Fourth Five-Year Review Report for

Stauffer Chemical Company (Cold Creek Plant) and Stauffer Chemical Company (LeMoyne Plant)

ALD095688875 and ALD008161 t 76

Frankl in E. Hill , Director Superfund Division

Bucks and Axis Mobile County, Alabama

August 2016

Uni ted States Environmental Protection Agency Region 4

Atlanta, Georgia

Date:

ii

Fourth Five-Year Review Report

for

Stauffer Chemical Company (Cold Creek Plant) and

Stauffer Chemical Company (LeMoyne Plant)

Highway 43 N

Bucks and Axis

Mobile County, Alabama

List of Acronyms ........................................................................................................................... v

Executive Summary .................................................................................................................... vii

Five-Year Review Summary Form ............................................................................................. ix

1.0 Introduction ............................................................................................................................. 1

2.0 Site Chronology ....................................................................................................................... 2

3.0 Background ............................................................................................................................. 3

3.1 PHYSICAL CHARACTERISTICS .......................................................................................... 3

3.2 LAND AND RESOURCE USE .............................................................................................. 7 3.3 HISTORY OF CONTAMINATION ......................................................................................... 8 3.4 INITIAL RESPONSE ........................................................................................................... 8

3.5 BASIS FOR TAKING ACTION ............................................................................................. 9

4.0 Remedial Actions .................................................................................................................. 10

4.1 REMEDY SELECTION ...................................................................................................... 10 4.2 REMEDY IMPLEMENTATION ........................................................................................... 15

4.3 OPERATION AND MAINTENANCE (O&M) ....................................................................... 16

5.0 Progress Since the Last Five-Year Review ......................................................................... 19

6.0 Five-Year Review Process .................................................................................................... 21

6.1 ADMINISTRATIVE COMPONENTS .................................................................................... 21

6.2 COMMUNITY INVOLVEMENT .......................................................................................... 21 6.3 DOCUMENT REVIEW ...................................................................................................... 22 6.4 DATA REVIEW ............................................................................................................... 27

6.5 SITES INSPECTION .......................................................................................................... 31 6.6 INTERVIEWS ................................................................................................................... 32

7.0 Technical Assessment ........................................................................................................... 33

7.1 QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENTS?

..................................................................................................................................... 33

7.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS AND

REMEDIAL ACTION OBJECTIVES (RAOS) USED AT THE TIME OF REMEDY SELECTION STILL

VALID? ......................................................................................................................... 34

7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO

QUESTION THE PROTECTIVENESS OF THE REMEDY? ...................................................... 35 7.4 TECHNICAL ASSESSMENT SUMMARY ................................................................................... 35

8.0 Issues, Recommendations and Follow-up Actions ............................................................. 36

9.0 Protectiveness Statements .................................................................................................... 37

iii

10.0 Next Review ......................................................................................................................... 37

Appendix A: List of Documents Reviewed ............................................................................. A-1

Appendix B: Press Notice ......................................................................................................... B-1

Appendix C: Interview Forms ................................................................................................. C-1

Appendix D: Site Inspection Checklist ................................................................................... D-1

Appendix E: Photographs from Sites Inspection Visit .......................................................... E-1

Appendix F: Detailed Groundwater and Soil Data Evaluation ............................................. F-1

Appendix G: Contaminant Groundwater Plume Maps ........................................................ G-1

Appendix H: Risk Evaluation of Groundwater and Soil Cleanup Goals ............................ H-1

Tables

Table 1: Chronology of Site Events ............................................................................................... 2

Table 2: OU1 Groundwater Cleanup Goals for the LP Site and the CCP Site ............................ 11 Table 3: LP OU2 Soil Cleanup Goals .......................................................................................... 12

Table 4: CCP OU2 Sub-surface Soil Cleanup Goals for the Old Neutralization Pond ............... 13 Table 5: LP and CCP OU3 Cleanup Goals for Mercury ............................................................. 14 Table 6: Annual O&M Costs ....................................................................................................... 19

Table 7: Progress on Recommendations from the 2011 FYR ..................................................... 20 Table 8: OU1 ARARs Evaluation for Groundwater COCs for the LP Site and the CCP Site .... 23

Table 9: Deed Documents from the Mobile County Probate Court Office ................................. 24 Table 10: Institutional Control (IC) Summary ............................................................................. 24 Table 11: CCP OU2 Summary of Thiocarbamate Exceedances ................................................. 30

Table 12: Evaluation of CCP OU2 2016 Biopile Soil Sample Results ....................................... 31

Table 13: Issues and Recommendations Identified in the FYR ................................................... 36 Table 14: Protectiveness Statements ............................................................................................ 37 Table F-1: Monthly Groundwater Monitoring Data for Molinate at the CCP Site ................... F-3

Table F-2: Summary of LP OU2 Groundwater Data ................................................................. F-4 Table F-3: Summary of LP OU2 former Halby Groundwater Monitoring Data ....................... F-6

Table F-4: Summary of December 2015 LP OU2 former Halby Soil Data .............................. F-7 Table F-5: Summary of Thiocarbamate Exceedances in CCP OU2 .......................................... F-8

Table H-1: Risk Evaluation of LP and CCP OU1 Groundwater Cleanup Goals....................... H-1 Table H-2: Risk Evaluation of 2012 CCP OU2 Soil Performance Standards ........................... H-1

Figures Figure 1: Site Location Map .......................................................................................................... 4

Figure 2: LP Site – Detailed Site Map ........................................................................................... 5 Figure 3: CCP Site – Detailed Site Map ........................................................................................ 6

Figure 4: Site Institutional Controls Map .................................................................................... 26 Figure 5: Summary of Wells Monitored for Remedy Performance at the LeMoyne Plant ......... 28 Figure 6: Thiocyanate Concentration Trend in IW-5 in the LP OU2 former Halby Pond .......... 29 Figure F-1: Carbon Tetrachloride Concentration Trend in MW-19 near the LP GWIP ........... F-1 Figure F-2: Thiocyanate Concentration Trend in IW-5 in the LP OU2 former Halby Pond ..... F-5 Figure F-3: Thiocarbamate Concentrations in MW-16 (ONP) at CCP OU2............................. F-9 Figure F-4: Molinate Concentration Trends at CCP OU2 ......................................................... F-9

iv

Figure F-5: Thiocarbamate Concentrations in MW-13R (North Landfill) at CCP OU2 ......... F-10

Figure F-6: Thiocarbamates Concentrations in MW-26 (South Landfill) at CCP OU2 .......... F-10

Figure F-7: Location of CCP OU2 Biopile Sample Locations ................................................ F-11 Figure G-1: Carbon Tetrachloride in the Shallow Wells at LP OU1, November 2010 ............. G-1 Figure G-2: Carbon Tetrachloride in the Shallow Wells at LP OU1, April 2015 ..................... G-2 Figure G-3: Carbon Tetrachloride in the Deep Wells at LP OU1, November 2010 ................. G-3 Figure G-4: Carbon Tetrachloride in the Deep Wells at LP OU1, April 2015 .......................... G-4

Figure G-5: Carbon Disulfide in the Shallow Wells at LP OU1, November 2010 ................... G-5 Figure G-6: Carbon Disulfide in the Shallow Wells at LP OU1, April 2015 ............................ G-6 Figure G-7: Carbon Disulfide in the Deep Wells at LP OU1, November 2010 ........................ G-7 Figure G-8: Carbon Disulfide in the Deep Wells at LP OU1 in April 2015 ............................. G-8 Figure G-9: 2015 Soil Sample Locations at the LP OU2 former Halby Pond Area .................. G-9

v

List of Acronyms

ADEM Alabama Department of Environmental Management

ADPH Alabama Department of Public Health

Akzo AkzoNobel Incorporated

AOC Area of Concern

ARAR Applicable or Relevant and Appropriate Requirement

AWIC Alabama Water Improvement Commission

CCP Cold Creek Plant

CD Consent Decree

CERCLA Comprehensive Environmental Response, Compensation and Liability Act

CFR Code of Federal Regulations

CIC Community Involvement Coordinator

CNA Courtaulds North America

COC Contaminant of Concern

EPA United States Environmental Protection Agency

EPTC Ethyl Dipropylthiocarbamate

ESD Explanation of Significant Differences

FOD Frequency of Detection

FS Feasibility Study

FYR Five-Year Review

GWIP Groundwater Improvement Pond

HCC Halby Chemical Company

HQ Hazard Quotient

IC Institutional Control

ICI ICI Americas, Inc.

ICIAP Institutional Control Implementation and Assurance Plan

IAROD Interim Amended Record of Decision

IW Interceptor Well

LHA Lifetime Health Advisory

LP LeMoyne Plant

MCL Maximum Contaminant Level

mg/kg Milligrams per Kilogram

µg/L Micrograms per Liter

MLSTZ Middle Lower Swamp Transition Zone

MW Monitoring Well

NCP National Oil and Hazardous Substances Pollution Contingency Plan

NPDES National Pollutant Discharge Elimination System

NPL National Priorities List

O&M Operation and Maintenance

ONP Old Neutralization Pond

OU Operable Unit

ppm Parts per Million

PRP Potentially Responsible Party

RAO Remedial Action Objective

RCRA Resource Conservation and Recovery Act

RI Remedial Investigation

ROD Record of Decision

vi

RPM Remedial Project Manager

RSL Regional Screening Level

Stauffer Stauffer Chemical Company

Syngenta Syngenta Crop Protections, Inc.

