Five-Year Review Report
Second Five-Year Review Report
for
Ciba-Geigy Chemical Superfund Site
Mcintosh, Washington County, Alabama
September 2006
PREPARED BY:
Science and Ecosystem Division
United States Environmental Protection Agency
Region 4
Athens, Georgia
Approved by:
Beverly H. Banister, Acting Director
Waste Management Division
USEPA, Region 4
Date:
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Five-Year Review Report
Table of Contents
List of Acronyms iv
Executive Summary v
Five-Year Review Summary Form vii
1.0 Introduction 1
2.0 Site Chronology 2
3.0 Background 3
3.1 Physical Characteristics 3
3.2 Land and Resource Use 3
3.3 History of Contamination 4
3.3.1 OU-1, Shallow Ground Water Aquifer 5
3.3.2 OU-2, Ten of Eleven Former Waste Management Areas 5
3.3.3 OU-3, Floodplain, the Effluent Ditch and Tombigbee River 7
3.3.4 OU-4, Former Waste Management Area 8 (or Bluff line Site) and
the Dilute Ditch 8
3.4 Initial Response 8
3.4.1 OU-1, Shallow Ground Water Aquifer 9
3.4.2 OU-2, Ten of Eleven Former Waste Management Areas 9
3.4.3 OU-3, Floodplain, the Effluent Ditch and Tombigbee River 10
3.4.4 OU-4, Former Waste Management Area 8 (or Bluff Line Site) and
the Dilute Ditch 10
3.5 Basis for Taking Action 11
3.5.1 OU-1, Shallow Ground Water Aquifer 11
3.5.2 OU-2, Ten of Eleven Former Waste Management Areas 13
3.5.3 OU-3, Floodplain, the Effluent Ditch and Tombigbee River 13
3.5.4 OU-4, Contamination of Soils in Former Waste Management Area
8 (or Bluff Line Site) and the Dilute Ditch 14
4.0 Remedial Actions 15
4.1 Remedy Selection 15
4.1.1 OU-1, Shallow Ground Water Aquifer 15
4.1.2 OU-2, Ten of Eleven Former Waste Management Areas 16
4.1.3 OU-3, Floodplain, the Effluent Ditch and Tombigbee River 17
4.1.4 OU-4, Former Waste Management Area 8 (or Bluff line Site) and the
Dilute Ditch 17
4.2 Remedy Implementation 18
4.2.1 OU-1, Shallow Ground Water Aquifer 18
4.2.2 OU-2, Ten of Eleven Former Waste Management Areas 19
4.2.3 OU-3, Floodplain, the Effluent Ditch and Tombigbee River 20
4.2.4 OU-4, Former Waste Management Area 8 (or Bluff line Site) and
the Dilute Ditch 20
4.2.5 Summary of Implementation 21
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4.3
System Operations/Operation and Maintenance
21
5.0
Progress since the Last Review
21
6.0
Five-Year Review Process
22
6.1
Administrative Components
22
6.2
Community Involvement
23
6.3
Document Review
23
6.4
Data Review
23
6.4.1 OU1, Shallow Ground Water Aquifer
23
6.4.2 OU2, Ten of Eleven Former Waste Management Areas
24
6.4.3 OU3, Floodplain, the Effluent Ditch and Tombigbee River
25
6.4.4 OU4, Former Waste Management Area 8 (or Bluff line Site) and
the Dilute Ditch
25
6.5
Site Inspection
25
7.0
Technical Assessment
26
7.1
Question 1
26
7.1.1 OUs 1, 2& 4
26
7.1.2 Operable Unit 3
27
7.2
Question 2
32
7.2.1 OUs 1, 2& 4
32
7.2.2 Operable Unit 3
32
7.3
Question 3
33
7.3.1 Operable Units 1, 2 & 4
34
7.3.2 Operable Unit 3
34
7.4
Question 4
34
7.5
Technical Assessment Summary
35
7.5.1 Operable Units 1, 2, & 4
35
7.5.2 Operable Unit 3
35
8.0
Issues
35
9.0
Recommendations and Follow-up Actions
36
9.1
Recommendations for Operable Units 1, 2 and 4
36
10.0
Protectiveness Statement(s)
38
11.0
Next Review
39
Attachment A
Figures
40
Attachment B
List of Documents Reviewed
46
Attachment C
Site Photos
50
Attachment D
Five Year Review Site Inspection Check List
55
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List of Acronyms
ADEM
Alabama Department of Environmental Management
ARAR
Applicable or Relevant and Appropriate Requirements
BHC
Hexachl orocy cl ohexane
COC
Chemical of Concern
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CRQL
Contract Required Quantitation Limit
CSCC
Ciba Specialty Chemical Corporation
DDD
p, p'-Dichlorodipheny 1 dichloroethane
DDE
p, p' -Di chl orodipheny 1 di chl oroethene
DDT
p, p' -Di chl orodipheny ltri chl oroethane
DDTr
All isomers of DDT and its metabolites DDD and DDT
ESD
Explanation of Significant Differences
HQ
Hazard Quotient
HSWA
Hazardous Solid Waste Amendment
Lindane
y-hexachlorocyclohexane or y-BHC
MCL
Maximum Contaminant Level
MDL
Minimum Detection Levels
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
NPDES
National Pollutant Discharge Elimination System
NPL
National Priorities List
OSWER
Office of Solid Waste and Emergency Response
OU
Operable Unit
PRP
Potentially Responsible Party
RAO
Remedial Action Objective
RCRA
Resource Conservation and Recovery Act
RD
Remedial Design
RD/RA
Remedial Design/Remedial Action
RfD
Reference Dose
ROD
Record of Decision
SESD
Science and Ecosystem Division
Site
Ciba-Geigy Superfund Site
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Executive Summary
The Ciba-Geigy Chemical Superfund Site (the Site) was divided into four operable units (OUs).
This is the Second Five-Year Review for OU-1, OU-2, and OU-4 for the Ciba-Geigy Superfund
Site. The Fist Five-Year Review for OU-1, OU-2, and OU-4 was conducted by Environmental
Resource Management on behalf of Ciba Specialty Chemicals Corporation (CSCC). The First
Five-Year Review period was from August 2000 to January 2001, and EPA approved the report
on September 29, 2001. Overall, the conclusion in the First Five-Year Review was that the
remedial actions taken at the site continued to be protective of human health and the
environment. Because OU-3 was not evaluated at the time of the First Five-Year Review for
OU-1, OU-2, and OU-4, this is the First Five Year Review for OU-3. This and subsequent
Five-Year Reviews will be conducted site-wide.
The remedy for the Ciba-Geigy Superfund Site in Mcintosh, Alabama included excavation
and/or thermal treatment of approximately 139,000 tons of contaminated soils and sediments
on-site, institutional controls, and pump and treatment of contaminated ground water under
RCRA authority. The site achieved construction completion with the signing of the Preliminary
Close-Out Report on July 19, 2000. The trigger for this second five-year review was the
completion of the first five-year review on September 20, 2001.
The EPA designated a "No Further Action" remedy, for Operable Unit 1, based on the
effectiveness of the ground water pump and treat system already installed under the RCRA
permit to address ground water contamination in the shallow aquifer at the site. Ground water
Corrective Action conditions under RCRA were specified originally in the 1985 RCRA Permit,
and have been amended in subsequent Permit Modifications. Review of all semi-annual ground
water monitoring reports since the last five year review, from 2002 through 2005 (Ciba
Specialty, 2002-2005) and performance of extensive data evaluation indicates that the alluvial
aquifer ground water remediation program is meeting expectations, and is being effectively
managed under RCRA authority. The remedy is functioning as intended by the decision
documents.
The Records of Decision (ROD) for Operable Units 2 and 4 (OU-2 and OU-4) address the source
of contamination (i.e. soils) to ultimately reduce leaching of chemicals into the ground water
(OU-1). The remedy selected for OU-2 is essentially the same as for OU-4, since both of the
OUs address soils in various parts of the Superfund site. Remediation of Operable Units 2 and 4
were conducted jointly. Additionally, OU-4 had a slurry wall installed to divert ground water to
the OU-1 RCRA Corrective Action pumping wells. Based on research of scientific and
engineering records, coupled with interviews of CSCC personnel and an inspection of the site in
June 2006, the conclusion is that the remedy has been successfully implemented for OU-2 and
OU-4 and is fulfilling its primary function. The cap and the surrounding areas of OU-2 and OU-4
were undisturbed, and no new uses of ground water were observed. The fence around the site is
intact and in good repair. The slurry wall installed at OU-4 performs its design function as a
hydraulic barrier.
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According to the data reviewed, the site inspection, and the interviews, the remedies for OUs 1,
2, and 4 are functioning as intended by the ROD, as modified by the ESD. There have been no
changes in the physical conditions of the site that would affect the protectiveness of the remedy.
The applicable or relevant and appropriate requirements ARARs for soil contamination cited in
the ROD have been met. There have been no changes in the toxicity factors for the contaminants
of concern that were used in the baseline risk assessment, and there has been no change to the
standardized risk assessment, and there has been no change to the standardized risk assessment
methodology that could affect the protectiveness of the remedy. There is no other information
that calls into question the protectiveness of the remedy. The implemented remedies for OUs 1, 2
and 4 are protective of human health and the environment, as intended by the decision
documents.
The major remedy component for OU-3 was excavation of soil and sediment to meet an average
of 15 ppm dichlorodiphenyl-trichloroethane (DDTr) within OU-3. This remedial strategy was
implemented in an effort to prevent the destruction of the forested wetlands during remediation.
Review of project records, interviews and inspection of the OU-3 area provided ample
verification that excavated surface soils and sediments the top twelve inches) that were
remediated in OU-3, achieved overall compliance with the site-wide average 15 ppm DDTr
remedial goal. Since the selected remedy left DDTr in place in OU-3 sediments, primarily in the
forested wetlands, EPA required post-remediation monitoring to evaluate the effectiveness of the
remedy. Two performance standards were selected to evaluate the effectiveness of the remedy;
sediment concentrations within the remediated area should remain below 15 ppm, and
mosquitofish DDTr body burdens less than 1.5 ppm. Ciba Specialty issued the Post-Remediation
Monitoring Report in March, 2004. The report summarizes five years of monitoring data
collected by Ciba Specialty to assess the effectiveness of the selected remedy. Review of the
monitoring report, and other information, indicate the remedial action was successful at reducing
DDTr in mosquitofish tissue, however, mosquitofish DDTr tissue concentrations have leveled
off above the desired performance standard at ecologically unacceptable levels. Therefore the
remedy, as implemented, is not protective of the environment.
Results of the five years of post-remediation monitoring of OU-3, indicates the remedy, as
implemented, is not protective of the environment. Although progress has been made towards the
remedial goals, additional remediation of contaminated sediment is recommended to achieve the
remedial goals for OU-3.
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Five-Year Review Summary Form
* ["OU" refers to operable unit.]
** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]
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Five-Year Review Summary Form, cont'd.
Issues:
No issues were encountered for OU-1, OU-2, and OU-4 during this Five-Year Review.
The remedy for OU-3 is not fully successful as intended by the decision documents.
Recommendations and Follow-up Actions:
Continue operating the ground water pump and treat system to address ground water contamination.
Continue monitoring ground water at OU-1 as stated in the existing RCRA permit.
Continue maintenance of OU-2/OU-4's vegetative cover.
Continue enforcing institutional controls on-site.
Perform subsequent Five-Year Reviews on all OU's.
Remediate additional sediments in OU-3.*
Protectiveness Statement(s):
The remedies at OU-1, OU-2, and OU-4 are expected to be or are protective of human health and the
environment, and in the interim, exposure pathways that could result in unacceptable risks are being
controlled.
The remedy at OU-1 is expected to be protective of human health and the environment upon attainment
of ground water cleanup goals, through the ground water pump and treat system. In the interim,
exposure pathways that could result in unacceptable risks are being controlled and institutional controls
are preventing exposure to, or the ingestion of, contaminated ground water. All threats at OU-2 and
OU-4 have been addressed through excavation, treatment, and backfilling of contaminated soil, the
installation of fencing and warning signs, and the implementation of institutional controls.
Long term protectiveness of the remedial action will be verified by ongoing ground water monitoring
of OU-1. Current monitoring data indicate that the remedy is functioning as required to achieve ground
water cleanup goals.
Sediment and fish remain protective of human health under the remedial action deployed in OU-3.
Implementation of the cleanup level as an area-wide average in OU-3, has reduced ecological risk and
minimized destruction of cypress/tupelo forest. However, post-remedy monitoring offish tissue has
indicated stable concentrations above the performance standard for protection of the environment. The
remedy in its current state of implementation is not protective of the environment.
* Additional recommendations associated with OU-3 are presented in Section 9
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Ciba-Geigy Superfund Site
Mcintosh, Alabama
Five-Year Review Report
1.0 Introduction
The purpose of the Five Year Review is to determine whether the remedy at a site is
protective of human health and the environment. The methods, findings, and conclusions of
reviews are documented in Five-Year Review Reports. In addition, Five-Year Review Reports
identify issues found during the review, if any, and identify recommendations to address them.
The United States Environmental Protection Agency (EPA) is preparing this statutory
Five-Year Review report pursuant to the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) §121 and the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). CERCLA § 121 states:
If the President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such
remedial action no less often than each five years after the initiation of such remedial
action to assure that human health and the environment are being protected by the
remedial action being implemented. In addition, if upon such review it is the judgment of
the President that action is appropriate at such site in accordance with section [104] or
[106], the President shall take or require such action. The President shall report to the
Congress a list offacilities for which such review is required, the results of all such
reviews, and any actions taken as a result of such reviews.
EPA interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states:
If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such action no less often than every
five years after the initiation of the selected remedial action.
This Five-Year Review was conducted by EPA, Region 4's Science and Ecosystem
Division (SESD) at the request of the Waste Management Division, pursuant to the CERCLA
§ 121(c), the NCP, Section 300.430(f)(4)(ii), and the Office of Solid Waste and Emergency
Response (OSWER) Directives 9355.7-03B (June 2001). This report documents the results of
the review.
The Ciba-Geigy Chemical Superfund Site (the Site) was divided into four operable units
(OUs). This is the Second Five-Year Review for OU-1, OU-2, and OU-4 for the Ciba-Geigy
Superfund Site. The Fist Five-Year Review for OU-1, OU-2, and OU-4 was conducted by
Environmental Resource Management on behalf of Ciba Specialty Chemicals Corporation
(CSCC). The First Five-Year Review period was from August 2000 to January 2001, and EPA
approved the report on September 29,2001. Overall, the conclusion in the First Five-Year
Review was that the remedial actions taken at the site continued to be protective of human health
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and the environment. Because OU-3 was not evaluated at the time of the First Five-Year Review
for OU-1, OU-2, and OU-4, this is the First Five Year Review for OU-3. This and subsequent
Five-Year Reviews will be conducted site-wide.
This Second Five-Review was triggered by the completion of the First Five-Year
Review, based on statutory requirements of review every five years. The First Five-Year Review
was completed September 29, 2001 for OU-1, OU-2, and OU-4, therefore it is the triggering
action for this report. The Five-Year Review is required because hazardous substances,
pollutants, or contaminants remain at the site above levels that allow for unlimited use and
unrestricted exposure.
