and smallmouth buffalo.
Accordingly, the levels of DDT in these fish in HSB is unknown.
W.A.R. did provide a limited amount of data on fish (catfish,
smallmouth buffalo and gizzard shad) from Indian Creek. Additional
data is needed for both 1C and HSB in order to define the existing
environmental concentrations .of DDT in the species of fish present
in 1C and HSB. The effect of remedial actions on the nektonic
community cannot be assessed without this baseline information.
Without additional data specific to HSB, one cannot reach valid
conclusions concerning the significance of fish migration in the
area (one of W.A.R.'s cited potential mechanisms of contamination..
S-17). There is insufficient information to determine if fish
migration is occurring from HSB or 1C to the TR or vice-versa. Given
the lack of data on fish migration and DDT levels, the need for
remedial action designed to prevent fish movement into or out of the
HSB-IC system (or segments thereof) to reduce DDT levels in-fish
cannot be assessed. The conclusions of the W.A.R. Report with
respect to fish are based primarily on data on TR fish. Information
4-2
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specifically obtained from 1C and HSB samples is required to
supplement the W.A.R. conclusions and to develop suitable remedial
actions. To these ends, monitoring programs for fish in 1C and HSB
have been developed.
4.2 Program Objectives
The fish monitoring program will provide data on
concentrations of DDT in fish in the HSB-1C study area to complement
the more regionally-oriented data of the W.A'.R. Report.
The purpose is to:
• Provide estimates of DDT in fish and relative
abundance of fish at specific locations for use
in choosing and assessing possible remedial
actions;
• Develop a sufficient data base to predict the
short- and long-term impacts of proposed
remedial actions; and
• Establish baseline data to monitor the
effectiveness of any remedial "action measures
over time.
4.3 Utilization of W.A.R. Data
W.A.R. data will be utilized to the extent possible. A large
amount of data was generated for fish in the TR. This information is
believed to provide an adequate data base for fish in the Wheeler,
Wilson, and Guntersville Reservoirs. However, additional sampling
of the TR will be conducted near (both Upstream and downstream)" the
confluence of Indian Creek. This data can be used to assess natural
changes occurring in the system and will ensure that future
4-3
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comparisons are based on a full and complete data base. Based upon
the extent of W.A.R. and TVA data, no sampling locations on the TR
beyond five miles of the IC-TR confluence are planned at this time.
The W.A.R. data appears sufficient for the goals of this project and
further sampling of the TR would not add significantly to the
existing data base.
The existing data base, and the two planned sampling locations
in TR, will be used to help develop the long-term monitoring program
and to help identify any necessary additional appropriate sampling
locations.
This Proposal will concentrate primarily on fish in and near
the HSB-IC system. The data to be generated will be used in
conjunction with all available W.A.R. information on HSB-IC fish, as
discussed belbv. The W.A.R. HSB-IC fish data have been utilized to
identify the types of fish which might be "encountered in the various
sections of the study area and, in combination with a consideration
of the site characteristics, have__also heJLped define . the most
appropriate sampling techniques and sample locations.
4. 4 Program Design
The specific design of the fish monitoring program is detailed
in the following subsections. These subsections set forth the
sampling locations and schedule, the kinds of equipment to be used,
the types of fish to be collected, and the sample handling and
analytical procedures. In addition, some of the concerns considered
4-4
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during the development of this program or expressed by concerned
parties are also discussed.
4.4.1 Sampling Locations
Eight locations on the HSB and 1C will be sampled in the fish
monitoring program. These locations, shown on Figure 4-1, are:
1. HSB near Martin Road bridge and Gate 1 of RSA,
2. HSB near Patton Road bridge,
3. HSB in the vicinity of the former DDT plant,
4. HSB upstream of Dodd Road bridge,
5. 1C near Centerline Road bridge,
6. 1C near the RSA boundary (ICM 1.0),
7. 1C near Martin Road bridge, and
8. HSB between HSBM 1.0 and HSBM 2.0.
These sampling locations were selected for a number of reasons.
Sites 1 and 2 are located at the HSB ""upstream of Reach A. No
information has been generated to date on the types and sizes of fish
inhabiting the upstream area_ ojr __the levels of DDT in_ these fish.
These sites were selected to help determine if fish upstream of
Reach A contain elevated levels of DDT and to determine if measures
should be taken to isolate fish in these areas from the section of
the HSB downstream of Patton Road.
Site 4 is roughly at the downstream boundary of Reach .A. Site 3
is located in HSB near HSBM 5.0. Site 3 will provide data on fish
within Reach A.
4-5
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Sites 5 and 6 are within Reach C. In conjunction with the
W.A.R. data, samples collected from these sites will be used to
establish the levels of DDT in fish in the various portions of Reach
C. These sites are important because they represent the transition
zone between the HSB and TR and must be traversed by fish moving
between HSB and TR. In addition, Site 6, at ICM 1.0, is the point of
the RSA closest to Triana. Site 7 is located on 1C upstream of the
confluence of the HSB. Like Site 1, Site 7 was selected to help
determine if fish containing DDT are present in other portions of
the HSB-1C system. Observations of fish at this site also may
provide information nelpful in understanding the patterns of
movement of fish in this system.
'Site 8 is located within Reach B and will provide a point for
comparison with Reaches A and C. Site 8 was not sampled during 1982
by Olin (Recra) . Site 8 was added to the list of sample locations in
order to provide a more complete picture of the fish species and
their DDT concentrations within HSB and IC..,..S.ampl.ijig at Site .8. will.
begin ir. February 1983.
4-6
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LJ Sample Locations
MARTIN nOAO
- \
Gonnr.ii Sil.o Hap - Iliintsvllle Sprlnq DrAiirh, Indian Crunk, and Vlclnlly
tounct' n/kTtn AND Am nf SIAHCK. INC.. i
-------
In addition to the eight sampling points within HSB and 1C, two
locations on the Tennessee River will also be sampled. One point
will be upstream of the IC-TR confluence in. the vicinity of TRM 323.
The other sampling point will be in the vicinity of TRM 319 which is
downstream of the IC-TR confluence (TRM 320.9).
4.4.2 Sampling Frecoiency
Under the monitoring program, fish will be collected monthly
for a year. Each monthly collection will require four to five days
to complete during which time each site will be sampled one to two
times. Fish distribution patterns are influenced by a number of
factors including seasonal fluctuations in water temperature, depth
and area extent of the water pool, food supply availability, and
other habitat conditions. The effect of the pool elevations and
.seasonal changes in the chemical and physical characteristics of the
^t
watervon the fish must be investigated.
A long-term fish sampling program comparing relative fish
..species abundance is inc-luded as -a—feasible method of collfe'C"liTouf
evidence of fish migration. Although exact fish migration patterns
in the HSB-1C system cannot be established by this method,
variations in the composition of the nektonic community could allow
one to infer if migration (or movement) is occurring. Portions of
the original sampling schedule have been completed (see Table 4.1).
The new program entails collecting monthly samples at the proposed
sites from August 1982 through May 1983 (thereby providing data for
4-8
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a complete year from June 1982 through May 1983). Sampling at sites
6, 8, 9 and 10 will continue on a monthly basis through August 1983.
4.4.3 Sampling Protocol
To the extent possible, the fish sampling program will be
directed towards channel catfish, largemouth bass, and smallmouth
buffalo. These fish were selected because they can be food for
humans and because of the existing data base for these fish in the
Wheeler Reservoir. Channel catfish is the primary species showing
DDT levels greater than 5 ppm. Also, due to their feeding habits,
monitoring these three species of fish may provide information on
DDT in the food chain in this section of the Wheeler Reservoir. For
example, the preferred food- of young largemouth bass includes
crustaceans, insects, zooplankton, and other invertebrates. Adult
.largemouth bass prefer small fish such as yellow bass, channel
A
catfish, perch, gizzard shad, and trout. Adult channel catfish feed
on crustaceans, mollusks, plants, and small fish such as minnows.
.-..Sma^J.mouth .buffalo, tend to feed-on plants- such as- duckweed-,—algae,-
protozoans, insects, and crustaceans such as copepods(summarized
from 11-156) .
4-9
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TABLE 1.1
SUMMARY OF OLIN/RECRA FISH COLLECTIONS IN THE HSB/IC SYSTEM
June, 1982 through February, 1983^
Number of Samplings
Fish Species Caught
Catfish (Channel, Flathead)
Bullhead (Black, Brown, Yellow)
Carp
Goldfish
Bass (Smallrnouth, Largemouth,
White)
Bluegill
Buffalo (Bigmouth, Smallmouth)
Sunfish
Bow fin
Car (Spotted, Shortnose)
Crappie
Sucker (White, Spotted, Redhorse)
Gizzard Shad
Other species ®
TOTAL
® Eleven collection trips
® Includes 20 young-of-year fish
SAMPLING
1
9
0
1
20
0
1
2
0
6
12
5
1
16
1
0
65
ickerel.
2
10
0
7
18
4
1
0
0
0
16
28
3
16
23
0
116
Freshwater
4-10
3
11
0
2
45
4
20
5
27
0
8
0
4
5
7
24
0
147
Drum
i
4
11
12
4
38
10
20
1
0
0
1
3
1
5
9
1
105
>
SITE NUMBER
5
11
i
i
13
20
17
i i
i f
i
i 24
t
; 1
1 0
0
; 1
t
' 17
i 2
i
I
; 28
r
') 31
; 159
I
t
i
i
6
3
7
14
40
1
30
0
14
0
0
1
0
1
13
8
129
7
9
0
28©
1
0
i
13
14
0
13
0
0
0
10
26
5
110
8
1
1
0
1
0
13
0
0
0
0
25
0
0
2
4
46
KDR/jmm
4/4/83
TOTAL
33
76
180
36
107
45
14
27
30
83
12
59
126
49
877
-------
W.A.R. data indicated that largemouth bass, smallmouth
buffalo, and channel catfish may be rare, or absent, at several of
the sampling locations. Other fish including gar, bluegills,
sunfish, bullheads, white bass, goldfish and gizzard shad are more
frequently encountered. Therefore, all species of fish taken at
•~ each station will be retained for analysis (up to a maximum of 6 fish
per species). The criteria for selection of fish for analysis is to
retain fish of each species collected at a given site and to save for
analysis, when possible, a sufficient number of fish (generally six)
to provide an adequate mass of fillet and offal for complete
analysis including the previously outlined quality assurance
procedures. Additionally, efforts will be made to collect similar
fish at all stations in order to generate a representative picture
of the types of fish present arid the levels of DDT in these species.
This is important because residues in one "species of fish at one site
cannot be compared with residues in another species of fish at
another site.
The fact that channel catfish, largemouth bass and smallmouth
buffalo may not be present or collected at several of the stations
should not be construed as a criticism of the sampling program
viability. To develop a meaningful long-term monitoring program,
one needs to know what types of fish are present and the relative
ease with which they can be caught. The knowledge of the fish
present is critical to the development of the monitoring program.
4-11
-------
Parallel to the fish collection, Olin will.perform a literature'
study of the life cycle, habits, etc., of the species in the HSB-IC
system to help explain the presence or absence of specific species
at specific locations.
Due to the variety of fish which may be present, several
different collection methods will be employed. The relative
effectiveness of various sampling equipment for different types .of
fish are compared in Table 4.2. Four methods will be employed in
this project. These are seining, trotlines, gill nets and shocking
(either from a boat or by wading using a portable, backpack
electrofishing outfit - Model BP-2 manufactured by Coffelt
Electronics Company, Englewood, Colorado). All four methods may be
employed at eacn site since the relative effectiveness of each will
vary with site characteristics and the types of fish present. Each
collection will be carefully documented with respect to species of
fish'caught, methods used, size of area fished, time required to
collect, etc.
4-12
-------
TABLE 4.2
KEI.ATIVE EFFICIENCY OF SEVERAL PTSH -
SAMPLING (METHODS (AFTER BENNETT, 1971)
METHOD OF SAMPLING
Kind of Flah
l-argewouth Baas
Snullmouth Baas .
Sunfish, etc.
Crupples
Carp
t
Gizzard Shad
Car
Bullheads
Channel Catfish
Traimcl
Nets
poor
poor
good
good
good
fair
good
fair
poor
i Wing and
Trap Nets
; poor
» fair
' good
i excellent
good
i good ^ .
fair
' good
good
Seines
fair
fair
good
good
good
good
good
poor
good
Spot
Poisoning
good
good
good
good
good
good
good
fair
good
(Boat)
Electroshocking
fair
fair
good
fair
fair
good
poor
poor
poor
Angling
good
good
good
poor
poor
—
poor
good
poor
I
M
U*
-------
The value of using Rotenone at each station on a semiannua3.
basis will be evaluated during this project. Utilization of Rotenone
shall be subject to approval by the RP. This collection method would
give a good estimate of species composition and relative abundance.
This is similar to Task 2 in the W.A.R. Report. The monthly sampling
program will provide guidance on the critical times of the year as to
when the fish population may be high or low. The fish collected by
Rotenone can also be used for DDT analysis since Rotenone does not
interfere with the DDT analysis.
At each station, up to six individuals of all species of fish
found, will be collected, if possible. The weight and length of each
fish will be recorded. The fish will then be wrapped in aluminum
foil, frozen, and shipped by air freight to Recra's Tonawanda, New
York laboratory for analysis (and/or subsequent shipment to
secondary and referee quality control laboratories). Each
collected fish will be field identified with the following
information: project number, specimen identification number,
species of fish, date of catch and sampling location. , Chain•of
custody forms will be initiated at the time of collection. Fish
captured but not saved for analysis will be noted and released. As
indicated previously, changes in the types, composition and
abundance of fish at the various stations will be used as an
indication of possible fisn migration.
4-14
-------
The following guides will be used to identify the fish
collected for analysis:
• Etnier, David, Personal notes on Fishes of
Tennessee, University of Tennessee, Knoxville,
TN, 1976 (rev. 1982).
• Eddy, Samuel, How to Know Freshwater Fishes,
William C. Brown, Co. 1957.
• Whitaker, John 0., Jr., Keys to the Vertebrates
of the Eastern United States Excluding Birds,
Burgess Publishing Co., Minneapolis, MN, 1968,
pl-127.
• Kuhn, E.R., A Guide to the Fishes of Tennessee
and the Mid-South. Tennessee Department of
Conservation, Division of Game and Fish, 1929,
12 4p.
• Smith-Vaniz, W. F., Freshwater Fishes of
Alabama. Auburn University, Agricultural Exp.
Station, 1968, 211 p.
* .
4.4.4 Analytical Parameters
«k
The analytical procedures to be employed for the fish are set
forth in Section 3.4.1 of this Proposal. The fillet and offal of
each fish will be- analyzed 'individually if" sufficient mass" is
available (approximately 250 grams each). Small fish' will "be
combined by site and species until the combined weight of 250 grams
is obtained and whole body analysis performed. Percent lipids (total
fat) will also be determined for all samples.
4.5 Mechanism of Fish Contamination
Evidence collected to date has not provided a clear picture of
the mechanisms responsible for elevated DDT concentrations in fish.
4-15
-------
DDT in fish may occur from numerous pathways but quantifying the DDT
contribution of each pathway to the total DDT measured in the fish is
a difficult undertaking. For example, do" fish accumulate more DDT
from the passing of water through the gills or from consuming
benthic macroinvertebrates which have ingested DDT from the water?
-
-------
OMNIVORES&
HIGHER CARNIVORES
PRIMARY CARNIVORES
HERBIVOROUS
FISH
ZOOPLANKTON
PLANTS
SOtt LtACM'MC
I «i.
WATER
«•£
Is
if
X txe*rrto*
BOTTOM
ORGANISMS
SEDIMENT
t DECAY
FIGURE 4. .2
Transport of DDT in an
Ecosystem - Adapted from
AEHA, 1S77
U.S. ARMY CORPS OF ENGINEERS.
MOBILE DISTRICT
Engineering and Environmental Study
C"f DDT Contamination of HunrjvUle Spring 3rsr
Indian Creek;, and Adjecsnt Lands and Wztsn
-------
The following discusses the conceptual aspects of such a study
rather than a definitive program. The design of the study can
proceed after further pre-study work, including detailed
discussions with government experts, is completed. These studies
may be especially pertinent to Reaches B and C.
Numerous laboratory studies have been undertaken to determine
the fate of DDT and other contaminants in both terrestrial and
aquatic environments. Metcalf et a]L., (1971) discuss the use of the
model ecosystem approach, where an attempt is made to reproduce (to
the extent possible) in situ conditions. Others (Branson, 1978)
have stated that an environmental rates approach using a material
balance equation will more accurately predict the environmental
•concentration of contaminants. In either case, the validity of the
data generate'd is subject to question due to the inability of
laboratory conditions to accurately model*the in situ environment.
In an uptake study, known concentrations of radio-labeled DDT
could be introduced into a closed system, and. the species .wouldJke...
tested over time to determine DDT uptake rates. Another type of test
involves determining the rate of bioconcentration from bottom
sediment. DDT could be introduced into sediments similar to those
in the KSB-IC system. Actual DDT contaminated sediments from HSB-IC
could also be used. Concentrations of DDT within the sediments could
be varied in various aquariums to determine the effect of sediment
concentrations on bioconcentrations. • Of special interest may be a
4-18
-------
test which covers DDT containing sediments with clay, plastic or
other material and establishes the rate of bioconcentration.
Finally, it could be possible, as Macek et aJL., (1979) have done, to
compare the rates of bioconcentration to bi©accumulation in aquatic
organisms. The results of this investigation showed that, unlike
Bother chemicals, DDT accumulated in higher trophic levels through
the food chain, as well as through bioconcentration.
A field study could be performed to study the uptake of DDT by
fish in KSB-IC. The study would entail obtaining channel catfish
from a hatchery and dividing them into two groups - fed and unfed.
The fish should be placed in cages and one set of fish from each
group suspended in the water and another set placed on the bottom
sediment. Another experiment would repeat the above except the
bottom sediment upstream from the cages would be disturbed on a
regular basis over a period of several weeJcs.
V .
The combination of field and laboratory studies could provide
an insight into the relationships, between uptake (ojr, DDT.
concentrations in fish) and (1) DDT in the in situ sediment versus
suspended sediment, (2) the effects of various concentrations of
DDT in sediment, and, (3) the effects of sediment isolation
(covering). Prior to the initiation of an uptake study, detailed
literature searches and discussions with experts in this field of
study must be undertaken to thoroughly define the objectives and
parameters of study.
4-19
-------
4. 6 Utilization of Data Base
The primary uses of the data to be collected in this project are
to help identify appropriate remedial measures and to" develop a
long-term monitoring program for the area. Migration of fish into
and out of the HSB and 1C has been suggested as one of the two
mechanisms by which DDT uptake in TR fish may be occurring (11-173).
The other is in situ exposure. Data concerning species diversity and
abundance collected from sampling of the study area will be used to
discuss the mechanism (in situ and/or migration) through which DDT
contamination in the fish occurs.
Some data has already been obtained through preliminary
sampling (Recra, June and July 1982). First, channel catfish have
been observed and collected for analysis at the Dodd Road bridge
* •
section of the ESB (Site 4). The capture-of channel catfish is the
+.
firstvdirect evidence that these fish are present in at least the
downstream. portions of Reach A during some parts of the year.
Second, young~cf-the- year largemouth bass and'"catfish" have been
found in the vicinity of the old DDT plant on the HSB '(Site 3).
Future fish collections in the spring may provide additional
evidence concerning the life habits of fish in the HSB-1C area. The
year-long sampling program in the Proposal may yield the data on
which to base conclusions on the significance oJE fish migration.
More importantly, the data will allow one to assess and monitor
the effects of whatever remedial actions are selected. A data base
4-20
-------
will have been developed concerning types of fish common to each
sampled section of the HSB and 1C and levels of DDT in certain fish
for use in the long-term monitoring program and also for purposes of
evaluating the short- and long-term environmental assessment (see
Section 7.0).
4-21
-------
5.0 IN SITU SEDIMENT SAMPLING PROGRAM
5.1 Introduction
As a means of assessing the regional DDT concentration
distribution and the potential for significant physical DDT
transport, an in situ sediment and water sampling program was
"conducted as a part of the W.A.R. Report. The areas investigated
include TR and tributaries (both upstream and downstream of the IC-
TR confluence) in Wheeler Reservoir, the downstream Wilson
Reservoir on the TR, and the upstream Guntersville Reservoir on the
TR (V-Task 3) .
The vertical distribution of DDT (and soil particle gradation)
within the in situ channel, and overbank area sediments is an
important historical indicator of hydraulically related activities.