TBC To-Be-Considered

UAO Unilateral Administrative Order

UASZ Upper Arm Swamp Zone

vii

Executive Summary

Between 1953 and 1966, the Stauffer Chemical Company (Stauffer) built and started operating two

chemical manufacturing plants in Mobile County, Alabama. The 220-acre Cold Creek Plant (CCP) and

adjacent 730-acre LeMoyne Plant (LP) are located 20 miles north of Mobile, Alabama, in the

communities of Bucks and Axis, respectively. Both plants are separate Superfund sites: the Stauffer

Chemical Company CCP Site (the CCP Site) and the Stauffer Chemical Company LP Site (the LP

Site). Due to the close proximity of the sites and joint operable units (OU), both sites are evaluated in

this five-year review (FYR).

Stauffer started manufacturing bulk organic and inorganic chemicals at the LP Site in 1953. Stauffer

discharged waste from manufacturing operations into an unlined landfill on the eastern side of the LP

Site from 1965 to 1974. In 1975, Stauffer discharged wastes to on-site ponds and to Cold Creek

Swamp. From 1965 to 1979, Stauffer leased a small area on the western end of the LP Site to the

Halby Chemical Company (HCC), which discharged waste products and effluents into a pond on the

southwest portion of the LP Site and into Cold Creek Swamp. Current owners of the LP Site stopped

manufacturing the agricultural chemical Vapam in 1993. At the CCP Site, Stauffer began

manufacturing agricultural chemicals in 1966; site operations discharged wastewater into two landfills,

clay-lined ponds and the Cold Creek Swamp until 1975. Owners of the CCP Site ceased

manufacturing operations in 2008 and decommissioned the facility in 2010. Waste handling operations

at both CCP and LP affected groundwater and soil as well as sediments and fish in Cold Creek

Swamp. Primary contaminants at the LP Site are thiocyanate and cyanide in the former Halby area

soil/sludge and carbon tetrachloride, carbon disulfide and thiocyanate in groundwater. Primary

contaminants at the CCP Site are thiocarbamate herbicides in soil and groundwater. The primary

contamination in the Cold Creek Swamp is mercury in sediment.

To manage the sites, the United States Environmental Protection Agency divided them into multiple

operable units (OUs). OU1 and OU3 are common to both sites; OU1 addresses groundwater and OU3

addresses surface water and sediment contamination in Cold Creek Swamp. Each site has its own OU2

to address separate soil contaminant sources. The OU1 remedy consists of groundwater extraction and

treatment and long-term monitoring. The OU2 remedy for the LP Site consists of soil flushing,

institutional controls and long-term monitoring. The OU2 remedy for the CCP Site consists of soil

excavation and on-site treatment, long-term monitoring and institutional controls. The OU3 remedy

consists of capping, long-term monitoring and institutional controls for Cold Creek Swamp. The

triggering action for this FYR was the signing of the previous FYR on August 30, 2011.

The remedy for OU1 currently protects human health and the environment because groundwater

monitoring continues at the CCP Site and treatment and monitoring continues at the LP Site. In

addition, on-site contamination is not migrating off site. For the remedy to be protective over the long

term, the cause of the increased carbon tetrachloride concentrations at the Groundwater Improvement

Pond (GWIP) requires further investigation and cleanup goals for cyanide and thiocyanates need

reassessment.

The remedy for LP OU2 is expected to be protective of human health and the environment upon

completion. In the interim, remedial activities completed to date have adequately addressed all

exposure pathways that could result in unacceptable risk at LP OU2.

viii

The remedy for CCP OU2 is expected to be protective of human health and the environment upon

completion. In the interim, remedial activities completed to date have adequately addressed all

exposure pathways that could result in unacceptable risk at CCP OU2.

The remedy for OU3 protects human health and the environment because the cap has eliminated

exposure to contaminated sediments and performance monitoring will be conducted over the next five

years to ensure the remedy continues to be protective.

ix

Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name: Stauffer Chemical Company (Cold Creek Plant) and Stauffer Chemical Company (LeMoyne Plant)

EPA ID: ALD095688875 and ALD008161176

Region: 4 State: AL City/County: Bucks and Axis/Mobile County

SITE STATUS

NPL Status: Final

Multiple OUs?

Yes

Have the sites achieved construction completion?

No

REVIEW STATUS

Lead agency: EPA

Author name: Deborah Cox (EPA), Claire Marcussen and Johnny Zimmerman-Ward (Skeo)

Author affiliation: EPA and Skeo

Review period: October 2015 – August 2016

Date of site inspection: December 10, 2015

Type of review: Statutory

Review number: 4

Triggering action date: August 30, 2011

Due date (five years after triggering action date): August 30, 2016

x

Five-Year Review Summary Form (continued)

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:

OU3

Issues and Recommendations Identified in the Five-Year Review:

OU(s): OU1 LP Issue Category: Remedy Performance

Issue: Carbon tetrachloride concentrations are increasing in monitoring well 19 (MW-19) at the GWIP to levels above the groundwater cleanup goal for the LP Site.

Recommendation: Further investigate to determine the cause of the increasing carbon tetrachloride concentrations at the GWIP and address as necessary.

Affect Current Protectiveness

Affect Future Protectiveness

Implementing Party

Oversight Party

Milestone Date

No Yes PRP EPA/State 07/20/2021

OU(s): OU1 and OU2 at LP

Issue Category: Remedy Performance

Issue: Toxicity values for cyanide and thiocyanates have become more stringent since the 1989 OU1 ROD and 1999 OU2 ROD were issued.

Recommendation: Reassess the groundwater and leachability-based soil cleanup goals for cyanide and thiocyanates.

Affect Current Protectiveness

Affect Future Protectiveness

Implementing Party

Oversight Party

Milestone Date

No Yes EPA/State EPA/State 07/20/2021

xi

Five-Year Review Summary Form (continued)

Protectiveness Statements

Operable Unit: OU1 LP and CCP

Protectiveness Determination: Short-term Protective

Addendum Due Date (if applicable): Click here to enter date.

Protectiveness Statement: The remedy for OU1 currently protects human health and the environment because groundwater monitoring continues at the CCP Site and treatment and monitoring continues at the LP Site. In addition, on-site contamination is not migrating off site. For the remedy to be protective over the long term, the cause of the increased carbon tetrachloride concentrations at the GWIP requires further investigation and cleanup goals for cyanide and thiocyanates need reassessment.

Operable Unit: LP OU2

Protectiveness Determination: Will be Protective

Addendum Due Date (if applicable): Click here to enter date.

Protectiveness Statement: The remedy for LP OU2 is expected to be protective of human health and the environment upon completion. In the interim, remedial activities completed to date have adequately addressed all exposure pathways that could result in unacceptable risk at LP OU2.

Operable Unit: CCP OU2

Protectiveness Determination: Will be Protective

Addendum Due Date (if applicable): Click here to enter date.

Protectiveness Statement: The remedy for CCP OU2 is expected to be protective of human health and the environment upon completion. In the interim, remedial activities completed to date have adequately addressed all exposure pathways that could result in unacceptable risk at CCP OU2.

Operable Unit: OU3 LP and CCP

Protectiveness Determination: Protective

Addendum Due Date (if applicable): Click here to enter date.

Protectiveness Statement: The remedy for OU3 protects human health and the environment because the cap has eliminated exposure to contaminated sediments and performance monitoring will be conducted over the next five years to ensure the remedy continues to be protective.

xii

Five-Year Review Summary Form (continued)

Environmental Indicators

- Current human exposures at the CCP Site and the LP Site are under control. - Current groundwater migration is under control.

Are Necessary Institutional Controls in Place?

All Some None For OU1 at the LP Site and the CCP Site, institutional controls are in place in the form of a consent decree and deed restrictions filed with the Mobile County Deeds Office to prevent the construction of drinking water wells and the use of contaminated groundwater, and provide notice of the institutional controls if ownership of the land changes. As part of implementing the OU2 remedies at the LP Site and the CCP Site, institutional controls restricting land use and construction should be implemented. The potentially responsible party (PRP) is in the process of finalizing an institutional control plan for OU3. Once approved by the EPA, the institutional controls will be implemented.

Has EPA Designated the Sites as Sitewide Ready for Anticipated Use?

Yes No

Have the Sites Been Put into Reuse?

Yes No Akzo continues to manufacture chemicals on the LP Site.

1

Fourth Five-Year Review Report

for

Stauffer Chemical Company (Cold Creek Plant) and

Stauffer Chemical Company (LeMoyne Plant)

Superfund Sites

1.0 Introduction

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a

remedy in order to determine if the remedy will continue to be protective of human health and

the environment. FYR reports document FYR methods, findings and conclusions. In addition,

FYR reports identify issues found during the review, if any, and document recommendations to

address them.

The United States Environmental Protection Agency prepares FYRs pursuant to the

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Section

121 and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).

CERCLA Section 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 5 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 EPA interpreted this requirement further in the NCP, 40 Code of Federal Regulations (CFR)

Section 300.430(f)(4)(ii), which 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 initiation of the selected remedial action.