2.0 Site Chronology
Table 2.1: Chronology of Site Events
Event
Date
Initial discovery of problem or contamination
5/01/1979
Pre-NPL responses:
Preliminary Assessment
Site Inspection
Hazard Ranking System Package
Proposal to National Priorities List
10/01/1982
3/05/1983
6/06/1983
9/08/1983
Final listing on EPA National Priorities List
9/21/1984
Removal actions (ground water treatment)
1987
Remedial Investigation/Feasibility Study (RI/FS)
OU-1, 9/28/1989
OU-2, 9/30/1991
OU-3, 8/1988
OU-4, 7/14/1992
OU-3 Final RI Addendum Report
OU-3, 7/1994
ROD selecting the remedy is signed
OU-1, 9/28/1989
OU-2, 9/30/1991
OU-3,
OU-4, 7/14/1992
ROD Amendments or ESDs
ESD for OU-4, 11/1993
Enforcement documents:
RCRA Permit issued
Administrative Order on Consent (site-wide)
10/1985
3/31/1992
Consent Decree (site-wide)
11/18/1992, 5/09/1994, &
10/11/1996
Consent Decree (OU-2), 1st addendum
Consent Decree (OU-4)
11/18/1992, 4/1/1994
5/09/1994
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Table 2.1: Chronology of Site Events
Event
Date
Remedial design start
OU-1, 9/28/1989
OU-2, 5/26/1992
OU-3, 8/1996
OU-4, 7/12/1993
Remedial design complete and approved by EPA
OU-1, 9/28/1989
OU-2, 9/30/1996
OU-3, 10/1997
OU-4, 9/30/1996
Ciba-Geigy becomes Novartis
1996
Novartis becomes Ciba Specialty Chemicals Corporation (CSCC)
1997
Actual remedial action start
OU-1, 9/28/1989
OU-2, 9/30/1996
OU-3, 7/1998
OU-4, 9/30/1996
Construction start date (1st clean-up action initiated)
9/28/1989
Construction completion date
7/19/2000
Preliminary Close-out Report completed
7/19/2000
Previous five-year review approved by EPA
7/29/2001
3.0 Background
3.1 Physical Characteristics
The Site encompasses 1,500 acres. Approximately 1,130 acres comprise the actual plant
facility operations, and the remaining 370 acres are undeveloped. This undeveloped area lies in
the floodplain of the Tombigbee River, and the area is mostly cypress-tupelo (Taxodium
distichum/Nyssa aquatica) swamp, and bottomland hardwood forest. The Site is located in
Washington County, near Mcintosh, Alabama, which is 50 miles north of the city of Mobile. The
Site is situated between the southern railroad right-of-way on the west and extends nearly to the
escarpment separating the upland terrace from the floodplain of the Tombigbee River. The
property boundaries extend beyond the railroad westward toward US Highway 43. The northern
edge of the property merges into an undeveloped pine forest. To the south, the property is
bounded by Olin Corporation Facility, which is also a Superfund Site. The southeastern portion
of the property extends to the banks of the Tombigbee River. The wetlands adjacent to the
Tombigbee River are subject to periodic flooding. The nearest population center is the town of
Mcintosh, which is located approximately two miles to the southwest of the CSCC property.
Figure 1 in Attachment A shows the location of the Ciba-Geigy Superfund Site.
3.2 Land and Resource Use
Currently the Site is set in an industrial setting, with Olin Corporation contiguous to the
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property on the south, and the Southern railroad to the west (see Figure 2). Part of the southern
boundary is adjacent to the Tombigbee River, including a bottomland floodplain. This floodplain
is entirely inundated with water for three to five months of the year, typically from December to
April.
The CSCC facility is currently operating, and is expected to continue production, so the
current land use for the property and adjacent area will continue to be considered industrial, as
will the Olin Corporation adjacent to the CSCC property.
The shallow ground water aquifer (i.e., alluvial aquifer) underlying the site is not
currently used as a drinking water source, although residents of Mcintosh receive drinking water
from a public well within three miles of the plant (Federal Register, 1984). The natural ground
water flow direction is to the south-southeast toward the Tombigbee River.
3.3 History of Contamination
The Geigy Chemical Corporation facility was built in the early 1950's, began operations
in October 1952 with the manufacture of one product, dichlorodiphenyl-trichloroethane (DDT).
Through 1970, Geigy Chemical Corporation expanded its products by adding the production of
fluorescent brighteners used in laundry products, herbicides, insecticides, agricultural chelating
agents, and sequestering agents for industry. In 1970, Geigy Chemical Corporation merged with
Ciba-Geigy, forming the Ciba-Geigy Corporation. The product line was expanded to include the
manufacture of resins and additives used in the plastics industry, anti-oxidants, and small volume
specialty chemical products (e.g., water treatment chemicals and fire-fighting foams). In the past,
waste was disposed in several on-site landfills and an open burning area located on a bluff line
on the eastern side of the plant complex. The Tombigbee River and associated fresh water
wetlands are situated to the east of the plant within 100 feet of several former waste disposal
areas.
EPA conducted an investigation of the Olin Chemical Company in 1982, when it
sampled a drinking water well on the Ciba-Geigy Corporation property, and discovered that the
well was contaminated. This discovery warranted further evaluation of a site contamination
problem at the facility. The Ciba-Geigy Corporation facility was proposed to the National
Priorities List (NPL) in 1983 with a hazard ranking score of 53.42, and listed as final on the NPL
in 1984.
Environmental regulation of this facility, as it pertains to remediation of land and ground
water impacted by historical operations, was under dual authority with requirements set by both
CERCLA and the Resource Conservation and Recovery Act (RCRA). The Site was placed on
the NPL based on detection of the pesticide lindane (y-hexachlorocyclohexane) in ground water,
and the pesticide DDT and its metabolites in soil. Identification of various organic and inorganic
chemical contaminants in alluvial aquifer ground water during the permitting process triggered
Corrective Action steps under RCRA. Both the CERCLA and RCRA authorities required that a
full site investigation be performed. In July 1985, EPA, the lead regulatory agency, authorized
Ciba-Geigy Corporation to perform a site investigation, using CERCLA's Remedial
Investigation/Feasibility Study (RI/FS) guidance, which would satisfy the requirements of both
the CERCLA and RCRA Programs concerning soil and ground water contaminant sources.
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As with many Superfund sites the problems at the Ciba-Geigy Site are complex. As a
result, EPA organized the work into four operable units (OU). The operable units at this site are:
OU-1 Shallow (alluvial) ground water aquifer;
OU-2 Ten of eleven former waste management areas;
OU-3 Floodplain, the effluent ditch (previously called the lower portion of the dilute
ditch) and areas in the Tombigbee River within close proximity to the Site; and
OU-4 Former waste management area designated as Site 8 (or bluff line site) and the
dilute ditch (previously called the upland portion of the dilute ditch).
3.3.1 OU-1, Shallow Ground Water Aquifer
Contaminant plumes containing organics, such as solvents and production by-products,
and inorganics, were identified in the part of Ciba-Geigy's Plant south of the developed areas,
which included manufacturing and infrastructure facilities and waste management systems. The
contaminant plumes were within Ciba-Geigy's southern property boundary. The alluvial aquifer
begins at a nominal 50 feet below the land surface and extends to a depth of 100 feet.
3.3.2 OU-2, Ten of Eleven Former Waste Management Areas
Contamination of both surface and deeper soils was identified and characterized by the
extensive site investigation which was performed according to CERCLA RI guidance, and
included all former waste management or waste impacted areas. The ten areas of contamination,
which were collectively specified as OU-2, were generally east of the manufacturing portion of
the plant. The predominant class of contaminants was commercial pesticides and the by-product
isomers and metabolites of these pesticide compounds. Contamination of the soil was the result
of leaching from former waste storage piles, and in some cases, sub-surface disposal of solid
waste materials.
The ten areas are described below:
Area 1 (Original Effluent Impoundments
Area 1 is a former wastewater impoundment currently filled-in with material from
sandblasting activities. The waste at Area 1 was sludge containing pesticide residues,
by-products, and intermediates from pesticide manufacturing. Waste in Area 1 extended into
unconsolidated soils within a saturated zone. The estimated volume of contamination in Area 1
was 12,500 cubic yards.
Area 2 (Waste Disposal Pif)
Area 2 is a small, former disposal pit covered by fill located immediately east of Area 1.
The pit contained wastes such as trash, pesticide residues, byproducts, and intermediates from
pesticide manufacturing. The estimated volume of contamination in Area 2 was 2,100 cubic
yards.
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Area 3 (Tar Disposal Area')
Area 3 is an area consisting of five discrete past waste management areas evidencing
broad surficial contamination based on the field work conducted during the RI/FS. Area 3 was
divided into five specific areas and a general area of contamination based on differences in
colors of the waste. The area now includes Areas 3A, 3B, 3C, 3D, 3E, and 3 General.
Area 3 As waste consisted of a white and pink chemical solid. Some of the material was
located within deteriorated steel drums. Area 3B's waste was a viscous clear to amber liquid and
a grayish-blue solid. Drums were encountered at four feet. Area 3C's waste consisted of white
solids. Deteriorated drums were encountered two feet below the surface area. Area 3D's waste
consisted of seven feet of clayey silt fill containing burnt wood, shell, and organic debris. A five
foot layer of black tar-like solid waste was encountered beneath the fill. Area 3E's waste
consisted of an approximately 10 foot thick layer of clayey silt fill. Material containing shell,
concrete, burnt wood, charcoal, and chemical waste overlay undisturbed soil. Area 3 General
included an area with a thin tar layer and contaminated soil, the stockpile area, and a former
cooling water ditch with associated contaminated soil. The stockpile area contained intermixed
soil and waste excavated during construction of a new cooling water discharge pipeline.
Contaminated sediments in the eastern segment of the former cooling water ditch were also
transferred to the stockpile area during construction of the new cooling water discharge pipeline.
The estimated volume of contamination in Area 3 was 51,100 cubic yards.
Area 4 (Waste Disposal Pits')
Area 4 consists of three isolated, shallow pits called Areas 4A, 4B, and 4C, all which are
covered by clay fill. The pits contained pesticide residues and intermediates from pesticide
manufacturing. Area 4A's waste consisted of two feet of dark gray solid below six feet of fill.
Area 4B's and 4C's wastes were determined to be identical and consisted of two feet of black
solid waste with green and yellow streaking covered by six feet of fill. The estimated volume of
contamination in Area 4 was 2,500 cubic yards.
Area 5 (Open Burn Area')
Area 5 is an area where open burning was formerly practiced. The area was covered by
clay fill and contained trash, burned demolition debris, pesticide residues, byproducts, and
intermediates from pesticide manufacturing. The estimated volume of contamination in Area 5
was 8,200 cubic yards.
Area 6 (Temporary Trash Staging Area')
Area 6 is the location of two adjacent former trash staging areas covered by clay fill. The
site contained trash consisting of combustible refuse such as plastic, paper, cardboard, and
rubber intermixed with manufactured pesticides and metals. The estimated volume of
contamination in . Area 6 was 10,400 cubic yards.
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Area 7 (Disposal Site South of the Class C Landfill")
Area 7 is a former disposal pit covered with clay fill. The area contained drums, solid
waste, jars, bulk solid wastes, and trash. The waste was comprised of pesticide residues,
byproducts, and intermediates from pesticide manufacturing. The estimated volume of.
contamination in Area 7 was 7,400 cubic yards.
Area 8 (Bluff line Area")
Area 8 is addressed in OU-4.
Area 9 (Hexachlorocvclohexane Burial Area")
Area 9 is a chemical material burial area covered with clay fill. The area contained bulk
pesticide byproducts, predominantly isomers of hexachlorocyclohexane (BHC), and residues.
The estimated volume of contamination in Area 9 was 32,100 cubic yards.
Area 10 (Warehouse Number 218")
Area 10 consists of a thin layer of waste partially covered by an existing storage
warehouse. The area contained solid waste consisting of pesticide residues and byproducts. The
waste was overlain by approximately eight feet of compacted clay fill. The ground surface is
primarily covered with reinforced concrete.
Area 11 (Trash Staging Area")
Area 11 consists of intermixed soil and waste underlying the current trash staging area.
The intermixed soil and waste consisted of pesticide byproducts and was overlain by
approximately four feet of compacted clay fill. The surface is covered with reinforced concrete
except for a small portion along the southern and eastern edges, which is bare ground. The
estimated volume of contamination in Area 11 was 1,000 cubic yards.
3.3.3 OU-3, Floodplain, the Effluent Ditch and Tombigbee River
OU-3 consists of the effluent ditch and 370 acres of the Tombigbee River floodplain and
the adjacent areas in the Tombigbee River. This area is separated from the rest of the facility by
the bluff line.
The source of contamination was primarily from the effluent ditch and runoff from the
waste management areas. Contamination of surface soil and sediment in the floodplain was
characterized by the site investigation. Additional characterization was performed in conjunction
with the extensive ecological risk assessment phase preceding EPA's ROD, and during soil
treatability studies conducted during the remedy evaluation phase. The principal contaminant of
concern was dichlorodiphenyl-trichloroethane (DDT) and its metabolites
dichlorodiphenyl-dichloroethane (DDD) and dichlorodiphenyl-chloroethane (DDE) (collectively
known as DDTr). Other chemicals of concern (COCs) included: Ametryn, Atrazine,
Butlybenzylphthalate, Diazinon, Prometon, Prometryn, Propazine, Simazine, Simetryn,
Turbuthylazine, Terbutryn, Tolban, Chromium, Copper, Cyanide, Mercury, and Nickel.
7
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3.3.4 OU-4, Former Waste Management Area 8 (or Bluff line Site) and the Dilute Ditch
Area 8 is located along a bluff line constructed by the U.S. Army Corps of Engineers and
is currently grassed with the bluff line escarpment stabilized with rip-rap to minimize soil
erosion. The bluff line contains large quantities of non-chemical construction and demolition
rubble such as concrete fragments (some very large), piles of crushed concrete, bricks, stone
fiberglass, asbestos, metal debris and alternate layers of residues from open burning, all covered
with clay fill. The waste disposed of in Area 8 is covered with 4-8 feet of fill material and sod.
There is no evidence of contaminated surface material in this area. Therefore, the media of
concern is subsurface soil.
Contamination of both surface and deeper soils was characterized by the site
investigation. The bluff line site is located at the extreme east side of CSCC property, and is .
roughly bisected by an escarpment which separates the upland portion of the property from the
floodplain of the Tombigbee River. An elevation change of approximately 45 feet occurs moving
west to east across the site. This site was designated as a separate OU by EPA due to its unique
topographic and waste constituent characteristics. The principle contaminants in soil were
pesticides, and additionally commercial herbicides. Specifically, the (COCs) for the Site include
high molecular weight chlorinated pesticides (BHC isomers), Site-manufactured pesticides
(atrazine, diazinon, prometryn, simazine), volatile solvents (chloroform, toluene, xylenes) and
metals (copper, lead, arsenic, chromium and an iron slurry waste). The media of concern for this
operable unit is contaminated subsurface soil; however, the former waste management Area 8 is
a contributor to the contaminated ground water. Contamination of the soil resulted from past
waste management practices such as open burning and solid waste disposal in sub-surface pits.
The estimated volume of contamination in Area 8 was 128,000 cubic yards.
3.4 Initial Response
EPA conducted an investigation in August 1982 of the Olin Chemical Company located
adjacent to the Ciba-Geigy site. As a part of the investigation, SESD sampled a drinking water
well on Ciba-Geigy property. This sampling indicated the presence of hazardous substances
which warranted further evaluation of the contamination problem at Ciba-Geigy. In June 1983,
the hazardous ranking system (HRS) survey was completed and the site was assigned a ranking
of 53.42. The Ciba-Geigy Mcintosh plant was included on the national priorities list (NPL) in
September 1983. In October 1985, EPA issued Ciba-Geigy a RCRA Permit, which included a
corrective action plan requiring Ciba-Geigy to remove and treat contaminated ground water and
surface water at the site. The Corrective Action Plan stipulated that Ciba-Geigy would prepare a
remedial investigation/feasibility study (RI/FS) for the disposal areas being studied by the
Superfund program.
CERCLA and RCRA programs required that a full site investigation be performed. In
July 1985, EPA, the lead regulatory agency, authorized Ciba-Geigy, to perform one site
investigation, using CERCLA's RI/FS guidance, which would satisfy the requirements of both
the CERCLA and RCRA programs concerning soil and ground water contaminant sources. A
chronology of site actions/events is presented in Section 2, Table 2.1.