Analysis of in* situ sediment can provide evidence on the type and
character of the DDT sediment ' deposition and the consequent
potential for sediment erosion. For example, recent depositon of
non-DDT containing sediments_over DDT-containing sediments could be
an indication that significant, active DDT isolation is occurring.
It can also indicate where scouring, which may expose sediments
containing DDT, is occurring.
The influence of sediment core compositing (vertical and
horizontal), a technique sometimes used by W.A.R., masked the
relationship between more heavily contaminated core fractions with
depth, location, or along significant transect lengths. _The
5-1
-------
approach to sediment sampling focuses, not on the areal distribution
of DDT but, more importantly for evaluating possible remedial
actions, on the vertical distribution of the DDT in the upper
(usually more erodible) six inches of sediment. It is not the intent
of the Proposal to recalculate the quantity of the DDT reported
present in the HSB-IC system. However, a more accurate vertical
profile of the DDT present must be known to determine the most
appropriate types of, and locations for, remedial actions.
The stream flow characteristics will dictate the size and
distribution of the in situ sediment that is likely to be placed, and
remain, in suspension. By determining the in situ particle sizes
(and the associated DDT) susceptible to hydraulic transport, a
proposed remedial action measure can be designed to prevent DDT
transport. The lack of data defining the relationship between DDT
+
and sediment characteristics is a significant problem in Reach B and
Reach C because remedial actions may need to be more selective and
specific in.-these areas. ... -...„.-. .- - -
The sediment sampling program is designed to incorporate the
information available from the existing data base, i.e., DDT
concentration and areal extent, and to obtain additional in situ
sediment data required to design cost effective remedial solutions
for the HSB-IC areas.
The method for development of remedial actions in this Proposal
dictates a more detailed, site specific understanding of the in situ
5-2
-------
and background sediment conditions in the HSB-IC system which is not
presently available from the existing data base. This involves the
acquisition of information necessary to address several concerns
associated with the development of remedial actions. These concerns
are as follows:
(1) What is the interaction between the DDT-containing
sediment and the overlying water, i.e., is sediment
available for resuspension and transport?
(2) Do the sediment character and sedimentation rates above
Dodd Road differ from that downstream?
(3) What is the physical and chemical character of the
sediment upstream of Patton Road?
(4) Are there sources of DDT-containing sediment upstream of
Patton Road? If so, what is the significance?
(5) What is the concentration of DDT in the sediment in the
ponded areas and in the reaches of tributaries entering
Indian Creek? Are these areas, such as isolated embayment
areas, potential sinks for DDT-containing sediment?
(6) What is the past sedimentation history of the HSB-IC
system and in what way does this relate to the physical
character of the in situ sediment?
(7) What is the effect of sewage treatment plant effluent on
• • • -••• DDT-avail ability and movement? — — '" '
(8) What effect does stormwater . from the HSB-IC basin
(including the city of Huntsville) have on the transport
of DDT?
5.2 Specific Objectives
The preceding discussion identified those concerns that must
be considered and investigated further. The expansion of the
existing data base will permit development of effective remedial
actions for the HSB-IC system. The specific objectives for the in
situ sediment sampling program are as follows:
5-3
-------
• determine the relationship bet'veen the DDT
concentration and particle size/soil type,
above and below Dodd Road (including 1C);
• determine the organic content in the sediment
and its relationship to DDT;
• determine the vertical DDT concentration
gradient in the sediment within the HSB-IC
system (with special emphasis on each one inch
layer in the top six (6) inches of sediment);
• determine the physical character of the
sediment available for transport within the
HSB-IC system, e.g., moisture content,
specific gravity, flocculation of clays;
• determine physical and chemical character of
channel sediments upstream of Patton Road to
Martin Road;
• establish DDT concentration in the ponded areas
and in the reaches of tributaries entering
Indian Creek;
• obtain knowledge of the past sedimentation
history within the system; and .
+.
• determine if sedimentation or scouring is
occurring in Reaches A, B, and C.
'5.3 Utilization of W.A.R. Data
As previously noted, the W.A.R. Report has.divided the HSB-IC
system into three specific areas, viz., • ICM 0.0 to HSB-IC
confluence, HSBM 0.0 to 2.4, and HSBM 2.4 to 5.4. These areas are
referred to as Reach C, Reach B, and Reach A, respectively. In
addition, this program will include evaluation of an area upstream
of Reach A, i.e. ; HSBM 5.4 to 9.7..
As described in the .W.A.R. Report (11-77), the surface
hydrologic regime can be divided into four major categories:
5-4
-------
channel, overbank, ponded, and floodplain. The terminology used,
with some modification for special situations, is defined as
follows:
" • Channel Areas - areas confined by well-defined
banks as determined from the transect profiles
and generally occupied by flowing water.
• Overbank Areas - areas outside of well-defined
channel banks, with or without a permanent
vegetative cover, periodically inundated as a
result of reservoir operations on the Tennessee
River and upstream streamflow conditions.
• Ponded Areas - areas generally inundated with
standing water and hydraulically connected to a
stream channel.
• Floodplain Areas - areas below the 100-year
flood evaluation as determined by TVA in the
course of this study."
These definitions will be used throughout the remainder of this
-disrussion for consistency with the W.A.R. Report.
^
.The data base generated during the W.A.R. Report generally
eliminates the need to determine the areal distribution of DDT
concentrations. -Exceptions-to-this are selected--iwcatioris within
Reach C and Reach B and upstream of Reach A which were -not fully
investigated during the W.A.R. study. These areas specifically
include the ponded areas and the lower reaches of tributaries in
Reaches B and C and the stream channel in the area upstream of Reach
A. The sampling program will emphasize the investigation of the DDT
concentration gradient in the top six (6) inches of sediment, the
associated physical character of the sediment and past
sedimentation history.
5-5
-------
5.4 Program Design
5.4.1 Sampling Locations
Data collected at selected sampling locations will supplement
the W.A.R. data base. The sampling locations will.include areas of
hydraulic interest such as channel bends, embayments, and
floodplains where sedimentation, erosion and/or fish spawning may
occur. The proposed sample locations will be provided to the RP.
Additional in situ sediment core sampling locations may be
selected during field activities in the HSB-IC system, after.
collection and analysis of the respective DDT concentration levels
and sediment gradations of the proposed samples, and during
development/design of remedial actions.
Within the stream channel of the HSB-JC system, the proposed
sampling locations will be spaced between the existing W.A.R.
transects. Proposed sampling sites within Reaches B and C will also
be located in ponded areas and lower reaches of tributaries to
bbtaln"data" aharogous to that collected within the channel and to
determine if these areas are potential sinks ("hot spots") for DDT.
The data necessary to make this determination have not previously
been obtained. The data must be obtained because these locations
may be fish habitats and may require the development of remedial
measures in discrete locations. Overbank and floodplain areas in
Reaches B and C will also be sampled.
5-6
-------
In Reach C, several overbank and floodplain sampling sites will
be selected. Although this area has been extensively investigated,
sampling at these locations will provide data on the physical nature
of the sediment and DDT concentration in the top six inches and will
complement the data to be obtained from channel sampling. The core
samples obtained at these selected sites will be examined to
determine the past sedimentation history of the HSB-IC system.
5.4.2 Sampling Frequency
This program is expected to be conducted in a single sampling
period of three or four weeks duration. As the project progresses,
additional samplings may be needed and conducted.
5.4.3 Sampling Protocol
Transects will be established across the HSB-IC channel and
.tributaries at the s..tes selected. Sonar recordings and manual
4k
probing will be conducted to map the sediment deposition. Sampling
locations will be marked in the field for identification and
..recorded, in .a bound field log book and o-n Sr site topograph-icr-wap- -
Conventional surveying techniques and/or aerial photographs of the
sampled areas will later be performed to verify sampling locations.
The water surface profile and elevations will be obtained from the
stream stage recording equipment discussed in Section 6.0.
Subsequently, the elevations of the extracted sediment cores will be
determined by subtracting the water depth at the sample locations
from the water surface elevation.
5-7
-------
Samples will be obtained in areas of the deepest sediment
deposits on each transect. Replicate samples will be taken to
insure that sufficient sample volume has been obtained to conduct
all analyses. In addition, there will be several sampling points
across each transect in order to insure that the transect is fully
defined.
A gravity-type sampler will be used to obtain core samples at
all locations. Briefly, this type of sampler consists of a top
section containing an encapsulated ball valve which creates a
partial vacuum necessary for retention of the sample when the unit
is retrieved, a- coring tube with a plastic liner insert attached to
the top section, and a retaining basket and cutting shoe attached to
the coring tube.
Depending on the depth of the wat*r at each sample location,
^
the method used to obtain the desired sample depth will vary. Where
the water depth is sufficient, a weighted sampler will be allowed to
-•free fall-f rorr;--£- -bcra-L--through-the WcTtrer" whic'h" penetrates the b"ottom
sediments to the desired sample depth. If free-fall sampling does
not achieve sufficient core depth, the sampler will be manually
advanced until the desired core depth is achieved. Where the water
is shallow, the sampler will be manually advanced to obtain the
desired depth of penetration.
Once the sampler and sample column have been retrieved, the
plastic liner that encapsulates the sediment sample will be removed
5-8
-------
from the core tube and a "new liner inserted for the next sample
location. While in the field, the entire sample column will then be
removed slowly from the plastic liner by the following procedure:
extraction from the top to minimize the possibility of smear effects
on the core, scraping of the perimeter of the sediment core to
minimize the possibility of contamination from the plastic liner,
such as phthalate esters, and separation at the desired depth
fractions, viz., 0"-1", l"-2", 2"-3", 3"-4", 4"-5", 5"-6", and 6"-
12". ''
Each sediment sample will be visually characterized -and the
following information will be noted in the field log book: sample
location, sample number, sample depth, and sample description. Each
depth fraction of the sample will be placed in a scrupulously
cleaned, w.. de-mouth, screw-capped, glass" bottle with a TEFLON-lined
•4*
lid, which will be labeled, securely packaged and chilled. Sediment
samples will be transported, via air freight, to Recra Environmental
In order to assure that the required sample volume necessary to
fulfill both physical and chemical analyses is obtained, multiple
core samples (probably five to six) will be obtained in close
proximity to each sampling location.
i
Another objective of the sampling program. is to define the past
sedimentation history within the basin. This information will be
acquired by obtaining core samples through the recent stream
5-9
-------
deposits and, if possible, into the underlying material. This core
will be obtained by gravity type sampler or other manual core
sampling devices. The core will be retrieved, left in the plastic
tube, capped, properly labeled, frozen and returned to Recra
Environmental Laboratories, Tonawanda, New York for later visual
"* and, if necessary, microscopic identification.
5.4.4 Analytical Parameters
Samples will be thoroughly homogenized and split prior to
physical and chemical characterization. One part of the homogenized
mixture will be used to determine DDT concentration. The analytical
procedure for DDT has been stated previously in Section 3.0. The
analytical procedures for volatile solids content, Method 208E,
described in Standard Method for the Examination of Water and
Wastevater, 14*th Edition, APHA, AWWA, WPCF, will also be performed.
In addition, the organic content of the sample will be determined by
v
the procedures stated in Section 3.0.
The remaining portion of the^.m.i,xture jwilj. be_divide.d.>in half*
One half will be placed into a clean glass bottle, as described
previously, labeled, refrigerated, and kept for possible future
analyses. The other half of this subsample will be used for physical
characterization. The physical soil properties of concern are grain
size, specific gravity and moisture content. Grain size
distribution will be obtained via an electronic particle size
procedure using a Sedigraph particle size analyzer. Specific
5-10
-------
gravity and moisture content will be determined by procedures
described in ASTM-D-854 (Test for Specific Gravity of Soils) and
ASTM-D-2216 (Laboratory Determination of Moisture Content of
Soils), respectively. *
5.5 Utilization of Proposed Data Base
This in situ sediment sampling program has not been designed to
duplicate the existing W.A.R. data. The program was developed to
expand the present data base to enable the assessment-of proposed
alternate remedial actions for Reach A, Reach B and Reach C.
Information developed from the physical properties of the
* Reference: American Society of Testing and Materials, Part 19
5-11
-------
sediment in the HSB-IC system, knowledge of past sedimentation and
the hydraulics of the HSB-IC system are required as inputs to this
assessment.
Information obtained concerning grain size versus DDT
concentration and the DDT concentration variation with depth will
enable the determination of whether the DDT in the top six inches is
ubiquitous, whether recent deposition covered DDT sediment, and
whether the sediment is available for resuspension, erosion,
transport and deposition. In addition, establishing the properties
of the surficial in situ sediments is required for long-term
monitoring after any necessary remedial actions are implemented.
The information developed concerning any "hot spots" that are
hydraulically connected to the main stream channel in Reaches B and
/
C will enable the assessment of the need for localized remedial
^
programs.
. A map of the areas, i.e., Reach A, Reach B, Reach C, and
-^upstream of Reach A, will be prepared to s'h~6w~DD°T"~avaYlable fo'r
transport or available to water or unavailable for either.' This inap
will illustrate the significant findings of the field data
collection programs (fish and sediment). W.A.R. data will also be
included. This will facilitate development of appropriate remedial
action plans to address field conditions. The .map will be a planning
tool for the selection and evaluation of potential remedial actions.
5-12
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6.0 SUSPENDED SEDIMENT TRANSPORT/WATER SAMPLING PROGRAM
6.1 Introduction
The W.A.R. investigation contains HSB-IC field measurements at
several in-place stream gaging stations which indicate the temporal
variations of DDT transport-related parameters (W.A.R. Appendix V,
"Task 6). These measurements include stream stage elevation and
stream velocity (and discharge) for seven (7) storm events and
related DDT concentration, total suspended sediment, and volatile
solids concentration for the last three (3) of .,seven (7) storm
events. Channel sampling of bedload material, which included solids
load and DDT concentration was also conducted in the field for four
(4) storm events. However, the bedload contribution to total
contaminant transport was determined to be negligible (W.A.R.
*
_Appendix II, p. 11-122).
W.A.R. statistically analyzed the river hydrology and sediment
data for trends and correlations. From this analysis, sediment
. transport, .was found to be the major rpu.te__£ojr_.DP.T ..movement.,. _. This.
analytical hydraulic modeling of the HS3-IC system provided the
input for quantifying contaminated and uncontaminated sediment
transport under existing conditions.
Additional data collection and analysis of sediment transport
data are required prior to the selection and design of remedial
actions. The transport of sediment during non-storm events must be
assessed. In addition, additional storm event data is required in
6-1
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order to -provide a complete picture of sediment transport in the
HSB-IC system throughout the year.
Advanced numerical computation techniques (computer modeling)
will be applied to the modeling of the HSB-IC sediment/hydraulic
system. This approach provides the greatest advantage because
parametric variations can be more effectively and expeditiously
evaluated. Mathematical representations of complex real world
conditions are necessary and are accepted in practice. Several
theories have been advanced to describe the sediment transport
phenomena. They are discussed in ASCE Manual No. 54(1975),
Sedimentation Engineering.
The suspended sediment .study will determine the rate and
quantity of DDT sediment that is hydraulically transported through
and from the HSB-IC system. This data, in turn, provides the basis
for identifying and relating the principal hydrogeologic parameters
and processes contributing to DDT sediment transport. Remedial
action measures, as appropriate, can then be formulated to address
these effects. The suspended sediment sampling program for non-
storm events and storm events in conjunction with fish monitoring
(Section 4.0) and in situ sediment sampling (Section 5.0), has been
developed to collect the necessary data. This data will be
supplemented by the storm event data reported by W.A.R. The field
s
measurements for determining the hydraulic transport of DDT
sediment will be conducted monthly over a year's period of time in
6-2
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order to ihclude a range of seasons, flows and reservoir pool
elevations in the study. Olin's storm and nonstorm events data,
when combined with the W.A.R. storm event data, should provide a
complete picture of sediment and DDT transport throughout the year.
The information developed during the sediment transport study
will be used to address several concerns which include the
following:
• How do stream flow conditions affect sediment
transport?
• Are storm events more significant than normal
day-to-day flow with respect to DDT transport?
6.2 Specific Objectives
The specific objectives of the suspended sediment transport
study are as follows:
• define the rate of transport of DDT and
suspended sediment through and^out of the HSB-
IC system with respect to time of year and flow
conditions such as stage elevation, storms,
reverse flow, etc.
..? .._ determine particle size . distribution-- - of
suspended sediment.
• quantify the concentration of settleable and
non-settleable DDT in the water of HSB-IC.
• determine the relationship between DDT and
particle size/soil type.
• develop a computer model of HSB-IC which
simulates DDT/sediment transport.
• develop design data for remedial actions which
will minimize sediment transport.
The Proposal, as related to the sediment transport program in
6-3
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the HSB-IC system, entails several components. Most importantly, a
sediment transport model must be developed for an accurate
prediction of sediment distribution and movement. The
determination of sediment deposition rates is necessary to quantify
the present situation and monitor subsequent in situ
burial/isolation of DDT sediments in any remedial action
undertaken. Based upon the stream/basin hydraulic characteristics,
determination of the relationship between DDT concentration and
particle size/soil type will be used to assess which sediments are
settleable, which are susceptible to transport, .and which surficial
in situ sediments, if containing DDT, possess the potential to be
re-entrained for fluvial transport. The flow regimes and areal
distributions of sediment characteristics are variables requiring
-y'urther consideration for a definitive assessment of conditions now
A
existing. The factors will provide the inputs for effective
engineering design of proposed remedial actions.
--• The'jjtse'd for, "feasibility'of and" e'f f ectiveness of any remedial
alternatives can best be determined by establishing a sound data
base with which long-term monitoring data can be compared. The
study will provide data which will permit an accurate evaluation of
Reaches A, B, and C. W.A.R. Report data will be utilized, to the
extent possible, in support of this work.
6-4
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6.3 Program Design
The suspended sediment sampling program consists of four
phases which are as follows:
• non-storm event water sampling
• storm event water sampling
• stream elevation and flow velocity measurements
• computer modeling (simulation of the HSB-IC system)
The first three phases will be data development and the fourth phase
will be the evaluation of that data.
6.3.1 Sampling Locations
The suspended sediment sampling program is designed to provide
information on the quantity - of sediment and the physical and
chemical characteristics of the sediment in transport for non-storm
.and storm related events. Each sampling.site will be located at or
near a TVA gauging station which will provide accurate information
on stream velocity (discharge) and stage elevation coincidental
with., .each . sampling... event. TVA.- vill-..op£rate and. Tnaintain.Jthese.
stations on a reimbursable basis. Within the HSB-IC basin (Wheeler
Reservoir), the stream gauging stations which have been selected for
reactivation by the TVA are:
6-5
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• ICM 0.38, near IC-Tennessee River confluence
• ICM 4.6, Centerline Road Bridge
• ICM 8.2, Martin Road Bridge
• HSBM 2.4, Dodd Road Bridge
• HSBM 5.0, Boat launch on HSB at Road No. 5669
HSBM 5.9, Patton Road Bridge
• HSBM 9.75, Martin Road Bridge
The transects at the above stream locations are distant from
any upstream confluences or conditions which would affect the
relationship between sediment transport rates and the pertinent
hydraulic variables. These are deemed suitable for providing
consistent and interpretable suspended sediment data. -In addition,
these sample locations correspond to the fish sampling locations.
6.3.2 Sampling Frequency ^
j?he sampling process employed at each transect is inherently
controlled by the variable hydraulic conditions of flow velocity and
stage elevation. Stage elevation data will be collected
continuously for one year by the TVA stage recorders. Flow velocity
data will be collected monthly by TVA personnel at Olin's expense.
This data will be collected using the same methods and personnel as
in the W.A.R. Report. .The time intervals for suspended sediment
data collection will occur coincident with the TVA stream velocity
measurements. For the latter collection, it is presently estimated
that one-month intervals will be utilized for one calendar year. In
addition, storm event sampling will be conducted.
6-6
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A schedule for the collection of recorded hydrological data
will be designed and established by TVA as a function of the type of
stage recording instrumentation selected. In general, the schedule
will be dictated by the servicing of the recorder power source(s),
the recording pen reservoir (if so equipped) or sensor or stylus,
and replacement of a recording chart and retrieval thereof. At
present, this appears to be a weekly function. The same methods and
TVA personnel used to gather data for the W.A.R. Report are being
used in this study.
6. 3.3 Sampling Protocol
The suspended sediment sampling described herein represents
standards and methods developed by the Federal Inter-Agency
Sedimentation Project (F.I.A.S.P.) of the Inter-Agency Committee on
_Water Resources (Guy and Norman, 1970). .The intended use of these
^
procedures and methods is to provide sediment-water samples for
physical and chemical analytical testing to define: DDT and
suspended sediment, cp.nci.entra±i OTIS at a .given location-a-nd time,-and
DDT and suspended sediment quantities transported per unit time past
a given location.