Skeo Solutions, an EPA Region 4 contractor, conducted the FYR and prepared this report

regarding the remedy implemented at Stauffer Chemical Company (Stauffer) Cold Creek Plant

site (the CCP Site) in Bucks, Mobile County, Alabama, and the Stauffer LeMoyne Plant site (the

LP Site) in Axis, Mobile County, Alabama, referred to collectively as the “Stauffer Sites” and

“the Sites.” The EPA’s contractor conducted this FYR from October 2015 to August 2016. The

EPA is the lead agency for developing and implementing the remedy for the potentially

responsible party (PRP)-financed cleanup at the Sites. The Alabama Department of

Environmental Management (ADEM), as the support agency representing the State of Alabama,

2

has reviewed all supporting documentation and provided input to the EPA during the FYR

process.

This is the fourth FYR for the Stauffer Sites. The triggering action for this statutory review is

signing of the previous FYR on August 30, 2011. The FYR is required due to the fact that

hazardous substances, pollutants or contaminants remain at the Sites above levels that allow for

unlimited use and unrestricted exposure. The Sites consist of multiple operable units (OUs). OU1

and OU3 are common to both Sites; OU1 addresses groundwater and OU3 addresses surface

water and sediment contamination in Cold Creek Swamp. The CCP Site and the LP Site each has

its own OU2 to address separate contaminant sources. This FYR report addresses all three OUs

at both Sites.

2.0 Site Chronology

Table 1 lists the dates of important events for the Sites.

Table 1: Chronology of Site Events

Event Date

EPA Notification of hazardous waste site – dates of waste handling 1953-1979 May 15, 1981

Stauffer Cold Creek Plant (CCP) and LeMoyne Plant (LP) Superfund Sites (Sites)

proposed for listing on the Superfund program’s National Priorities List (NPL)

September 8, 1983

Stauffer Sites placed on the NPL September 21, 1984

Administrative Order on Consent for site-wide RI/FSs at the Sites January 21, 1986

Remedial Investigation (RI) Report for the CCP/LP Sites May 1, 1988

Final Feasibility Study (FS) for the CCP/LP Sites June 21, 1989

Addendum to FS and Proposed Plan for the CCP and LP Sites Operable Unit (OU) 1

Ground Water

July 11, 1989

Record of Decision (ROD) CCP and LP Sites OU1 Ground Water September 27, 1989

Consent Decree (CD) CCP and LP Sites OU1 Ground Water April 25, 1990

RI/FS Fact Sheet CCP and LP Sites OU3 Cold Creek Swamp January 1, 1991

Final RI Report CCP and LP Sites OU3 Cold Creek Swamp June 1, 1992

ROD CCP and LP Sites OU3 Cold Creek Swamp September 17, 1993

Final Focused FS CCP Site OU2 Soil November 4, 1994

Superfund Proposed Plan Fact Sheet CCP Site OU2 Soil April 1, 1995

ROD CCP Site OU2 Soil August 16, 1995

Explanation of Significant Differences (ESD) for CCP and LP Sites OU3 Cold

Creek Swamp

May 1, 1996

Unilateral Administrative Order (UAO) for Remedial Design/Remedial Action

(RD/RA) CCP Site OU2 Soil

August 26, 1996

ROD LP Site OU2 Soil March 18, 1999

ESD Superfund Fact Sheet CCP Site OU2 Soil June 1, 1999

ESD Memorandum CCP Site OU2 Soil June 28, 1999

First Five-Year Review (FYR) for the Stauffer CCP and LP Sites June 2, 2000

CD LP Site OU2 Soil March 5, 2001

Second FYR for the Stauffer CCP and LP Sites December 21, 2005

Superfund Proposed Plan Fact Sheet CCP and LP Sites OU3 Cold Creek Swamp August 1, 2008

Administrative Settlement Agreement and Order on Consent to expand the focused

FS CCP and LP Sites OU3 Cold Creek Swamp

November 30, 2009

3

Event Date

Focused FS and Proposed Plan Fact Sheet CCP and LP Sites OU3 Cold Creek

Swamp

July 01, 2010

Interim Amended ROD (IAROD) CCP and LP Sites OU3 Cold Creek Swamp September 30, 2010

Third FYR for the Stauffer CCP and LP Sites August 30, 2011

CD for RD/RA at CCP and LP Sites OU3 Cold Creek Swamp June 8, 2012

ESD for CCP Site OU2 Soil August 29, 2012

Interim RA final inspection for CCP and LP Sites OU3 Cold Creek Swamp November 2015

3.0 Background

3.1 Physical Characteristics

The Stauffer Sites are located in an industrial area about 20 miles north of Mobile, Alabama, on

U.S. Highway 43 in the cities of Bucks and Axis, Alabama (Figure 1). The 730-acre LP Site is an

industrial facility bounded by the CCP Site to the north, chemical companies to the south, the

Mobile River to the east, and Highway 43 to the west (Figure 2). The parcels of the LP Site are

owned by Akzo that Halby Chemical Company (HCC) leased. Chemtura is the successor owner

to the assets of HCC. Parcels of the CCP Site are owned by Syngenta Crop Protections, Inc.

(Syngenta). The 220-acre CCP Site is situated between Highway 43 to the west and the Mobile

River to the east. The Alabama Power Company Barry Steam Generating Plant is located

immediately north of the CCP Site. Other major chemical processing facilities surround the CCP

Site to the north, west and south. The LP Site borders the CCP Site to the south. (Figure 3).

The primary historical sources of contamination at the LP Site include the former Halby area,

LeMoyne Landfill, the Old Chlorine Wastewater Treatment Pond and the Old Brine Mud Pond.

The primary historical sources of contamination at the CCP Site include the former Old

Neutralization Pond (ONP), the North Landfill, the South Landfill and LeCreek Wastewater

Treatment Pond. Contaminated soil and sediment removed from the ONP is currently enclosed in

a covered biopile located immediately south of the South Landfill.

The 650-acre Cold Creek Swamp is a wetland located between U.S. Highway 43 to the west and

the Mobile River to the east (Figure 1). Cold Creek Swamp is adjacent to both Sites and

discharges water into the Mobile River, which flows south toward the Gulf of Mexico. The

eastern part of the LP Site is adjacent to the Mobile River and drains toward it (Figure 1).

The Stauffer Sites are underlain by alluvial deposits consisting of interbedded clays, sand and

gravels. These deposits range in thickness from 130 to 60 feet at the edge of the Mobile River

and form the surficial Miocene aquifer, the principal source of water for industries and local

communities in the Mobile River Valley area. The surficial aquifer has two water-bearing zones.

The upper 80 feet has low to moderate permeability with the lowermost sands containing the

most highly permeable material. A dense blue-gray estuarine clay forms the base of the aquifer.

4

Figure 1: Site Location Map

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding the EPA’s response actions at the Site.

5

Figure 2: LP Site – Detailed Site Map

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA's response actions at the Sites, and is not intended for any other purpose.

6

Figure 3: CCP Site – Detailed Site Map

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding the EPA’s response actions at the Sites.

7

Prior to industrialization, the direction of groundwater flow was eastward toward the Mobile

River and the water table ranged from 0 to 20 feet below ground surface. Installation of wells on

the Courtaulds North America (CNA) property immediately south of the LP Site resulted in the

lowering of the water table to between 25 and 75 feet below ground surface. Due to local

influence of pumping at the CNA wells and interceptor wells on the southern part of the LP Site,

groundwater flowed south to southeast toward the wells. In early 2002, CNA completely ceased

groundwater extraction; the groundwater flow equilibrated and is again flowing east toward the

Mobile River.

3.2 Land and Resource Use

Surrounding land uses are predominantly industrial, and related to chemical processing and

electrical power generation. Timber production (southern pine) is the other major land use

nearby. Most land east of the Sites (across the Mobile River) is undeveloped river bottom swamp

with some timber harvesting.

Stauffer operated a chemical manufacturing facility at the LP Site from the 1953 to 1987. From

1965 to 1979, the HCC leased a portion of land on the western end of the Site (the “former Halby

Area”) from Stauffer. Halby is a predecessor to Chemtura. On November 16, 1972, Halby was

purchased by Argus Chemical Corporation, a subsidiary of Witco Corporation. In 1999, Witco

Corporation merged with Crompton & Knowles to form CK Witco. In 2000, CK Witco changed its

name to Crompton Corporation. In 2005, Crompton Corporation merged with Great Lakes Chemical

Corporation to form Chemtura Corporation. In 1987, Akzo Chemie America, Inc., now called

AkzoNobel (Akzo), purchased the LP facility. Akzo continues to manufacture chemicals at the

LP Site.

Stauffer started manufacturing agricultural pesticides and herbicides at the CCP Site in 1966.

Ownership of the CCP Site later transferred to ICI Americas, Inc., which later became Syngenta

Crop Protection, LLC (Syngenta), the PRP for the CCP Site. Syngenta ceased manufacturing

operations at the CCP Site in 2008, and completed decommissioning of facility operations in

2010. Although there are no uses planned for the CCP Site, portions of the property could be

leased in the future for industrial activities.

Operations at both Sites have impacted the surficial aquifer. However, there are no exposure

pathways because the contamination is contained within site boundaries and site activities do not

use contaminated groundwater from this aquifer. During past operations, the CCP Site obtained

drinking water under ADEM permits from wells CC-11 and CC-13 on the western portion of the

CCP Site and upgradient from groundwater contamination. These two production wells remain

on site but are not in use. The LeMoyne Public Water Supply provides water for drinking

fountains, bathroom sinks, kitchens, breakrooms, toilets and showers – except emergency

showers and eyewash stations – at the LP Site. Three supply wells – LM-6, LM-7 and LM-10,

located upgradient from the groundwater contamination – have been used for production/process

water and emergency showers and eyewash stations on the LP Site. These wells are analyzed for

constituents that need to be managed for production water quality. LM-7 and LM-10 continue to

be used; LM-6 has been shut down and replaced by LM-11. There are no cross-connections

between the LeMoyne Public Water Supply and the production well water supply.