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3.4.1 OU-1, Shallow Ground Water Aquifer
Ground water corrective action conditions under RCRA were specified originally in the
1985 RCRA Permit (i.e., RCRA Part B Permit, which included a corrective action plan requiring
Ciba-Geigy to remove and treat contaminated ground water and surface water at the site), and
have been upgraded and amended in subsequent permit modifications. The corrective action
objective for the alluvial aquifer was to set up a hydraulic barrier extending across the southern
boundary of the facility (the down gradient area of alluvial aquifer ground water flow) to fully
reverse the hydraulic gradient and retain the contaminant plumes on Ciba-Geigy's property.
Ciba-Geigy installed a ground water pumping system consisting of 10 fully penetrating, alluvial
pumping wells to intercept and remove contaminated ground water from the shallow alluvial
aquifer, and four corrective action monitoring wells along the southern boundary of the property
to monitor the effectiveness of the pumping wells system. All ground water removed by the
pumping wells is treated by CSCC's on-site waste water treatment system and discharged with
treated process waste water under the plant's National Pollutant Discharge Elimination System
(NPDES) Permit.
The RCRA ground water corrective action system was started up in 1987 and has
operated continuously since. In addition to conditions setting operating parameters for the
pumping system, RCRA corrective action specifies extensive monitoring and reporting
requirements. For example, water level data is collected each month, and semiannually a
verification of reversal of the hydraulic gradient is submitted to the Alabama Department of
Environmental Management (ADEM), the current lead regulatory agency for Ciba-Geigy RCRA
compliance. Contaminant concentrations in designated monitoring wells are also reported to
ADEM semiannually.
3.4.2 OU-2, Ten of Eleven Former Waste Management Areas
The major component of the remedy was excavation of contaminated soil and sludge to
cleanup levels established by health-based risk assessment protocols (the excavation
performance standards). Excavated soil above specified contaminant levels was treated on-site
by a thermal decomposition process designed to reduce organic contaminants adhering to the soil
particles to below established treatment levels (the treatment performance standards).
The original ROD requirement for disposal of treated soil called for its placement in an
on-site RCRA Subtitle C land vault. This stipulation was amended during the OU-2 Consent
Decree process, allowing treated soil, which passed the treatment performance standards, to be
backfilled in the excavation areas!
EPA's ROD allowed several alternative treatment remedy components, only if such steps
could be proven effective in treatability studies to be conducted during the OU-2 Remedial
Design period. None of the alternative process options were adopted in the final Remedial
Action Plan.
In the Remedial Design process, public notification of key events and implementation of
institutional controls concerning land and ground water use, were also provisions of EPA's ROD
for OU-2.
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3.4.3 OU-3, Floodplain, the Effluent Ditch and Tombigbee River
The original OU-3 RI was completed in 1988, which included results of OU-2 and OU-4.
EPA had concerns of possible ecological risk and in Marchl992 requested additional
investigations to evaluate ecological concerns. In 1992 Ciba-Geigy implemented an extensive
supplemental RI. Results were submitted to EPA in March 1993. The results concluded there
were no ecological risks associated with the contamination in OU-3. EPA disapproved the report
based on the ecological conclusions, however, EPA did accept the data presented in the Report,
July 1994.
EPA conducted their own ecological risk assessment and concluded there were
unacceptable risks to ecological receptors (EPA ERT, 1994). Subsequently EPA developed an
ecological clean-up goal for OU-3 of less than 1 ppm DDTr in soils and sediments.
3.4.4 OU-4, Former Waste Management Area 8 (or Bluff Line Site) and the Dilute Ditch
The Dilute Ditch was closed in accordance with an approved RCRA closure plan. The
ditch, as well as other closed units, was excavated, capped and is being maintained through
RCRA post-closure care. Upon further evaluation, EPA has decided to continue addressing the
Dilute Ditch under RCRA authority, as administered through the Hazardous Solid Waste
Amendment (HSWA) Permit.
All OU-4 remedy components, with the exception of the final item described in this
section, are virtually identical to the OU-2 remedy steps. There are, however, differences in the
contaminants of concern between the two OUs, as will be noted. The remedial design for OU-2
and OU-4 was conducted jointly.
The principal component of the remedy was excavation of contaminated soil and sludge
to cleanup levels established by a health-based risk assessment (the excavation performance
standards). Contaminants of concern for OU-4 are commercial herbicides and pesticides.
Excavated soil above specified contaminant levels was treated on-site by a thermal
decomposition process designed to reduce organic contaminants adhering to the soil particles to
below established treatment levels (the treatment performance standards).
The original ROD requirement for disposal of treated soil in an on-site RCRA Subtitle C
land vault, like OU-2, was subsequently changed by the November 1993 Explanation of
Significant Differences to allow treated soil that passed the treatment performance standards to
be used as backfill material in the OU-4 excavations.
Also similar to OU-2, EPA's ROD allowed several alternative treatment remedy
components, if such steps could be proven effective in treatability studies to be conducted during
the OU-2 Remedial Design period. None of the alternative process options were adopted in the
final Remedial Action Plan.
Public notification of key events in the Remedial Design process, and implementation of
institutional controls concerning land and ground water use were also provisions of EPA's ROD
for OU-4.
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A significant component of the OU-4 remedy, which is unique to this OU, is the
provision for installation of an isolation barrier and extraction of ground water to facilitate
continuing remediation in areas where excavation of soils alone would not achieve total
compliance with the cleanup levels. The remedy for OU-4 included installation of a slurry wall
on the east and south extremities of the bluff line area. By design, this hydraulic barrier extends
the full depth of the alluvial aquifer, and redirects ground water flow to the west where it is
intercepted by the RCRA Corrective Action pumping wells.
3.5 Basis for Taking Action
Contaminants:
Hazardous substances that have been released at the site and clean-up goals in each
media are included in Table 3.1.
These Remedial goals were obtained from the Record of Decisions (ROD) for each OU.
Exposures to soils were associated with significant human health risks, due to exceedence of
EPA's risk management criteria for either the average or the reasonable maximum exposure
scenarios. At the time of the ROD, individual exposure via ingestion of contaminated ground
water was not occurring due to the ground water corrective action program. However, the
unacceptable risk levels indicated that the pump and treat program was necessary to prevent the
potential exposure to unacceptable levels of contaminants in the ground water in the future. The
bases for taking action (i.e., effects or potential effects of contaminants on people, resources they
use, or the environment) for each OU is described in the sections below.
3.5.1 OU-1, Shallow Ground Water Aquifer
The COCs in the ground water were determined from the 1989 first quarter ground water
monitoring conducted by Ciba-Geigy in February, 1989. The data from the pumping and
observation wells were used to select the ground water COCs. The human risk assessment was
based on both the maximum concentration detected and the mean of each well containing a
detectable level for each chemical.
Clean-up goals for ground water remediation have been established for the RCRA ground
water corrective action program. To remain consistent with the RCRA permit, maximum
contaminant levels (MCLs) or proposed MCLs will be used as clean up goals for ground water
contamination. Contract required quantitation limits (CRQLs) will be used when MCLs or
proposed MCLs are not available. The final surface soil COCs for this OU are found in Table
3.1. The COCs are lindane, diazinon, atrazine, bladex, simazine, and prometryn.
Ecological risk for this OU was considered to be negligible since ground water is an
incomplete exposure pathway to ecological receptors. However, the ground water-surface water
interface potentially becomes a risk, and exposure then becomes an issue for wildlife. Surface
water is evaluated in OU-3 for ecological risk.
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Table 3.1 Chemicals of Concern and Remedial Goals
Ground Water (OU-1)
Contaminant
Remedial Goal (|ig/l)
aniline
10
arsenic
50
benzene
5
a-BHC
.05
y-BHC
0.2
carbon tetrachloride
5
chlorobenzene
5
chloroform
5
cresols (m-, p-)
10
methyl ethyl ketone
10
naphthalene
10
toluene
2000
Soil (OU-2 and/or OU-4)
Surface Soil (0-12") (OU-2 and/or OU-4)
Subsurface Soil (>12") (OU-2 and/or OU-4)
Contaminant
Remedial Goal (mg/kg)
Contaminant
Remedial Goal (mg/kg)
DDT
17
DDT
5,034
7,500
DDD
24
DDD
6,758
7,500
DDE
17
DDE
16,527
17,250
a-BHC
1
a-BHC
4
156
P-BHC
3
P-BHC
17
152
6-BHC
2
6-BHC
3
154
y-BHC (lindane)
4
y-BHC (lindane)
1
105*
diazinon
1,796
Chlorobenzilate
209
340
atrazine
10,000
Diazinon
3.6*
60*
bladex
4,100
Bladex
2
37
simazine
4,100
Simazine
3.7
1000
prometryn
8,200
Atrazine
3.6
19
chlorobenzilate
39,922
Prometryn
38.5
1557
Surface Soils and Sediment (OU-3)
DDTr**
15
* ROD contains different numbers, but the ESD identified these were incorrect, and the correct clean-up levels are in
the table.
** DDTr is total DDT, which consists of DDT and its metabolites DDD, and DDE.
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3.5.2 OU-2, Ten of Eleven Former Waste Management Areas
The excavation performance standards, for OU-2 and OU-4, were based on human health
risk evaluation. For each OU, excavation criteria were determined for surface soil (the top 12
inches) based on direct contact risk analysis, and for subsurface soil (deeper than 12 inches)
based on migration through the soil to ground water followed by human ingestion. Subsurface
soil was further evaluated for two different geologic conditions, the absence of an undisturbed
clay barrier between the contaminated material and the alluvial (upper) ground water aquifer (the
Summers Standards), and the presence of a clay barrier between contamination and ground water
(the PESTAN Standards). Use of the Summers or PESTAN contaminant transport model to
determine clean-up goals depended on the thickness of clay below the contaminant zone. In
general, the Summers model was used for zero clay up to a contaminant specific minimum
thickness. The PESTAN model was used where clay was present at a thickness of 122
centimeters (approximately 4 feet) or greater.
Ecological risk at this OU was negligible because at the time of the ROD, each of the
source areas were covered with fill dirt or fenced and therefore, were not easily accessible to
certain terrestrial species. For this reason, the source areas in this OU were not expected to have
had toxic effects on those terrestrial animals. However, the ecological assessment indicated that
the Site may have toxic effects on certain plant species, as well as mammals and birds in the
areas of concern in the future. The selected remedy based on human health was expected to
eliminate the potential for toxic effects since the environmental exposure pathways would no
longer exist.
3.5.3 OU-3, Floodplain, the Effluent Ditch and Tombigbee River
Two ecological risk assessments were conducted to evaluate contaminants in OU-3. One
was conducted by Ciba-Geigy and the other by EPA's Emergency Response Team (ERT). After,
evaluating both risk assessments, the recommended clean up goal for OU-3 sediments was a
concentration of DDTr no greater than 1 (ppm). This was based primarily on the ecological risk
assessment developed by EPA's Environmental Response Team (ERT) ecologists and EPA's
Region 4 Waste Management Division ecological risk assessors. The 1995 ROD set the sediment
remedial goal at 15 ppm DDTr. The 15 ppm remedial goal was selected because of the
uncertainties associated with the conservatism of the models used in the ecological risk
assessment and difficulty of remediating all sediment to less than 1 ppm DDTr. The ROD stated
that remediating the sediments to less than 1 ppm would result in the destruction of the bottom
land hardwood forest and Tupelo Cypress swamp. This would have unacceptable short- and
long-term impacts on ecological receptors. The 15 ppm DDTr remedial goal was considered to
be the best balance of overall protection among cleanup goals.
Pursuant to the requirements outlined in the ROD, Ciba-Geigy conducted a remedy
design study. The results were presented in the Remedial Design Study Report and Preliminary
Work Plan for Operable Unit Number 3 {CSCC, June 1998). During the remedial design study,
over 500 sediment/soil samples were collected to better evaluate the extent of the DDTr
contamination. Based on the results of the remedial design study, Ciba-Geigy proposed a
remedial design that would achieve a site-wide average of 15 ppm as the remedial goal, rather
than all soil/sediment having a concentration less than 15 ppm DDTr. This remedial design was
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proposed primarily because EPA and Ciba-Geigy had concerns about the ecological impacts
associated with the destruction of the forested wetlands if all sediment greater than 15 ppm
DDTr were remediated. The proposed remedial design would not destroy the forested wetlands
of OU-3, and it was believed the design would achieve the ecological performance standards.
The assumptions associated with the site wide average 15 ppm cleanup level were:
1. The exposure to the fish and other ecological receptors could be represented by the area
average of DDTr concentrations.
2. The degree of sediment to biota accumulation of DDTr would be such that a cleanup
level of 15 ppm would result in achievement of the performance standard for fish tissue
concentrations.
3. Reducing the DDTr to acceptable levels would also reduce other site COCs to acceptable
levels. The other site COCs include Ametryn, Atrazine, Butlybenzylphthalate, Diazinon,
Prometon, Prometryn, Propazine, Simazine, Simetryn, Turbuthylazine, Terbutryn,
Tolban, Chromium, Copper, Cyanide, Mercury, and Nickel.
It was assumed that the majority of piscivorus fauna (the receptors at greatest risk) were
feeding in the open areas of the wetland rather than the forested areas. Therefore, remediating
the contaminated soil and sediments in the open, non-forested, areas of the wetlands would
greatly reduce the risks to piscivorus receptors. This would also reduce the site-wide DDTr
average to below 15 ppm. This approach would allow the forested wetlands to remain intact and
greatly reduce the cost and logistical issues of remediating sediments in the forested wetlands.
However, this approach left several acres of DDTr contaminated sediment still in place.
Ciba-Geigy estimated 9.2 acres of cypress-tupelo habitat and 3.3 acres of bottomland hardwood
forest, with DDTr contaminated soil/sediments, would remain in place.
3.5.4 OU-4, Contamination of Soils in Former Waste Management Area 8 (or Bluff Line
Site) and the Dilute Ditch
The comparison of the health-based clean-up level concentrations for the protection of
ground water with the actual soil concentrations indicates that the soils in the Former Waste
Management Area 8 contained concentrations of Site-related contaminants which exceeded the
health-protective soil levels.
The clean-up level for lindane represents a 10"6 risk level. The clean-up levels for the
remaining COCs (i.e., diazinon, atrazine, bladex, simazine, and prometryn) represent an HQ of
one. The clean-up levels for lindane and simazine are soil levels derived to achieve ground water
protection based on the MCL and proposed MCL, respectively. The clean-up levels for the
remaining chemicals represent a concentration which, when combined with the Site specific
exposure assumptions, yielded a daily intake which does not exceed the chemical's reference
dose (RfD). The RfD is an estimate of the lifetime daily exposure level for humans, including
sensitive individuals, which will not produce adverse health effects. In addition, the risk based
concentration was reduced to allow ground water to provide only 20% of the acceptable daily
intake.
Ecological risk for this OU was considered negligible because at the time of the ROD,
the source areas were covered with fill and therefore was not easily accessible to terrestrial
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species. For this reason, the source areas were not expected to have had toxic effects on
terrestrial animals. However, the ecological assessment indicated that the Site may have toxic
effects on certain plant species, as well as birds and mammals in the areas of concern in the
future. The selected remedy based on protection of human health was expected to eliminate the
potential for such toxic effects since the environmental exposure pathways would no longer
exist.
4.0 Remedial Actions
Remedial Action Objectives (RAOs) were developed as a result of the data collected
during the Remedial Investigation to aid in the development and screening of remedial
alternatives to be considered for the ROD. Since four RODs were developed for this site, the
RAOs for each OU are described below. As will be documented in the following sub-sections,
remedy steps for this site are a combination of CERCLA and RCRA requirements.
4.1 Remedy Selection
Each operable unit will be discussed separately.
4.1.1 OU-1, Shallow Ground Water Aquifer
The September 1989 ROD for OU-1 addresses the contaminated ground water exposure
pathway. The EPA designated a "No Further Action" remedy based on the effectiveness of the
ground water pump and treat system already installed under the RCRA permit to address ground
water contamination in the shallow aquifer at the site. The clean-up levels of the currently
operating ground water pump and treat system, which are applied at the Site boundary ensures
that concentrations of contaminants in the ground water do not exceed (MCLs) or Minimum
Detection Levels (MDLs) for any future consumers of this water.