U.S.-series time-integrating suspended sediment samplers will
be utilized in either point or depth-integration methods to obtain
flow proportional samples at the locations described in Section
6.3.1. Point sampling methods are preferred for low stream velocity
conditions. Consistent with procedures developed for the equal
6-7
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transit rate (ETR) method of sampling for the U.S.-series samplers,
each stream section will be divided by several equally spaced points
(verticals). The number and location of the verticals will be
determined for existing field conditions and from the sampling
protocol.
Samples will be obtained at the verticals by lowering and
raising a sampler at an equal transit rate (depth integration). This
technique requires a knowledge of the immediate stream channel
profile, stage height, and mean flow velocity prior to each sampling
event. The suspended sediment program will be developed to
coordinate field sampling with the scheduled TVA hydrological data
collection (Section 6.3.2).
Existing data on channel form, stage elevation, and mean
.velocity suggest use of the U.S.-rseries depth-integrating
A.
sampler(s) USDK-59 and/or USDK-48 (National Handbook of Recommended
Methods for Water Data Acquisition, 1978). Each is designed for use
with a.473_.m£ glass_b.o_ttle f or..sampj-e..co.l].ec.ti on,-. -A-..separate -bottle •
will be used at each vertical and the total group of transect bottles
will be composited to yield a sample proportional to the total
stream flow.
The method of depth integration, used in the ETR method, is
limited to a stream depth of approximately 15 ft. If conditions
arise which exceed this limit, point integration samples (US P-72)
will be utilized to depth-integrate in a single direction (up-
6-8
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transit) or to obtain point-integrated samples at the centroids of
equal discharge increments, such as 0.2 and 0.8 or 0.6 of the stream
depth from the water surface. This technique is covered in the
method and will not result in a decrease in accuracy.
Alternatively, point sampling at stations with low stream
velocities will be accomplished using a pump-type'sampler that has a
high intake velocity relative to the stream velocity at 0.6 of the
stream depth.
Methods and personnel employed by TVA in collection of
hydrological data are expected to be the same as, or at least
equivalent to, those methods utilized by W.A.R. (V-Task 6).
Discharge measurements were taken using standard procedures as
specified in the U.S. Department of the Interior, Geological Survey
»
.Water Supply Paper 888, Stream-Gaging Procedures, A Manual
Describing Methods and Practices of* the Geological Survey,
Washington, D.C., 1943. Procedures for calculating depth, mean
velocity and discharges, are alsj? .given j.n.£b£.s_.!nanua]_^ . . .._,..
All bottles will have a cap lined with TEFLON or aluminum foil
and will, be cleaned following the procedures suggested by TVA in
their 1978 study, "DDT Residues in Sediment and Fish in the Vicinity
of Redstone Arsenal, Alabama." Site identification, date, time,
station section, bottle number, and initials of field crew members
*
will be noted on each bottle's label. It is estimated that 10 liters
of water will be required to provide sufficient volume for the
6-9
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analysis. Samples will be 'stored in ice immediately after
collection and will remain as such until received at the laboratory.
Samples will be refrigerated at 4°C at the laboratory until physical
and chemical analyses have been performed.
6.3.4 Analytical Parameters
As indicated in the Quality Assurance Program (Section 3.0),
the primary analytical parameters to be determined for composited
samples at each transect are DDT concentration and total suspended
solids. If a sufficient sample volume of sediment is available,
suspended sediment particle size will be determined. The analytical
protocols are cited by reference in Section 3.4.3.
6.4 Utilization of Proposed Data Base
Field data supplied by the W.A.R. investigation and this
* •
suspended sediment sampling program wi.ll provide representative
^
inputs of the KSB-IC average stream hydraulic characteristics and
will enable proposed remedial actions to be developed as well as
_establi.sb. the baseline conditions, -for -post-construc*icn~Sfonitorrng-
of remedial actions.
The utilization of the data base to determine the type and
predicted effectiveness of any proposed actions is of paramount
importance. Hence, descriptions of the fundamental principles,
concepts of sediment deposition, and methodology employed in the
assessment of the proposed remedial action effectiveness are herein
provided.
6-10
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In general, the in situ sediment that is available for
hydraulic transport (in suspension) is a function of the
hydrodynamic forces directly acting upon discrete sediment
particles. Entrainment of the sediment is primarily dependent upon
the sediment properties (such as particle size) - stream velocity
relationship; that is, the higher the velocity the greater the
maximum particle size to be placed in suspension, while
simultaneously increasing the quantity of finer_grained sediment.
By maintaining stream velocity and turbulence of the water, sediment
particles (up to a certain maximum size) will remain in suspension.
High stream discharge/velocity conditions normally degrade or erode
the channel sediments. Low stream discharge/velocity creates
conditions conducive to sediment deposition.
6.4.1 Computer Modeling of HSB-IC
The in situ sediment sampling program and the water sampling
program will generate a significant quantity of data on the HSB-IC
system. In order to utilize this data to the greatest extent, the
development of a computer model of the HSB-IC system is planned. The
general programming scheme is as follows:
1) Identify a computer model applicable to the HSB-IC
system.
2) Modify the program (if necessary) to incorporate • the
significant characteristics of the HSB-IC system.
3) Verify the model with field data collected during the
field sampling program.
4) Modify program to include potential remedial actions.
6-11
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5) Evaluate effectiveness of potential remedial actions
. under various flow conditions.
The computer model can assist in evaluating the effectiveness
of potential remedial actions (and combinations of remedial
actions).
Any computer program which is used to model a system must
accurately simulate actual characteristics of the system. The HSB-
IC has several unique and important characteristics:
• reverse flow occurs in the system
• fine particles (clays and silts) make up a
significant portion of the sediment load
• transport of DDT in absorbed or dissolved forms
• water flow (and sediment transport) in both
channel and overbank areas
Several computer models have been reviewed to determine if they
are applicable for modeling the HSB-I-C system. All available
^
computer models have certain limitations when applied to the HSB-IC
system. Any computer model chosen may require, programming __._^ _.
-— • T •••• — • ' • • ..-..»• —~• - • ———* H-- ' • . .' -
modifications. However, a computer program developed by- the
<
Hydrologic Engineering Center, Corps of Engineers has been
identified as possibly applicable for simulating the HSB-IC system
and for predicting the effectiveness of the proposed remedial
actions. The program is entitled "Scour and Deposition in Rivers
and Reservoirs, HEC-6". A descriptive abstract of the program is
presented below, along with the theoretical methods that are used to
compute the trap efficiencies for silts, clays, and sand for any
proposed containment structure, e.g., dam.
6-12
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The total sediment load is transported along a stream. Changes
in the stream's bed elevation and water surface profile with respect
to time are calculated at each cross section considering the
following': the inflowing water discharge, inflowing sediment load,
gradation of material in the stream's bed, armoring, and destruction
of the armor layer. A series of reservoirs in tandem can be
utilized. A dredging option is available. Diversions of water can
be specified and inflowing water and sediment can be entered at
tributary junctions. Clay, silt, sand and gravel sizes are
transported and cooble sizes can be included for armor calculations.
The program is dimensioned for up to 150 cross sections, 15 grain
sizes, 20 tributary inflow points and 20 reservoirs in tandem.
Water surface profiles are calculated by the standard step
•method. The bed material load is calculated by either Toffaleti's
^
application of the Einstein Bed Load function, Madden's
modification of the Laursen Transport Relationship or a transport
"••Capacity"'per "foot" of width" versus the depth-slope product. Based
upon an assumption of steady state, the silt and clay sizes are
transported until the shear stress on the streambed becomes less
than critical. Deposition then begins using fall velocity as a
variable in the exponential decay function. Changes in the bed
elevation are calculated with the Exner eguatioA for continuity of
sediment material.
6-13
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The preceding computer program 'may require a slight
programming modification in order to incorporate the sediment
resuspension aspect. Another drawback of the model is its inability
to handle backflow. This must be investigated further.
The applicability of other relevant programs and/or theories
are actively being evaluated to determine their applicability to the
HSB-IC system.
6-14
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7.0 REMEDIAL ACTION APPROACHES
7.1 Introduction
Previous sections of this document have presented a review of
information from the W.A.R. Report and the specific investigative
activities which will be completed in this project in order to
provide site specific data of the required degree of accuracy and
precision to evaluate and assess remedial action alternatives for
Reaches A, B, and C with the HSB-IC system.
The fundamental methodology for determining an acceptable
remedial action is to completely assess the feasibility of
alternative remedial approacnes. The objectives of the sampling
program are directly relevant to and essential for both engineering
design inputs and a full understanding of existing conditions. In
-this respect, the combination of existing site information as
A
provided by the W.A.R. Report and design data inputs resulting from
the fish, in situ sediment and suspended sediment sampling programs,
will provide necessary information for develbpment of 'remedial
actions and will permit demonstration of the adequacy and
effectiveness of any remedial action options.
7 .2 Overview of Action Considerations
The study, the selection, and the design of the most
appropriate remedial action alternatives for Reaches A, B, and C are
by no means simple tasks. In the previous sections, the overall
project objectives, the project approach, the hypotheses to be
7-1
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tested, the data to be collected and the utilization of that data
were discussed in detail. All of this was directed toward the
development of remedial actions for the HSB-JC system.
Any "suggested" remedial action for Reaches A, B, and C would
be premature. They are very much dependent upon the outcome of
investigative programs covered in this Proposal. The types of
remedial actions that may be warranted and investigated include:
isolation of DDT "hot spots" in the stream channel; removal of DDT
"hot spots" from the stream channel; isolation of DDT-containing
embayment sediments; diversion; enhanced channel and out-of-channel
sediment deposition through artificial means; and sedimentation
devices. Other remedial actions may also be developed and evaluated
as the study progresses.
* 4
The evaluation process for selecting remedial actions will
also take into consideration future changes in the HSB-IC drainage
v
basin that may significantly affect the characteristics of the HSE-
_ICI .system. _ One of these changes is. .the,.p.o.tentiai_diversion of-the-:
discharge of the Huntsville POTW directly to the Tennessee River.
This action would significantly reduce the base flow in HSB although
the peak flows would not be materially affected unless there is
diversion of Huntsville storm runoff. It would also eliminate a
source of organic matter which may have an affinity for DDT. The
effect of the diversion on flow and sediment transport and on
potential remedial actions will be 'evaluared using the computer
7-2
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model. It will also be evaluated conceptually using
engineering/physical principles such as flow velocities, direction
of flow, etc.
7 .3 Long-Term Envlronmental Monitoring Program
Throughout this Proposal, reference is made to the long-term
environmental monitoring of the HSB-IC system. The purpose of the
long-term environmental monitoring plan is to determine the
effectiveness of the implemented remedial actions, to assess any new
or residual environmental impacts or hazards, and to identify the
needs for additional remedial actions. The long-term monitoring
plan will, if appropriate, measure the rate of change in DDT levels
in fish, migration of DDT in sediments and water, or the dynamics and
proportions of DDT components in the sediments, water and biota of
-Huntsville Spring Branch, Indian CreeTc and Wheeler National
A
Wildl-ife Refuge, depending upon the remedial action chosen. The
long, term monitoring program developed will continue until the
termination of the ConsemrDe'cree": ''"" "'" ' * ' "~"
For the purposes of the long-term 'environmental monitoring
plan, baseline conditions shall be those levels of DDT in fish,
water, and sediment determined during the Olin study supplemented
with data from the W.A.R. Report. The results of analyses performed
under the long-term monitoring program will be compared with
baseline data to evaluate the effectiveness of remedial actions.
7-3
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The types of samples and the sampling and analytical protocols
of the long-term monitoring program will be the same as those
detailed in Sections 3.0 through 6.0 with the exception of sampling
frequency and the groundwater program. The sampling frequency and
the groundwater program are discussed below.
Although an accurately defined time frame and completely
developed program cannot be established at this time, a long-term
monitoring plan which is similar in concept to the fish, in situ
sediment, and suspended sediment sampling programs in Sections 4.0,
5.0, and 6.0, respectively, is contemplated. It is presently
envisioned that DDT concentrations (both total, filterable and non-
filterable) and the suspended sediment concentrations in the
surface water will be determined from samples collected at semi-
»
annual intervals at the seven selected'locations indicated in
4k.
Section 6.0. For the fish species, DDT concentration levels will be
determined on an annual basis following implementation of any
remedial acti-ons. Sampl-ingr locations wii'i~'b"e"~as~ discus'sed~in"
Section 4.0. In situ sediment sampling maybe conducted on-an annual
basis at selected locations corresponding approximately to those
presented in Section 5.0. Quantitatively, the number of sample core
locations will be fewer than indicated in Section 5.0 but will
include points common to both this Proposal and the W.A.R.
*
investigation. The analytical parameters to be determined will be
DDT concentration variation with depth, and soil particle size
7-4
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distribution with depth. The latter will be indicative of the type,
rate, and extent of the suspended sediment deposition. A relative
comparison of DDT parameters over time with the baseline conditions
established under this Proposal will indicate the rate of
effectiveness of the remedial action, e.g., the sediment transport
model predictive capabilities, the HSB basin sediment deposition
rates, and, most importantly, the rate of reducing the DDT
concentration levels in fish in specified areas to 5 ppm.
7.3.1 Groundwater Monitoring
The groundwater in the vicinity of HSB-IC will be monitored to
determine if construction and implementation of any remedial
actions affect DDT in groundwater. The monitoring program shall
consist of water samples taken from existing groundwater wells (RS
20, .RS 22, RS 23, RS 27, RS 30) and drinking water wells (X 37, X 44,
^
Q 79,"U 67 and U 98) (see W.A.R. Report 11-74 and EPA memorandum
dated October 9, 1979 entitled "Transmittal of the Public and
Private Water Supply Investigation, Redstone Arsenal and Vicinity,
Huntsville, Alabama Area"). RS 30 is upgradient of the DDT source
area, RS 27 is immediately downgradient of the source, RS 22 and RS
23 are a downgradient shallow/deep pair at Huntsville Spring Branch,
into which the groundwater flows, and RS 20 is an additional
downgradient shallow well at the Branch. If any of these wells are
found to be dry or damaged, alternate wells may be sampled.
7-5
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All wells will be sampled once in 1983 and once every two years
for up to ten years after completion of construction.
The wells will be sampled with a peristaltic (surface) pump
using a dedicated, disposable inert sample tube. Each well will be
flushed until it is dry or until 2-3 well casing volumes (about 12
gal.} have been evacuated. Sampling will then be done for DDT. Each
sample will be filtered at the laboratory through a 63y filter prior
to analysis to remove suspended solids. Sample handling and
analysis will be conducted according to the procedures specified for
water samples in Section 3.4.3.
7.3.2 Measurement of Performance Standard
The performance standard "is a DDT level of 5 ppm in fillets of
channel catfish, largemouth bass and-smallmouth buffalo in Reaches
'A, B, and C. Olin shall be deemed to "attain the performance
4*.
standard" when the average DDT concentration in the fillets of each
of the aforementioned fish species is five ppm (or less) in Reaches
A/ B, and "C. "Continued attainment of the performance ~s~tahBard""~"""
occurs when the average DDT concentration in the fillets of each of
the aforementioned fish species is five ppm (or less) for three (3)
consecutive years (including year of attainment) in Reaches A, B,
and C.
The average DDT concentration of a species will be determined
as an arithmetic mean concentration of DDT in the fillets within a
species adjusted for the weight of each individual. Mathematically,
this can be represented as follows:
7-6
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cT = Iwici
zwi
where C is the average DDT concentration of a species
W.^ is the weight of fillet of each individual
fish of that species (in grains)
C^ is the concentration of DDT in the fillet
of each individual fish of that species (vg/g)
After continued attainment of the .performance standard is
achieved for each species of fish in each reach (A, B, and C), that
species will no longer be monitored. As continued attainment of the
performance standard is achieved in each reach (A, B, and C), that
reach will be eliminated from the monitoring program.
After individual analysis of the fillets, the average DDT
concentration for each species will be determined and compared to
v
the performance standard. The number of samples of each species to
be analyzed will be determined solely by the quantity caught^ during.
the sample collection. A maximum of six fish by species per site
will be analyzed. If less than six fish are caught and analyzed, the
computed average DDT concentration will be based on the number of
fish caught (one to five) .
7-7
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8.0 ENVIRONMENTAL ASSESSMENT OF REMEDIAL ACTIONS
The size of the study area in which the DDT is reported creates
»
a complex situation involving many components of the environment.
Remedial action(s) may affect the ecology of the HSB-IC system. In
evaluating a proposed remedial action, the RP will assess its
environmental impact. Olin will provide information with respect to
anticipated effects on people and the environment of any actions to
be implemented under the remedy. At a minimum, the information
included will be that set forth in paragraph 52 of the Consent
Decree. Such information will be patterned after the applicable
guidelines under the National Environmental Policy Act, 42 U. S. C.
§§4321 et seq. . currently set forth in 40 CFR Parts 1500-1508 and 40
CFR Part 6.
8-1
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9.0 PROPOSAL TIKE FRAME
To ensure a timely implementation of this Proposal, a
generalized project timeline was developed and is illustrated in
Figure 9.1. The elements of study, in conjunction with the assigned
durations, have been categorized as follows:
A. Fish Studies
B. Suspended Sediment Sampling and Stream Hydraulics
C. In situ Sediment Sampling
D. QA/Interlab Equivalency Program
E. Sediment Transport Model - Development and Application
F. Engineering Development of Remedial Actions
G. Preliminary Design of Remedial Actions
H. Long-term Monitoring Program Development for Remedial
Actions
I. Environmental Assessment of Remedial Actions
*•
J. Report - Recommendations for Remedial Actions
Each particular proposal element will encompass the accomplishment
of those detailed facets described in the preceding sections, and a
- '."....• . ' *
final report of recommended remedial actions to be implemented will
be made.
9-1
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FIGURE 9.1 .
i
;PROPOSED PROJECT TIMELINE
i
1982 1983 ' 1984
TASK JJASONDJFMAMJJASONDJFMAMJ
A. FISH MONITORING
Field, Analytical, Data Reduction
Compilation
B. SUSPENDED SEDIMENT SAMPLING AND STREAM
HYDRAULICS
Field, Analytical, Data Reduction
Compilation
c. IN SITU SEDIMENT'SAMPLING I I . [ I
Field, Analytical, Data Reduction • * •
Compilation
1 D. QA/INTERLAB EQUIVALENCY PROGRAM | |
E. SEDIMENT TRANSPORT MODEL-DEVELOPMENT . | | | |
AND APPLICATION i
Selection, Verification, Application^ .
F. ENGINEERING DEVELOPMENT OF REMEDIAL | |
'ACTIONS
G. PRELIMINARY DESIGN OF REMEDIAL ACTIONS i J
II. LONG-TERM MONITORING PROGRAM DEVELOPMENT . | |
FOR REMEDIAL ACTIONS
I. ENVIRONMENTAL ASSESSMENT OF REMEDIAL | |
ACTION i'
J. REPORT - RECOMMENDATIONS FOR]REMEDIAL pi
ACTIONS L-J
:
I
NOTES: Dots indicate field sampling efforts •. .
Quarterly Progress Reporls will also be prepared throughout project
-------
10.0 REFERENCES
American Society of Civil Engineers. (1975). Sedimentation
Engineering. Manual No. 54.
American Society of Testing and Materials (Published annually),
Annual Book of ASTM Standards, Part 19, Natural Building
: Stones, Soil and Rocks, Peats, Mosses and Numus, ASTM,
Philadelphia, Pennsylvania.
Branson, D.R. (1978). "Predicting the Fate of Chemicals in
the Aquatic Environment from Laboratory Data". Estimating
the Hazard of Chemical Substances to Aquatic Life.
Cairns/Dickson/Maki - editors. American Society for
Testing and Materials, PA.
Bennett, G.W. (1971). Management of Lakes and Ponds. Van
Nostrand Reinhold Co. New York. P. 182-193.
Council on Environmental Quality, Regulations on Implementing
National Environmental Policy Act Procedures. 40 CFR,
Parts 1500-1508.
Eddy, Samual, -How to Know Freshwater Fishes, William C. Brown
Co. 1957.
^
Etnier, David, personal notes on fishes of Tennessee, University
of Tennessee, Knoxville, TN, 1976 (rev. 1982).