8

Cold Creek Swamp and the Mobile River area are a natural habitat for a variety of invertebrates,

amphibians, reptiles, fish, birds and mammals. Land use in Cold Creek Swamp is limited to

drainage of surface water runoff and wetland functions, including providing mammal and bird

habitat and fish spawning grounds. The swamp is bisected by a large power line right-of-way.

According to the 2010 Interim Amended OU3 Record of Decision (IAROD), there are no

anticipated changes to future land use for the swamp (Figure 1). The 1989 Records of Decision

(ROD) for the Stauffer Sites identified two species of concern – the American Alligator, which is

on the federal list of threatened species, and the Alabama Red-Bellied Turtle, which is proposed

for the list.

3.3 History of Contamination

The LP Site discharged waste (e.g., brine muds, plant refuse, used samples and absorption oil)

into an unlined landfill on the eastern side of the Site from 1965 to 1974. In 1975, Stauffer closed

the landfill under the direction of the Alabama Water Improvement Commission (AWIC, now

ADEM). Stauffer stored wastewaters generated from site operations in ponds, all of which were

clay-lined except for one; some of the ponds discharged to the Cold Creek Swamp. Wastewater

from the LP Site included discharges of process waters from several production units; one of the

units contained mercury. Except for LeCreek Pond, Stauffer closed all of the ponds in the 1970s

and replaced them with membrane-lined ponds under AWIC’s direction. LeCreek Pond is an

active wastewater treatment plant. In 1975, operators at the LP Site completed a wastewater

pipeline to the Mobile River and started discharging wastewaters in the river under a National

Pollutant Discharge Elimination System (NPDES) permit.

From 1965 to 1979, HCC discharged waste into a pond on the northwest portion of the LP Site

next to the Norfolk Southern rail line and eventually into Cold Creek Swamp. In 1979, when

HCC closed the facility, the pond was filled with soil and other demolition debris from the

former Halby Pond. The pond may have been clay lined and does not have an impermeable cap

in place. The contribution from HCC may have included metal-contaminated wastewater.

The Stauffer CCP discharged wastewater into clay-lined ponds and the nearby Cold Creek

Swamp from 1966 until 1975, when an effluent transport line was constructed to convey

wastewater from treatment areas directly to the Mobile River, subject to a NPDES permit.

Neutralized waste brine from the Stauffer CCP was also discharged to the swamp during the late

1960s. The Stauffer CCP disposed of sludge and solid wastes containing a variety of herbicides

and pesticides in two waste disposal areas known as the North and South Landfills. Stauffer

closed both landfills in 1974 with geo-membrane caps and sidewall liners. Until 1975, a

clay-lined lagoon was used for neutralization of wastewater, and was later closed in 1978. A new

lined pond was constructed as a replacement for the lagoon to hold non-process wastewater and

stormwater from process units at the plant.

3.4 Initial Response

In the early 1970s, Stauffer notified the AWIC of the presence of contaminants in on-site and

off-site wells. Following the discovery of site-related groundwater contamination, Stauffer

installed 21 additional groundwater monitoring wells at the Sites in 1973. Stauffer closed the

9

unlined ponds and constructed lined ponds by 1977. However, groundwater quality had already

substantially deteriorated. The EPA was notified of hazardous waste handling in May 1981. As a

result, Stauffer installed seven observation wells on the southern property line of the LP Site. In

late 1980, Stauffer also installed three interceptor wells and an air stripper on the LP Site, as

requested by AWIC.

The Alabama Department of Public Health (ADPH) conducted a health assessment for the Sites

in 1982 and requested that the PRP install additional monitoring wells around the LeMoyne

Landfill. Based on the results from these wells, the EPA proposed listing the CCP Site and the

LP Site on the Superfund program’s National Priorities List (NPL) in September 1983. The EPA

finalized the listing in September 1984.

In October 1986, the EPA issued a Resource Conservation and Recovery Act (RCRA) permit for

the LP Site for the operation of two hazardous waste surface impoundments and a hazardous

waste storage tank. The permit also required that Stauffer address releases at solid waste

management units. Stauffer satisfied this requirement by addressing these releases through the

implementation of a remedial investigation and feasibility study (RI/FS) under CERCLA.

In November 1984, the EPA sent Stauffer a letter notifying the company of its potential liability

for contamination at the Sites. The EPA performed preliminary sampling for the groundwater

operable unit (OU1) in May 1985 to assist in preparation of a work plan for an RI/FS. Under a

1986 Administrative Order on Consent, Akzo/ICI completed the RI in May 1988 and a draft FS

Report in July 1988. After the EPA required modifications to the report, the final FS Report was

submitted in June 1989.

3.5 Basis for Taking Action

The EPA approved an amended FS Report for OU1 for both Sites in May 1990. The results of

the RI/FS indicated that source contamination in several ponds at both Sites and in groundwater

at the LP Site was contaminated with carbon tetrachloride, carbon disulfide, thiocarbamates and

thiocyanate. Thiocarbamates were also impacting groundwater at the CCP Site.

The PRP completed an RI for the source areas OU (OU2) at the CCP Site in 1986. It concluded

that, under current conditions, the North and South Landfills and LeCreek Wastewater Treatment

Pond did not pose a risk from human exposure to soil, surface water and groundwater. However,

risks were posed to human receptors exposed to soils contaminated with six thiocarbamate

herbicides at the ONP as a result of the subsurface soil contamination leaching into the

underlying groundwater.

Akzo completed an RI/FS at the LP Site in 1988, concluding that thiocyanate and cyanide in

subsurface soils at the former HCC area presented a future risk to human health and the

environment based on leaching models. The EPA reviewed the RI and concluded that potential

exposure to Cold Creek Swamp did not present unacceptable human health risks based on the

isolated nature of the wetland and the limited exposure pathway. However, to be conservative,

the Mobile County Department of Health issued a “Fish Consumption Advisory” for Cold Creek

Swamp in May 1992, resulting in the posting of “no fishing” signs along the wetland. The EPA

10

concluded that two areas of Cold Creek Swamp – the Upper Arm Swamp Zone (UASZ) to the

Middle Lower Swamp Transition Zone (MLSTZ) – contained elevated levels of mercury in

sediment that posed a potential risk to ecological receptors from direct exposure to contaminated

sediment and uptake of mercury through bioaccumulation in the food chain.

4.0 Remedial Actions

In accordance with CERCLA and the NCP, the overriding goals for any remedial action are

protection of human health and the environment and compliance with applicable or relevant and

appropriate requirements (ARARs). A number of remedial alternatives were considered for the

Sites, and final selection was made based on an evaluation of each alternative against nine

evaluation criteria that are specified in Section 300.430(e)(9)(iii) of the NCP. The nine criteria

are:

1. Overall Protection of Human Health and the Environment

2. Compliance with ARARs

3. Long-Term Effectiveness and Permanence

4. Reduction of Toxicity, Mobility or Volume through Treatment

5. Short-Term Effectiveness

6. Implementability

7. Cost

8. State Acceptance

9. Community Acceptance

4.1 Remedy Selection

OU1 – LP Site and CCP Site

The EPA signed two separate RODs for OU1 on September 27, 1989, selecting the same

groundwater remedy and cleanup goals for the CCP Site and the LP Site. The EPA identified that

the objective of the remedial actions is to protect human health and the environment by

controlling the migration of contaminated groundwater in the surficial aquifer, which is a

principal source of water for industrial and domestic users in the Mobile River Valley. The major

components selected in both RODs include:

Continued use of existing groundwater intercept and treatment system.

Installation of additional extraction wells.

Modifications to treatment system to be determined through pilot scale tests using

in-situ treatment alternatives.

Monitoring effluent, groundwater concentrations and pumping rates.

Monitoring surface water discharge to ensure concentration limits specified in the

NPDES permit are met.

Implementing a contingency remedy in case the pumping of the CNA wells was

terminated.

A summary of the cleanup goals that the EPA listed in the 1989 RODs for groundwater

contaminants of concern (COCs) are presented in Table 2.

11

Table 2: OU1 Groundwater Cleanup Goals for the LP Site and the CCP Site

COC

1989

Cleanup Goala

(µg/L)

Basis

Carbon disulfide 700 Lifetime Health Advisory (LHA)

Carbon tetrachloride 5

Maximum Contaminant Level

(MCL)

Cyanide 200 LHA

Mercury 2 MCL

Thiocyanates 200 LHA

Thiocarbamate Herbicides

Butylate 350 LHA

Cycloate 7 LHA

Ethyl dipropylthiocarbamate

(EPTC) 210

LHA

Molinate 14 LHA

Pebulate 7 LHA

Vernolate 7 LHA

Notes:

a. Values obtained from Table 8-1 in both the CCP and LP 1989 RODs.

µg/L = micrograms per liter

OU2

The EPA signed two separate RODs to address the source areas at the LP Site and the CCP Site.

The OU2 RODs are summarized below.