The ROD for OU-1 does not address the sources of contamination, but the sources are
being addressed with OU-2 and OU-4. Addressing the contamination source will decrease the
time required to pump and treat the contaminated ground water. Clean-up levels for the
contamination source (i.e., the subsurface soils) for ground water protection are based on a 1 x
10"4 risk level for carcinogens and a hazard quotient (HQ) of 1 for noncarcinogens. Setting the
clean-up levels for subsurface soils at the 1 x 10"4 risk level is consistent with the NCP's
requirement for establishing clean-up levels within the 1 x 10"4 to 1 x 10"6 range. This clean-up
level provides an acceptable exposure level that is protective of human health and the
environment in an isolated industrial setting.
Although the COCs were not the only contaminants at the site, they were chosen based
on toxicity, mobility and frequency of detection throughout the site. It was anticipated that
chemicals at the site that did not have clean-up levels presented in the ROD would be reduced to
acceptable levels when clean-up levels were met for the most toxic and most mobile
contaminants for which clean-up levels have been established.
At the time the ROD became effective, the ground water at the Ciba-Geigy Site contained
concentrations of site-related contaminants at levels which posed an unacceptable risk (i.e.,
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cumulative risk in excess of 1 x 10"4 to human health if the water was being used for human
consumption). Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in the ROD, could present an imminent
and substantial endangerment to public health, welfare, or the environment.
4.1.2 OU-2, Ten of Eleven Former Waste Management Areas
The RODs for OU-2 and OU-4 address the source of contamination (i.e. soils) to
ultimately reduce leaching of chemicals into the ground water (OU-1). The remedy selected for
OU-2 is essentially the same as for OU-4, since both of the OUs address soils in various parts of
the Superfund site.
Alternative 5 was selected from all of the alternatives included in the ROD as the best
alternative providing the best balance with respect to the statutory balancing criteria in Section
121 of CERCLA and in Section 300.430 of the NCP. The remedial action selected was removal,
on-site thermal treatment, and on-site disposal of treated soils. The ROD was signed in
September 1991.
The remedy consisted of excavation of contaminated soil and sludge within the site until
the clean-up levels established by health-based risk assessment protocols (the excavation
performance standards) were reached, or until excavation became technically impracticable from
an engineering perspective. Excavated material above specified contaminant levels was treated
on-site by a thermal decomposition process designed to reduce organic contaminants adhering to
the soil particles to below established treatment levels (the treatment performance standards). It
was estimated that 60,000 cubic yards of highly contaminated soils and sludge would require the
thermal treatment, and approximately 62,300 cubic yards of low level contaminated soils and
sludge would not require thermal treatment, but would require stabilization/solidification. The
excavated material, or ash from the thermally treated soil, was stabilized/solidified and the
material disposed of in an on-site RCRA land vault. Following excavation activities, the areas
were backfilled and a vegetative cover was established.
The majority of the contamination in this OU was subsurface soils. However, three of the
11 former waste management areas had surficial contamination (i.e., the top 12 inches of soil), so
clean-up levels for surface soils were also developed. The three areas that had surficial
contamination were Area 2, the eastern portion of Area 3 and Area 9. Clean-up levels for
contaminated surface soil are based on a worker exposure scenario and assume a commercial/
industrial land use. These levels are based on the ingestion and inhalation exposure routes and
represent a 1 x 10"6 risk level for carcinogens and a hazard quotient of 1 for noncarcinogens.
Clean-up levels for the contamination source (the subsurface soils) for ground water protection
are based on the EPA MCL for the carcinogen (lindane) and a hazard quotient of 1 for
noncarcinogens. This clean-up level provides an acceptable exposure level that is protective of
human health.
The ROD stipulates that confirmatory samples would be collected and analyzed during
the remedial design to assure that contamination was not above clean-up levels for both surface
and subsurface soils. If confirmatory samples indicated that concentrations of subsurface soils
were at or below clean-up levels, then institutional controls, including deed restrictions and/or
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other measures necessary would be utilized to ensure that any future excavations of the
contaminated soil would include the same handling and treatment as set out in the selected
remedy.
The key to successful implementation of the OU-2/OU-4 remedy was, therefore, removal
of all contaminated soil that exceeded the health-based standards.
4.1.3 OU-3, Floodplain, the Effluent Ditch and Tombigbee River
The major remedy component was excavation of soil and sediment to meet an average of
15 ppm DDTr within OU-3.
Excavated soils in excess of 500 ppm DDTr were thermally treated with OU-2 and OU-4
soils. Concentrations of excavated soil less than 500 ppm DDTr were used as subsurface
(defined as a depth greater than twelve inches below the land surface) backfill material in OU-2
excavation areas. OU-3 excavated areas were backfilled to original land surface elevations with
clean fill material. EPA's ROD allowed the use of in-situ bioremediation as an alternative
remedy to excavation/treatment, if the process could be demonstrated to be effective to EPA's
satisfaction. After an extensive treatability study, this process option was not implemented.
The OU-3 Final Design Report (April 1998) provided definition of the engineering and
science applications for implementation of EPA's ROD. Remedial Action was initiated in June
1998 and was completed in October 1998. Approximately 23,000 yards of contaminated
sediment were removed from the OU-3 wetland.
Review of project records, interviews and inspection of the OU-3 area provided ample
verification that excavated surface soils and sediments (the top twelve inches), that were
remediated in OU 3, achieved overall compliance with the site wide average 15 ppm DDTr
performance goal. Attainment of these limits, and backfilling of the excavated areas with clean
sediment to the original surface elevations, was certified by a professional land surveyor. The
Final Construction Report (December 1998) documents concurrence with performance
standards. Concerning ecological monitoring in OU-3, parameters for measuring pre-remediation
baseline conditions were set by the Final Design Report (April 1998) and the Post-Remediation
Monitoring Plan (February 1999).
4.1.4 OU-4, Former Waste Management Area 8 (or Bluff line Site) and the Dilute Ditch
The remedy selected by EPA, and defined in its July 1992 ROD, like OU-2, was a
combination of steps to control contaminant sources. All OU-4 remedy components, with the
exception of the final item described in this section, are virtually identical to the OU-2 remedy
steps (i.e., clean-up goal levels, institutional controls, etc.). There are, however, differences in
the COCs between the two OUs, as will be noted. Remedial Design for OU-2 and OU-4 was
conducted jointly.
The principle component of the remedy was excavation of contaminated soils and sludge
to clean-up levels established by a health-based risk assessment (the excavation performance
standards). Excavated soil above specified contaminant levels was treated on-site by a thermal
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decomposition process designed to reduce organic contaminants adhering to the soil particles to
below established treatment levels (the treatment performance standards). Public notification
provisions and institutional controls for land and ground water use were also elements of the
OU-4 ROD.
The waste disposed of in Area 8 were covered with 4-8 feet of fill material and sodded,
and there was no evidence of contaminated surface material in this area, so only subsurface
contamination was addressed in this OU. Subsurface soil and its surrounding ground water
clean-up levels are applied at the 1 x 10"4 risk level since this is an industrial site and, in this
case, it would be more cost effective to let any residual contamination be captured by the
currently operating ground water pump and treatment system. This is consistent with areas in
OU-2 requiring no localized deep soil treatment. Ground water extracted in the soil flushing
portion of the remediation will be treated by the existing pump and treat system.
A very significant component of the OU-4 remedy, which is unique to this OU, is the
provision for installation of an isolation barrier and extraction of ground water to facilitate
continuing remediation in areas where excavation of soil alone would not achieve total
compliance with the clean-up levels. The remedy for OU-4 included installation of a slurry wall
on the east and south extremities of the bluff line area. By design, this hydraulic barrier extends
the full depth of the alluvial aquifer, and rechannels ground water flow to the west where it is
intercepted by the RCRA Corrective Action pumping wells.
The Dilute Ditch was part of OU-4. However, the Dilute Ditch was closed in accordance
with an approved RCRA closure plan. The ditch was excavated, capped and is being maintained
through RCRA post-closure care. Upon further evaluation, EPA has decided to continue
addressing the Dilute Ditch under RCRA authority, as administered through the HSWA Permit.
The ROD for OU-4 includes a statement that because the remedy will result in hazardous
substances remaining on-site above health-based levels, a review will be conducted within five
years after commencement of the remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
4.2 Remedy Implementation
This section describes the history of and implementation of the remedies. It also contains
the current status of the remedies. Because the site is separated into 4 OUs, each OU will be
discussed in the following subsections.
4.2.1 OU-1, Shallow Ground Water Aquifer
In a Consent Decree signed with EPA on 1992, the Potentially Responsible Party (PRP)
agreed to perform the remedial design/remedial action (RD/RA) and pay past costs for cleaning
up the site. The RD was conducted in conformance with the ROD as modified by the ESD. The
RD was approved by EPA on 1989.
Alluvial aquifer ground water remediation was initiated in 1987 with startup of the ten
RCRA corrective action pumping wells. This system operates continuously, with the exception
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of short maintenance outages of individual wells. The initial collective pumping rate was
approximately 2.2 million gallons per day. At the time of the first Five-Year Review, the
pumping rate was approximately 1.4 million gallons per day to ensure that reversal of the
hydraulic gradient was maintained. Currently, the pumping rate is 1.2 to 1.5 million gallons per
day.
The primary regulatory authority for alluvial aquifer ground water remediation at the Site
is the RCRA corrective action program, with ADEM functioning as the lead agency. Under the
RCRA program, water levels have been routinely measured at designated up gradient and down
gradient (from the line of pumping wells) monitoring wells since 1987, with interpretation and
validation of reversal of the ground water gradient performed by an independent professional
hydrogeologist. Routine ground water sampling and analysis for a suite of RCRA COCs are also
performed. Quarterly reports containing certification of alluvial aquifer gradient reversal and
analytical results have been submitted to ADEM from 1987 through 1997. The Site's RCRA
permit allowed a reduction in the reporting frequency to semiannual starting in 1998.
4.2.2 OU-2, Ten of Eleven Former Waste Management Areas
In a Consent Decree signed with EPA on November 18, 1992, and amended on April 1,
1994, the PRP agreed to perform the RD/RA and pay past costs for cleaning up the site. The
original ROD requirement for disposal of treated soil called for its placement in an on-site
RCRA Subtitle C land vault. This stipulation was amended during the OU-2 Consent Decree
process, allowing treated soils which passed the treatment performance standards, to be
backfilled in the excavation areas. In addition, the original ROD allowed several alternative
treatment remedy components, if such steps could be proved effectively in treatability studies to
be conducted during the OU-2 RD period. None of the alternative process options were adopted
in the final Remedial Action Plan. The RD was conducted in conformance with the ROD. The
RD was approved by EPA on September 30, 1996.
OU-2 and OU-4 remedy construction was initiated in July 1996, and continued through
the remainder of 1996 and all of 1997. Key events in this period included beginning excavation
of contaminated soil in December 1996 and construction of the soil thermal treatment unit. This
activity started in February 1997 and was completed in November 1997. A preliminary test burn
in the thermal unit was performed in December 1997.
The first quarter of 1998 was committed to startup and checkout of the soil thermal
treatment unit. This shakedown period terminated with a formal performance demonstration test
burn, which was concluded in March 1998.
Remedial action operations to fully implement the OU-2 and OU-4 remedy pertaining to
excavation and treatment of contaminated soil began March 23,1998 and were concluded
February, 16,1999. An intermediate milestone, completing of all soil excavation in the OU-2 and
OU-4 areas, occurred on November 8,1998.
The final phase of Remedial Action covered the period between shutdown of thermal
operations in February 1999 and the end of April 1999. Activities completed included shutdown
of the wastewater treatment system, which provided pretreatment of all wastewater generated by
remediation operations, backfilling of all excavation sites and decontamination of all equipment
and facilities.
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Two institutional control measures contained in the remedy for OU-2 and OU-4 have
been fully implemented. Notification signs have been placed adjacent to the well head on all
ground water wells that pump contaminated alluvial aquifer ground water to the surface. Signs
have also been placed around the perimeter of all areas where subsurface soils (>12") may not be
in full compliance with the performance standards. These signs constitute a warning against
unauthorized excavation which could move contaminated subsurface soil to the land surface.
Based on research of scientific and engineering records, coupled with interviews of
CSCC personnel and an inspection of the site in June 2006, it is concluded that the remedy has
been successfully implemented for OU-2 and OU-4 and is fulfilling its primary function.
4.2.3 OU-3, Floodplain, the Effluent Ditch and Tombigbee River
USEPA submitted the proposed plan in December 1994. The Record of Decision was
submitted in July 1995 and the Consent Decree for Ciba-Geigy was signed in March 1996.
Remedial Action was initiated in June 1998 and was completed in October 1998.
Approximately 23,000 yds of contaminated sediment were removed from the OU-3 wetland.
A review of project records, interviews and inspection of the OU-3 area provide
verification that excavated surface soils and sediments (the top twelve inches), that were
remediated in OU 3, achieved overall compliance with the site wide average 15 ppm DDTr
performance goal. Attainment of these limits, and backfilling of the excavated areas with clean
sediment to the original surface elevations, was certified by a professional land surveyor. The
Final Construction Report (December 1998) documents concurrence with performance
standards. Concerning ecological monitoring in OU-3, parameters for measuring pre-remediation
baseline conditions were set by the Final Design Report (April 1998) and the Post-Remediation
Monitoring Plan (February 1999).
4.2.4 OU-4, Former Waste Management Area 8 (or Bluff line Site) and the Dilute Ditch
In a Consent Decree signed with EPA on May 9,1994, the PRP agreed to perform the
RD/RA and pay past costs for cleaning up the. site. The RD was conducted in conformance with
the ROD, as modified by the ESD. The original ROD requirement for disposal of treated soil in
an on-site RCRA Subtitle C land vault, like OU-2, was substantially changed by the November
1993 Explanation of Significant Differences to allow treated soil that passed the treatment
performance standards to be used as backfill material in the OU-4 excavations. Also similar to
OU-2, EPA's ROD allowed alternative treatments, if validated. None were adopted into the final
Remedial Action Plan. The RD was approved by EPA on September 30, 1996.
As was performed for OU-2, two institutional control measures contained in the remedy
for OU-2 and OU-4 have been fully implemented. Notification signs have been placed adjacent
to the well head on all ground water wells that pump contaminated alluvial aquifer ground water
to the surface. Signs have also been placed around the perimeter of all areas where subsurface
soils (>12") may not be in full compliance with the performance standards. These signs
constitute a warning against unauthorized excavation which could remove contaminated
subsurface soil to the land surface.
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Most of the remedy implementation information for OU-4 is covered with the OU-2
discussion in Section 4.2.2. As stated, Section 4.2.4, will add only a description of facts pertinent
to the OU-4 slurry wall.
Construction of the OU-4 slurry wall began in July 1996, and was completed in
November 1996. The completed slurry wall was approximately 1000 feet long, and required
excavation of a trench approximately five feet wide to a depth of up to 90 feet in some locations.
Construction practices were monitored for and compliance of design specifications were
validated.
4.2.5 Summary of Implementation
The site achieved construction completion status when the Preliminary Close-Out Report
was signed on July 19, 2000. The EPA and ADEM have determined that all RA construction
activities, including the implementation of institutional controls, were performed according to
specifications. After ground water clean-up levels have been met, EPA will issue a Final
Close-Out Report.
4.3 System Operations/Operation and Maintenance
Table 4.1: Operations/O&M Costs
Dates
Annual Cost Rounded to Nearest
$1,000
To
From
Ground water pump & treat
1987
2006
~ $400,000
Maintain fencing and landscaping
1999
2006
~ $250,000
5.0 Progress since the Last Review
This is the second Five-Year Review for the site.
Recommendations from the 2001 Five-Year Review are listed below:
1. Refer all future activity regarding remediation of site ground water (OU-1) to the
authority of RCRA Corrective Action as specified in the Mcintosh Site RCRA Permit.
2. Additional Five-Year Reviews of CERCLA OU-1 are not required. This recommendation
was made in error. According to CERCLA and the NCP, Five Year Reviews are still
required for all OUs at the site.