Fleming, W.M. and Cromartie, E. (1981). "Fish, Wildlife, and
Estuaries: DDE Residues in Young V7ood .Ducks i\ear a • "
Former DDT Manufacturing Plant". Pesticide Monitoring
Journal. Vol. 14, p. 115-118.
Garrett, G. Lee (August, 1982) personal correspondence to
L. J. Schiffer, re "Guano samples (a/k/a meadow muffins)"
Guy, K.P. (1969). "Laboratory Theory and Metnods of Sediment
Analysis". Techniques of Water-Resources Investigations
of the UjJS^ Geological Survey. U.S. Government Printing
Office. Washington, D.C.
10-1
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Guy, Harold P. and Norman, Vernon W. (1970). "Field Methods
for Measurement of Fluvial Sediment". Chapter C, Book
3. Techniques of Water-Resources Investigations of the
U.S. Geological Survey. U.S. Dept. of Interior.
Kuhne, E.R. (1929). A Guide to the Fishes of Tennessee and the
Mid-South. Tennessee Department of Conservation, Division
of Game and Fish.
.Lawrence, G.D., Jr. February 16, 1982. Letter written to
Charles E. Watkins, Jr. and G. Lee Garrett, Jr., Hansell,
Post, Brandon. & Dorsey. Atlanta, Georgia.
Macek, K.J., Petrocelli, S.R., Sleight, B.H. (1979).
"Considerations in Assessing the Potential for, and
Significance of, Biomagnification of Chemical Residues
in Aquatic Food Chains". Aquatic Toxicology. Marking/
Kimerle - editors. American Society for Testing and
Materials, PA.
Metcalf, R.L., Gurcharan, K.S., Kapoor, I.E. (1971). "Model
Ecosystem for the Evaluation of Pesticide Biodegradability
and Ecological Magnification". Environmental Science and
Technology. Vol. 5, No. 8, August, 1971.
Micrometrics Instrument Corp (.1978),' Instruction Manual, Sedigraph
SOJOD Particle Size Analyzer, MIC P/N 500/42801/00,
Norcoss, GA.
National Environmental Policy Act of 1969.
National Handbook of Recommended Methods for Water Data
_AcCTuisi.t3.on= . Chapter 3_- .Sediment, Section .3..D. l.b..lc.
U.S. - Series Samples, p. 3-19 to 3-22.
O'Shea, T.J., Fleming, W.J. and Cromartie, E. (1980). "DDT
Contamination at Wheeler National Wildlife Refuge".
Science. Vol. 209, p. 509-510.
Recra Research, Inc. (1982). Huntsville DDTR Environmental
Project Scope (Draft). Huntsville, Alabama.
Standard Methods for the Examination of Water and Wastewater..
14th Edition. APHA, AWWA, WPCF.
Smith-Vaniz, W.F. (1968). Freshwater Fishes of Alabama.
Auburn University, Agricultural Exp. Station.
10-2
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U.S. Department of the Interior. (1943). Stream-Gaging
Procedures, A Manual Describing Methods and Practices
of the Geological Survey, Washington, D.C.
U.S. Department of Justice. (1982). Government Response to
"Huntsville DDTR Environmental Project Scope". July 6,
1982. Prepared by Recra Research, Inc.
U.S. Environmental Protection Agency. (1979). Regulations on
Preparation of Environmental Impact Statements. 40 CFR 6.
U.S. Environmental Protection Agency. (1977). Revised October
1980. "Interim Method for the Sampling and Analysis of
Priority Pollutants in Sediment and Fish Tissue".
U.S. Environmental Protection Agency. (1979). "Guidelines
Establishing Test Procedures for the Analysis of
Pollutants". 40 CFR Part 136. December 3, 1979.
U.S. Environmental Protection Agency. (1979). Methods for
Chemical Analysis of Water and Wastes. EPA-600/4-79-
020, March 1979.
U.S. Environmental Protection Agency. (1982). "Test Method:
Organochlorine Pesticdes and PCBs - Method 617".
U.S. Environmental Protection Agency. (1980). Manual of
Analytical Methods for the Analysis of Pesticides in
Humans and Environmental Samples. "EPA-600/8-80-038,
June 1980.
Water and Air Research, Inc. (1980). "Engineering and Environmental
Study of DDT Contaminatipn_of Huntsyille Spring _ _._ ..
Branch,. Indian Creek, and Adjacent Lands and Waters, Wheeler
Reservoir, Alabama". Final Contract Report. November 1980.
Volume 1 - Summary Document. Volume 2 - Appendices I-III;
Appendix I - General Information on DDT and DDTR; Appendix
II - Site Specific Information and Analysis; Appendix III -
Alternatives for Mitigation of DDTR Contamination in
Huntsville Spring Branch and Indian Creek. Volume 3 -
Appendices IV-VI; Appendix IV - Quality Assurance Document;
Appendix V - Worktask Descriptions and Results for 7 TVA
Worktasks; Appendix VI - Worktask Descriptions and Results
for 3 W.A.R. Worktasks and Quality Assurance Document.
10-3
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Watkins, C.E., Jr. and Garrett, G.L., Jr. December 4, 1981.
Letter written to Kenneth A. Reich, Department of Justice,
Washington, D.C.
Welch, N.H., Allen, P.B. and Galindo, D.J., "Particle-Size
Analysis by Pipette and Sedigraph," prepublication
manuscript (.refer to W.A.R. Report, Appendix IV).
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix C
REVIEW PANEL MEMBERSHIP
Review Panel Chair
Dr. Edward S. Bender
Office of Science Policy (8103R)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, B.C. 20460
E-mail Address: bender.ed@epamail.epa.gov
Period of Review Panel service—June 14, 1983 to present
(Dr. Bender was appointed Chair of the Review Panel on December 5, 1996
following the death of Anne Asbell)
Dr. Bender is an aquatic biologist with the U.S. Environmental Protection
Agency in Washington DC. He chairs the Technical Committee which provides
advice and support for Review Panel activities. In 1977, while working for the U.S.
Army, Dr. Bender became involved with DDTR sampling at Redstone Arsenal. He
joined EPA in 1979 and served as the technical coordinator for the litigation that
led to the Consent Decree in U.S. vs Olin Corporation, and the establishment of the
Review Panel. Dr. Bender has more than twenty years experience in environmental
monitoring, aquatic ecology and toxicology. His dissertation, entitled "Recovery of a
Macroinvertebrate Community from Chronic DDTR Contamination," studied the
toxic effects of DDTR runoff from an abandoned manufacturing facility on fish and
aquatic invertebrates in a south-central Arkansas stream. Dr. Bender has a
bachelor of science degree in biology from Westminster College, a master of science
degree in zoology from the University of Florida, and a doctorate in biology from the
Virginia Polytechnic Institute and State University.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
State of Alabama
James W. Warr
Director
Alabama Dept. Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
Email "jww@adem.state.al.us"
Period of Review Panel Service: June 14, 1983 to present
Mr. Warr is the Director of the Alabama Department of Environmental
Management (ADEM), a position that he has held since April 1996. Prior to April
1996, Mr. Warr was the Deputy Director from August 1982 (when AD EM was
created) to November 1993 and from November 1994 to September 1995. He served
as the Acting Director from November 1993 to November 1994 and from September
1995 until April 1996 when he became the Director. AD EM is responsible for the
implementation and coordination of the State of Alabama's environmental program
activities. Mr. Warr was previously the Director of the Alabama Water
Improvement Commission (AWIG), which administered the Alabama Water
Pollution Control Act. He joined the AWIC in 1968 and has several years of
experience and knowledge concerning the environmental conditions in the Wheeler
Reservoir, Huntsville Spring Branch — Indian Creek System. Mr. Warr has a
Bachelor of Science Degree in Civil Engineering, a Masters Degree in Civil
Engineering, and a Master of Business Administration, all from Auburn University.
He is a registered professional engineer and is a member of several professional
associations. He currently holds the rank of Major General in the U.S. Army
Reserve.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Department of Army, RSA
Colonel Steven C. Hamilton
Deputy Post Commander
AMSAM
Redstone Arsenal, AL 35898-5300
Period of Review Panel service—July 1998 to present
Colonel Hamilton was assigned as Deputy Post Commander, Redstone
Arsenal, Alabama in July 1998. Previous assignments have been Platoon Leader, 2-
34th Infantry, Ft. Stewart, GA; Executive Officer, 24th Ordnance Company, Ft.
Stewart, GA; Commander, Surveillance and Accountability Control Team #1
(SAACT #1), 6th Ordnance Battalion, Uijongbu, Korea; Materiel Officer, 80th
Ordnance Battalion, Ft. Lewis, WA; Commander, 63rd Ordnance Company, Ft.
Lewis, WA; and Operations Officer, Test and Evaluation Division, Army
Development and Employment Agency (ADEA), Ft. Lewis, WA. He served as
Executive Officer, 80th Ordnance Battalion, Ft. Lewis, WA; Chief, Ammunition
Management Branch, 3D COSCOM, Germany; Chief, Supply Management Division,
3D COSCOM, Germany and Commander, 6th Ordnance Battalion, Korea. His most
recent assignments have been as Action Officer, J-4, The Joint Staff, Pentagon;
Chairman, Joint Munitions Rule Implementation Council (MRIC), Pentagon and
Chief, Plans and Operations Division, ODCSLOG, Pentagon. Colonel Hamilton's
awards and decorations include the Defense Meritorious Service Medal, the
Meritorious Service Medal with 3 Oak Leaf Clusters, the Joint Service
Commendation Medal, the Army Commendation Medal with Oak Leaf Cluster, the
Joint Chiefs of Staff Identification Badge, the Army Staff Identification Badge, the
Parachutist Badge and the Ranger Tab. Colonel Hamilton holds a bachelor of
science degree in Medical Technology from the University of Utah, a master of
business administration degree from Utah State University and a master of science
in National Resource Strategy from the National Defense University. Colonel
Hamilton was commissioned a second lieutenant in the Ordnance Corps with a
detail in infantry in 1975. He is a graduate of the Infantry Officer Basic Course, the
Ordnance Officer Advance Course, the Materiel Acquisition Management Course,
the Command and General Staff College, and the Industrial College of the Armed
Forces.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
US Fish and Wildlife Service
Dr. W. Allen Robison
Environmental Contaminants
Coordinator-Southeast Region
U.S. Fish & Wildlife Service
1875 Century Blvd.
Suite 200
Atlanta, GA 30345
Email "allen_robison@fws.gov"
Period of Service: July 15, 1993 to present.
Dr. Robison holds degrees in wildlife biology, aquatic biology and toxicology.
He has worked for the Fish and Wildlife Service (Service) as a Biological Technician,
an Environmental Contaminants Biologist, and as an Ecologist. Dr. Robison has
also worked in the areas of water quality assessment, fish community analysis, fish
contaminant residue evaluation, and the transport/fate of PCBs for the
Commonwealth of Kentucky. His involvement with the HSB-IC DDT project began
when he came to work in the Service's Tennessee/Kentucky Field Office located in
Cookeville, Tennessee. Dr. Robison has continued the monitoring programs at
Wheeler National Wildlife Refuge. He is presently employed in the Service's
Southeast Regional Office located in Atlanta, Georgia.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Tennessee Valley Authority
Robert Pryor
Business Development
Tennessee Valley Authority
400 Summit Hill Drive (WT-10D)
Knoxville, TN 37902-1499
Email "rjpryor@tva.com"
Period of Review Panel Service: January 1, 1991to present.
Mr. Pryor has over 20 years of accountable management experience in
environmental and pollution prevention disciplines. He has a technical background
in scientific and environmental engineering professions and broad experience in all
TVA businesses. For example, he has managed assessment and protection
programs for natural resources, served as Project Engineer for capacity additions to
the Power System from siting to sub-system modifications. Advised agency
management on effects of operations on natural resources and provided corporate-
level oversight of environmental activities at operating sites, has management
responsibility for performing National Environmental Policy Act reviews.
He has a master of science in zoology and a bachelor of science in biology and
chemistry from the University of Texas at San Angelo, Texas. He also has an
engineering certification from Texas A&M.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
NON-VOTING MEMBERS
Town of Triana. AL
Honorable Clyde Foster (Town Hall)
480 Zierdt Road
Triana, AL 35756
E-mail "cfoster293@aol.com"
Mr. Foster, formerly the Mayor of the Town of Triana, Alabama, is a
prominent community leader. He was instrumental in the restoration of the town
charter for Triana, originally chartered in 1819, and was appointed Triana Mayor in
1964, serving in that capacity until 1984. He has been a strong community
advocate and instrumental in focusing community concerns. His efforts on behalf of
the town of Triana have been successful in improving many areas of community life.
Mayor Foster has been involved with the resolution of the DDTR
contamination problem in the Huntsville Spring Branch-Indian Creek System for
many years. His contributions include effective and successful coordination of the
Review Panel activities with the local community. His efforts have resulted in a
spirit of cooperation and understanding within the community.
Mayor Foster was the Director of the Equal Employment Office at the
National Aeronautics and Space Agency, George C. Marshall Space Flight Center in
Huntsville, Alabama until his retirement in January 1987. He has a bachelor of
science degree in mathematics and chemistry from Alabama A & M, and has taken
graduate courses at that university.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Olin Corporation
Mrs. Laura B. Tew
Director, Community Outreach
Olin Corporation
PO Box 248
Charleston, TN 37310
E-Mail: lbtew@corp.olin.com
Period of Review Panel service: 1998 to present
Mrs. Tew is Director of Corporate Community Outreach with Olin
Corporation's Public Affairs department. She has been with Olin for twenty-two
years and has served on the Review Panel as Olin's non-voting member since 1998.
Mrs. Tew has an undergraduate degree in chemistry from the University of North
Carolina at Greensboro, advanced studies in chemistry at Duke University, and an
MBA in marketing from Pace University in White Plains, NY. Mrs. Tew's career
with Olin has included positions in quality, environmental, production management
and marketing. She was plant manager of Olin's packaging facility in Livonia, ML
Mrs. Tew holds an advanced certificate from Boston College, Center for Corporate
Community Relations.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
FORMER REVIEW PANEL MEMBERS
Past Chairs
U.S. Environmental Protection Agency
Mr. Howard D. Zeller
Period of Review Panel service: June 14, 1983 through December 31, 1987
Mr. Zeller served as the first Chair of the Review Panel and the United
States' designated Program Coordinator for the implementation of the Consent
Decree in U.S. vs Olin Corporation. Mr. Zeller was the Assistant Administrator for
Policy and Management for the U.S. Environmental Protection Agency in Atlanta,
Georgia until his retirement in January 1987. Mr. Zeller retired with more than
thirty years experience in environmental matters. He lead the Review Panel
through the initial phases of implementing the Consent Decree and adopting
procedures for functioning as a body. Mr. Zeller has a bachelor of science degree in
biology and chemistry from the University of Nebraska and a master of science
degree in zoology from the University of Missouri.
Ms. Anne Asbell
Period of Review Panel service: June 14, 1983 through November 2, 1996
Ms. Asbell was the second Chair of the Review Panel from January 1987
until her death, November 2, 1996. She served as the Legal Counsel for the Review
Panel from 1983 until her appointment as Chair. She was an Associate Regional
Counsel for the U.S. Environmental Protection Agency, Region IV, in Atlanta,
Georgia. Ms. Asbell represented the Region in the litigation that led to the Consent
Decree and the establishment of the Review Panel. She was actively involved in all
aspects of the Review Panel activities and the implementation of the Consent
Decree. Ms. Asbell had a juris doctor degree from Woodrow Wilson College of Law.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Former Members
Tennessee Valley Authority
Mr. Bruce Brye
Period of Review Panel service: June 14, 1983 to December 31, 1990
During Mr. Brye's service as TVA's representative on the Review Panel, he
also served as Chairman of Review Panel's Inspection Committee. Mr. Brye was a
staff Environmental Engineer in the TVA's Division of Water Resources and served
as TVA's senior technical expert on water quality issues. Since 1963, Mr. Brye has
been involved in the environmental review , permitting, licensing, and litigation of
many major TVA projects. During 1979-1980, Mr. Brye was extensively involved in
the data acquisition activities for the DDTR studies of the environment in the
Huntsville Spring Branch-Indian Creek System. During 1981-1983, he provided
assistance to the U.S. Environmental Protection Agency and the Department of
Justice in the development and review of technical documents during the
negotiations which led to the final consent decree in U.S. vs. Olin Corporation.
After his retirement from TVA in 1991, Mr. Brye was retained by the Review Panel
as a consultant. Mr. Brye has a bachelor of arts in mathematics from Wartburg
College, a bachelor of science in civil engineering (sanitary option) from the
University of Iowa, and a master of science in sanitary engineering from the
University of Iowa. He is a Diplomat in the American Academy of Environmental
Engineers, a Certified Hazardous Materials Manager, and a registered professional
engineer in 14 states including Alabama.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
U.S. Fish and Wildlife Service
1. Mr. W. Waynon Johnson
Period of Review Panel service: June 14, 1983, to March 10, 1987
Mr. Johnson was the Senior Staff Specialist with the US FWS in Atlanta, Georgia.
2. Dr. Lee A. Barclay
Period of Review Panel service-March 10, 1987, to December 3, 1987
Dr. Barclay was the Environmental Contaminants Specialist with the US FWS in
Cookville, Tennessee.
3. Dr. Donald P. Schultz
Period of Review Panel service: December 3, 1987 through June 15, 1990
Dr. Schultz was the contaminant coordinator for the Southeast Region of the U.S.
FWS.
4. Mr. R. Mark Wilson
Period of Review Panel service: June 15, 1990-December 12, 1992
Mr. Wilson was the Environmental Contaminants Specialist with the US FWS in
Cookville, Tennessee.
4. Dr. Charles Facemire
Period of Review Panel service: December 12, 1992 - July 15, 1993
Dr. Facemire was the Regional Contaminants Coordinator for U.S. Fish and
Wildlife Service, Atlanta, Georgia during that time.
Department of the Army
1. Colonel Dahl J. Cento (Retired)
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Period of Review Panel service: June 14, 1983 to October 30, 1985
Colonel Cento was the Deputy Post Commander of Redstone Arsenal during his
Review Panel service. He was active in soliciting participation by the Corps of
Engineers.
2. Colonel James A. Hall (Retired)
Period of Review Panel service-August 1986 to June 1988.
Colonel Hall was named Deputy Post Commander, Redstone Arsenal in August
1986.
3. Colonel Perry C. Butler (Retired)
Period of Review Panel service: July 1988 to July 1991.
Colonel Butler was assigned as Deputy Post Commander in July 1988.
4. Colonel Stephen Peter Moeller (Retired)
Period of Review Panel service: July 1994 to July 1996.
Colonel Moeller was assigned as Deputy Post Commander in June 1994.
5. Colonel Duane E. Brandt
Period of Review Panel service: July 1996 to July 1998.
Colonel Brandt was assigned as Deputy Post Commander, Redstone Arsenal,
Alabama in July 1996.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Former Non- Voting Review Panel Members
Olin Corporation
Mr. William G. McGlasson
Corporate Director, Environment, Health, & Safety
Olin Corporation
PO Box 248
Charleston, TN 37310
Phone: (423) 336-4734
Period of Review Panel service: 1990 to 1998
Mr. McGlasson was Corporate Director, Environmental, Health, and Safety
for Olin Corporation and Olin's designated Program Coordinator for the
implementation of the Consent Decree in U. S. vs. Olin Corporation from 1990 to
1998. He succeeded Mr. Verrill Norwood in July, 1990, who was Olin's primary
technical representative in the negotiation of the Consent Decree and the
development and implementation of the environmental remedy in the Huntsville
Spring Branch-Indian Creek System. Mr. McGlasson served as Olin's non-voting
member of the Review Panel from 1990 to until his retirement in 1998. During 22
years of service with Olin, Mr. McGlasson served in various technical and
management positions within Olin Corporation. He has a Bachelor of Science
degree in Chemical Engineering from the University of Missouri and a Master of
Science degree in Chemical Engineering from Louisiana State University.
Olin Advisor to the Technical Committee/Review Panel and Former
Review Panel Participant
Mr. Verrill M. Norwood
Olin Consultant
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
116 Sunburst Lane NW
Cleveland, TN 37312
Phone: (423) 476-1082
E-Mail: vmnorwoo@piona.com
Period of Review Panel service: 1983 to 1990
Mr. Norwood was Vice President, Environmental Affairs, for Pioneer Chlor
Alkali and is retired. Previously, he was Vice President, Environmental Affairs, for
Olin Corporation and Olin's designated Program Coordinator for the
implementation of the Consent Decree in U. S. vs. Olin Corporation. He was Olin's
primary technical representative in the negotiation of the Consent Decree. Mr.