LP Source Areas

The EPA signed the OU2 ROD for the LP Site on March 18, 1999. The objective of the remedy

for OU2 at the LP Site is to prevent contamination from migrating into groundwater, which has

potential beneficial use as a drinking water supply. Although the settling defendants, Akzo and

CK Witco Corporation (successor to HCC), signed a Consent Decree agreeing to implement the

ROD, the remedy has not yet been implemented. CK Witco’s successor, Chemtura Corporation,

filed a bankruptcy petition in 2009. In September 2010, the U.S. attorney, on behalf of the EPA,

obtained a cash settlement in U.S. Bankruptcy Court. The EPA and Akzo are in discussions for

Akzo to perform the remedy.

The selected remedy for OU2 at the LP Site addresses the cleanup of the contaminated

subsurface soil. Major remedial components include:

Institutional controls to restrict construction on the former Halby area until subsurface

soil performance standards are met and to restrict the LP Site from converting to

residential use.

Construction of a soil flushing system in the former Halby area to accelerate the

migration of contaminants from the subsurface soil into the groundwater where it will be

captured and treated by the OU1 groundwater remedy.

12

Annual monitoring of subsurface soil in the former Halby area for cyanide and

thiocyanate to determine if contaminants are moving into the groundwater in a controlled

manner where they will be captured and treated by the OU1 groundwater remedy.

Periodic reporting of annual monitoring results to the EPA.

The cleanup goals for subsurface soil are presented in Table 3.

Table 3: LP OU2 Soil Cleanup Goals

COC Cleanup Goal a

(mg/kg) Basis

Cyanide 0.47 Ensure soil does not migrate to groundwater

above the health-based standard of 200 µg/L

Thiocyanate 8.5 Ensure soil does not migrate to groundwater

above the health-based standard of 3,500 µg/Lb

Notes:

a. Values are leachability-based values from Table 6-9 of the 1999 LP OU2 ROD.

b. The groundwater health-based standard was revised from 200 µg/L, as listed in the

1989 OU1 ROD to 3,500 µg/L in the 1999 ROD.

mg/kg – milligrams per kilogram.

CCP Source Areas

The EPA signed the OU2 ROD for the CCP Site on August 16, 1995, to address four source

areas (the North Landfill, the South Landfill, LeCreek Wasterwater Treatment Pond and the

ONP). The Agency identified remedies to address unacceptable human health risks associated

with contaminated subsurface soils leaching from the ONP to groundwater and preventing

exposure to contaminants in the North and South Landfills. The EPA selected a “no action”

remedy for LeCreek Wastewater Treatment Pond because the CCP Site was an active facility in

compliance with applicable permits as part of the NPDES program.

The EPA modified the OU2 ROD for the CCP Site with an Explanation of Significant

Differences (ESD) on June 28, 1999, requiring ex-situ treatment of contaminated soil from the

ONP with bioremediation. In August 2012, the EPA issued a second ESD. It revised the 1995

performance standards for soil and included institutional controls to provide for the long-term

protection of the integrity of existing landfill caps and construction of the cap over the ONP.

The EPA identified the following remedy components for the ONP:

Excavation of the source area in conjunction with on-site land treatment (bioremediation)

of thiocarbamate contaminants to levels protective of groundwater, backfilling and

capping.

Performance of a treatability study to determine the appropriate design and operational

parameters for treatment of contaminated soil.

Setup of the treatment pad.

Excavation of contaminated soil and placement into a treatment cell.

Periodic fertilization, irrigation and tilling of soil until reaching the performance

standards and verified by sampling.

13

Backfilling excavated areas with clean soil, treated soil or both.

Construction of a cap equivalent to a RCRA Subtitle C cap.

Groundwater monitoring for 30 years.

Maintenance of the integrity of the cap.

Implementation of institutional controls.

A summary of the final CCP OU2 soil cleanup goals is presented in Table 4.

Table 4: CCP OU2 Sub-surface Soil Cleanup Goals for the Old Neutralization Pond

COC

1995 Performance

Standards a

(mg/kg)

2012 Revised Performance Standard (mg/kg)b

Without RCRA Cap With RCRA Cap

Butylate NA NA NA

Cycloate 2.187 36.35 10,648

EPTC 25.74 283.70 83,106

Molinate 1.464 16.39 4,803

Pebulate 1.971 3,215.00 941,971

Vernolate 2.298 31.30 9,170

Notes:

a. Values obtained from Table 5 from the 1995 OU2 CCP ROD, which were based on a leaching model.

b. Values from Table 2 from the 2012 OU2 ESD for the CCP Site; the EPA revised the standards based on

soil treatment data collected during the biopile operation together with updated risk-based drinking

water values established for the thiocarbamates.

mg/kg = milligrams per kilogram

NA = Modeling results yielded a sub-surface soil level that indicated no remedial action was necessary for

this COC.

The EPA identified limited action at the North and South Landfills since these source areas did

not pose a risk under current conditions. The primary remedy components for the two landfills

included:

Development and implementation of landfill operation and maintenance (O&M) to

ensure current cap integrity and access control.

Development and implementation of a groundwater monitoring program for the six

thiocarbamate COCs.

OU3 – LP Site and CCP Site

The EPA signed the ROD for OU3 on September 17, 1993, to select a remedy to address

mercury contamination in Cold Creek Swamp sediment. The EPA issued an ESD in May 1996 to

remove the 1993 ROD requirement for a levee between Cold Creek Swamp and the Mobile

River. In addition, the ESD included a requirement for long-term monitoring for Cold Creek

Swamp. In September 2010, the EPA issued an OU3 IAROD, requiring the use of a new capping

technology that was not available for consideration when the ROD was issued. It also included

revised cleanup goals for fish and wildlife tissue. The ESD and IAROD resulted in less habitat

destruction during cleanup of sediment contamination.

14

The RAOs listed in the IAROD include:

Reduce concentrations of contaminants in sediments in Cold Creek Swamp to levels that

are protective of ecological receptors.

Prevent continued migration of contaminants from the UASZ to the MLSTZ and the

Mobile River.

Prevent exposure to contaminants in sediments in the UASZ, above levels that pose an

unacceptable risk to ecological receptors.

Reduce contaminant levels in fish tissue to levels that are protective of ecological

consumers.

The major components of the remedy include:

Construction of an in-situ cap to isolate the contaminated sediments in the UASZ.

Installation of water level controls within the UASZ to maintain current pool conditions.

Wetland mitigation to compensate for the temporary or permanent loss of wetlands due to

the use of in-situ capping technology in the UASZ.

Implementation of a monitoring and assessment program in Cold Creek Swamp.

Institutional controls to prevent future disturbance of the UASZ cap and the floodplain

and swamp areas in the MLSTZ.

The EPA determined that the measurement of mercury body burdens is the most accurate method

for determining if the remedy is functioning.1 Therefore, the EPA established cleanup goals for

OU3 based on the uptake of mercury into biota tissue, as summarized in Table 5.

Table 5: LP and CCP OU3 Cleanup Goals for Mercury

Cleanup Level Mercury in Biota

Tissuea (ppm) Basis

Target Level 0.3 Edible fish fillet (wet weight) based on National

Recommended Water Quality Criterion for methylmercuryb

Performance Level 0.2 Whole body of forage-size fish (wet weight)c or background

if 0.2 ppm is not attainable

Notes:

a. Values from Table 7 in the 2010 IAROD.

b. Value based on protection of human health for consumption of organisms, which the EPA interpolated

for consumption of upper-trophic-level ecological consumers.

c. Value based on sublethal effects of mercury in fish tissue body burdens on fish growth, reproduction,

development and behavior, and considered protective of populations and communities of fish from

harmful effects of mercury as well as protective of fish-eating wildlife.

ppm = parts per million

1 Because of the nature of mercury in the wetland system and the fact that the potential for long-term methylation of

mercury can affect the amount of methylmercury within sediment over time, the measurement of mercury body

burdens was considered the most accurate method for determining if contaminants in Cold Creek Swamp are at

levels that may adversely affect the ecosystem.

15

4.2 Remedy Implementation

LP Site and CCP Site – OU1

On September 27, 1989, the EPA issued an Administrative Order on Consent for site PRPs to

complete remedial design and remedial actions at OU1. On September 7, 1990, the PRPs

submitted the OU1 Remedial Design Work Plan. The Preliminary Remedial Design Report was

issued in January 1992. In December 1992, the PRP modified the treatment system to speed up

the remediation process by intercepting groundwater near source areas and not pulling

groundwater across the Stauffer Sites. The remedial action finished in 1994. It included

installation of IW-4, IW-5 and CC-14. IW-4 was installed downgradient of the LeMoyne

Landfill. IW-5 was installed near the former pond at the Halby area on the LP Site. CC-14 was

installed at the CCP Site. Intercept wells IW-1, IW-2, IW-3 and IW-4 directed discharge through

the air stripper manifold system into the Groundwater Improvement Pond (GWIP) that was

installed in the 1980s, and then discharged to surface water as a permitted discharge. The PRP

operated this portion of the intercept system until 2002.

Akzo implemented the contingency remedy that included shutting down IW-3 and IW-4 in

March 2005 because these wells were no longer capturing contaminated groundwater due to

changes in groundwater flow direction caused by the 2002 shutdown of extraction wells at the

adjacent CNA property. The CNA extraction well shutdown caused groundwater flow at the

Stauffer Sites to begin flowing east toward the Mobile River instead of south to southeast. In

April 2006, IW-6 and IW-7 were installed near the Vertical Carbon Disulfide Storage Tank #4

and east of the LeMoyne Landfill, respectively, to capture the new flow of contaminated

groundwater. IW-5 discharges to the LP Site’s wastewater treatment plant. It is then discharged

to an ADEM permitted discharge to the Mobile River.