3. Any newly discovered soil contamination at the Mcintosh Facility should be addressed
by existing RCRA Permit Conditions under Corrective Action.
4. Continued ecological risk-based monitoring in OU-3 according to ROD stipulated
EPA-approved work plans.
5. Health-based performance standards for soil contamination defined as CERCLA OU-2
and OU-4 were fully achieved. Additional Five-Year Reviews for OU-2 and OU-4 are
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not required, but CSCC should furnish certification to EPA on alternate years beginning
in 2003 that the Consent Decree institutional controls concerning soil excavation are
being enforced.
Responses and updates to the 2001 recommendations are listed below:
1. Ongoing remediation and monitoring are being conducted under the authority of the
existing RCRA permit.
2. CERCLA§ 121 states:
If the President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such remedial
action no less often than each five years after the initiation of such remedial action to
assure that human health and the environment are being protected by the remedial action
being implemented. In addition, if upon such review it is the judgment of the President
that action is appropriate at such site in accordance with section [104] or [106], the
President shall take or require such action. The President shall report to the Congress a
list of facilities for which such review is required, the results of all such reviews, and any
actions taken as a result of such reviews.
The Agency interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii)
states:
If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such action no less often than every
five years after the initiation of the selected remedial action.
3. The RCRA Corrective Action Permit has the ability to address any future issues that may
arise due to unknown soil contamination.
4. Post-remediation monitoring continued through 2004. A post-remediation monitoring
Report, that include monitoring results from 1999-2003, was submitted to EPA in March
2004.
5. See Comment Number Two.
There were no new issues discovered for the site during this Five-Year Review. OU-1 ground
water remediation is performing adequately and there were no changes to OU-2 and OU-4.
6.0 Five-Year Review Process
6.1 Administrative Components
The Science and Ecosystem Support Division and the Waste Management Division of
USEPA Region 4 established the review schedule whose components included:
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• Community Involvement;
Document Review;
Data Review;
Site Inspection;
Local Interviews;
Five-Year Review Report Development and Review.
The schedule extended through September 30, 2006.
6.2 Community Involvement
A public notice announcing initiation of the second Five Year Review for the Ciba-Geigy
Superfund site was published in the Washington County News on September 20, 2006. Upon
signature, the report will be placed at the following repositories for the site: Washington County
Town Hall in Mcintosh, Alabama and the EPA Region 4 office in Atlanta, Georgia.
6.3 Document Review
This Five-Year Review consisted of a review of relevant documents including Operation
Maintenance (O and M) records and Semi-Annual Ground Water Monitoring Reports (Ciba
Specialty, 2002-2005) (Attachment B). Applicable soil and ground water cleanup standards as
listed in the 1989 (OU-1), 1991 (OU-2), and 1992 (OU-4) Records of Decision, were reviewed
(Attachment B).
6.4 Data Review
6.4.1 OU-1, Shallow Ground Water Aquifer
Groundwater Corrective Action conditions under RCRA were specified originally in the
1985 RCRA Permit, and have been amended in subsequent Permit Modifications. The
Corrective Action objective for Ciba-Geigy Mcintosh alluvial aquifer ground water was to set up
a hydraulic barrier extending across the south boundary of the facility (the down gradient area of
alluvial aquifer ground water flow) to fully reverse the hydraulic gradient and retain the
contaminant plumes on CSCC's property. All ground water removed by the pumping wells is
treated by CSCC's on-site Wastewater Treatment System and discharged with treated process
wastewater under the Plant's National Pollutant Discharge Elimination System (NPDES) Permit.
The RCRA Groundwater Corrective Action System was started up in 1987 and has operated
continuously since that time. In addition to conditions setting operating parameters for the
pumping system, RCRA Corrective Action specifies extensive monitoring and reporting
requirements (Ciba Specialty, 2002-2005). For example, water level data is collected each
month, and semi-annually a verification of reversal of the hydraulic gradient is submitted to
ADEM, the current lead regulatory agency for CSCC RCRA compliance. Contaminant
concentrations in designated monitoring wells are also reported to ADEM semiannually.
Progress toward achievement of compliance with RCRA ground water protection
standards is well documented in the Site records. As an example, 1985-1987 pre-corrective
action startup ground water data identified 39 organic contaminants in the down gradient
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point-of-compliance monitoring wells. The 2000 data identified only two organic contaminants
above detection limits in these point-of-compliance wells. The July 2005 data also identified
three contaminants above detection limits in these compliance wells, arsenic, delta-BHC, and
barium. However, only arsenic is a COC for ground water (Ciba Specialty, 2002-2005).
The CERCLA ROD defined ground water clean-up goals for arsenic and 11 organic
chemicals (Table 3.1). Comparative analysis of the site's ground water database against the
clean-up goals using the RCRA point-of-compliance monitoring wells shows that based on the
July 2005 data, only two compliance wells, M-3 and M-6, had an exceedance. Well M-3
exceeded the standard for arsenic and delta-BHC and well M-6 exceeded the standard for arsenic
and barium. It should be noted that barium was also reported in the samples collected from the
background wells.
The latest semi-annual reports show sporadic detections of specific chemicals of concern
occurring in various compliance wells. These COCs (chloroform, arsenic, benzene, alpha-BHC,
delta-BHC, beta-BHC, chromium, lindane, and chlorobenzene) do not show any viable trends
and are not considered to be a hindrance toward achievement of compliance with RCRA ground
water protection standards.
As stated in the RCRA permit, time trend graphs for all the ground water pumping wells
are submitted with each semi-annual report for chlorobenzene as this is the main COC that has
occurred over time with the highest detections. The graphs illustrate the declining trend for
chlorobenzene in the pump and treat wells during their operation for 1988 to 2005.
Review of all semi-annual ground water monitoring reports from 2002 through 2005
(Ciba Specialty, 2002-2005) and performance of extensive data evaluation indicates that the
alluvial aquifer ground water remediation program is meeting expectations, and is being .
effectively managed under RCRA authority. In conclusion, the RCRA corrective action of
actively pumping and treating ground water should continue to operate.
6.4.2 OU 2, Ten of Eleven Former Waste Management Areas
As noted previously, the remedial design for OU-2 and OU-4 was performed as a joint
activity. Likewise, remedial action for OU-2 and OU-4 was implemented as one project. All
reports subsequent to the Final Design Report were prepared to cover both OUs. Remedy
components of OU-2 and OU-4 were essentially identical, with one notable exception,
construction of the OU-4 slurry wall. Therefore, Section 4.2.2, will cover the remedy
implementation and chronology for OU-2 and OU-4 jointly. Section 4.2.4 of this report will
cover only the OU-4 slurry wall.
Two institutional control measures contained in the remedy for OU-2 and OU-4 have
been fully implemented. Notification signs have been placed adjacent to the well head on all
ground water wells that pump contaminated alluvial aquifer ground water to the surface. Signs
have also been placed around the perimeter of all areas where subsurface soils greater than 12
inches may not be in full compliance with the performance standards. These signs constitute a
warning against unauthorized excavation which could remove contaminated subsurface soil to
the land surface.
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Based on research of scientific and engineering records, coupled with interviews of
CSCC personnel and an inspection of the site in June 2006, the conclusion is that the remedy has
been successfully implemented for OU-2 and OU-4 and is fulfilling its primary function.
6.4.3 OU-3, Floodplain, the Effluent Ditch and Tombigbee River
Since the selected remedy left DDTr greater than 15 ppm in of OU-3, EPA required
post-remediation monitoring to evaluate the effectiveness of the remedial action. During the
remedial design phase, two performance standards and one data objective were developed to
evaluate the remedy. The two performance standards were: (1) sediment concentrations, within
the remediated area, should remain below 15 ppm, (2) mosquitofish (Gambusia affinis) DDTr
body burdens of 0.3-1.5 ppm (Ciba Specialty, June 1998). One other objective of the monitoring
was to have a statistically significant declining trend in DDTr concentrations in the sediment
worm, Lumbriculus variegates, laboratory bioaccumulation tests. Ciba Specialty Chemical
Corporation issued The Post-Remediation Monitoring Report in March, 2004. The report
summarizes five years of monitoring data collected by CSCC to assess the effectiveness of the
selected remedy. Data from this report were evaluated for this review.
6.4.4 OU-4, Former Waste Management Area 8 (or Bluff line Site) and the Dilute Ditch
CSCC submitted post-construction reports verifying technical evidence that the slurry
wall performed its design function as a hydraulic barrier to the flow of alluvial aquifer ground
water in OU-4. Performance demonstration work plans were submitted to EPA and ADEM
which defined parameters for (1) an alluvial aquifer pump test, (2) an assessment of ground
water flow paths, and (3) ground water chemical testing.
The Performance Demonstration Reports from May 1997 and March 2000 provide
credible evidence that the OU-4 Slurry Wall is performing according to the requirements of the
Remedial Design.
6.5 Site Inspection
There were two site visits conducted as part of this five year review. Personnel form
SESD, including Bobby Lewis (ecologist) and Dr Pete Kalla (wildlife ecologist), conducted a
site visit on May 18, 2004. EPA SESD was also accompanied by personnel from CSCC and their
consultants. EPA SESD was able access the majority of OU-3. No significant issues were
identified during the site visit regarding the area of OU-3 that had been remediated.
When touring other areas of OU-3, specifically the forested wetlands, it was observed the
forested wetland occurs in the geomorphic setting known regionally as BLH Zone IV (Conner et
ah, 1990), marked by seasonal flooding and pronounced micro-topography (drainage features
and "saucer-and-mound" landforms). Though well-stocked with mature trees, the overstory is
co-dominated, if not dominated, by sugarberry (Celtis laevigata). Although other native
bottomland hardwood and cypress trees were observed in the forested areas, they were not the
dominant species.
When visiting the north end of Olin Basin, a fishing pole was observed on the shore. It's
possible the fishing pole may have been transported to the area by flooding. However, Olin
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Basin is accessible by boat during the flood season. A local angler indicated that fisherman will
fish in Olin Basin when flood waters allow, even though the basin is posted.
A second site inspection was conducted by Stacey Box (EPA SESD) on June 13, 2006. A
Five-Year Review Site Inspection Checklist was completed at that time. The Check list is
presented in Attachment D. Photos from the site visit are presented in Attachment C.
7.0 Technical Assessment
This five year review addresses four basic questions, as outlined in the Five-Year Review
Guidance (June 2001). The basic questions are:
1) Is the remedy functioning as intended by the decision documents?
2) Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives used at the time of the remedy selection still valid?
3) Has any other information come to light that could call into question the protectiveness of
the remedy?
4) Has substantial progress toward achievement of remedial goals been demonstrated in
Operable Unit 3?
7.1 Question 1
Is the remedy functioning as intended by the decision documents?
7.1.1 OUs 1, 2& 4
The review of documents, ARARs, risk assumptions, and the results of the site inspection
indicate that the remedy is functioning as intended by the ROD, as modified by the "Explanation
of Significant Differences" (ESD). In OU-2 and OU-4, the excavation, treatment and backfilling
of contaminated soils has achieved the remedial objectives to minimize the migration of
contaminants to ground water and surface water and prevent direct contact with, or ingestion of
contaminants in soils. Also, technical evidence was submitted that indicates the slurry wall
installed at OU-4 performs its design function as a hydraulic barrier. In OU-1, the pump and treat
system has shown its effectiveness at preventing further contaminant plume migration and has
also decreased contaminant concentrations in the alluvial aquifer.
In addition, two institutional control measures contained in the remedy for OU-2 and
OU-4 have been fully implemented. Notification signs have been placed adjacent to the well
head on all ground water wells that pump contaminated alluvial aquifer ground water to the
surface. Signs have also been placed around the perimeter of all areas where subsurface soils
may not be in full compliance with the direct contact surface soil performance standards. These
signs constitute a warning against unauthorized excavation which could remove subsurface soil,
which doesn't meet surface soil standards, to the land surface. No activities were observed that
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would have violated the institutional controls. The cap and the surrounding area were
undisturbed, and no new uses of ground water were observed. The fence around the site is intact
and in good repair.
7.1.2 OU-3
To evaluate question 1, the three media that were evaluated during the five years of
monitoring (1999-2003), sediment, mosquitofish, and sediment worms will be discussed
separately.
7.1.2.1 Sediment Data
To address if the remedy is functioning as intended by the decision documents, a subset
of questions are discussed to evaluate the sediment. The sediment questions are:
1) Has the performance standard for DDTr in sediment been attained?
2) Does monitoring data demonstrate continued attainment of the standard?
3) Does data indicate any trends (+ or -) in DDTr in sediment?
4) Have clean sediments in remediated area been recontaminated?
5) Is there any evidence of suggesting DDT degradation?- at what rate?
6) Are there continuing sources of release to the flood plain?
7) Are the other 19 COC's identified during the RI having any effects on the
environment?
Sediment data collected within the remediated area of Cypress Swamp, during the 5 years
monitoring, indicate that DDTr in sediments are remaining below the 15 ppm remedial goal.
DDTr was detected in sediments in the remediated areas in 2001 in the Cypress Swamp
West area and in 2002 in the Cypress Swamp East area. These detections were well above the 15
ppm remedial goal. This was discussed with CSCC, and it was determined that the field crews in
2001 and 2002 collected the sediment samples outside the remediated areas. The sediment
sampling locations were dependent upon where mosquitofish were collected. If the mosquitofish
were collected in the un-remediated areas, then the corresponding sediments were collected
there. Therefore, the 2001 and 2002 DDTr detections in the sediments of the remediated areas do
not necessarily indicate that the sediments have been re-contaminated. However, the exact
location where these sediment points were collected needs to be verified. At this time, no
investigations have been conducted to evaluate the potential of re-contamination of remediated
areas from the areas that were not remediated.
In other areas of the OU-3 wetland, that were not remediated, the sediment DDTr data are
variable. The area between Round Pond and the Cypress Swamp had elevated DDTr in
sediments for 2000 (654 ppm) and 2002 (578 ppm). Round Pond West had high DDTr detects in
sediment in calendar year 2000 (184 ppm) and 2002 (97 ppm). These spikes in the Round Pond
area are well above the 15 ppm remedial goal. Based on the monitoring plan design, no
distinguishable trends could be identified for these areas. Since the sediment sample locations
were dependent upon where the mosquitofish were collected, which will vary from year to year,
the sediment data reflect the variability of DDTr within these areas. The data also shows the
elevated concentrations of DDTr that remain in the wetland.
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Although the average DDTr concentration, for the entire floodplain, is less than 15 ppm,
there are several acres within OU-3, that were not remediated, that have DDTr concentrations
that are greater than 15 ppm. Figure 3 (Attachment A) shows the areas, by Kriging using
different DDTr concentration contours, within OU-3 that have DDTr concentrations greater than
15 ppm. The figure shows the 100 ppm, 50 ppm, 25 ppm, and 15 ppm contours with average
DDTr concentration calculated for each area. Within the 100 ppm contour there is approximately
17 acres with an average DDTr concentration of 240 ppm. Within the 50 ppm contour there are
approximately 21 acres with an average DDTr concentration of 224 ppm. Within the 25 ppm
contour there are approximately 32 acres with average concentration of 156 ppm. Within the 15
ppm contour there is approximately 37 acres with an average concentration of 134 ppm. This
figure illustrates how much DDTr remains in OU-3, and a concentration gradient southward
across the wetland toward the Tombigbee River. The majority of these areas are forested
wetlands. Since a habitat evaluation was not conducted, it is unclear how much of the area would
be considered ecologically sensitive. No quantitative assessment was done to evaluate the
impacts of leaving the DDTr in place.
Based on the monitoring design it is unclear if there have been, or are any continuing
releases of DDTr from the un-remediated areas to the remediated area, or other areas of the
wetland and the Tombigbee River, since the remedial action was completed. Data collected as
part of other investigations indicate past releases of DDTr to the Tombigbee River. The results of
the five years of monitoring tissue, indicate there is a biological pathway for DDTr to leave the
site. But, there is insufficient data to determine if the remaining DDTr in OU-3 sediments is
being transported offsite through other pathways. Additional investigations are needed to assess
other transport pathways.