Norwood served as Olin's non-voting member of the Review Panel from its inception
until he was succeeded by Mr. William G. McGlasson in July, 1990. Mr. Norwood
has continued on a contract basis to be an advisor to Olin and participate in the
Technical Committee and Review Panel meetings. Mr. Norwood has a Bachelor of
Science degree in Chemical Engineering from the Massachusetts Institute of
Technology and a Master of Science degree in Chemical and Metallurgical
Engineering from University of Michigan.
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix D. Inspection Committee Letter
-------
AD EM
JAMES W. WARR
DIRECTOR
ALABAMA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
POST OFFICE Box 301463 « 1751 CONG. W. L. DICKINSON DRIVE 36109-2608
MONTGOMERY, ALABAMA
WWW.ADEM.STATE.AL.US
(334) 271-7700
October 2, 1998
Dr. Edward S. Bender
Chair, Review Panel
U.S. EPA Headquarters
401 M Street, S.W.
Washington, DC 20460
FOB JAMES, JR.
GOVERNOR
Facsimiles: (334)
Administration: 271-7950
Air 279-3044
Land: 279-3050
Water: 279-3051
Groundwater: 270-5631
Field Operations: 272-8131
Laboratory: 277-6718
Education/Outreach: 213-4399
Dear Dr. Bender:
This letter summarizes the observations and findings of the Review Panel
Inspection Team for the calendar years 1991-1998. Since the last report of the
Review Panel activities, the Inspection Team and others have made on-site
reviews of the remediation site at least annually. Consistent with those reviews,
our records reflect assessments of structural integrity were also performed in
1991, 1992, 1993, 1994, 1996, and 1998.
In my capacity as leader of the Inspection Team, I have reviewed the
reports on structural integrity for the referenced years and find that a
consistently applied assessment process reflects that natural succession has and
is occurring without threatening the stability of the remedy. The area is now in
an essentially natural state and I find no cause for concern relative to the
integrity of the remediation. In fact, the most recent assessment suggests that
intrusive actions may be necessary for access if reviews are to continue on an
annual basis.
acerely,
James W. Warr
Director
JWW/rdg
Birmingham Branch
110 Vulcan Road
Birmingham, Alabama 35209-4702
(205) 942-6168
(205) 941-1603 (Fax)
Oecatur Branch
400 Wen Street. N.E. » P.O. Box 953
Decatur. Alabama 35602-0953
(256) 353-1713
(256) 340-9359 [Fax]
Mobile Branch
2204 Perimeter Road
Mobile. Alabama 36615-1131
(334) 450-3400
(334) 479-2593 [Fax]
Mobile Branch - Coastal Section
4171 Commanders Drive
Mobile. Alabama 36615-1421
(334) 432-6533
(334) 432-6598 [Fax]
Printed on Recycled Paper Q_TN
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix E. Olin Reports Submitted to the Review Panel
Report Title
Huntsville Quality Assurance/Method Equivalency
Report
Huntsville Quarterly Report No. 1
Huntsville Groundwater Report
Huntsville Quarterly Report No. 2
Huntsville Analytical Methods Manual
Huntsville Quarterly Report No. 3
Huntsville Quarterly Report No. 4
Huntsville Remedial Action Report
Huntsville Quarterly Report No. 5
Huntsville Quarterly Report No. 6
HSB-IC Long-Term Data Acquisition Report
Draft 404/26a Permit Application
Huntsville Quarterly Report No. 7
Huntsville Engineering Quarterly Report No. 1
Huntsville Preliminary Engineering Drawings
Second Draft 404/2 6a Permit Application
A Cultural Resource Survey for the
Huntsville Remedial Action Plan
Huntsville Quarterly Report No. 8
Huntsville Engineering Quarterly Report No. 2
Final Engineering Drawings and Specifications
404/26a Permit Application
Environmental Analysis for the
Huntsville Remedial Action Plan
Field and Laboratory Investigations of the HSB-IC System
Report on DDT in HSBM 4.0 to 2.4 (Lower Reach A)
HSB-IC Post Remedial Action Interim Goals
Huntsville Quarterly Report No. 9
Huntsville Engineering Quarterly Report No. 3
Huntsville Groundwater Monitoring Program
Springs Report
Huntsville Quarterly Report No. 10
Date
August 1, 1983
September 1, 1983
November 17, 1983
December 1, 1983
February 22, 1984
March 1, 1984
June 1, 1984
June 1, 1984
September 1, 1984
December 1, 1984
February 1, 1985
February 5, 1985
March 1, 1985
March 1, 1985
April 1, 1985
April 19, 1985
May 13, 1985
June I, 1985
June 1, 1985
July 1, 1985
July 1, 1985
July 1, 1985
July 1, 1985
August 1, 1985
August 1, 1985
September 1, 1985
September 1, 1985
November 20, 1985
November 27, 1985
December 1, 1985
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Huntsville Engineering Quarterly Report No. 4
Huntsville Remedial Action Plan Policy and Procedures Manual
Cultural Resources Survey Report (Oxbow Alternative)
Assessment of Revegetation Needs for the Olin Corporation
Huntsville Remedial Action Plan
Final Engineering Drawings (Oxbow Alternative)
Huntsville Quarterly Report No. 11
Huntsville Engineering Quarterly Report No. 5
HSB-IC Long-Term Data Acquisition Report
HSB-IC Substitute Fish Species Report
HSB-IC DDT in Fish and Water Baseline Report
Huntsville Engineering Quarterly Report No. 6
404/26a Permit Modification
Catastrophic Subsidence Action Plan
Draft 404/26a Permit Application (Lower Reach A)
Huntsville Quarterly Report No. 12 (Semiannual No. 1)
Huntsville Engineering Quarterly Report No. 7
Report on DDT in Reach B and Reach C of the HSB-IC System
404/26a Permit Application (Lower Reach A)
Environmental Analysis for the
Huntsville Remedial Action Plan (Lower Reach A)
Preliminary Engineering Drawings (Lower Reach A)
Technical Specifications for the
Huntsville Remedial Action Plan (Lower Reach A)
Cultural Resource Assessment (Lower Reach A)
Endangered Species Monitoring Report
Revised 404/26a Permit Application (Lower Reach A)
Huntsville Engineering Quarterly Report No. 8
HSB-IC Long-Term Monitoring Program (Draft)
Evaluation of Substitute Fish for Largemouth Bass
Huntsville Semiannual Report No. 2
Huntsville Engineering Quarterly Report No. 9
HSB-IC Long-Term Monitoring Program (Draft)
Huntsville Engineering Quarterly Report No. 10
HSB-IC Long-Term Monitoring Program
Huntsville Engineering Quarterly Report No. 11
December 1, 1985
January 6, 1986
January 7, 1986
January 15, 1986
January 15, 1986
March 1, 1986
March 1, 1986
March 1, 1986
March 1, 1986
March 1, 1986
June 1, 1986
June 26, 1986
July 30, 1986
August 18, 1986
September 1, 1986
September 1, 1986
September 1, 1986
September 15, 1986
September 15, 1986
October 1, 1986
October 1, 1986
October 15, 1986
October 20, 1986
October 27, 1986
December 1, 1986
February 1, 1987
February 6, 1987
March 1, 1987
March 1, 1987
May 5, 1987
May 29, 1987
August 14, 1987
August 27, 1987
E-3
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Huntsville Semiannual Report No. 3
Huntsville Project "As Built" Drawings
Hunts ville Engineering Quarterly Report No. 12
Huntsville Semiannual Report No. 4
Huntsville Semiannual Report No. 5
Huntsville Long-Term Monitoring Report No. 1
Huntsville Long-Term Monitoring Report No. 2
Huntsville Long-Term Monitoring Report No. 3
Huntsville Long-Term Monitoring Report No. 4
1992 HSB-IC Liter-laboratory Data Comparison
Huntsville Long-Term Monitoring Report No. 5
1993 HSB-IC Interlaboratory Data Comparison
Huntsville Long-Term Monitoring Report No. 6
1994 HSB-IC Interlaboratory Data Comparison
Huntsville Long-Term Monitoring Report No. 7
Huntsville Quality Assurance Meeting
1995 HSB-IC Interlaboratory Data Comparison
Report on Interlaboratory
Quality Assurance and Quality Control
Huntsville Long-Term Monitoring Report No. 8
Post Remediation Sediment Investigation
- Reach A and Reach B
1996 HSB-IC Interlaboratory Data Comparison
Huntsville Long-Term Monitoring Report No. 9
1997 HSB-IC Interlaboratory Data Comparison
Huntsville Long-Term Monitoring Report No. 10
Long-Term Monitoring Plan for Time Extension
Interim Goals for Time Extension
Contingency Plans for Time Extension
September 1, 1987
September 2, 1987
December 8, 1987
March 1, 1988
September 1, 1988
April 15, 1989
April 15, 1990
April 15, 1991
April 15, 1992
March 18, 1993
April 15, 1993
May 11, 1994
June 1, 1994
April 19, 1995
May 15, 1995
September 13, 1995
April 30, 1996
May 17, 1996
June 1, 1996
January 6, 1997
March 17, 1997
May 15, 1997
March 24, 1998
May 15, 1998
February 1, 1999
February 1, 1999
February 1, 1999
E-4
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix F. Decision Document No. 8,
Groundwater Monitoring, December 6, 1990
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REVIEW PANEL DECISION DOCUMENT NUMBER 8
GROUNDWATER MONITORING
I. Introduction
In the April 15, 1990 Long Term Monitoring Program Annual
Report Number 2, Olin proposed to discontinue groundwater sample
collection. Their proposal covers two sets of wells: a) Five
existing groundwater wells on Redstone Arsenal and five public
drinking water wells that were identified in the Technical Proposal
to the Consent Decree; and b) Thirty seven wells, arranged in five
traverses, across the filled channel of the remedial action site.
These are referred to here as the "Technical Proposal" groundwater
wells (or "Far Field wells") and the "Filled Channel" groundwater
wells (or "Near Field wells") respectively.
The Consent Decree (paragraph 10) requires Olin to conduct
groundwater studies as set forth in the Technical Proposal. These
studies included monitoring water samples from prescribed wells
before construction, during construction and every two years
following construction of the remedial action. Groundwater
sampling of the Technical Proposal wells would be discontinued
after three consecutive samples confirmed no significant
concentrations of DDT in the groundwater. Olin proposed that
monitoring of the Technical Proposal wells would be discontinued
because three consecutive samplings confirmed no significant
concentratons of DDT in these wells.
A second groundwater monitoring program was developed by Olin
at the request of the Review Panel to study the potential for DDT
contamination and movement in the groundwater around the filled
channel (HSBM 5.4 to 4.0). This program is described in the HSB-
IC Long-Term Monitoring Program (August, 1987). Review Panel
Decision Document No. 6 approved the program and established a
schedule for monitoring each well. Initially, all thirty-seven
wells were sampled quarterly and then in years 2,4,8, and 10
following construction of the remedial action. In Olin's April
1990 Report, Olin proposed discontinuing monitoring of the Filled
Channel wells after year two.
II. Decision
A. Monitoring of the Technical Proposal ("Far Field") Wells
The decision of the Review Panel is to accept Olin's proposal
for discontinuing the monitoring of the Technical Proposal
groundwater wells. The Technical Committee of the Panel has
reviewed the results of three years of sampling from these wells
and agree that no significant DDT have been found in the public
-------
water supplies. If DDT is found in the filled channel wells in the
future, the Review Panel may require further sampling of specific
Technical Proposal wells to evaluate the extent of migration.
B. Monitoring of the Filled Channel ("Near Field") Wells
The decision of the Review Panel is to discontinue monitoring
of the Filled Channel wells in years 4 and 8 but to resume
monitoring those wells for year 10 or during the year following the
initial demonstration of attainment as specified in the Consent
Decree. Olin shall also sample and analyze groundwater from all
of the filled channel wells as part of the demonstration of
continued attainment before the termination of the Consent Decree.
III. Conclusion
This decision document confirms the Review Panel's decision
from its June 14, 1990 meeting. This document consists of 2 pages
of text and comprises the Review Panel decision and is .accepted and
adopted by the representatives of the Review Panel member agencies
and concurred in by the nonvoting participants as shown by the
signatures affixed hereto.
MEMBERS
Anne L. Asbell
Chairperson, Review Panel
Dr. Edward S. Bender
EPA - Washington, D.C.
Bruce Brye
Tennessee Valley Authority
Dr. Donald P. Schull
U.S. Fish and Wildllre
Service
:ol. Charles Wood, U.S.
Army, Redstone Arsenal
James W.
Alabama Department of
Environmental Management
NONVOTING PARTICIPANTS
Honorable dyde~Foster
Towrr of Triana, Alabama
William G. McGlasson
Olin Corporation
DATEDi
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix G. Decision Document No. 9,
Process for Review of Monitoring Data and
Olin Notification of Compliance by the Technical Committee,
January 23, 1992.
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REVIEW PANEL DECISION DOCUMENT NUMBER 9
PROCESS FOR REVIEW OF MONITORING DATA
AND OLIN NOTIFICATIONS OF COMPLIANCE
BY THE TECHNICAL COMMITTEE
I. Introduction
Pursuant to the requirements of the Consent Decree, U.S. vs.
Olin Corp.. May 31, 1983, the Review Panel is authorized to
review the remedial action implemented by Olin and determine
whether the remedy has achieved compliance with the Performance
Standard consistent with the goals and objectives of the Consent
Decree. The Review Panel may review a variety of information and
data to assess the adequacy of the remedy and compliance with the
Performance Standard, including the Long-Term Monitoring Reports
(Decision Document No. 6) and the Interim Goals (Decision
Document No. 5).
The Review Panel established a Technical Committee to advise
it on technical issues related to the development and
implementation of a remedial action and the monitoring of its
efficacy. The Technical Committee has met regularly to evaluate
the data presented by Olin and has applied sound analytical and
technical principles to the task. The Technical Committee
recommended revisions to the quality assurance and quality
control (QA/QC) plan developed as part of the Joint Technical
Proposal to the Consent Decree, which were incorporated into the
QA/QC requirements through Decision Document Number 7. During
reviews of the long-term monitoring programs data, the Technical
Committee has observed instances when it would be appropriate for
them to have guidance and principles for their evaluations of the
data. As a result, the following areas will be addressed in this
Review Panel document to aid the Technical Committee in its
review of the data presented by Olin:
1. What data should be available to determine compliance with
the Performance Standard consistent with the goals of the Consent
Decree?
2. What principles should be applied to evaluate the quality of
that data?
3. What procedures should be followed to evaluate the data and
what factors should be considered to provide technical assistance
and recommendations to the Review Panel?
The purpose of this document is to provide the Review
Panel's guidance to the Technical Committee on how to address
these questions and provide recommendations to the Review Panel
-------
for its consideration and decision.
II. Decision:
The decision of the Review Panel is that both the Review
Panel and the Technical Committee will continue to receive
information and data from Olin as set forth below. Further, the
Technical Committee will continue to apply sound analytical and
technical principles to evaluate the data and advise the Review
Panel on the status of the remedial action in attaining and/or
maintaining compliance with the Consent Decree.
A. Data to Evaluate Compliance
1. The Technical Committee and the Review Panel members
will continue to receive information and monitoring data
from Olin as part of the regular monitoring programs
(Decision Documents No. 6, 1, and 8). A partial list of the
information that Olin will be reporting in the Annual
Report starting with the report due April 15, 1992, is
presented in Appendix A. In addition, Olin has conducted
and will conduct special studies to investigate particular
aspects of the remedy (e.g., Decision Documents No. 2 on
Baseline Data, Substitute Species and Interim Goals for Fish
and Water, and No. 7 on Quality Assurance and Fish Sample
Sizes) either on its own initiative, at the request of the
Technical Committee or the Review Panel. From time to time,
the Technical Committee and Olin may recommend modifications
to the monitoring program or modifications to the analysis
and presentation of data that are consistent with the
Performance Standard, the goals and objectives of the
Consent Decree, the Joint Technical Proposal, and the
Decision Documents approved by the Review Panel. Additional
monitoring and data analysis by Olin will depend upon the
results of the monitoring information and the Technical
Committee's recommendations.
2. The Technical Committee, with the concurrence of the
Review Panel, has determined that detailed sediment mapping
of the HSB-IC system is needed to review the remedial
action. Sediment mapping will establish the areas of
sediment deposition and erosion which exist following
implementation of the remedial action and following major
hydrologic events. This baseline and future sediment
mapping will permit the Review Panel to make informed
decisions on the stability and long-term integrity of the
remedial action (especially in Reaches B and C) . Detailed
mapping should be compared to previous transects surveyed by
Olin. Such comparisons and in conjunction with periodic
updated mapping will permit the Review Panel to determine
which areas are erosional and which are depositional. Olin
-------
has agreed to conduct such mapping during 1992 to establish
post-remedial action baseline conditions and at appropriate
intervals thereafter to account for the effects of major
flood or hydrologic events (e.g., 25 year headwater flood)
on sediment profiles. If such events do not occur, then
this data should be collected prior to the final
demonstration of continued attainment and again prior to the
termination of the Consent Decree.
B. Data Evaluation Principles
The following principles will be used to review
monitoring data and information submitted for the remedial
action program on the HSB-IC system.
1. The Consent Decree, the Joint Technical Proposal, and
the Review Panel Decision Documents will continue to serve
as the basis for all procedures and requirements.
2. The Review Panel is charged with the authority to
determine compliance with the provisions of the Consent
Decree. The Review Panel may exercise its authority to
modify the remedial action, develop or modify implementation
schedules, and require additional monitoring and studies
from Olin.
3. Trends in long-term monitoring are of prime importance,
in evaluating the efficacy of the remedial action.
Standardized methodologies established at the outset of the
Consent Decree will be maintained as long as monitoring is
required so that comparability with the baseline conditions
is maintained.
4. Sampling, analysis, and data interpretation will follow
standard methods and QA/QC procedures as outlined in the
reference documents or as modified by any subsequent Review
Panel decisions.
5. All monitoring data collected will be retained and
reported. Technical justification for rejection of any
monitoring data collected must be well documented.
6. The remedial action must achieve compliance with the
Performance Standard for DDT1 levels in channel catfish,
largemouth bass, and smallmouth buffalo consistent with the
goals and objectives of the Consent Decree.
1 DDT is defined in the consent decree as the sum of isomers
and degradation products of DDT; including p,p'- and o,p'- DDT,
ODD, and DDE.
-------
7. All methods of data evaluation will be considered which
are appropriate for the interpretation of the data developed
under the Consent Decree.
C. Procedures for Review and Evaluation of Monitoring Data
1. Each year, following the submission of the Long-Term
Monitoring Report, the Technical Committee, on behalf of the
Review Panel, will review the data and any recommendation
from Olin that compliance has been attained or continued to
be attained for any performance standard fish species. The
Technical Committee will review the data and recommendation
for completeness, quality assurance certification, and
accuracy.
2. The Technical Committee review will include
considerations of the trends in DDT levels, requirements for
additional monitoring by Olin, supplemental data from
participating agencies, and modifications to the monitoring
program or construction and implementation schedules as
approved by the Review Panel.
a. Changes in Fish DDT Levels. The Review Panel
recognizes that DDT residues are highly variable among
individual fish and, therefore, reserves the option to
focus on the long-term trend(s) of this contaminant in
the community of fish within the specified study
reaches. If the Technical Committee determines it is
appropriate, it may utilize other measures of central
tendency (e.g., geometric means, medians) or pool data
among reaches to evaluate the effect of individual fish
on the arithmetic average.
b. Partitioning of DDT among various media. A dynamic
relationship exists between the levels of DDT in
sediment, suspended sediments, water, and fish tissue.
Fish residues are also influenced by the level of DDT
in the food, percent of lipids, age, feeding behavior,
and movements in and out of contaminated areas. In
reviewing trends of DDT concentrations in fish tissue,
the Technical Committee will compare the levels of DDT
in various media with the levels of DDT in each
Performance Standard fish species. Although the level
of DDT in any one medium (water or sediment) is
expected to vary, it will be used as one indication of
the efficacy of the remedial action. The Committee
will also examine relationships between DDT residues in
fish and percent lipids in the filet, age of the fish
and the level of DDT in filets, and the percent of each
isomer in the total DDT level using data and analyses
provided by Olin.