In June 2012, Syngenta shut down the groundwater treatment system for maintenance and repairs

on well CC-14. In July 2012, Syngenta met with the EPA and ADEM, recommending a

groundwater rebound study to assess whether the concentrations of COCs would remain stable

over time without the benefit of the groundwater pump-and-treat system. With the EPA and

ADEM concurrence, Syngenta began the rebound study on September 9, 2012. The EPA

reviewed the results in 2014 and determined that MW-16 exhibited exceedances of the

groundwater performance standard, which may suggest the potential exists for contaminant

rebound. Due to variability of the contaminant concentrations in MW-16, the EPA identified the

need for an additional two years of semi-annual monitoring for five wells (MW-13R, MW-16,

MW-24, MW-25 and MW-26) to determine if rebound is occurring and to evaluate the need for

additional monitoring. The additional rebound sampling was conducted from July 2014 through

October 2015 and is evaluated in Section 6.4.

LP Site – OU2

Although Chemtura Corporation, the PRP for the former Halby site, filed for bankruptcy, Akzo

is working with the EPA to sample groundwater and soil in the Halby area to determine whether

a flushing system, as prescribed in the ROD, is warranted or whether natural rain in the area is

sufficient to accommodate soil flushing. Soil and groundwater sampling results are discussed in

Section 6.4.

16

Under a RCRA permit, Akzo is completing corrective action at several source areas, including

Area of Concern (AOC) A, the former carbon disulfide transfer tanks area, and AOC M, Vertical

Carbon Disulfide Tank #4 area. Between April 2008 and October 2013, Akzo completed oxidant

injections at AOC A to address carbon disulfide contamination in groundwater. Starting in May

2011, Akzo started a soil vapor extraction system at AOC A to expedite mitigation of sourcing to

groundwater however the SVE wells have collapsed and Akzo is currently evaluating other

options to address AOC A contamination under RCRA. AOC M corrective action is addressed

through the operation of IW-6, which started in April 2006. IW-6 was replaced with IW-6R in

July 2014. IW-6 was abandoned and closed in August 2014. IW-6R continues to operate as part

of the OU1 groundwater remedy that also addresses AOC M carbon disulfide contamination.

CCP Site – OU2

The EPA approved a Remedial Action Work Plan for OU2 at the CCP Site in 1998. Most of the

excavated material from the ONP was mixed with fly ash and placed in a constructed biopile.

Phase 1 of the biopile remediation took place between September and December 1999. Syngenta

sent some of the excavated material to a disposal facility in Emelle, Alabama. The remainder

was placed in the biopile for treatment. Syngenta completed Phase 2 of the biopile remediation

by operating the biopile to reduce the mass of contamination through aeration and irrigation from

March 2000 to March 2004. Since March 2004, the biopile has been used to store the treated

soils.

As part of Phase 3 (the final phase), Syngenta has proposed removing the material from the

biopile, placing it back in the former neutralization pond excavation area and capping the

material with a RCRA-equivalent cap (per the OU2 ROD) without further treatment of the

material. In 2015, Syngenta submitted a Sampling Plan and Quality Assurance Project Plan to

the EPA and ADEM to evaluate residual contamination within the biopile in support of preparing

the remedial design for this area. The EPA and ADEM approved the Sampling Plan in March

2016. The PRP completed the collection of seven composite soil samples in April 2016.

Monitoring wells have been installed at the Cold Creek North and South Landfills. An O&M

Plan has been developed for the landfills.

LP and CCP – OU3

The PRP began remedy construction in February 2015 and completed it in November 2015.

Activities included site preparation, construction of the in-situ cap to sequester mercury

contaminated sediments in the UASZ, construction of three permanent water-level control

structures in the UASZ, and installation of fencing and gates. Akzo prepared a draft Institutional

Control Implementation and Assurance Plan for OU3 in August 2015. It is in the process of

being finalized.

4.3 Operation and Maintenance (O&M)

LP Site

OU1 Groundwater Treatment System

Akzo conducts O&M for the groundwater treatment system according to the July 2010 O&M

Plan. O&M activities by Akzo include maintaining and sampling of groundwater intercept wells

17

IW-1, lW-2, IW-6R, IW-7 and the GWIP, as well as the former Halby area intercept well system,

which includes IW-5 and the LeCreek System. Akzo is currently updating the O&M Plan to

accommodate some changes to the system and forms used to document system maintenance and

sampling.

O&M activities include:

Daily maintenance activities on the pumps, wells and pipeline for any indications of

leaks.

Daily visual inspections of the GWIP to ensure that system spray nozzles, aerators, flow

meters and samplers are operating.

Daily samples to check the flow and pH of the system, and confirm the number of

operating aerators and the proper operation of the sampler.

Weekly maintenance checks of the sampler and flow meter and collection of samples at

the LeCreek System at intervals specified by the NPDES permit.

Monthly vibration monitoring of the pumps and collection of monthly discharge samples

from each pump.

Monthly samples from GWIP monitoring wells and reporting of results to the EPA on a

quarterly basis.

Annual inspections of the groundwater treatment system and calibration of the flow

meter/sampler in the GWIP.

Maintenance and repair activities as necessary.

If the GWIP overflows, Akzo shuts off intercept wells IW-I, IW-2, lW-6R and IW-7 temporarily

while a portable pump is used to pump from an outlet sump to flume until overflow ceases. Once

the cause of the overflow is determined and corrected, the PRP restarts the groundwater

treatment system. Some intercept wells in the systems have temporarily been taken offline to

complete maintenance and occasionally repair pumps and aerators. However, the groundwater

treatment system has been operating continuously to treat remaining groundwater contamination

at the LP Site.

OU2 Source Areas

An O&M Plan is currently being finalized by Akzo to document O&M activities that have been

routinely conducted at OU2 since the last FYR. However, the plan had never been formally

approved. O&M activities at OU2 include routine groundwater level measurements, sampling

and analysis of groundwater for carbon tetrachloride, carbon disulfide, cyanide, thiocyanate and

other water quality parameters, and routine inspection and maintenance of the integrity and

effectiveness of the final covers at the source areas, including making repairs to the vegetative

layer and cap as necessary to correct the effects of subsidence, erosion or other damage.

Stormwater runoff control structures, fencing and access road are also maintained.

CCP Site

OU1 Groundwater Treatment System

Consistent with the 1994 O&M Plan, Syngenta began O&M activities in June 1995 for OU1.

Activities included monitoring the carbon adsorption beds for breakthrough and replacing the

18

carbon once it was depleted, monthly well pump and effluent flow transmitter maintenance, and

weekly maintenance of the effluent pH meter.

Disruptions in the operation of the groundwater treatment system during this FYR period have

included: 1) a 70-hour shutdown of well CC-14 in 2011 due to a power outage from demolition

activities; and 2) shutdown of the groundwater treatment system on June 12, 2012, due to the

need for maintenance and repairs. The groundwater treatment system at the CCP Site has not

been restarted.

OU2 Source Areas

Syngenta conducts O&M activities at the ONP and the North and South Landfills according to

the 1998 O&M plan, Appendix A. Activities include measuring groundwater levels, sampling

groundwater for thiocarbamate analysis and other water quality parameters (e.g., pH,

conductivity and temperature). In addition, Syngenta routinely inspects and maintains the

integrity and effectiveness of the final covers at the source areas, including making repairs to the

vegetative layer and cap as necessary to correct the effects of subsidence, erosion or other

damage. Syngenta maintains stormwater runoff control by maintaining the integrity of surface

grading and the access road are also maintained. Although vents were observed on the landfills,

no monitoring of the vents is conducted according to the 1998 O&M Plan.

Syngenta prepared an O&M Plan for the biopile area in 2001. O&M activities for the early

phases of the remedy include maintaining the aeration system as well as the irrigation and

surfactant addition systems and the leachate and stormwater collection systems. Active

remediation of the biopile finished in March 2004. The only ongoing O&M activity conducted at

this time is cap maintenance until the soil remedy is completed.

CCP and LP OU3

Remedy construction finished in November 2015. The PRP began O&M activities, including

long-term monitoring in 2016. Planned activities will include long-term monitoring of surface

water, soil, sediment, and fish tissue as well as sedimentation and depositional studies. In

addition, O&M activities will include engineered cap performance monitoring, including

measures of cap desiccation, thickness, erosion and sediment accumulation. In addition, water

pool elevations will be monitored along with the integrity of the water control structures.

Sitewide O&M Costs

Estimated total annual O&M costs from the feasibility study for the LP Site for the OU1 remedy

were $235,000. Total estimated O&M costs for CCP were not provided. Table 6 below includes

annual O&M costs for both Sites for the past five years. O&M costs for the CCP treatment

system have decreased since June 2012 due to the groundwater treatment system being shut

down for the ongoing rebound study. However, this reduction in O&M costs was offset by

additional well sampling and analyses in subsequent years for the rebound study, which is also

included in the costs. OU3 O&M only recently was initiated. Thus, costs will be presented in the

next FYR.