Additional characterization of OU-3 sediment during the remedial design phase only
analyzed DDTr. Results indicated that DDTr was more wide spread and at higher concentrations
than found during the RI investigations. If the other site COCs, identified in the ROD, are
co-located with the DDTr, then its possible that other COCs may also be more wide spread and
at higher concentrations. If so, are the remaining COC's in OU-3 sediments potentially causing
unacceptable ecological risks? Other site related COCs should be analyzed as part of any future
monitoring program.
The implemented remedial action was selected primarily to protect the uniqueness of the
forested wetlands. This left approximately 37 acres of forested wetlands with soil/sediment
DDTr concentrations greater than 15 ppm. EPA and Ciba-Geigy wanted to protect the wetlands
because of the ecological value of the bottomland hardwood/Tupelo Cypress swamp. In their
narrative, presented in the Remedial Design Study Report and Preliminary Work Plan for
Operable Unit Number 3 (Ciba Specialty, June 1998), CSCC described the ecological benefits of
maintaining these tree species and the forested wetland because of the habitat it provides for fish
and wildlife. However, the biologically available DDTr in the sediments may harm the wildlife
that it attracts. The contaminated forested wetlands may act as an attractive nuisance. Wildlife
will be attracted to the habitat and then exposed to high concentrations of DDTr in the
sediments.
Many areas of the forested wetlands were protected from remediation because they were
defined as "sensitive habitat". The remedial design report (Ciba Specialty, June 1998) described
this "sensitive habitat" as being established bottomland hardwoods and Tupelo cypress. Initial
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observations made during the site visit summarized the majority of the forested wetland were
secondary succession species, indicating the area was probably clear-cut at one time. The
forested wetlands were co-dominated, if not dominated by sugar berry. The paucity of oaks and
other hard-mast species (probably removed by logging) reduces the wildlife food value of this
stand to an ecologically significant degree (Sharitz 1992, Higgins et al., 1994). The soft mast
produced by sugarberry, while useful in season to birds and other fauna, has neither the
nutritional value nor the persistent availability of acorns and other hard mast produced by a
diverse community of both heavy- and light-seeded species (USFWS 1981, Schroeder et al.,
1994).
Since no quantitative habitat evaluation was conducted, it is unclear just how many acres,
of the 37 acres (Figure 3) of contaminated wetland sediments, are bottomland hardwoods and
Tupelo Cypress. A quantitative habitat evaluation should be conducted to quantify how much of
the contaminated forested wetlands are actually established bottomland hardwoods and tupelo
cypress when considering additional remedial actions.
7.1.2.2 Mosquitofish Tissue
To address if the remedy is functioning as intended by the decision documents, a subset
of questions that address the mosquitofish monitoring were evaluated:
1) Has the performance standard for DDTr in mosquitofish been attained?
2) Do data indicate any trends (+ or -) in DDTr in mosquitofish?
3) When would compliance with performance standard be predicted?
The results of five years of monitoring mosquitofish tissue indicate the DDTr
concentration in fish tissue has decreased from pre-remedial conditions. However they have not
attained the remedial objective goal of 0.3-1.5 ppm. Mosquitofish collected from Cypress
Swamp West in 2003 had an average DDTr concentration of 22 ppm, and mosquitofish from
Cypress Swamp East had an average concentration of 15 ppm. The mosquitofish DDTr
concentrations in 2003 for Round Pond West, Round Pond East, and Round Pond Outlet were 6
ppm, 3 ppm, and 2 ppm, respectively (Attachment A, Figure 4, from the 2003 post-remediation
monitoring report). Pre-remedial mosquitofish concentrations were approximately 41 ppm DDTr
for the Cypress swamp area and 14 ppm for the Round Pond area.
The 2004 Monitoring Report concluded there was a statistically significant decreasing
trend in mosquitofish concentrations from 1999-2003. This was based on an analysis of variance
(ANOVA) and a linear fit to the mean. Based on their collection and sample processing
techniques, the ANOVA was inappropriately used. One of the major assumptions for the
ANOVA is the independent variances of each sample point within the data. At each location, the
fish samples were pooled then split into different replicates. This may dramatically reduce the
independent variance at a location; therefore, the ANOVA should not be applied to the data set,
and so a statistically significant trend cannot be predicted.
Based on visual assessment of graphically displayed data, presented in the Monitoring
Report, there is a downward trend in the mosquitofish DDTr concentrations in the Round Pond
area. The monitoring report also presented charts that displayed the mosquitofish mean DDTr
29
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concentrations for Cypress Swamp. The charts used linear fit to the mean to show DDTr trends
in mosquitofish tissue. These charts reveal a downward trend in DDTr concentrations. EPA
SESD combined the Cypress Swamp East and Cypress Swamp West samples to evaluate DDTr
trends in the mosquitofish tissue. Using a linear fit to the mean revealed a downward trend, with
an R2 value of 0.51. However, using a polynomial fit to the mean results in an R2 value of 0.66,
indicating a better fit to the mean. This chart shows a leveling off in DDTr concentrations in
mosquitofish. (Attachment A, Figure 5).
Based on the monitoring design and the handling of the mosquitofish tissue there is no
way to statistically predict when the performance standard would be . attained. A visual
assessment of the mosquitofish data, indicate the DDTr tissue concentrations are leveling off
well above the desired performance standard. Mosquitofish data was collected in 2004, but were
not available for this report.
The ecological significance of leaving DDTr in place, in the forested wetlands was only
evaluated qualitatively, not quantitatively. The qualitative assessment predicted that leaving the
DDTr contaminated sediments in place, in the forested wetlands, would have minimal risks to
ecological receptors at greatest risk (piscivorus birds), because they were said to be feeding in
the open areas of the wetland, which were remediated. The results of the mosquitofish
monitoring indicate that leaving the DDTr in the forested wetlands still poses a risk to the
piscivorus birds feeding in the open areas of the wetland.
The remedy has partially met its goals by showing initial progress toward reaching the
performance standards by reducing the DDTr concentration in mosquitofish from 41 ppm to 18
ppm. To date, however, the remedy has not been successful in achieving its performance
standard for mosquitofish by lowering the concentration to between 0.3 and 1.5 ppm. Initial
progress toward reaching the performance standard has leveled out, such that it does not appear
that substantial progress will be made in the future unless additional action is taken.
The elevated levels of DDTr remaining in the fish tissue, is based on the biology of
mosquitofish. Mosquitofish are a short lived species that normally forages in shallow water (<1
m). When the Tombigbee River floods every year, OU-3 water levels rise, flooding the
un-remediated areas within the forested wetlands. Mosquitofish will move into the shallow
waters of the flooded forested areas and will forage there until the flood waters recede. Figure 3
illustrates the biologically available DDTr concentrations the mosquitofish are exposed to during
the flood season.
Based on the monitoring design, the mosquitofish were not collected until flood waters
had receded and the Cypress Swamp was no longer directly connected to the Tombigbee River.
The remaining water in Cypress Swamp was normally confined to the open areas which were
remediated in 1998. The mosquitofish and the associated sediment sample were collected in the
remediated areas of Cypress Swamp where the sediments are relatively clean. The mosquitofish
may have foraged for several months in the forested wetlands, un-remediated areas, of OU-3.
Therefore, the sediments that were collected in association where the mosquitofish, do not
accurately represent the DDTr concentrations the mosquitofish were exposed to throughout the
year. This would explain the elevated concentrations of DDTr still found in mosquitofish
collected in the remediated areas of Cypress Swamp. When the flood waters recede into the open
30
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areas of Cypress Swamp the mosquitofish are more exposed and are quickly preyed upon
thereby making the DDTr available to the upper trophic level receptors, such as piscivorus birds.
The monitoring data indicate that DDTr is still biologically available and accumulating in
the food chain. Past investigations, EPA (1995), Woodward-Clyde (1994), and F&WS (1992),
have shown that DDTr in largemouth bass collected from Olin Basin have DDTr concentrations
that exceed the EPA (2001) screening value of 0.117 ppm. Woodward-Clyde (1994) reported
DDTr in bass that were well above the EPA screening value.
The results of the human health risk assessment indicate the hazard indices for OU-3 are
within the acceptable risk range. The human health risk assessment assumed there would be
limited access to the area because of the annual flooding which limits development and both
Ciba Geigy and Olin have fences around the property boundaries and have security guards on
duty 24 hours a day. Since there is indication that anglers are accessing Olin Basin, from the
Tombigbee River during high flood season, additional measures should be taken to reduce access
to anglers. If access to Olin basin is not controlled, then human health exposure scenarios should
be re-evaluated and edible tissue data should be considered as part of any future monitoring
program.
7.1.2.3 Sediment Worm (Lumbriculus) Tissue
As part of the post-remediation monitoring of OU-3, laboratory sediment worm
bioaccumulation tests were conducted on sediments collected in conjunction with the
mosquitofish. The sediment worm data was to be used to help evaluate the mosquitofish data.
Although the sediment worm data was not intended to be a performance standard, a data
evaluation objective for the worm data was a significantly declining trend in tissue
concentration.
The Lumbriculus bioaccumulation data can not be used as intended. The sediments for
lumbriculus bioaccumulation testing were collected in conjunction with where the mosquitofish
were collected each year. The areas where the mosquitofish were collected varied from year to
year depending on where the fish were located at time of collection. Since location of the
sediment collection varied year to year, trends cannot accurately be assessed. If the sediments
had been collected from the same locations, as reasonable as possible, each year, the data could
be used to establish trends. However, at one location, transition area between Round Pond and
Cypress Pond, the sediment sample was collected at the same location each year. Results for this
location indicate there is no decreasing or increasing trend in DDTr concentrations in
lumbriculus tissue.
The lumbriculus data was also intended to help evaluate the mosquitofish tissue data. As
discussed in section 7.1.2.2, the locations of where the sediments were collected do not reflect all
of the areas where the mosquitofish have foraged over the course of a year. Since the
mosquitofish will forage over unremediated areas during flood season, where DDTr average
concentrations are much higher than 15ppm, their exposure to DDTr is much greater during
flood season than the dry season. The sediments for the lumbriculus bioaccumulation testing are
collected during the dry season, usually in areas that were remediated. Therefore, the
lumbriculus data cannot be used to help explain the mosquitofish tissue results.
31
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Results of the Lumbriculus testing, demonstrates that DDTr is still biologically active and is
available for uptake by upper trophic level receptors.
7.2 Question 2
Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives
fRAOs) used at the time of the remedy selection still valid?
7.2.1. OUs 1, 2& 4
There have been no changes in the physical conditions of the site that would affect the
protectiveness of the remedy.
Changes in Standards and To Be Considered
As the remedial work has been completed, most ARARs for soil contamination cited in
the ROD have been met. ARARs that still must be met and that have been evaluated include: the
Safe Drinking Water Act (SDWA) (40 CRF 141.11-141.16) from which many of the ground
water cleanup levels were derived - [Maximum Contaminant (MCLs), and MCL Goals
(MCLGs)]. In 2001, the MCL for arsenic was changed from 50 |ig/L to 10 |ig/L and the new
MCL was applied to the data review conducted during this Five-Year Review. There have been
no other changes in these ARARs and no new standards or To Be Considered Materials (TBCs).
Changes in Exposure Pathways. Toxicity, and Other contaminant Characteristics
The exposure assumptions used to develop the Human Health Risk Assessment included
both current exposures (older child trespasser, adult trespasser) and potential future exposures
(young and older future child resident, future adult resident and further adult worker). There
have been no changes in the toxicity factors for the contaminants of concern that were used in
the baseline risk assessment. These assumptions are considered to be conservative and
reasonable in evaluating risk and developing risk-based cleanup levels. No change to these
assumptions or the cleanup levels developed from them is warranted. There has been no change
to the standardized risk assessment methodology that could affect the protectiveness of the
remedy. The remedy is progressing and it is expected that all ground water cleanup levels will be
met.
7.2.2 OU-3
EPA reviewed the ARARs that are presented in the ROD for OU-3 and finds them still
valid. The selected remedial goal of 15 ppm DDTr, in sediments was considered to be the best
balance between sediment remediation and habitat destruction. Although no quantitative
justification was presented, the 15 ppm value was considered to be a more realistic value, given
the conservative nature of the models used to predict risk. The assumptions made in developing
the remedial goal were:
The exposure to the fish and other ecological receptors could be represented by the area
average of DDTr concentrations.
32
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The degree of sediment to biota accumulation of DDTr was assumed to be such that a
cleanup level of 15 ppm would result in achievement of the performance standard for fish
tissue concentrations.
Reducing the DDTr to acceptable levels would also reduce other site COCs to acceptable
levels.
The results of the mosquitofish monitoring indicate that assumption 1 underestimated
exposure to ecological receptors. Receptors in the remediated area of Cypress Swamp are still
being exposed to elevated levels of DDTr through the food chain. The concentration of DDTr
still found in the mosquitofish indicates the original assumption of only remediating the open
areas of OU-3 would significantly reduce the risk to piscivorus receptors within the entire flood
plain, underestimated the exposure of mosquitofish to DDTr in the forested wetlands. Although
DDTr body burdens were decreased in mosquitofish, they are still well above the performance
standard of less than 1.5 ppm.
Since the implemented remedial action did not clean up all sediments to 15 ppm, the
protectiveness of the 15 ppm DDTr cannot be evaluated. The remaining DDTr within the OU-3
sediments complicates the ability to evaluate whether the 15 ppm DDTr would achieve the
performance standards. The mosquitofish performance standard may be achievable, if all
sediments greater than 15 ppm DDTr are remediated.
The ROD listed 17 other site COCs of OU-3. The 17 COC's are Ametryn, Atrazine,
Butlybenzylphthalate, Diazinon, Prometon, Prometryn, Propazine, Simazine, Simetryn,
Turbuthylazine, Terbutryn, Tolban, Chromium, Copper, Cyanide, Mercury, and Nickel. Previous
investigations concluded that these other site COCs were associated with the DDTr. An
assumption was made, in the ROD, that all of these site COCs would be remediated when the
DDTr in sediments were remediated. This assumption may hold true if the implemented remedial
action had cleaned up all sediments to less than 15 ppm DDTr. However, the selected remedial
action left approximately 37 acres (Figure 3) of sediment with DDTr concentration greater than
15 ppm. In some areas DDTr is 16 times greater than the remedial goal. Therefore, the other site
COC's, associated with the DDTr, may still be present in the OU-3 sediments at high levels that
could contribute to ecological risk.
Although DDTr, and other COCs, in surface water were identified as a concern for the
OU-3 wetland, surface water was not analyzed as part of the monitoring plan. The ROD did
specify that surface water would be monitored after the completion of the remedial action. The
assumption was that remediating DDTr in the uplands and in OU-3 soils and sediments would
take care of the surface water concerns. This assumption may hold true if all sediments were
remediated to 15 ppm DDTr. Since elevated concentrations of DDTr were left in place, the
remaining DDTr could be a potential source to surface water. In addition, other COCs associated
with the remaining DDTr may be at unacceptable levels in the surface water.
7.3 Question 3
Has any other information come to light that could call into question the protectiveness of the
remedy?
33
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7.3.1 OUs 1, 2& 4
No ecological targets were identified during the baseline risk assessment and none were
identified during the five-year review, and therefore monitoring of ecological targets is not
necessary. There is no other information that calls into question the protectiveness of the remedy.
7.3.2 OU-3
The primary new information that has come to light are the results of the
post-remediation monitoring for OU-3. As discussed in previous sections of this report,
mosquitofish DDTr body burdens have decreased over time but have leveled off at
concentrations well above the selected performance standard.
The ROD selected a remedial goal of 15 ppm for total DDT and indicated the RD would
detail how the 15 ppm remedial goal would be implemented. Because of EPA's and Ciba-Geigy's
concerns about the destruction of the forested wetlands, EPA implemented a cleanup strategy
that allowed the more heavily forested portions to remain undisturbed, achieving a site-wide
average of 15 ppm rather than cleaning up all sediments to less than 15 ppm. The monitoring
data indicates that a site-wide average of 15 ppm was not sufficient to attain the performance
standards established in the remedial design. Future remedial action strategies using the 15 ppm
remedial goal in OU-3 should be approved by EPA and presented to the Ecological Technical
Advisory Group (ETAG) and all stakeholders for review.