-------
c. Use of resampling, reanalysis, or additional
studies for continued attainment. Following the
attainment of the Performance Standard, the Technical
Committee may require additional information to
evaluate changes in DDT levels. For example, it may
recommend that QA/QC split sample analysis be conducted
for all performance standard fish of concern in each
reach after the initial attainment of the Performance
Standard. It may also recommend that larger sample
sizes be collected, particular fish be reanalyzed, or
that the age of all fish be verified. After the
Performance Standard has been met for three consecutive
years (by species and reach) collection and analysis
may be discontinued but all samples collected shall be
maintained in a repository.
d. Use of data from other sources. The Technical
Committee may use monitoring data from other sources to
evaluate changes in DDT levels in the HSB-IC system;
however, analytical measurements must be supported by
evidence of strict protocols and QA/QC must be
demonstrated to be equivalent to that required of Olin.
Any discrepancies in collection of samples, preparation
of tissues for extraction, or analytical procedures
must be justified to the Technical Committee.
e. Data analysis and presentation. The Technical
Committee may consider other statistical analyses of
the Olin data sets (e.g., geometric means, medians),
pooling of the reach data, and testing the means for
sensitivity to individual data points to determine
trends and patterns of the monitoring results.
D. Evaluation of the Remedial Action
1. The Technical Committee will advise the Review Panel
if, based on their review of the data and the notification
of compliance, they believe that the Performance Standard
was attained and/or continued to be attained in a manner
consistent with the goals and objectives of the Consent
Decree.
a. If the Technical Committee finds that the
Performance Standard has been attained consistent with
the goals and objectives of the Consent Decree, the
Technical Committee may advise the Review Panel whether
or not they believe the Performance Standard will
continue to be met consistent with the requirements of
the Consent Decree as well as document the basis for
such determination.
-------
b. If the Technical Committee finds that the
Performance Standard is not being attained, but that
the remedial action is consistent with the goals and
objectives of the Consent Decree, they will advise the
Review Panel whether or not they believe the remedial
action can attain the Performance Standard over a
longer period of time and whether or not further
remedies are necessary.
c. If the Technical Committee finds that the end of
the compliance period is reached without DDT levels in
fish having reached the Performance Standard for all of
the required species within all study reaches as
specified in the consent decree, it may recommend:
extending the compliance period, further sampling to
define/refine any trends, or other options, consistent
with the procedures set forth in the Consent Decree.
2. Following a determination of compliance with the
Performance Standard for channel catfish, largemouth bass,
and smallmouth buffalo, consistent with the goals and
objectives of the Consent Decree discussed in paragraph D.I
of this document, Olin shall submit to the Review Panel a
proposed list of future monitoring activities, DDT
measurements, studies, and other information by which Olin
would demonstrate that the remedy has provided, is providing
and will continue to provide achievement of the Performance
Standard once the Consent Decree terminates.
a. The Technical Committee will review the proposal
of monitoring activities and advise the Review Panel on
its adequacy and/or recommend modifications to the
proposal. The proposal should explain how the future
monitoring activities, studies, and information will be
integrated with existing data.
b. The Technical Committee will seek to coordinate
the monitoring activities of DDT in HSB-IC among the
members, agencies and Olin to minimize duplicative
requirements.
3. Following the approval and implementation of the
monitoring activities and data collection discussed under
paragraph D.2 of this document, the Review Panel and the
Technical Committee will review this information for
compliance with paragraph 54 of the Consent Decree.
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III. Conclusion
This decision document is the Review Panel's decision from
its January 23, 1992 meeting. This document consists of 7 pages
of text and one appendix of three pages and comprises the Review
Panel decision. It is accepted and adopted by the representatives
of the Review Panel member agencies and concurred in by the
nonvoting participants as shown by the signatures affixed hereto.
MEMBERS
Anne L. Asbell
Chairperson, Review Panel
Dr. Edward S. Bender
- Washington, D.C.
Robert J~7~-Pryor
Tennessee Valley Authority
R. Mark Wilson
U.S. Fish and Wildlife
Service
-6V
seph M. Mabi
Army, Redstone Ars<
James W. Warr
Alabama Department of
Environmental Management
NONVOTING PARTICIPANTS
Honorable Clyjfe Foster
Town/of Triana, Alabama
DATED:
William G. McGlasson
Olin Corporation
JAN 2 3 1992
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Review Panel Decision Document No. 9
Appendix A
Long Term Monitoring Data Reporting
Review Panel Decision Document No. 6, as amended, requires
the submission of an annual report describing the previous year's
activities and the data collected. The types of information and
environmental data which are reported are described in the
following sections. Some additional data which are being
reported for the first time in 1992 and they are marked with an
asterisk.
1. Fish Monitoring Program
The fish monitoring program consists of the collection of
performance standard fish, substitute fish, and other fish
species in the spring and a collection of young-of-year
performance standard fish in the fall. General data to be
reported includes species of fish, numbers of fish collected,
field observations and water quality data (pH, dissolved oxygen
and water temperature).
a. Individual fish data to be reported include:
-length
-weight
-filet weight
-total DDT in filet
-DDT isomers in filet
-lipids in filet
-location of capture
-date of capture
b. Additional data on the performance standard fish
collected in the spring include:
-age(either using standard aging techniques or
length-weight relationships)*
-condition factor*
2. Surface Water Monitoring Program
The surface water monitoring program consists of semi-annual
water sampling and velocity-discharge measurements. General data
to be reported include stage elevation, water quality (pH,
dissolved oxygen and water temperature), flowrate, flow velocity
and direction, and field observations.
Individual sample data to be reported include:
-sample location
-------
-sample date and time
-total DDT
-filterable DDT
-total suspended solids
-total organic carbon (3 sampling locations only)
3. Other Environmental Studies
Other monitoring studies may be conducted. These may
include daily water sampling, macroinvertebrate studies and
sediment sampling. Data to be reported will vary from study to
study but will generally include:
-samples collected
-measurements made
-sample/measurement location
-time and date of sampling/measurements
-analytical data (DDT, moisture, etc. as
applicable)
4. Quality Assurance/Quality Control Data
All field sampling and laboratory analyses include a quality
assurance program. Data generated for quality assurance purposes
will also be reported. These data include field, intralaboratory
and interlaboratory data such as:
-split sample results
-spike sample results
-duplicate sample results
-SRM sample results
5. Data Evaluation
Data evaluation will utilize statistical analysis to
describe the data collected for fish, water and other media.
a. Analysis of Fish Data
Analysis of fish data will include the following:
-DDT by reach by species
-DDT by system by species
-DDT by age class by species *
-DDT by lipid content by species*
b. Statistics and Comparisons
Various statistical parameters will be determined and
presented where appropriate for fish and other data. These
ii
-------
include:
-arithmetic mean
-geometric mean*
-median*
-standard deviation
-range
-sample size
-statistical distribution
-other evaluations to describe the data
Comparisons of data to baseline values and previous sampling
years will be presented. Trends in data will be evaluated by
reach and by species for fish data. Trends in water and sediment
data will also be compared where appropriate.
c. Water Data Evaluation
Evaluation of water data will include:
-DDT concentrations by site
-DDT transport by site
-total suspended sediment concentrations by site
-suspended sediment transport by site
Trends and comparisons of water quality data including DDT
concentrations to past data and baseline data will be presented.
d. Quality Assurance Evaluations
Evaluation of the quality assurance data will also be
presented. Both intralaboratory and interlaboratory data will be
evaluated for accuracy and precision. The referee laboratory's
certification will also be included.
111
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix H. Decision Document No. 10,
Process for Review of Olin's Notifications of Continued Attainment
by the Technical Committee
Decision Document 10-Appendix A , Finding of Continued
Attainment, Largemouth Bass, Reach C, January 19,
1995.
Decision Document 10-Appendix B, Finding of Continued
Attainment Largemouth Bass, Reach A, July 20, 1995.
Decision Document 10-Appendix C, Finding of Continued
Attainment Largemouth Bass, Reach B, July 20, 1995
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REVIEW PANEL DECISION DOCUMENT NUMBER 10
PROCESS FOR REVIEW OF OLIN'S NOTIFICATIONS OF CONTINUED
ATTAINMENT BY THE TECHNICAL COMMITTEE
I. Introduction
Pursuant to the requirements of the Consent Decree,
U.S. vs. Olin Corp., May 31, 1983, the Review Panel is authorized
to review the remedial action implemented by Olin and determine
whether the remedy has achieved compliance with the performance
standard consistent with the goals and objectives of the Consent
Decree. The Review Panel may review all significant information
and supporting data to assess the adequacy of the remedy and
compliance with the performance standard, including the Long-Term
Monitoring Reports (Decision Document No. 6), the Interim Goals
(Decision Document No. 5), and advice and data evaluations from
the Technical Committee (Decision Document No. 9).
Pursuant to the Consent .Decree and Decision Documents No. 6
and No. 9, Olin will notify the Review Panel and the Technical "~
Committee when Olin determines that it has attained the
performance standard and when it has demonstrated continued
attainment of the performance standard. The Joint Technical
Proposal to Implement Remedial Activities Pursuant to Consent
Decree at Section 7.3.2, Measurement of Performance Standard,
defines Attainment and Continued Attainment as follows:
The performance standard is a DDT level of 5 ppm
in fillets of channel catfish, largemouth bass and
smallmouth buffalo in Reaches A, B, and C. Olin
shall be deemed to "attain the performance standard"
when the average DDT concentration in the fillets of
each of the aforementioned fish species is five ppm
(or less) in Reaches A, B, and C. "Continued attainment
of the performance standard" occurs when the average
DDT concentration in the fillets of each of the
aforementioned fish species is five ppm (or less)
for three (3) consecutive years (including year
of Attainment) in Reaches A, B, and C.
On behalf of the Review Panel, the Technical Committee will
evaluate Olin's notification of attainment and continued
attainment of the performance standard for each species in each
Reach and determine if attainment and continued attainment of the
Performance Standard have been satisfactorily demonstrated for
purposes of compliance with the Consent Decree and will make
recommendations to the Review Panel. The process for the
Technical Committee review of the monitoring data, other
appropriate factors, and recommendations to the Review Panel is
described in Decision Document No. 9.
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The purpose of this document is to establish procedures for
recording the Decisions of the Review Panel relative to
attainment and continued attainment of the performance standard.
The procedures are intended to provide guidance for consistent
reviews and to document the rationale for the decisions in one
easily accessible location. In that spirit, all future
"continued attainment" Decisions will be added as appendices to
Decision Document No. 10.
II. Decision .The decision of the Review Panel is:
A. The Technical Committee will review Qlin's notification
of attainment and continued attainment of the performance
standard and supporting data. Through the application of sound
analytical and technical principles, the Technical Committee will
evaluate the data and advise the Review Panel on the status of
the remedial action in attaining and/or demonstrating continued
attainment with the performance standard. Following this
evaluation, the Technical Committee will make recommendations tcr
the Review Panel on the continued attainment demonstration for
•each species in each Reach and recommend preparation of an
appendix to Decision Document No. 10.
B. The Review Panel will review the recommendations of the
Technical Committee and make a decision as to the demonstration
of continued attainment of the performance standard.
C. The Review Panel will acknowledge the notification of
the attainment of the performance standard for a species in the
Minutes of the Review Panel, meeting.
D. Decisions related to continued attainment of the
performance standard will be documented in signed appendices to
this Decision Document. Each appendix will identify the
notification, the supporting data from Olin including the EPA
Certification of the data set, and any recommendations of the
Review Panel foY additional .monitoring or modifications to the
remedial action plan.
E. Once the Review Panel determines that continued
attainment has been achieved for a performance standard spec.ies
in a particular Reach, compliance for that species in that Reach
will not be reevaluated until the seventh year of the seven year
period prior to termination of the Consent Decree. Olin may
continue to monitor that species in that Reach for informational
purposes and will report the results of any informational
monitoring to the Review Panel in the Annual Report.
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III. Conclusion
This Decision Document confirms the Review Panel decision at
its July 21, 1994 meeting. This document consists of three pages
of text and Appendix A with four Attachments and comprises the
Review Panel decision. Appendices for subsequent determinations
of continued attainment of the performance standard will be
attached and incorporated herein as they are developed, approved,
and signed by the Review Panel. Acceptance and adoption of this
document by the representatives of the Review Panel member
agencies and concurrence by the nonvoting participants are shown
by the signatures affixed hereto.
MEMBERS
Anne L. Asbe11
Chairperson, Review Panel
Dr. W. Allen Robo_son
U.S. Fish and Wildlife
Service
Dr. Edward S. Bender
EPA - Washington, D.C.
Col. Stephen P. Moeller
U.S. Army, Redstone Arsenal
Robef£
Tennessee Valley Authority
James W. Warr
Alabama Department of
Environmental Management
NONVOTING PARTICIPANTS
Hononable Clyde" Foster
Town/of Triaria, Alabama
William G. McGlasson
Olin Corporation
DATED; JM 1 9 IMS
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Review Panel Decision Document No. 10
Appendix A
Finding of Continued Attainment
Largemouth Bass, Reach C
I. Introduction
Pursuant to the requirements of the Consent Decree, U.S. vs.
Olin Corp., May 31, 1983, the Review Panel is authorized to
review the remedial action implemented by Olin and determine
whether the remedy has achieved compliance with the performance
standard consistent with the goals and objectives of the Consent
Decree. This Appendix documents the Decision of the Review Panel
regarding Olin's demonstration of continued attainment of the
performance standard for Largemouth bass in Reach C.
II. Findings of the Review Panel
A. Notification: Olin provided notification that Largemouth
bass had demonstrated continued attainment of the performance
standard of 5 ppm DDT in Reach C on June 1, 1994 in Annual Report
Number 6 for the Huntsville Spring Branch Indian Creek Long-Term
Monitoring Program. The data showing DDT concentrations in
Largemouth bass by Year are presented on Table 22 of the June 1,
1994 Report (copy of Table 22 is attached hereto and incorporated
herein).
B. Data; The Technical Committee reviewed the data and
determined that the average DDT concentrations in fillets of
Largemouth bass in Reach C have been less than 5 parts per
million for four consecutive years, based on data from annual
fish collections from 1990 through 1993.
C. Quality Assurance Evaluations; The EPA referee
laboratory Certifications -for each set of data are attached to
this Appendix A and confirm that the data are acceptable for use
in determining achievement of the performance standard set forth
in the Consent Decree. .
D. Recommendations for Further Studies or Analysis; There
are no recommendations for further study or analysis by Olin at
this time. ' .
-------
III. Decision
The Review Panel has evaluated the recommendation of the
Technical Committee and determined that the data provided by Olin
for Largemouth bass for DDT concentrations in fillets demonstrate
.continued attainment with the performance standard of 5 parts per
million for Largemouth bass in Reach C.
IV..Conclusion
This decision document confirms the Review Panel decision at
its July 21, 1994 meeting. This document consists of two pages
of text and four attachments and comprises the Review Panel
decision. Acceptance and adoption of this document by the
representatives of the Review Panel member agencies and
concurrence by the nonvoting participants are shown by the
signatures affixed hereto.
•MEMBERS s^
Anne L. Asbell
Chairperson, Review Panel
Dr. Edward S. Bender
EPA - Washington, D.C.
Dr. W. Allen Robison
U.S. Fish and Wildlife
Service
Col. Stephen P. Moeller
Army, Redstone Arsenal
Robert J.~ Pryor
Tennessee Valley Authority
aes W. Warr
Alabama Department of
Environmental Management
NONVOTING PARTICIPANTS
Honorable Clyde Foster
Town of Triana, Alabama
' f
DATED:
William G. McGlasson
Olin Corporation
J*f9 MK
-------
TABLE 22
AVERAGE DDT CONCENTRATIONS IN FISH BY YEAR
LARGEMOUTH BASS
Reach
B
rameter
n
ave
s.d.
min
max
n
ave
s.d.
min
max
n
ave
s.d.
min
max
Baseline*
21
7.1
7.8
1.2
28
3
37
11
28
49
34
8.2
6.0
1.2
24
Yearl
1988
10
5.6
5.5
.7
16
'9
5.0
8.5
0.4
27
17
2.7
4.8
0.2
16
Year 2
1989
17
4.9
4.1
0.2U
15
13
2.2
2.4
0.2U
8.8
26
6.4
13
0.2U
56
Year 3
1990
18
4.3
4.2
0.1 U
16
14
3.7
4.0
0.45
16
u
U^ .
1.4
0.64
5.0
Year 4
1991
14
9.7
6.8
2.0
23
10
9.5
5.6
2.3
21
o
©
3.7
0.03U
12
Year 5
1992
11
1.5
2.4
0.27
8.0
18
1.3
1.4
0.03U
5.6
26 .
&7£
o?89
0.03U
4.0
Year 6
1993
10
1.2
1.3
0.13
3.8
15 —
3.8-
3.5
0.08
14
17
&4
1.7
0.50
6.8
* Decison Document No. 2 [1982-1985 Fish Collection (Year Group H-V)]
DDT concentrations are ppm (mg/kg) in filets
** ' '
n is number of samples analyzed
ave is average DDT concentration (ppm) of samples analyzed
s.d. is standard deviation of the DDT concentrations (ppm)
min is the minimum DDT concentration (ppm) analyzed
max is the maximum DDT concentration (ppm) analyzed
C:HSVTAB6AJX)C
6/1/94
-------
I
. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
. REGION IV
ENVIRONMENTAL. SERVICES DIVISION
ATHENS. GEORGIA 3O013
May 25, 1994
4ES-AS-LES
SUBJECT: Huntsvill<=T DDT Project
FROM: . H. La von Revells
Senior Staff Specialist
Analytical Support Branch
TO:
of Regional Counsel
I have reviewed the fish inter-laboratory comparison data
for the 1993 Huntsville DDT Project and find it acceptable.
There were 38 fish samples split with EPA as the Referee
laboratory and Olin-Charleston as the Primary laboratory. The
average % RSD was 18.8, which is well within the required % RSD
of 30. However, a data bias check performed by Keith Roberts
determined that there was bias between laboratories. Of the 38
split samples, Olin's results were less than EPA's for 32 of
them. Keith Roberts and I have begun studies to determine the
cause of this difference.
cc: Dr. Edward Bender (14OOF, HDQTR)
Mr. Keith Roberts (Olin-Charleston)
James Finger (ESD)
Wade Knight (ESD)
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ENVIRONMENTAL SERVICES DIVISION
ATHENS, GEORGIA
AUGUST 17, 1994
4ES-AS-LES..
MEMORANDUM
SUBJECT: OLIN'S 1991 AND 1992 PISH MONITORING DATA
FROM: Lavon Revells, Chemist: $z^f
Senior Staff Specialist:
s f -^VA
TO: Annfe L.«Asbell
. Chairperson, Review Panel
As you know, Olin's 1991 and 1992 fish monitoring, data were
flagged because the percent relative standard deviation (%RSD) of
split fish sample results between Olin and EPA Region IV Labora-
tories was greater than the target goal of 30. Since the
reporting of the 1991 fish data, representatives from our EPA
laboratory and Olin's primary and secondary laboratories had
several .meetings and discussions in an effort to determine the
cause of the high %RSD. As a result of these discussions, a
series of studies were designed and conducted to identify the
problem areas. While all laboratories were using the same
analytical method, the studies indicated that slight variations
in laboratory procedures could give different results. For this
reason, the procedures were standardized and incorporated into
the method. Subsequently, thirty fish samples representing the
1991 and 1992 fish collection were split between the three
laboratories and analyzed according to the standardized pro-
cedures. All samples that had results greater than 5 PPM DDT met
the goal of 30% RSD between Olin's primary and EPA Laboratories.
The Technical Committee in it's July 1993 meeting recommend-
ed that other**QC parameters in addition to %RSD be used in
evaluating fish monitoring data. The Committee agreed that 30%
RSD is not as important, if the sample results from the Olin and
EPA laboratories are below 5 PPM DDT.
After reviewing the analytical data and the conclusions of
the Technical Committee, I concur with the recommendation of the
Technical Committee and the decision of the Review Panel to
remove the asterisk from the 1991 and 1992 fish data. The data
are appropriate for use by the Review Panel in making decisions
regarding compliance with the performance standard of 5 PPM DDT
\r\ fillets of performance standard fish.
-------
FIGURE 3
EPA QUALITY ASSURANCE DATA CERTIFICATION
I UNfTED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ENVIRONMENTAL SERVICES DIVISION
ATHENS. GEORGIA 3O61 3
March 11, 1991
Anne Asbell
US Environmental Protection Agency
Office of Regional Counsel
345 Courtland St. NE
Atlanta, GA 30365
Dear Anne,
I have reviewed the fish inter-laboratory comparison data for the
1990 Huntsville DOT Project and find it acceptable. There were 26
fish samples, split with EPA as the Referee lab and Olin-Charleston
as .the Primary lab. The average %RSD was 25%, which is quite
acceptable for fish tissue split samples. Also, a data bias check
performed by Keith Roberts determined that there was no bias
between labs.