19

Table 6: Annual O&M Costs

Date Range Total Cost (rounded to the nearest $1,000)

From To

Cold Creek Plant (OU1 and OU2)

2010 2011 $108,000

2011 2012 $114,000

2012 2013 $164,300

2013 2014 $99,400

2014 2015 $93,000

LeMoyne Plant (OU1 and OU2)

2010 2011 $72,900

2011 2012 $81,000

2012 2013 $93,100

2013 2014 $48,400

2014 2015 $83,300

5.0 Progress Since the Last Five-Year Review

The protectiveness statement from the 2011 FYR for the Sites stated:

“The Stauffer Sites' remedy for OU1 currently protects human health and the environment in the

short term because the groundwater treatment systems at the CCP and LP Sites continue to

operate and treat contaminated groundwater. Contamination is not migrating off-site and

contaminated groundwater is not in use. Restrictions are in place to prevent the construction of

wells and the use of contaminated groundwater at the Sites. However, the Sites should be

assessed to determine what steps may be needed in order to add institutional controls to restrict

groundwater use to site decision documents to ensure long-term protectiveness.

Although the remedy for CCP Site OU2 has not been completed, the CCP Site OU2 remedy is

expected to be protective of human health and the environment upon completion, and in the

interim, the contaminated material being addressed at CCP Site OU2 is contained at the CCP

Site and no exposure pathways currently exist. Action should be taken to move forward with the

completion of the final phases of the remedy. Action should be taken to clarify what activities

will be done once the 30-year monitoring period established in the 1995 CCP Site OU2 ROD has

been reached.

Although the remedy for LP Site OU2 has not been completed, the LP OU2 remedy is expected to

be protective of human health and the environment upon completion, and in the interim

contaminated groundwater is being captured and treated by the OU1 groundwater treatment

system and groundwater is monitored annually. No uncontrolled exposure pathways currently

exist. Action should be taken to complete the LP OU2 remedy.

The Stauffer Sites' amended remedy for OU3 has not yet been implemented; therefore, the

protectiveness of this remedy was not evaluated in this FYR.”

The 2011 FYR included five issues and recommendations. This report summarizes each

recommendation and its current status in Table 7.

20

Table 7: Progress on Recommendations from the 2011 FYR

Recommendations Party

Responsible

Milestone

Date Action Taken and Outcome

Date of

Action

LP Site OU2: The soil

flushing system should

be installed, as required

by the 1999 LP Site OU2

ROD.

PRP 12/30/13

Ongoing. Akzo completed a series of

groundwater and soil sampling in the

former Halby area between September and

December of 2015. The data suggest that

leaching of thiocyanate is still occurring

because it was detected above the ROD

leachability-based cleanup goal in three of

the five sample locations primarily at depth

and is present in the groundwater within the

former Halby area above the groundwater

cleanup goal (See Section 6.4).

These results indicate that additional

monitoring continue to ensure the

thiocyanate does not migrate from the

former Halby area or consider a response

action to reduce sourcing from soil to

groundwater.

09/18/2015

10/20/2015

11/03/2015

and

12/8/2015

LP Site OU2:

Institutional controls

need to be implemented

to restrict land use and

construction activities

that would interfere with

construction and O&M

of the selected remedy.

PRP 12/30/13

Ongoing. Once a final remedy has been

implemented at the former Halby area,

appropriate institutional controls will be

implemented.

NA

CCP Site OU2: PRPs

should work with the

EPA to determine

appropriate actions that

will be necessary to

maintain the remedy at

the CCP Site once the

30-year monitoring

period has been reached.

PRP 12/30/12

Ongoing. The EPA and ADEM approved

the sampling plan in March 2016. The PRP

collected samples in April 2016 and is in

the process of designing the remedy.

04/21/16

CCP Site OU2:

Remaining

contamination in the

biopile should be

addressed so that treated

soil can be backfilled

and capped.

Alternatively, other

remedial actions need to

be evaluated to address

the remaining biopile

and determine if

institutional controls will

be necessary.

PRP 01/01/15

Ongoing. The EPA and ADEM approved

the sampling plan in March 2016. The PRP

collected samples in April 2016 and is in

the process of designing the remedy.

04/21/16

21

Recommendations Party

Responsible

Milestone

Date Action Taken and Outcome

Date of

Action

LP and CCP OUl: The

Sites should be assessed

to determine what steps

may be needed in order

to add institutional

controls to restrict

groundwater use.

EPA 12/30/12

The issue in the 2011 FYR stated that site

decision documents do not explicitly call

for groundwater restrictions in the form of

institutional controls. However, institutional

controls in the form of deed restrictions

prohibiting use of drinking water wells at

the Sites were required by the OU1 Consent

Decree and, in accordance with the Consent

Decree, the deed restrictions are in place for

the LP and CCP Sites.

07/1990

6.0 Five-Year Review Process

6.1 Administrative Components

The EPA Region 4 initiated the FYR in October 2015 and scheduled its completion for August

2016. The EPA remedial project manager (RPM) Deborah Cox led the EPA site review team,

which also included the EPA site attorney Jade Rutland, the EPA community involvement

coordinator (CIC) Angela Miller and contractor support provided to the EPA by Skeo Solutions.

In October 2015, the EPA held a scoping call with the review team to discuss the Sites and items

of interest as they related to the protectiveness of the remedy currently in place. The review

schedule established consisted of the following activities:

Community notification.

Document review.

Data collection and review.

Site inspection.

Local interviews.

FYR Report development and review.

6.2 Community Involvement

In October 2015, the EPA published a public notice in the Press-Register newspaper announcing

the commencement of the FYR process for the Sites, providing contact information for RPM

Deborah Cox and CIC Darriel Swatts and inviting community participation. The press notice is

available in Appendix B. No one contacted the EPA as a result of the advertisement.

The EPA will make the final FYR Report available to the public. Upon completion of the FYR,

the EPA will place copies of the document in the designated site repository: the Satsuma Public

Library, 5466 Old Highway 43, Satsuma, Alabama 36572.

22

6.3 Document Review

This FYR included a review of relevant, site-related documents, including the RODs, ESDs,

remedial action reports and recent monitoring data. A complete list of the documents reviewed

can be found in Appendix A.

ARARs Review

CERCLA Section 121(d)(1) requires that Superfund remedial actions attain “a degree of cleanup

of hazardous substances, pollutants, and contaminants released into the environment and of

control of further release at a minimum which assures protection of human health and the

environment.” The remedial action must achieve a level of cleanup that at least attains those

requirements that are legally applicable or relevant and appropriate.

Applicable requirements are those cleanup standards, standards of control and other

substantive requirements, criteria or limitations promulgated under federal environmental

or state environmental or facility siting laws that specifically address a hazardous

substance, remedial action, location or other circumstance found at a CERCLA site.

Relevant and appropriate requirements are those standards that, while not “applicable,”

address problems or situations sufficiently similar to those encountered at the CERCLA

site that their use is well suited to the particular site. Only those state standards more

stringent than federal requirements may be applicable or relevant and appropriate.

To-Be-Considered (TBC) criteria are non-promulgated advisories and guidance that are

not legally binding, but should be considered in determining the necessary remedial

action. For example, TBC criteria may be particularly useful in determining health-based

levels where no ARARs exist or in developing the appropriate method for conducting a

remedial action.

Chemical-specific ARARs are health- or risk-based numerical values or methodologies which,

when applied to site-specific conditions, result in the establishment of numerical values. These

values establish an acceptable amount or concentration of a chemical that may remain in, or be

discharged to, the ambient environment. Examples of chemical-specific ARARs include

maximum contaminant levels (MCLs) under the federal Safe Drinking Water Act and ambient

water quality criteria enumerated under the federal Clean Water Act.

Action-specific ARARs are technology- or activity-based requirements or limits on actions taken

with respect to a particular hazardous substance. These requirements are triggered by a particular

remedial activity such as discharge of contaminated groundwater or in-situ remediation.

Location-specific ARARs are restrictions on hazardous substances or the conduct of the response

activities solely based on their location in a special geographic area. Examples include

restrictions on activities in wetlands, sensitive habitats and historic places.

23

Remedial actions are required to comply with all “applicable” ARARs identified in the ROD. In

performing the FYR for compliance with ARARs, only those ARARs that address the

protectiveness of the remedy are reviewed.

Groundwater

According to the 1989 OU1 ROD for groundwater at the CCP Site and the LP Site, cleanup goals

for carbon tetrachloride and mercury were based on federal MCLs, which were the same as state

MCLs. MCLs listed in the 1989 ROD were compared to current federal MCLs (Table 8). Since

the 1989 RODs, an MCL has been established for cyanide of 200 µg/L, which is equivalent to

the health-based cleanup goal established in the 1989 RODs. Cleanup goals for remaining

groundwater COCs were health based. They are evaluated further in Section 7.2. Both 1989 OU1

RODs included monitoring surface water discharges under the NPDES permits that were already

in place prior to issuing the RODs. Thus, concentration limits specified in the NPDES permits

were not included in the RODs.

Table 8: OU1 ARARs Evaluation for Groundwater COCs for the LP Site and the CCP Site

COC 1989 ARARsa

(µg/L)

2015 Federal

MCLs b (µg/L) ARARs Change

Carbon tetrachloride 5 5 None

Cyanide NAc 200 New value

Mercury 2 2 None

Notes:

a. ARAR based on the federal MCL.

b. Current federal standards based on National Primary and Secondary Drinking Water

MCLs, available at http://water.epa.gov/drink/contaminants/index.cfm#Primary (accessed

12/01/15). Alabama standards for the contaminant were the same as the federal MCL.