Alabama Department of Conservation and Natural Resources (ADCNR) have reported an
active bald eagle nest in the vicinity of OU-3 (Attachment B). The failure of the nest between
1999 and 2004 is a concern. The DDTr remaining on site and in the biota are at levels that could
have an effect on the bald eagle nesting success.
7.4 Question 4
Has substantial progress toward achievement of remedial goals been demonstrated in Operable
Unit 3?
The remedial action for OU-3 removed 9 acres of contaminated sediment in the open area
of Cypress Swamp. The results of the monitoring indicate this area has not been recontaminated
and DDTr still remains below the 15 ppm.
Although a site wide average was below 15 ppm following the completion of the
remedial action, the implemented remedy did leave 37 acres of sediment with DDTr
concentrations greater than 15 ppm (Figure 3). The ecological significance of leaving the DDTr
contaminated sediment in place was not evaluated quantitatively. In addition, the monitoring
design did not statistically evaluate whether a site wide average of 15 ppm DDTr in sediments is
being maintained.
Although mosquitofish DDTr body burdens have decreased, they still exceed the
designated performance standards. The mosquitofish DDTr body burdens have decreased from
post remediation concentrations, of 41 ppm to 18 ppm. However, mosquitofish tissue DDTr
concentrations have leveled off above the performance standard (Figure 5, Attachment A).
34
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The data objective for the sediment worm tests was a significantly declining trend of
DDTr in tissue. Because of the way the sediment worm samples were collected (Section 7.1.2.3),
no trends could be accurately established for most the sampling areas. The sediment worm
results do indicate the DDTR is still biologically available for uptake by upper trophic level
receptors. No substantial progress toward this data evaluation objective can be demonstrated.
7.5 Technical Assessment Summary
7.5.1 OUs 1,2, & 4
According to the data reviewed, the site inspection, and the interviews, the remedy is
functioning as intended by the ROD, as modified by the ESD. There have been no changes in the
physical conditions of the site that would affect the protectiveness of the remedy. Most ARARs
for soil contamination cited in the ROD have been met. There have been no changes in the
toxicity factors for the contaminants of concern that were used in the baseline risk assessment,
and there have been no change to the standardized risk assessment, and there have been no
change to the standardized risk assessment methodology that could affect the protectiveness of
the remedy. There is no other information that calls into question the protectiveness of the
remedy.
7.5.2 OU-3
The DDTr levels still remaining in mosquitofish tissue in OU-3 are at ecologically
unacceptable levels. Although the remedial action was successful at reducing DDTr in
mosquitofish tissue, the monitoring data demonstrates that DDTr remaining in OU-3 sediments
is still biologically available to upper trophic level receptors. These receptors could include
threatened and endangered species in the area.
8.0 Issues
No issues were encountered in OU-1, OU-2, or OU-4.
The following summarizes the issues regarding OU-3, discussed in the technical
assessment, Section 7.
Of the 370 acres of OU-3, there are still 37 continuous acres of OU-3 that have an
average DDTr concentration in sediment of 134 ppm (Figure 3 in Attachment A). The remedial
goal for DDTr in sediments for OU-3 is 15 ppm. The results of the five years of monitoring,
indicates the DDT remaining in the sediments is contributing to the elevated body burdens found
in the mosquitofish. Although mosquitofish body burdens have decreased over the five years of
monitoring, the concentrations are leveling off well above the performance standard. Additional
remediation of contaminated sediment is required to reduce body burdens in the mosquitofish
and attain the performance.
35
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9.0 Recommendations and Follow-up Actions
9.1 Recommendations for Operable Units 1,2 and 4
Table 9.1 presents the recommendations for OUs 1, 2, and 4.
Table 9.1, Recommendations and Follow-Up Actions
Issue
Recommendations and
Follow-Up Actions
Party
Responsible
Oversight
Agency
Milestone
Date
Affects
Protectiveness
(Y/N)
Current
Future
Operable Units 1,2 & 4 Recommendations
1
Recommend that the pump and
treat system continue operation to
address ground water
contamination.
cscc
ADEM/EPA
On-going
Y
Y
2
Recommend the continued
inspection and maintenance of
OU-2/OU-4 grass cover.
cscc
ADEM/EPA
On-going
Y
Y
3
Recommend the continued ground
water monitoring of OU-1
regulated under RCRA authority.
cscc
ADEM/EPA
On-going
Y
Y
Operable Unit 3 Recommendations
4
Remediate additional sediments.
cscc
ADEM/EPA
Sept. 2008
Y
Y
5
After additional remediation,
continue monitoring to evaluate
performance.
cscc
ADEM/EPA
Dec. 2008
Y
Y
6
Evaluate the other site COCs,
listed in the ROD during any
additional characterization or
monitoring.
cscc
ADEM/EPA
Aug. 2008
Y
Y
7
Habitat evaluation of forested
wetlands
cscc
ADEM/EPA
June 2007
Y
Y
8
Coordinate with Olin Chemical to
Control public access to Olin
Basin
CSCC/Olin
ADEM/EPA
Jan. 2007
Y
Y
9
Evaluate surface water in future
monitoring.
CSCC
ADEM/EPA
June 2008
Y
Y
10
Evaluate fate and transport
mechanisms of DDTr left in place
after additional remediation.
cscc
ADEM/EPA
Dec. 2009
Y
Y
Additional discussion of the recommendations for OU-3 is presented below.
36
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Recommendation 4. The assumptions made during the development of the remedial design
underestimated the exposure to ecological receptors. Additional sediment should be remediated
to attain the performance standard in mosquitofish tissue. Identifying how much and where is
beyond the scope of this report. CSCC should be responsible for any additional remediation with
oversight by EPA/ADEM
Recommendation 5. If the next remedial action leaves elevated DDTr in place, then CSCC needs
to continue monitoring to evaluate the performance of the implemented action. EPA
recommends the monitoring plan include the appropriate statistical design to evaluate significant
change and trends regarding the attainment of the performance standards. The statistical design
should be approved by EPA and reviewed by all stakeholders before any additional data is
collected.
Recommendation 6. Other site COCs should be evaluated during any additional characterization
or monitoring to evaluate the assumption in the ROD they would be addressed when the DDTr is
remediated.
Recommendation 7. During the remedial design phase a habitat evaluation should be conducted
to assess the potential loss of "sensitive habitat" to additional remediation. "Sensitive habitat"
should be clearly defined and approved by EPA and reviewed by all interested stakeholders
before conducting any habitat evaluations. Sensitive habitat areas should be delineated and
results presented to interested stakeholders for discussion of final remedial design decisions.
Recommendation 8. The edible fish tissue was not monitored as part of the five year monitoring
program because the hazard indices for the human health risk assessment were within the
acceptable risk range. It was assumed there would be limited access to anglers, therefore, limited
exposure. CSCC should coordinate with Olin Chemical to control access to OU-3 and Olin Basin
to reduce potential human health exposure that was not considered during the risk assessment. If
access is not controlled, then assumptions used in the human health risk assessment may need to
be reconsidered
Recommendation 9. Without fully understanding fate and transport mechanisms associated with
sediment DDTr, surface water should be analyzed during monitoring. The ROD does state that
surface water would be monitored after the completion of the remedy. Since elevated DDTr
concentrations, and the other COCs associated with the DDTr, were left in place the surface
water should be monitored. The monitoring program should evaluate if the selected remedial
action, or any future remedial action, leaves elevated DDTr, and associated site COCs, in place,
would hinder the attainment of the performance standards.A Conventional methods for analyzing
pesticides in surface water are not adequate to detect DDT at low levels. However there are other
collection and analytical methods available to reach low detection limits to evaluate DDT in
surface water.
Recommendation 10. If the additional remedial action leaves DDTr in place above 15 ppm, then
fate and transport mechanisms and ecological considerations should be thoroughly evaluated to
understand the ecological consequences of leaving elevated DDTr in place.
37
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10.0 Protectiveness Statement(s)
The remedies at OU-1, OU-2, and OU-4 are expected to be or are protective of human
health and the environment, and in the interim, exposure pathways that could result in
unacceptable risks are being controlled.
The remedy at OU-1 is expected to be protective of human health and the environment
upon attainment of ground water cleanup goals, through the ground water pump and treat
system. In the interim, exposure pathways that could result in unacceptable risks are being
controlled and institutional controls are preventing exposure to, or the ingestion of, contaminated
ground water. All threats at OU-2 and OU-4 have been addressed through excavation, treatment,
and backfilling of contaminated soil, the installation of fencing and warning signs, and the
implementation of institutional controls.
Long term protectiveness of the remedial action will be verified by ongoing ground water
monitoring of OU-1. Current monitoring data indicate that the remedy is functioning as required
to achieve ground water remedial goals.
The implemented remedial strategy for OU-3, which protected the forested wetlands, is
not fully successful as intended by the decision documents. The remedial action was successful
at reducing the DDTr in mosquitofish tissue, however, the levels of DDTr still found in the tissue
have leveled off and are still well above the performance standard, 0.3-1.5 ppm. The DDTr in
mosquitofish tissue, in the Cypress Swamp area, decreased over the first couple of years of
monitoring, but leveled off the following three years (Figure 5, Attachment A). This indicates
the performance standard for mosquitofish tissue will not likely be reached. Review of the
monitoring data and other available information, reveals that remaining DDTr in sediments is at
ecologically unacceptable concentrations and the remedy, as implemented, is not protective of
the environment.
There is also concern that other site COCs, identified in the ROD, still may be at
ecologically unacceptable levels. Since high concentrations of DDTr still remain in the wetland
sediments, other site COCs, associated with the DDTr, may also remain elevated at the site.
There is no data available to evaluate the assumption made in the ROD that the remediation of
DDTr would address the other site COCs listed in the ROD. Implementing Recommendation 6
(Section 9) would provide the necessary data to evaluate the other COCs associated with OU-3.
Since the areas that were not remediated during the initial cleanup (because they were
identified as ecologically sensitive) contain DDTR at concentrations that are not protective of the
environment and no ROD amendment or ESD has been issued at this time to prevent destruction
of these areas, by definition the entire OU3 is not protective of the environment. The remedy is
protective of human health.
38
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11.0 Next Review
The Ciba-Geigy site requires a statutory review every five years until the cleanup goals
are achieved. The third Five Year Review report is due to be approved within five years of the
date of the signature of this report.
Perform a Five-Year Review of all OUs in September 2011.
39
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Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Attachment A
Figures
Site Location Map
Ciba Specialty Chemical Corporation Facility Map
OU-3 DDTr Concentrations in Sediment/Soil
Figure 2 form Ciba Specialties Post Remediation Monitoring Report (CSCC, 2004)
Figures Illustrating Trends in Mosquitofish DDTr Concentrations
40
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Figure 1.
Site Location Map
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¦ Figure 3. OU-3 DDTr Cocentrations in Sediment/Soils
Figure produced by Ciba Specialty Chemical Corporation
QU3 FLOODPLAIN AREA
Area And Average DDTr Concentration Within Selected DDTr Contours
Remediated Area in Cypress Swamp
17 acres within 10(1 mg/kg ddtr contour (24 0 mg/kg mean ddtr!
21 acres within 50 mg/kg ddtr contour (224 mg/kg mean ddtr)
32 acres within 25 mg/kg ddtr contour (156 mg/kg mean ddtr)
37 acres within 15 mg/kg ddtr contour (134 mg/kg mean ddtr)
200 feet —
Acreage presented above la accumulative
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Figure 5. Figures Illustrating Trends in Mosquitofish DDTr Concentrations
Cypress Swamp (East and West)
Mean DDTr Concentrations in Gambusia Tissue for All
Sampling Years
1998 1999 2000 2001 2002 2003 2004
Sampling Year
Cypress Swamp (East and West)
Mean DDTr Concentrations in Gambusia Tissue for all
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Attachment B
List of Documents Reviewed
46
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References
BCM Converse Inc., 1988. Remedial Investigation/Feasibility Study Remedial Investigation
Report. Prepared for the Ciba-Geigy Corporation Superfund Site, Mcintosh Alabama, August
1998.
Ciba Specialty Chemical Corporation, Remedial Investigation/Feasibility Study Remedial
Investigation Report Addendum. The Ciba-Geigy Superfund Site, Mcintosh, Alabama, April
1994.
Ciba Specialty Chemical Corporation, 1998. Remedial Action Plans for Operable Unit No. 3.
Ciba-Geigy Superfund Site, Mcintosh, Alabama, April 1998
Ciba Specialty Chemical Corporation, 1998. Final Design Report for Operable Unit No. 3.
Ciba-Geigy Superfund Site, Mcintosh, Alabama, April 1998.
Ciba Specialty Chemical Corporation, 1998. Remedial Design Study Report and Preliminary
Work Plan for Operable Unit Number 3. The Ciba-Geigy Superfund Site, Mcintosh, Alabama,
June 1998.
Ciba Specialty Chemical Corporation, 1998. Final Construction Report for Operable Unit No. 3.
The Ciba-Geigy Superfund Site, Mcintosh, Alabama, December 1998.
Ciba Specialty Chemical Corporation, 2000. Post-Remediation Monitoring Plan for Operable
Unit Number 3. Ciba-Geigy Superfund Site, Mcintosh, Alabama, August 2000.
Ciba Specialty Chemical Corporation, 2002. 2002- Annual Ground Water Monitoring Report.
Ciba-Geigy Superfund Site, Mcintosh, Alabama, March 2002.
Ciba Specialty Chemical Corporation, 2002. 2002- Annual Ground Water Monitoring Report.
Ciba-Geigy Superfund Site, Mcintosh, Alabama, September 2002.
Ciba Specialty Chemical Corporation, 2003. 2003- Annual Ground Water Monitoring Report.
Ciba-Geigy Superfund Site, Mcintosh, Alabama, September 2003.
Ciba Specialty Chemical Corporation, 2004. 2004- Annual Ground Water Monitoring Report.
Ciba-Geigy Superfund Site, Mcintosh, Alabama, September 2004.
Ciba Specialty Chemical Corporation, 2004. 2003 Post-Remediation Monitoring Report,
Operable Unit Number 3. Ciba-Geigy Superfund Site, Mcintosh, Alabama, March 2004.
Ciba Specialty Chemical Corporation, 2005. 2005- Annual Ground Water Monitoring Report.
Ciba-Geigy Superfund Site, Mcintosh, Alabama, October 2005.
47
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Conner, W. H., R. T. Huffman, and W. Kitchens. 1990. Composition and productivity in
bottomland hardwood forest ecosystems: The report of the vegetation workgroup. Pages 455-479
in Gosselink, J. G., L. C. Lee, and T. A. Muir. Ecological processes and cumulative impacts:
Illustrated by bottomland hardwood wetland ecosystems. Lewis Publishers, Inc., Chelsea, MI.
708 pp.
Environmental Resources Management, Inc. 2001. Five-year Review Report, prepared for Ciba
Specially Chemicals Corporation, The Ciba-Geigy Superfund Site, Mcintosh, Alabama. Revised
September 17.
Higgins, K. F., J. L. Oldemeyer, KJ. Jenkins, O. K. Clambey, and R. F. Harlow. 1994.
Vegetation sampling and measurement. Pages 567-591 in Bookhout, T. A. Research and
management techniques for wildlife and habitats. The Wildlife Society, Bethesda, MD. 740 pp.
Schroeder, R. L., L. J. O'Neal, and T. M. Pullen, Jr. 1994. Wildlife community habitat
evaluation: A model for bottomland hardwood forests in the southeastern United States.
Biological Report 92(x), U.S. Dept. of the Interior, NBS, Washington, DC.
Sharitz, R. 1992. Bottomland hardwood wetland restoration in the Mississippi drainage. Pages
496-505 in National Research Council. Restoration of aquatic ecosystems. National Academy
Press, Washington, DC. 552 pp.