Sincerely yours,.
E. William Loy, Jr., Ch
Analytical Support Branch
cc: Keith Roberts, Olin-Charleston
-------
Review Panel Decision Document No. 10
Appendix B
• /
Finding of Continued Attainment
Largemouth Bass, Reach A
I. Introduction
Pursuant to the requirements of the Consent Decree, U.S. vs.
Olin Corp., May 31, 1983, the Review Panel is authorized to
review the remedial action implemented by Olin and determine
whether the remedy has achieved compliance with the performance
standard consistent, with the goals and objectives of the Consent
Decree. This Appendix documents the Decision of the Review Panel
regarding Olin's demonstration of continued attainment of the
performance standard for Largemouth bass in Reach A.
II. Findings of the Review Panel
A. Notification; Olin provided notification that Largemouth
bass had demonstrated continued attainment of the performance
standard of 5 ppm DDT in Reach A on May 15, 1995 in Annual Report
Number 7 for the Huntsville Spring Branch Indian Creek Long-Term
Monitoring Program. The data showing DDT concentrations in
Largemouth bass by Year are presented on Table 22 of the May 15,
1995 Report (copy of Table 22 is attached hereto and incorporated
herein).
B. Data; The Technical Committee reviewed the data and
determined that the average DDT concentrations in fillets of
Largemouth bass in Reach A have been less than 5 parts per
million for three consecutive years, based on data from annual
fish collections from 1992 through 1994.
C. Quality Assurance Evaluations; The EPA referee
laboratory Certifications for each set of data are attached to
this Appendix B and confirm that the data are acceptable for use
in determining achievement of the performance standard set forth
in the Consent Decree.
D. Recommendations for Further Studies or.Analysis; There
are no recommendations for further .study or analysis by Olin at
this time.
-------
III. Decision
The Review Panel has evaluated the recommendation of the
Technical Committee and determined/that the data provided by Olin
for Largemouth bass for DDT concentrations in fillets demonstrate
continued attainment with the performance standard of 5 parts per
million for Largemouth bass in Reach A.
IV. Conclusion
This decision document confirms the Review Panel decision at
its July 20, 1995 meeting. This document consists of two pages
of text and four attachments and comprises the Review Panel
decision. Acceptance and adoption of this document by the
representatives of the Review Panel member agencies and
concurrence by the nonvoting participants are shown by the
signatures affixed hereto.
MEMBERS
_
Anne L. Asbell
Chairperson, Review Panel
Dr. W. Allen Robison
U.S. Fish and Wildlife
Service
Dr. Edward S. Bender
EPA - Washington, D.C.
C6l. Stephen P. Moeller
U.S. Army, Redstone Arsenal
Roberf «3>~ Pryor
Tennessee Valley Authority
fames W. Warr
Alabama Department of
Environmental Management
. NONVOTING PARTICIPANTS
Honorable Clyde Foster
Town/of Triana, Alabama
William G. McGlasson
Olin Corporation
DATED:
-------
TABLE 22
AVERAGE DDT CONCENTRATIONS IN HSH BY YEAR
LARGEMOUTH BASS
Reach
B
arameter
n
ave
s.d.
min
max
n
ave
s.d.
min
max
n
ave
s.d.
min
max
Baseline*
21
7.1
7.8
1.2
28
3
37
11
28
49
34
8.2
6.0
1.2
24
Year!
J988
10
5.6
5.5
.7
16
9
5.0
8.5
0.4
27
17
2.7
4.8
0.2
16
Year 2
1989
17
4.9
4.1
0.2U
15
13
2.2
2.4
0:2U
8.8
26
6.4
13
0.2U
56
YearS
1990
18
4.3
4.2
0.11J
16
14
3.7
4.0
0.45
16
14
2.4
1.4
0.64
5.0
Year 4
1991
14
9.7
6.8
2.0
23
10
9.5
5.6
2.3
21
13
4.9
3.7
0.03U
12
Year 5
1992
11
1.5
2.4
0.27
8.0
18
1.3
1.4
0.03U
5.6
26
0.78
0.89
0.03U
4.0
Year 6
1993
10
1.2
1.3
0.13
3.8
15
3.8
3.5
0.08
14
12
1.4
1.7
0.50
6.8
Year 7
1994
17
1.6
1.7
0.03U
5.6
4
4
'12
1.9
2.3
0.03U
8.2
15
1.1
1.1
0.03U
3.8
DDT concentrations are ppm (mg/kg) in fillets
* Decison Document No. 2 [1982-1985 Fish Collection (Year Group H-V)]
n is number of samples analyzed
ave is average DDT concentration (mg/kg) of samples analyzed
s.d. is standard deviation of the DDT concentrations (mg/kg)
min is the minimum DDT concentration (mg/kg) analyzed
max is the maximum DDT concentration (mg/kg) analyzed
-------
* -
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
' REGION IV
ENVIRONMENTAL SERVICES DIVISION
ATHENS. GEORGIA 3O6 1 3
OS 1995
'
4ES-AS-OCS
MEMORANDUM
SUBJECT: Huntsville DDT Project, 1994
FROM: H. Lavon Revells
Senior Staff Specialist
Analytical Support Branch
TO:
of Regional Counsel
I have reviewed the fish inter-laboratory comparison data
for the 1994 Huntsville DDT project and find it acceptable.
There were 37 fish samples split with EPA as the Referee
laboratory and Olin-Charleston as .the Primary laboratory. The
average % RSD was 18.1, which is veil within the required 30%
RSD. Also; a data bias check performed by Keith Roberts
determined that there was bias between laboratories. However,
this appears to be a minor problem at this time.
cc: Dr. Edward Bender (140OF, HDQTR)
Mr. Keith Roberts (Olin-Charleston)
Mr. Russell Wright (BSD)
Mr. Charles Hooper (BSD)
-------
_
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
'
- REGION IV
ENVIRONMENTAL SERVICES DIVISION
ATHENS. GEORGIA 300 1 3
May 25, 1994.
4ES-AS-LES '
SUBJECT: Huntsville- DDT Project
FROM: . H. Lavon Revells
Senior Staff Specialist
Analytical Support Branch
TO: Anne/Asbel
Office of Regional Counsel
I have reviewed the fish . inter-laboratory comparison data
for the 1993 Huntsville DDT Project. ,and find it acceptable.
There were 3 & fish samples split with EPA as the Referee
laboratory .and .61 in-Charleston as "the Primary laboratory. The
average %.RSD was 18.8, which is well within the required % RSD
of 30. ' However, a data bias check performed by Keith Roberts
determined . that there was bias between laboratories. Of the 38
split samples, Olih's results were less than EPA's for 32 of
them. Keith Roberts and I have begun studies to determine the
cause of this difference.
cc: Dr. Edward Bender (140QF, HDQTR)
Mr. Keith Roberts (Olin-Cljarleston)
.James Finger (ESD)
Wade Knight (ESD)
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ENVIRONMENTAL SERVICES DIVISION
ATHENS, GEORGIA
AUGUST 17, 1994
4ES-AS-LES.. '
MEMORANDUM '
SUBJECT: OLIN'S 1991 AND 1992 FISH MONITORING DATA
FROM: Lavon Revells, Chemist
Senior Staff Specialist
S V AOViA
TO: : Ahnfe Z,..TAsbell . -
. . Chairperson, Review Panel ..
As you know, Olin's 1991 and 1992 fish monitoring, data were
flagged because the percent relative standard deviation (%RSD) of,
split fish sample results between Olin and EPA Region IV Labora- •
tories was greater than the target goal of 30. Since the . t~
reporting of the 1991 fish data, representatives from our EPA -
laboratory and oiin's primary and .secondary laboratories had •-•
several .meetings and discussions,'iti an effort to determine the
cause of the high %RSD. As a result of these discussions, a
series of studies were designed and conducted to identify the-
problem areas. While all laboratories were using the same
analytical method, the studies indicated that slight variations
in laboratory procedures could give different results. For this
reason, the procedures were standardized and incorporated into
the method. Subsequently, thirty fish samples representing the
1991 and. 1992 fish collection were split between the three
laboratories and analyzed according to the standardized pro-
cedures. All samples that had results greater than 5 PPM DDT met
the goal of 30% RSD between Olin's primary and EPA Laboratories.
The-Technical Committee in it's July 1993 meeting recommend-
ed that other**QC parameters in addition to %RSD be used in :
evaluating fish monitoring data. The Committee agreed that 30%
RSD is not as important, if the sample results from the Olin and
.EPA laboratories are below 5 PPM DDT.
After reviewing the analytical data and the conclusions of
the Technical Committee, I concur with the recommendation of the
Technical Committee and the decision of the Review Panel to
remove the asterisk from the 1991 and 1992 fish data. The data
are appropriate for use by the Review Panel in making decisions
regarding compliance with the performance standard of 5 PPM DDT
in fillets of performance standard fish.
-------
Review Panel Decision Document No. 10
Appendix C
Finding of Continued Attainment
Largemouth Bass, Reach B
I. Introduction
Pursuant to the requirements of the Consent Decree, U.S. vs.
Olin Corp., May 31, 1983, the Review Panel is authorized to
review the remedial action implemented by Olin and determine
whether the remedy has achieved compliance with the performance
standard consistent with the goals and objectives of the Consent
Decree. This Appendix documents the Decision of the Review Panel
regarding Olin's demonstration of continued attainment of the
performance standard for Largemouth bass in Reach B.
II. Findings of the Review Panel
A. Notification; Olin provided notification that Largemouth
bass had demonstrated continued attainment of the performance
standard of 5 ppm DDT in Reach B o'n May 15, 1995 in Annual Report
Number 7 for the Huntsville Spring Branch Indian Creek Long-Term
Monitoring Program. The data showing DDT concentrations in
Largemouth bass by Year are presented on Table 22 of the May 15,
1995 Report (copy of Table 22 is attached hereto and incorporated
herein).
B. Data; The Technical Committee reviewed the data and
determined that the average DDT concentrations in fillets of
Largemouth bass in Reach B have been less than 5 parts per
million for three consecutive years, based on data from annual
fish collections from 1992 through 1994.
C. Quality Assurance Evaluations; The EPA referee
laboratory Certifications for each set of data are attached to
this Appendix C and confirm that the data are acceptable for use
in determining achievement of the performance standard set forth
in the Consent Decree.
D. Recommendations for Further Studies or Analysis; There
are no recommendations for further study or analysis by Olin at
this time.
-------
III. Decision
The Review Panel has evaluated the recommendation of the
Technical Committee and determined that the data provided by Olin
for Largemouth bass for DDT concentrations in fillets demonstrate
continued .attainment with the performance standard of 5 parts per
million for Largemouth bass, in Reach B.
IV. Conclusion
This decision document confirms the Review Panel decision at
its July 20, 1995 meeting. This document consists of two pages
of text and four attachments and comprises the Review Panel
decision. Acceptance and .adoption of this document by the
representatives of the Review Panel member agencies and
concurrence by the nonvpting participants are shown by the
signatures affixed hereto.
MEMBERS
Anne L. Asbell
Chairperson, Review Panel
Dr. W. Allen Robison
U.S. Fish and Wildlife
Service
Dr. Edward S. Bender
EPA - Washington, D.C.
Col. Stephen P. Moeller
U.S. Army, Redstone Arsenal
Tennessee Valley Authority
James W. Warr
Alabama Department of
Environmental Management
NONVOTING PARTICIPANTS
e~~£lyde Foster
Triana, Alabama
DATED:
William G. McGlasson
Olin Corporation
. JOL 20 1995
-------
TABLE 22
AVERAGE DDT CONCENTRATIONS IN FISH BY YEAR
LARGEMOUTH BASS
B
rameter
n
ave
s.d.
min
max
n
ave
s.d.
min
max
n
ave
s.d.
min
max
Baseline*
21
7.1
7.8
1.2
28
3
37
11
28
49
34
8.2
6.0
1.2
24
Yearl
1988
10
5.6
5.5
.7
16
9
5.0
8.5
0.4
27
17
2.7
4.8
0.2
16
Year 2
1989
17
4.9
4.1
0.2U
15
13
2.2
2.4
0:2U
8.8
26
6.4
13
0.2U
56
Year 3
1990
18
4.3
4.2
0.11J
16
14
3.7
4.0
0.45
16
14
2.4
1.4
0.64
5.0
Year 4
1991
14
9.7
6.8
2.0
23
10
9.5
5.6
2.3
21
13
4.9
3.7
0.03U
12
Year 5
1992
11
1.5
2.4
0.27
8.0
18
1.3
1.4
0.03U
5.6
26
0.78
0.89
0.03U
4.0
Year 6
1993
10
1.2
1.3
0.13
3.8
15
3.8
3.5
0.08
14
12
1.4
1.7
0.50
6.8
Year 7
1994
17
1.6
1.7
0.03U
5.6
t
12
1.9
2.3
0.03U
8.2
15
1.1
1.1
0.03U
3.8
DDT concentrations are ppm (mg/kg) in fillets
* Decison Document No. 2 [1982-1985 Fish Collection (Year Group H-V)]
n is number of samples analyzed
ave is average DDT concentration (mg/kg) of samples analyzed
s.d. is standard deviation of the DDT concentrations (mg/kg)
min is the minimum DDT concentration (mg/kg) analyzed
max is the maximum DDT concentration (mg/kg) analyzed
C-.HSVTAB7A.DOC
-------
\
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ENVIRONMENTAL SERVICES DIVISION
ATHENS. GEORGIA 3O6 1 3
r-
4ES-AS-OCS
MEMORANDUM
SUBJECT:
FROM:
TO:
Huntsville DDT Project,, 1994
H. Lavon Revells .
Senior Staff Specialist
Analyt^L cal Support Branch
of Regional Counsel
I have reviewed the fish inter-latioratory comparison data
for the 1994 Huntsville DDT project and find it acceptable.
There were 37 fish samples split with EPA as the Referee
laboratory and Olin-Charleston as the Primary laboratory. The
average % RSD was 18.1, which is well within the required 30%
RSD. Also, a data bias check performed by Keith Roberts
determined that there was bias between laboratories. However,
this appears to be a minor problem at this time.
cc: Dr. Edward Bender (1400F, HDQTR)
Mr. Keith Roberts (Olin-Charleston)
Mr. Russell Wright (BSD)
Mr. Charles Hooper (BSD)
-------
rf •
-* ' --
? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
y •
'<< ««Jt«- .7 REGION IV
ENVIRONMENTAl. SERVfCCS DIVISION
• '-" ATHENS. CeORGtASCMS 13
May 25, 1994
4ES-AS-LES
SUBJECT: Huntsvill
-------
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ENVIRONMENTAL SERVICES DIVISION
ATHENS, GEORGIA
AUGUST 17, 1994
4ES-AS-LES. .
MEMORANDUM '
SUBJECT: OLIN'S 1991 AND 1992 FISH MONITORING DATA
FROM: Lavon Ravells, Chemist
Senior Staff Specialist
TO: : Ahn£ iSAsbell . -
CHairperson, Review Panel ..
As you know, Olin's 1991 and 1992 fish monitoring, data were
flagged because the percent relative standard deviation (%RSD) of
split fish sample results between Olin and EPA Region IV Labora- -
tories was greater than the target goal of 30. Since the t~
reporting of the 1991 fish data, representatives from our EPA
laboratory and Olin's primary and secondary laboratories had '•-•
several .meetings and discussions.- rn an effort to determine the
cause of the high %RSD. As a result of these discussions, a
series of studies were designed and conducted to identify the
problem areas. While all laboratories were using the same
analytical method, the studies indicated that slight variations
in laboratory procedures could give different results. For this
reason, the procedures were standardized and incorporated into
the method. Subsequently, thirty fish samples representing the
1991 and 1992 fish collection were split between the three
laboratories and analyzed according to the standardized pro-
cedures. All samples that had results greater than 5 PPM DDT met
the goal of 30% RSD between Olin's primary and EPA Laboratories.
The -Tecbjiical Committee in it's July 1993 meeting recommend-
ed that other**QC parameters in addition to %RSD be used in
evaluating fish monitoring data. The Committee agreed that 30%
RSD is not as important, if the sample results from the Olin and
EPA laboratories are below 5 PPM DDT.
After reviewing the analytical data and the conclusions of
the Technical Committee, I concur with the recommendation of the
Technical Committee and the decision of the Review Panel to
remove the asterisk from the 1991 and 1992 fish data. The data
are appropriate for use by the Review Panel in making decisions
regarding compliance with the performance standard of 5 PPM DDT
in fillets of performance standard fish.
-------
Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix!. DecisionDocumentNo.il,
Extension of Time for Meeting the Performance Standard
for Channel Catfish and Smallmouth Buffalo,
December 3, 1998.
-------
REVIEW PANEL DECISION DOCUMENT NUMBER 11
EXTENSION OF TIME FOR MEETING THE PERFORMANCE STANDARD FOR
CHANNEL CATFISH AND SMALLMOUTH BUFFALO
INTRODUCTION
On May 31,1983, the United States District Court for the Northern District of
Alabama (Northeastern Division, the Honorable Robert B. Propst presiding) entered, as part of
an overall order settling litigation between the United States of America, the state of Alabama,
and four sets of private parties against Olin Corporation (Olin), a Consent Decree (CD) that
governs development and implementation of remedial action for DDTR1 contamination in the
Huntsville Spring Branch-Indian Creek (HSB-IC) system.
The CD requires Olin to develop and implement a Remedial Action to meet the
performance standard of 5 parts per million (ppm) of DDTR in filets of channel catfish,
largemouth bass, and smallmouth buffalo in specified reaches of the HSB-IC system:
Reach A-Huntsville Spring Branch mile (HSBM) 5.4-2.4
Reach B-HSBM 2.4-0.0, and
Reach C-Indian Creek mile (ICM) 5.6-0.0.
The purpose of the remedy, monitoring, and other actions that Olin is required to perform
under the CD is to isolate DDTR in the HSB-IC system from people and the environment, to
minimize transport of DDTR out of the HSB-IC system, and to protect human health and the
environment. The performance standard is to be achieved by a remedy consistent with the goals
and objectives of the CD, which are summarized below:
1. Isolate DDTR from people and the environment;
2. Minimize the transport of DDTR out of the HSB-IC system;
3. Minimize adverse environmental impacts of remedial actions;
4. Mitigate effect of DDTR on wildlife habitats in Wheeler National Wildlife Refuge
(WNWR);
1 For purposes of the CD and as used in this report, DDTR is defined as 1,1,1 -trichloro-2,2-
bis- (p-chlorophenyl) ethane, including its isomers, and the degradation products and metabolites
DDD or TDE (l,l-dichloro-2,2-bis (p-chlorophenyl) ethane), and DDE (l,l-dichloro-2,2-bis (p-
chlorophenyl) ethylene), and the isomers thereof.
Page 1 of 10
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5. Minimize adverse effects on operations at Redstone Arsenal (RSA), Wheeler
Reservoir, and WNWR;
6. Avoid any increase in flooding, especially at the city of Huntsville and RSA, except
those increases in water level that can reasonably be expected in connection with
implementation of remedial action, provided Olin takes all reasonable steps to minimize
or prevent such increases; and
7. Minimize the effect of loss of storage capacity for power generation, in accordance
with the TVA Act.
The Review Panel reviewed and approved the proposed remedy for Reach A (Decision
Documents Numbers 1 and 3) and a Long Term Monitoring Program (Decision Document
Number 6) for evaluating progress toward meeting the performance standard.
The performance standard must be achieved within ten years after completion of
construction of the remedial action. The remedial action plan, the long-term monitoring
program, and the attainment of the performance standard are all subject to the review and
approval of the Review Panel.
Paragraph 40 of the Consent Decree provides "If Olin and the United States agree that
Olin has acted in good faith consistent with the schedule set forth in this Consent Decree but has
failed to meet the performance standard within the time set forth herein, Olin and the United
States shall agree to an extension of time for meeting the performance standard...".
DATA
Olin implemented the remedial action plan for Reach A as approved by the Review
Panel. Construction was completed in January 1, 1988. Beginning January 1,1988, Olin
implemented the Long-term Monitoring Program which was approved by the Review Panel in
Decision Document Number 6.
The long-term monitoring plan measured DDTR concentrations in surface water, ground
water, sediments, and fish tissue as an indicator of effectiveness of the remedy in meeting the
goals of the CD. A baseline of conditions for surface water and DDTR concentrations in
performance standard species and other species offish was established before the remedial
action. Other biota were also monitored periodically by Olin and other agencies to measure
DDTR concentrations and assess trends.