United States Environmental Protection Agency (USEPA). 1989. EPA Superfund Record of
Decision: Ciba-Geigy Corp. (Mcintosh Plant), EPA ID: ALD001221902, OU01, Mcintosh, AL.
09/28/1989. EPA/ROD/R04-89/056.
URL: http://www.epa.gov/region4waste/npl/nplal/cibagval.htm
USEPA. 1991. EPA Superfund Record of Decision: Ciba-Geigy Corp. (Mcintosh Plant), EPA
ID: ALD001221902, OU-2, Mcintosh, AL. 09/30/1991. EPA/ROD/R04-91/091.
URL: http://www.epa.gov/region4waste/npl/nplal/cibagval. htm
USEPA. 1992. EPA Superfund Record of Decision: Ciba-Geigy Corp. (Mcintosh Plant), EPA
ID: ALD001221902, OU-4, Mcintosh, AL. 07/14/1992. EPA/ROD/R04-92/117.
URL: http://www.epa.gov/region4waste/npl/nplal/cibagval. htm
USEPA. 1992. Region 4 Environmental News Superfund Fact Sheet: EPA Selects Clean-up
Remedy for Disposal at Ciba-Geigy Superfund Site in Mcintosh, Alabama. July 23.
USEPA. 1993. Region 4 Explanation of Significant Differences Superfund Fact Sheet for
Ciba-Geigy Site, Mcintosh, Washington County, Alabama, November 1993.
USEPA 1994. Ecological Risk Assessment Final Report, Ciba-Geigy Corporation Site, Mcintosh
Alabama, December 1994.
USEPA. 1995. EPA Superfund Record of Decision: Ciba-Geigy Corp. (Mcintosh Plant), EPA
ID: ALDOO1221902, OU-3, Mcintosh, AL. 07/25/1995. EPA/ROD/R04-95/244.
URL: http://www.epa.gov/region4waste/npl/nplal/cibagval. htm
48
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USEPA. 2001. Comprehensive Five-Year Review Guidance. Office of Emergency and Remedial
Response, US Environmental Protection Agency, Washington, DC. EPA/540-R-01-007. June.
URL: http://www.epa.gov/Superfund/pubs.htm
USEPA. 2006. Alabama NPL/NPL Caliber Clean-up Site Summaries: Ciba-Geigy Corporation
(Mcintosh Plant). URL: http://www.epa.gov/region4waste/npl/nplal/cibagval.htm. Last updated
April 25.
USEPA. 2006. Superfund Information Systems, CERCLIS (or WasteLAN): Ciba-Geigy Corp.
(Mcintosh Plant). EPA ID: ALD001221902.
URL: http://cfpub.epa.gov/supercpad/cursites/csitedocs.cfm?id=0400073. Last updated May 8.
United States of America. 1992. US Environmental Protection Agency CERCLA Remedial
Design/Remedial Action Consent Decree, Operable Unit No. 2, Ciba-Geigy Superfund Site,
Mcintosh, Washington County, Alabama. November.
United States of America. 1994. US Environmental Protection Agency CERCLA Remedial
Design/Remedial Action Consent Decree Addendum, Operable Unit No. 2, Ciba-Geigy
Superfund Site, Mcintosh, Washington County, Alabama. April.
United States of America. 1994. US Environmental Protection Agency CERCLA Remedial
Design/Remedial Action Consent Decree, Operable Unit No. 4, Ciba-Geigy Superfund Site,
Mcintosh, Washington County, Alabama. May.
USFWS. 1981. Standards for the development of habitat suitability index models. 103-ESM,
U.S. Fish and Wildlife Service. Government Printing Office, Washington, DC.
49
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Attachment C
Site Photos
50
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OU-2 Site 1
OU-2 Site 3
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OU-2 Site 7
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0U-2 Site 9
OlJ-4 Site 8A
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GLI-4 Site 8B
011-4 Site 8C
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Attachment D
Five Year Review Site Inspection Check List
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OSWER No. 9355.7-03B-P
Please note that "O&M" is referred to throughout this checklist. At sites where Long-Term
Response Actions are in progress, O&M activities may be referred to as "system operations" since
these sites are not considered to be in the O&M phase while being remediated under the Superfund
program.
Five-Year Review Site Inspection Checklist (Template)
(Working document for site inspection. Information may be completed by hand and attached to the
Five-Year Review report as supporting documentation of site status. "N/A" refers to "not applicable.")
I. SITE INFORMATION
i / nk
Site name
1
Location and Region:
Date of inspection:
EPA ID:
/
Agency, office, or company leading the five-year
review:
Weather/temperature:
f-jj-f / £¦*.<
Remedy Includes: (Check all that apply)
ndfill cover/containment
Access controls
Institutional controls
*^Or"6undwater pump and treatment.
Surface water collection and treatment
Other
Monitored natural attenuation
Groundwater containment
"•^'Vertical barrier walls
Attachments: --ffispection team roster attached
Site map attached
H. INTERVIEWS (Check all that apply)
1. O&M site manager ;
Name
Interviewed at site at office by phone Phone no.
Problems, suggestions; Report attached
Title
Date
2. O&M staff.
Name
Interviewed at site at office by phone Phone no.
Problems, suggestions; Report attached
Title
Date
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OSWER No. 9355.7-03B-P
3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency
response office, police department, office of public health or environmental health, zoning office,
recorder of deeds, or other city and county offices, etc.) Fill in all that apply.
Agency •_ f\
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OSWER No. 9355.7-03B-P
in. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1. O&M Documents
O&M manual Readily available Up to date N/A
As-built drawings • Readily available Up to date N/A
Maintenance logs Readily available Up to date N/A
Remarks.
2. Site-Specific Health and Safety Plan Readily available Up to date N/A
Contingency plan/emergency response plan Readily available Up to date N/A
Remarks
O&M and OSHA Training Records
Remarks
Readily available
Up to date
N/A
Permits and Service Agreements
Air discharge permit
Effluent discharge
Waste disposal, POTW
Other permits
Remarks
Readily available
Readily available
Readily available
Readily available
Up to date
Up to date
Up to date
Up to date
N/A
N/A
N/A
N/A
5. Gas Generation Records
Remarks ¦
Readily available
Up to date N/A
Settlement Monument Records
Remarks
/' ;
Readily available
Up to date N/A
Groundwater Monitoring Records
Remarks'
Readily available
Up to date N/A
8. Leachate Extraction Records
Remarks; ¦ -
Readily available
Up to date N/A
9.
Discharge Compliance Records
Air
Water (effluent)
Remarks '
Readily available
Readily available
Up to date
Up to date
N/A
N/A
10. Daily Access/Security Logs
Remarks
Readily available
Up to date
N/A
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OSWER No. 9355.7-03B-P
TV. O&M COSTS
O&M Organization
State in-house
PRP in-house
Federal Facility in-house
Other
Contractor for State
Contractor for PRP
Contractor for Federal Facility
O&M Cost Records
Readily available Up to date
Funding mechanism/agreement in place
Original O&M cost estimate
Breakdown attached
Total annual cost by year for review period if available
From
To_
Date
Date
Total cost
From
To
Date
Date
Total cost
From
To
Date
Date
Total cost
From
To
Date
Date
Total cost
From
To
Date
Date
Total cost
Breakdown attached
Breakdown attached
Breakdown attached
Breakdown attached
Breakdown attached
3.
Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons: '
V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A
A. Fencing
1. Fencing damaged . . Location shown on site map ^ Gates secured
Remarks
N/A
B. Other Access Restrictions
1. Signs and other security measures
Remarks
Location shown on site map N/A
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OSWERNo. 9355.7-03B-P
C. Institutional Controls (ICs)
1. Implementation and enforcement
Site conditions imply ICs not property implemented
Site conditions imply ICs not being fully enforced
Type of monitoring (e.g., self-reporting, drive by).
Frequency
Responsible party/agency.
Contact
Title
Yes
Yes
©
N/A
N/A
Name
Reporting is up-to-date
Reports are verified by the lead agency
Specific requirements in deed or decision documents have been met
Violations have been reported
Other problems or suggestions: Report attached
Date
Phone no.
Yes
No
N/A
Yes
No
N/A
Yes
No
N/A
Yes
No
N/A
2. Adequacy
Remarks
ICs are adequate
ICs are inadequate
N/A
D. General
1. Vandalism/trespassing Location shown on site map
Remarks ;
^lo vandalism evident^
Land use changes on site N/A,
Remarks
Land use changes off si
Remarks
VI. GENERAL SITE CONDITIONS
A. Roads
Applicable N/A
Roads adequate^
1. Roads damaged
Remarks
Location shown on site map
N/A
X.
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OSWERNo. 9355.7-03B-P
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OSWERNo. 9355.7-03B-P-
Wet Areas/Water Damage
Wet areas
Ponding
Seeps
Soft subgrade
Remarks
et areas/water damage not evidei;
ration sliuwn uu biieinap
Location shown on site map
Location shown on site map
Location shown on site map
Areal extent.
Areal extent_
Areal extent_
Areal extent
Slides Location shown on site map evidence of slope instabili^
9.
Slope Instability
Areal extent
Remarks
B. Benches Applicable x^N/A J
(Horizontally constructed mounds o£eai£h-pteced across a steep landfill side slope to interrupt the slope
in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined
channel.)
1. Flows Bypass Bench
Remarks; .
Location shown on site map
2.
Bench Breached
Remarks
Location shown on site map
<^3l/A-©r-c
3. Bench Overtopped
Remarks_
Location shown on site map
C. Letdown Channels Applicable f N/A.
(Channel lined with erosion controhnats, riprap, grout bags, or gabions that descend down the steep
side slope of the cover and will allow the runoff water collected by the benches to move off of the
landfill cover without creating erosion gullies.)
1.
Settlement
Areal extent.
Remarks
Location shown on site map
Depth
No evidence of settlement
2.
Material Degradation
Material type
. Remarks '
Location shown on site map
Areal extent_ :
No evidence of degradation
3.
Erosion
Areal extent.
Remarks
Location shown on site map
Depth
No evidence of erosion
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OSWERNo. 9355.7-03B-P
Undercutting
Areal extent
Remarks
Location shown on site map
Depth
No evidence of undercutting
5.
Obstructions Type
Location shown on site map
Size
Remarks
No obstructions
Areal extent
Excessive Vegetative Growth Type
No evidence of excessive growth
Vegetation in channels does not obstruct flow
Location shown on site map Areal extent_
Remarks
D. Cover Penetrations Applicable
1.
Gas Vents Acti
Properly secured/locked Functio
Evidence of leakage at penetration
N/A
Remarks_
Passive
Routinely sampled Good condition
Needs Maintenance
Gas Monitoring Probes
Properly secured/locked Functioning
Evidence of leakage at penetration
Remarks
Routinely sampled Good condition
Needs Maintenance N/A
Monitoring Wells (within surface area of landfill)
Properly secured/locked Functioning Routinely sampled Good condition
Evidence of leakage ait penetration Needs Maintenance N/A
Remarks
Leachate Extraction Wells
Properly secured/locked Functioning
Evidence of leakage at penetration
Remarks
Routinely sampled Good condition
Needs Maintenance N/A
Settlement Monuments
Remarks
Located
Routinely surveyed
N/A
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OSWER No. 9355.7-03B-P
E. Gas Collection and Treatment
Applicable
1. Gas Treatment Facilities
Flaring Thermal destruction
Good condition Needs Maintenance
Remarks
Collection for reuse
2. Gas Collection Wells, Manifolds and Piping
Good condition Needs Maintenance
Remarks
3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
Good condition Needs Maintenance N/A
Remarks ;
F. Cover Drainage Layer
Applicable
1.
Outlet Pipes Inspected
Remarks
Functioning
N/A
2.
Outlet Rock Inspected
Remarks ¦
Functioning
N/A
G. Detention/Sedimentation Ponds
Applicable
N/A..
1.
SiltationAreal extent
Siltation not evident
Remarks
Depth_
N/A
Erosion Areal extent_
Erosion not evident
Remarks
Depth_
Outlet Works
Remarks
Functioning N/A
4. Dam
Remarks
Functioning N/A
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OSWER No. 9355.7-03B-P
H. Retaining Walls Applicable ( N/A J
1.
Deformations Location shown^OTfsite map Deformation not evident
Horizontal displacement Vertical displacement
Rotational displacement
Remarks
2.
Degradation Location shown on site map Degradation not evident
Remarks
I.
Perimeter Ditches/Off-Site Discharge Applicable N/A
1.
Siltation Location shown on site map Siltation not evident
Areal extent Depth
Remarks
2.
Vegetative Growth Location shown on site map N/A
Vegetation does not impede flow
Areal extent Tvpe
Remarks
3.
Erosion Location shown on site map Erosion not evident
Areal extent Depth
Remarks
4.
Discharge Structure Functioning N/A
Remarks
VIII. VERTICAL BARRIER WALLS Applicable N/A
1.
Settlement Location shown on site map . Settlement not evident
Areal extent Depth
Remarks
2.
Performance MonitoringTvpe of monitoring
Performance not monitored
Frequency Evidence of breaching
Head differential
Remarks
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OSWERNo. 9355.7-03B-P
IX. GROUND WATER7SURFACE WATER REMEDIES Applicable N/A
A. Groundwater Extraction Wells, Pumps, and Pipelines Applicable^) N/A
1. PujnpsrWellhead Pliipibing, andJEleetrifal -
M3ood condition-' '' Atfrequired wells properly operating Needs Maintenance N/A
" ~ — ~ '
2. EjtFactftnrSysteBi Pipelines, Valves, Valve Boxes, and Other Appurtenances
Good condition J Needs Maintenance
3. Spare Parts and Equipment
Readily available Good condition Requires upgrade Needs to be provided
Remarks
B. Surface Water Collection Structures, Pumps, and Pipelines Applicable N/A
1. Collection Structures, Pumps, and Electrical
Good condition Needs Maintenance
Remarks
2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
Good condition Needs Maintenance
Remarks
3. Spare Parts and Equipment
Readily available Good condition Requires upgrade Needs to be provided
Remarks i
D-17
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OSWER No. 9355.7-03B-P
c.
Treatment System Applicable N/A y
1.
Treatment Train (Check components that apply)
Metals removal Oil/water separation Bioremediation
Air stripping Carbon adsorbers
Filters
Additive Ce.e.. chelation agent. flocculenO
Others
Good condition Needs Maintenance
Sampling ports properly marked and functional
Sampling/maintenance log displayed and up to date
Equipment properly identified
Ouantitv of groundwater treated annuallv
Ouantitv of surface water treated annuallv
Remarks
2.
Electrical Enclosures and Panels (properly rated and functional)
N/A Good condition Needs Maintenance
Remarks •
3.
Tanks, Vaults, Storage Vessels
N/A Good condition Proper secondary containment Needs Maintenance
Remarks
4.
Discharge Structure and Appurtenances
N/A Good condition Needs Maintenance
Remarks
5.
Treatment Building(s)
N/A . Good condition (esp. roof and doorways) Needs repair
Chemicals and equipment properly stored
Remarks
6.
Monitoring Wells (pump and treatment remedy)
Properly secured/locked Functioning Routinely sampled- - Good condition
All required wells located Needs Maintenance N/A
Remarks
D. Monitoring Data
1. Monitoring Data
Is routinely submitted on time Is of acceptable quality
2.
Monitoring data suggests:
Groundwater plume is effectively contained Contaminant concentrations are declining
D-18
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OSWER No. 9355.7-03B-P
D. Monitored Natural Attenuation
1. Monitoring Wells (natural attenuation remedy)
Properly secured/locked Functioning Routinely sampled Good condition
All required wells located Needs Maintenance N/A
Remarks
X. OTHER REMEDIES
If there are remedies applied at the site which are not covered above, attach an inspection sheet describing
the physical nature and condition of any facility associated with the remedy. An example would be soil
vapor extraction.
XL OVERALL OBSERVATIONS
A. Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as
designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant
plume, minimize infiltration and gas emission, etc.).
B. Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
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OSWERNo. 9355.7-03B-P
C. Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be
compromised in the future.
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
D-20
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