Olin submits annual monitoring reports to the Review Panel. Results for 1997
(representing the 10th year after completion of the remedial action) were received in 1998.
Baseline vs. 1997 fish sampling results are as follows:
Page 2 of 10
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DDTR in Performance Standard Fish Over Time
Species
Reach DDTR Concentration (ppm) in Fish Filets
% Reduction
from Baseline
Baseline
1988
1997
Channel Catfish
A
B
C
95
69
66
33
45
36
5.0
6.9
5.5
95
90
92
Largemouth Bass
Smallmouth Buffalo
A
B
C
A
B
C
7.1
37
8.2
140
180
110
5.6
5
2.7
31 (1989)
82
89
1.5(1996)
1.1 (1996)
0.5 (1996)
12
21
9.4
79
97
94
91
88
92
Largemouth bass have met the performance standard and continued attainment has been
demonstrated in all three reaches for this species in 1994. Channel catfish in Reach A also met
the performance standard in 1997. Channel catfish in Reaches B and C and smallmouth buffalo
in Reaches A, B, and C have not yet met the performance standard. Channel catfish are very
close to the standard and smallmouth buffalo are approaching it. All three (3) species have
shown a 90% reduction in DDTR overall and the trend appears to be continuing toward further
reductions.
DDTR concentrations in the water column are believed to be an important route of exposure for
fish in HSB-IC. Baseline vs. 1997 water sampling results are as follows:
Page 3 of 10
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DDTR in HSB-IC Water Over Time
Sample
Location
Reach
Total DDTR Concentration (ppb) in Water
Baseline
1988
1997
% Reduction
from
Baseline
HSBM 9.75 Upstream of A
HSBM 4.85
HSBM 3.9
HSBM 2.4
ICM 4.6
ICM 0.38
ICM 8.2
A
A
A
C
C
Upstream of C
0.77
3.4
12
13
4.3
1.7
0.6
0.0*
0.0*
0.35
1.23
1.51
0.54
0.0*
0.0*
0.0*
0.0*
0.05
0.11
0.0*
0.0*
>98
>98
>98
>97
>98
* Below quantitation limit of the analytical method.
As shown in the above table, average DDTR concentrations in the water column are
reduced by 97% or greater below the baseline conditions (pre-remedial action) throughout the
entire HSB-IC system. Water column concentrations are affected by sediment DDTR
concentrations within the HSB-IC system. The remedial action in Reach A isolated significant
quantities of DDTR in sediments.
The Remedial Action Plan developed by Olin, reviewed and approved by the Review
Panel, has been implemented consistent with all of the goals and objectives of the CD. Even
though the ten year monitoring period has expired, Olin has continued, in good faith, the
monitoring to evaluate changes in DDTR concentrations in performance standard species. The
results for 1998 should be available by the summer of 1999.
Although significant reductions in DDTR concentrations for channel catfish and
smallmouth buffalo have occurred, these species have not achieved the performance standard in
each of the stream reaches. In anticipation of this situation, the Review Panel requested that Olin
provide an evaluation of the progress achieved through the initial ten years and an analysis of
when the performance standard would be achieved. In Olin's HSB-IC Long-Term Monitoring
Program, Annual Report No. 10, May 15,1998, Olin included extensive trend and statistical
evaluation of the results and projections of when performance standards would be achieved.
Results of this evaluation conclude that channel catfish and smallmouth buffalo would achieve
the performance standard in all three reaches within 5 and 10 years respectively. Based on these
results, Olin made the following recommendations:
Page 4 of 10
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1. The attainment period for the channel catfish be extended by five (5) years to
December 31,2002.
2. The attainment period for the smallmouth buffalo be extended by ten (10) years to
December 31,2007.
PUBLIC INVOLVEMENT
On September 15,1998, the Review Panel held a public information meeting at the
Triana Youth Center to inform the public on: a) the progress that had been achieved through
1997 and b) the Review Panel proposal to extend the time to attain the performance standard for
channel catfish and smallmouth buffalo.
At the meeting, members of the Review Panel and other agency representatives discussed
the background of the problem, the design and implementation of the remedy, and the progress
toward meeting the performance standard which is summarized here. Questions were answered
in one-on-one discussions with members of the public. One hundred and fourteen people
attended the sessions. Oral and written comments at the meeting supported the recommendation
of the Review Panel to extend the time to attain compliance with the performance standards,
while requiring monitoring, interim goals, and contingency plans. However, questions from the
public also reflected their concerns about the permanence of the remedy, the necessity for the
time extension, groundwater or water supply contamination, and the risks of eating fish today.
Many individuals said that the monitoring results were very encouraging, they believed that the
remedy would work, and they were pleased with the commitment of all involved.
After, the public meeting the record remained open for the receipt of written comments
until October 9,1998. Comments offered at the meeting or in writing were consolidated by topic
and are presented with Review Panel responses in Appendix A to this decision document.
RATIONALE FOR THIS DECISION
The Review Panel members recognized the following points in developing this decision:
1. DDTR concentrations in the HSB-IC system have declined significantly in fish, sediments,
and surface water following the construction of the remedial action. Analysis of existing
data predict that further reductions should occur in the future.
2. There is no evidence of contamination of groundwater. Extensive monitoring supports the
conclusion that DDTR does not move in groundwater at this site.
3. DDTR concentrations are expected to continue to gradually decline in sediments and water
due to natural processes, including hydrologic mixing with clean sediments, burial from
Page 5 of 10
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deposition, microbial degradation and rrietabolism to other compounds, binding with
organic particles, and photolysis. There is no evidence that additional sources of DDTR
are contributing to the HSB-IC system loadings.
4. The remedial action structures containing the known sources, i.e., DDTR in sediments, have
continued to maintain their integrity and isolate DDTR. Engineering inspections by the
Review Panel's Inspection Committee (comprised of staff from all represented agencies)
confirm that the remedy has been stable and has not required repair or maintenance.
5. The HSB-IC system is a valuable resource, water quality is improving, and desirable species
offish and wildlife are increasing in abundance and diversity. Independent studies and
evaluations by Fish and Wildlife Service, Tennessee Valley Authority, Department of the
Army (both USAGE and Redstone Arsenal), the Environmental Protection Agency, and
Alabama support these conclusions.
6. The DDTR concentrations offish in Wheeler reservoir have decreased to levels sufficient
that the Alabama Department of Public Health removed its fish consumption advisory
from the Tennessee River in 1996.
7. The Review Panel has reviewed Olin Annual Report No. 10 and concurs that the predictions
of time to achieve the performance standard for channel catfish and smallmouth buffalo
are reasonable estimates based on current data.
8. At this time, it is unclear whether further remedial action would decrease the time to attain
the performance standard.
9. The Review Panel will monitor progress and require action as needed.
DECISION
Based on consideration of achievements to date and public comments, the decision of the
Review Panel is that Olin has acted in good faith with the provisions of the Consent Decree.
Monitoring data verifies that DDTR levels in fish have declined significantly. Concentrations in
fish, sediment and water have all decreased. Analysis of existing data on fish, water and
distribution of DDTR in sediments support the conclusion that this trend will continue.
Largemouth Bass have met the performance standard in all three reaches since 1992 (with
continued attainment since 1994) and concentrations in channel catfish and smallmouth buffalo
have declined significantly toward the performance standard. Furthermore, all of the goals and
objectives of the CD have been achieved.
The Review Panel concludes that an extension of the time to attain the performance
standard for channel catfish of 5 years (until December 31,2002) and for smallmouth buffalo of
10 years (until December 31, 2007) should be granted. These extensions are subject to the
conditions that Olin:
Page 6 of 10
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a) monitor to evaluate attainment of the performance standard for these fish species and
the effectiveness of the remedy during the period of the extension;
b) establish interim goals to evaluate progress toward compliance; and
c) develop contingency plans if the interim goals are not achieved, the performance
standard(s) is not attained, or the performance standard(s) cannot be maintained as
defined by the CD.
Within 60 days following the date of this decision document, Olin shall submit to the
Review Panel for review and approval, proposals for:
1) a monitoring program for the balance of the time extension;
2) interim goals for the time extension; and
3) contingency plans in the event that the interim goals or performance standards are not
achieved within the period of this time extension, or the performance standard cannot be
maintained.
Olin shall submit this information to the Review Panel for approval. The current
monitoring program will remain in effect until the Review Panel approves a modification.
Page 7 of 10
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CONCURRENCE
This Decision Document, consisting of text (including this concurrence section) and
appendix A, comprises the Review Panel decision and is accepted and adopted by the
representatives of the Review Panel member agencies and concurred in by the nonvoting
participants as shown below by the signatures affixed hereto.
MEMBERS
Edward S. Bender, Ph.D.
Chairman, Review Panel
^Alan Yarbrou
Environmenta'rrotection Agency
W. Allen Robison, Ph.D.
U.S. Fish and Wildlife Service
Colonel Steven C. rfamilton
U.S. Army, Redstone Arsenal
Robert Pryor
Tennessee Valley Authority
James W, Warr
Alabama Department of
Environmental Management
NONVOTING PARTICIPANTS
Hono^ble Clyde Foster
Town of Triana, Alabama
Laura B. Tew
Olin Corporation
Dated:
DEC 2 I 1998
Page 8 of 10
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Appendix A.
Review Panel Responses to Public Comments
Comments2 listed here are a consolidation of oral and written public comments and
questions on the Review Panel proposed decision to extend the time for meeting the performance
standard for channel catfish and smallmouth buffalo under the terms and conditions of the
Consent Decree, U.S. v. Olin Corporation.
Comment: The remedy has been given ten years to reach the performance standard, why should
more time be granted?
Response: The remedial action for the Huntsville Spring Branch-Indian Creek System
has been very effective in reducing DDTR concentrations in fish, water and sediments.
Concentrations in some fish are declining more slowly than expected when the Consent
Decree was signed. However, monitoring data show that concentrations continue to
decline.
There is convincing evidence that the remedy is working and, given additional time, will
fully comply with the Consent Decree. People and the environment would experience
fewer additional adverse effects by extending the time to allow the trends to continue
declining than by undertaking additional remedial actions that probably would release
additional DDTR into the environment temporarily.
If Olin has acted in good faith consistent with the schedule set forth in the Consent
Decree but has failed to meet the performance standard, the Consent Decree provides that
the Review Panel shall grant an extension of time for meeting the performance standard.
The Review Panel has concluded that Olin has acted in good faith in planning,
construction, and monitoring the remedial action project. Consequently, at this point, a
time extension is prudent and consistent with the Consent Decree.
Comment: What is the basis for the time period of the extension?
Response: Monitoring data have shown that the average concentrations of DDTR are
declining in the water column and in fish filets. Analysis of this data can be used to
estimate the amount of time required to achieve the performance standard. The Review
Panel reviewed analyses supplied by Olin and concurred with predictions of the time for
channel catfish and smallmouth buffalo to reach the performance standard.
Comment: What will Olin do if they are given more time to reach the performance standard?
2 Comments received about the medical fund monies were forwarded to the Chair of the Health
Review Panel because the issues raised were outside the scope of this Review Panel.
Page 9 of 10
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Response: During the period of the extension, Olin must continue to monitor DDTR
concentration trends and maintain the remedy. Olin also must continue to report annually
to the Review Panel on progress toward achieving the performance standard. If progress
toward achieving the performance standard is not considered to be adequate by the
Review Panel, Olin must pursue contingency plans. In addition, Olin must comply with
all other provisions of the Consent Decree.
Comment: What is the current status of DDTR contamination in fish for the Triana area?
Response: In 1996, the State of Alabama lifted the fish consumption advisory in the
Tennessee River in the vicinity of Triana. Average DDTR concentrations in channel
catfish and smallmouth buffalo in Indian Creek and Huntsville Spring Branch continued
to exceed the performance standard in 1997, and the fish consumption advisory for
bottom-feeding fish (primarily channel catfish and smallmouth buffalo) in Indian Creek
and Huntsville Spring Branch remains in effect. Largemouth bass have achieved the
performance standard and are not subject to the fish consumption advisory in the HSB-IC
system or the Tennessee River.
Page 10 of 10
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Review Panel Activities HSB-IC System DDT Remedial Action (3rd Report)
Appendix J
Joint Petition for Modification of Schedule to Meet Consent Decree Performance
Standards and Court Order
J-l
-------
THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF ALABAMA
NORTHEASTERN DIVISION
UNITED STATES OF AMERICA, )
)
Plaintiff, ) CIVIL ACTION
)
OLIN CORPORATION, ) NO. CV80-PT-5300-NE
)
Defendant. )
JOINT PETITION FOR MODIFICATION OF SCHEDULE TO MEET
CONSENT DECREE PERFORMANCE STANDARDS
The United States of America, on behalf of the U.S. Environmental
Protection Agency (EPA), the U.S. Fish and Wildlife Service (FWS), the U.S.
Department of the Army (DOA), and the Tennessee Valley Authority (TVA), joins
with Olin Corporation in filing this Petition for Modification of Schedule to Meet
Performance Standards. This Petition is being filed pursuant to Paragraph 40 of
the Consent Decree entered by this Court on May 23, 1983. A copy of the Consent
Decree is attached to this Petition as Attachment A
I. BACKGROUND
On December 4, 1980, the United States filed a Complaint against Olin
Corporation alleging that Olin's discharge of DDT into the waters of the United
States, the Wheeler National Wildlife Refuge, and the environment from Olin's
DDT manufacturing plant located on the Redstone Arsenal, had created an
imminent and substantial endangerment to human health and the environment.
-------
The United States sought relief under federal statutory law and common law.1' -
On May 31,1993, this Court entered a Consent Decree between the United
States and Olin Corporation under which Olin agreed to conduct cleanup activities
at its former DDT plant (also known as the Olin Super-fund Site) in order to abate
the risk of harm. More specifically, the Consent Decree required Olin to develop
and implement a remedial action plan which will isolate DDT contaminated soils
and sediments from people and the environment, and reduce DDT levels in filets of
three selected indicator fish species to 5 parts per million (ppm) within ten (10)
«
years after Olin completed construction of the remedy. The Consent Decree
established a Review Panel with voting members from EPA, TVA, FWS, and DOA,
and the State of Alabama3', and non-voting members from Olin and the Town of
Triana, Alabama. The Review Panel is authorized to make decisions concerning the
selection and modification of the remedy, achievement of performance standards,
compliance with the goals and objectives of the Decree, and other activities
required under the Decree. The Review Panel approved Olin's proposed remedial
action plan.
Olin implemented the remedial action and completed construction on
January 1, 1988. A ten-year monitoring period began on January 1, 1988, and the 5
^Congress enacted the Comprehensive Environmental Response, Compensation,
and Liability Act ("CERCLA" or "Superfund") in 1980.
State of Alabama filed a separate suit (Civ. Action No. CV79-PT-5174-NE)
against Olin seeking similar relief to that requested by the United States. The
Court consolidated the cases.
-2-
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ppm performance standard was required to have been achieved by December 31,
1997. During the monitoring period, Olin measured DDT concentrations in the
surface water, ground water, sediments, and fish tissue as an indicator of the
effectiveness of the remedy. Results for 1997, representing the 10th year after
construction of the remedy, were received in 1998 and indicated that while the
remedy has been successful in achieving the Goals and Objectives set out in
paragraph 13 of the Decree, the performance standards have not yet been met in all
3 fish species in all 3 reaches of the river system.
*
Largemouth bass have met the performance standard and continued
attainment has been demonstrated in all three reaches for this species in 1996.
Channel catfish in Reach A have also met the performance standard. Channel
catfish in Reached B and C and smallmouth buffalo in Reaches A, B, and C have not
yet met the performance standard. All three species have shown a 90% reduction
in DDT overall and the trend appears to be continuing toward further reductions.
Based on these results, the Review Panel requested Olin to provide and evaluation
of the progress achieved during the ten-year monitoring period and projection of
when the performance standard would be met for channel catfish and smaUmouth
buffalo. Olin's Annual Report No. 10, dated May 15, 1998, included extensive trend
and statistical analyses of the monitoring results, and concludes that channel
catfish would achieve the performance standard within 5 years, and
-------
smallmouth buffalo within 10 years. Based on this report, Olin recommended that:
1. The schedule for attainment of the performance standard for channel catfish
be extended five years to December 31, 2002;
2. The schedule for attainment of the performance standard for smallmouth
buffalo be extended by ten years to December 31,2007.
After extensive review and evaluation of Olin's recommendations, the
Review Panel concurs with Olin's conclusions and recommendations concerning
the attainment of the performance standard. The evidence in the record strongly
indicates that the decline in DDT levels will continue and that the performance
standard will be met without the need for additional remedial action. The Review
Panel's findings and concurrence with Olin's recommendations are set forth in
Decision Document #11 (attached hereto as Attachment B)3'. Prior to signing the
Decision Document, the Review Panel issued a Proposed Plan which explained the
Review Panel's findings and the proposed schedule extension. A public meeting
was conducted on September 15,1998, and the public comment period remained
open until October 9,1998. None of the comments received by the Review Panel
presented compelling facts or circumstances which demonstrated that the schedule
extension agreed to by Olin and the Review Panel Review is inappropriate, unfair or
unlawful. A summary of the public comments submitted to the Review Panel and
Decision Document requires Olin to submit to the Review Panel, for review
and approval, proposals for a monitoring program and establishments of interim
goals to be met during the time extension, and contingency plans in the event that
the interim goals or performance standards are not achieved within the period of
the extension.
-4-
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the Review Panel's responses thereto are included in Decision Document #11.- The
review Panel members, including the non-voting members Olin Corporation and
the City of Triana, have signed Decision Document #11.
Paragraph 40 of the Consent Decree provides "If Olin and the United States
agree that Olin has acted in good faith consistent with the schedules set forth in
this Consent Decree but has failed to meet the performance standards within the
time set forth herein, Olin and the United States shall agree to an extension of
time for meeting the performance standard, shall jointly petition the Court for a
modification of the schedule and Olin shall not be liable for penalties set forth in
paragraph 35 based solely on its failure to meet the performance standard within
the time required during such extended period." The Review Panel (comprised of
4 agencies of the United States) and Olin have agreed that Olin has acted in good
faith with the Consent Decree. Therefore, under paragraph 40 of the Decree, the
parties are petitioning the Court to grant an extension of time for Olin to achieve
the performance standard. .
II. REQUEST FOR MODIFICATION OF SCHEDULE
Based on the foregoing facts and circumstances, the United States and Olin
Corporation hereby request the Court approve a modification of the schedule in
the Consent Decree for compliance with the performance standard as follows:
1. The time for attainment of the performance standard for channel
catfish shall be extended from December 31, 1997, until December 31,
2002.
-5-
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2. The time for attainment of the performance standard for smallmouth
buffalo shall be extended from December 31,1997, until December 31,
2007.
Respectfully Submitted,
Cheryl L. S6fout
Trial Attorney
Environment and Natural "Resources
Division
U.S. Department of Justice
P.O. Box 7611
Washington, D.C. 20044-7611
202-514-5466
-6-
-------
Signature Page for Joint Petition For Modification Of Schedule To Meet Consent
Decree Performance Standards in United States v. Olin Corporation CV80-PT-5300-
NE (N.DAla.)
ON BEHALF OF OLIN CORPORATION
-7-
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MRY-10-1999 08=54
USDC HUNTSUILLE
305 551 0741 P.002/003
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ALABAMA
NORTHEASTERN DIVISION
JAMES CLOUD, ET AL. ,
FILED
99 APR 23 PN t'
U.S.O.SVR1CJ COURT
H.D. OF ALABAMA
PLAINTIFFS ,
VS.
OLIN CORPORATION, ET AL.,
DEFENDANTS.
CV79-S
CV79-S
CV80-S
CV80-S
CV80-S
CVBO-S
5128-NE
5174-NE
5057-NE
S098-NE
5300-NE
5115-NE
ENTERE
°*DI» APR 2 3 1999
This action is before the court on the joint petition for
modification of schedule to meet consent decree •• performance
standards filed February 26, 1999. The court has reviewed the
Consent Decree entered May 31. 1983 (the "Decree") , the attachments
and submittals of the parties, particularly the Review Panel
Decision Document No. 11 dated January 5, 1999, and is of the
opinion that the petition should be granted. Accordingly, it is
ORDERED, ADJUDGED, and DECREED as follows: (1) the time for
attainment of the performance standard for channel catfish shall be
extended from December 31. 1997, until December 31, 2002; and (2)
the time for attainment of the performance standard for smallmouth
buffalo shall be extended from December 31, 1997, until December
31. 2007.
DONE this 23 """ day of April, 1999.
States District Judge
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