Alabama standards are available at

http://adem.alabama.gov/alEnviroReglaws/files/Division7.pdf (accessed 12/01/15).

c. The cleanup goal of 200 µg/L was a health-based value established in the 1989 ROD; it is

now equivalent to the MCL established for cyanide.

µg/L – micrograms per liter.

Soil

ARARs were not established for soil COCs listed in the 1995 OU2 ROD, 1999 ESD and 2012

ESD for the CCP Site and the 1999 OU2 ROD for the LP Site. Cleanup goals for subsurface soil

COCs were based on a leaching model and site-specific risk-based criteria. The validity of these

cleanup goals is further evaluated in Section 7.2.

Institutional Control Review

On December 11, 2015, Skeo staff conducted research at the Mobile County Probate Court

Office, and found property record information pertaining to the Stauffer Sites. This information

is listed in Table 9.

24

Table 9: Deed Documents from the Mobile County Probate Court Office

Date Type of

Document Description Book Page

April 1990 Consent

Decree

Akzo and ICI entered into a Consent Decree agreeing to

complete the work required by the 1989 ROD and Scope of

Work to remediate the Stauffer Sites. The Consent Decree

also prohibited the following activities at the site properties:

Interference with the performance of site work as defined

in the Consent Decree.

Use of property in a manner which would adversely affect

the integrity of the groundwater intercept and treatment

system or the function of any groundwater monitoring

system required.

Placement of any drinking water wells on the property

prior to the completion of remediation.

Placement of drinking water wells into any of the solid

water management units on the property.

3575 1

July 1990 Deed

Notice

In accordance with the Consent Decree for the Stauffer Sites,

a notice prohibiting activities that would interfere with the

groundwater remedy at the LP Site was recorded.

3601 376

The Consent Decree entered into by the PRPs at the CCP Site and the LP Site required that the

PRPs complete the work outlined in the 1989 ROD and Scope of Work to remediate the Sites.

The Consent Decree also prohibited activities at site properties, including any activities that

would adversely impact the groundwater treatment system. Placement of drinking water wells on

the properties or into any of the solid waste management units at the Stauffer Sites is also

restricted in the Consent Decree. The Consent Decree required the implementation of

institutional controls in the form of a list of deed restrictions while the OU1 remedy was being

completed. Those institutional controls have been implemented. Table 10 lists the institutional

controls associated with areas of interest at the Stauffer Sites.

Table 10: Institutional Control (IC) Summary

Media ICs

Needed

ICs Called

for in

Decision

Documents

IC

Objective

Instrument

in Place Notes

LP and CCP OU1

Groundwater Yes No

Restrict property use

that would affect the

integrity of the

groundwater treatment

system or the

installation of drinking

water wells prior to

completion of the

selected remedy.

Consent

Decree

and Deed

Notice

The Consent Decree

applies to both Sites but

does not run with the

land. However, the

Deed Restrictions and

Notice do run with the

land and provide legal

notice to third parties of

the applicable

restrictions.

Deed notice applies

only to the LP Site.

25

Media ICs

Needed

ICs Called

for in

Decision

Documents

IC

Objective

Instrument

in Place Notes

CCP OU2

Soil Yes Yes

2012 ESD

Protect integrity of

landfill caps and cap to

be constructed over the

Old Neutralization

Pond.

None

Soils samples have

been collected in April

2016 to support the

remedial design for the

CCP OU2.

LP OU2

Soil Yes Yes

1999 ROD

Restrict the LP Site

from being used as

residential property and

restrict any construction

at the former Halby

area that would

interfere with the

construction and O&M

of the remedy.

July 1990

Notice

Soil and groundwater

samples are being

collected to support the

design of the final

remedy.

LP and CCP OU3 Cold Creek Swamp

Sediment Yes

Yes

2010

IAROD

Prevent future

disturbance of the

UASZ cap and the

floodplain and swamp

areas in the MLSTZ.

Draft

Prepared

August 2015

The PRP is currently

finalizing a Institutional

Control Implementation

and Assurance Plan

(ICIAP); the ICIAP

requires proprietary,

government and

enforcement controls

for OU3.

Parcels at the CCP Site are owned by Syngenta. Parcels at the LP Site are owned by Akzo. The

remedies for OU2 at both the LP Site and the CCP Site have not been completed for all source

areas. The remedy is in the design phase for the CCP Site ONP; therefore, the institutional

controls as outlined in the 2012 OU2 ESD for the CCP Site have not yet been implemented.

Akzo is currently collecting additional data to support the remedial design for the former Halby

area (LP OU2). A deed notice is in place to restrict groundwater use and prohibit interference of

the soil remedy performance. Akzo is in the process of finalizing an Institutional Control

Implementation and Assurance Plan (ICIAP) for OU3. The ICIAP includes layered institutional

controls, including proprietary, government and enforcement controls, to reduce or eliminate

human exposures to OU3.

Areas where the institutional controls apply are shown in Figure 4. Once the EPA and ADEM

approve the Institutional Control Plan for OU3, the boundaries of OU3 areas requiring restrictive

covenants will be presented in the next FYR. The PRPs currently have proposed the boundary

limits for the restrictive covenant for OU3 to be two feet from the OU3 fenceline.

26

Figure 4: Site Institutional Controls Map

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA's response actions at the Sites, and is not intended for any other purpose

27

6.4 Data Review

The data evaluated for this FYR includes groundwater monitoring data collected between 2010 and 2015

at OU1 and OU2 at the LP Site and the CCP Site. There are numerous monitoring wells at the LP Site

and the CCP Site. However, this data review provides a summary of those wells that have been selected

in O&M plans to monitor remedy effectiveness. Figure 3 and Figure 5 show the locations of the

monitoring wells used to monitor remedy effectives at the CCP Site and the LP Site, respectively.

Although the remedy for OU3 is construction complete, the PRPs have not yet entered into the O&M

phase of the remedy. Therefore, data review was limited to OU1 and OU2 for this FYR. A brief

summary of the data review is provided below, with additional detail presented in Appendix G.

LP Site – OU1 Groundwater Treatment System

Akzo monitors carbon disulfide and carbon tetrachloride in groundwater from two wells (O-52 and

MW-19) (Figure 5) associated with the treatment system that consists of interceptor wells that pump

groundwater to the GWIP. Although there are several carbon disulfide/carbon tetrachloride plumes at

the LP Site, this FYR for OU1 at the LP site focuses on contamination at the GWIP, as this area is being

addressed under OU1 of the CERCLA response action. Carbon disulfide and carbon tetrachloride were

primarily below detection limits for all samples collected from O-52. A similar pattern was observed in

MW-19 until November 2011 when carbon tetrachloride started being detected at 3.37 µg/L and

concentrations steadily increased from below the MCL of 5 µg/L to above the MCL in January 2012

(6.01 µg/L). Since January 2012, the concentrations increased to a high of 29.5 µg/L in July 2015, with

a gradual decline to 24.1 µg/L in December 2015. The cause of this increase over the last five years

should be investigated to determine if additional response action is warranted at the GWIP area.

LP Site – RCRA Sources Contributing to Groundwater Contamination

The highest carbon tetrachloride concentrations and largest carbon tetrachloride groundwater plume at

the LP Site occurs in the vicinity of two RCRA areas, AOC A (near MW-30) and AOC M (near O-29);

contamination extends from the shallow zone to the deep zone (Figures G-1 and G-2). The highest

carbon tetrachloride concentrations at AOC A (616,000 µg/L in MW-30 in February 2015) and AOC M

(200,000 µg/L in O-29 in June 2010) were detected in the shallow zone. Much lower levels are present

in the deep wells (Figure G-3 and G-4). Although these two AOCs are not part of the CERCLA remedy,

there are ongoing RCRA corrective actions at these two AOCs to complement the CERCLA OU1

remedy for the LP Site.

A single plume of carbon disulfide is also present at the LP Site; it underlies AOC A and AOC M

(Figures G-5 through G-8). The highest carbon disulfide concentration at AOC A was detected in

MW-30 (shallow zone) at 460,000 µg/L (March 2010). The highest carbon disulfide concentration at

AOC M was 609,000 µg/L in O-36 (deep zone) (August 2014). The concentrations over time appear to

be variable, with no apparent trends observed within the two AOCs.

CCP Site – OU1 Groundwater Treatment System

Monthly sampling data from the groundwater treatment system at the CCP Site from January 2011

through June 2012 were reviewed for the thiocarbamate COCs. The highest molinate concentrations

were observed in the samples collected from the inlet of the lead carbon tower. However, the treatment

groundwater concentrations were below detection in all of the outlet samples. Syngenta shut down the

treatment system in June 2012 for repairs on interceptor well CC-14 and the system has not operated

since then. Due to continued detections of four thiocarbamates above cleanup goals in OU2 Source

Areas, as per EPA’s recommendation in 2014, Syngenta completed an additional 2 years of monitoring

as part of the rebound study using wells in the vicinity of CC-14 to determine if rebound is occurring

28

Figure 5: Summary of Wells Monitored for Remedy Performance at the LeMoyne Plant

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA's response actions at the

Sites, and is not intended for any other purpose.

29

and whether additional actions are warranted to address residual groundwater contamination. The results

of the rebound study are discussed further in OU2-CCP.

LP Site – OU2 Source Areas

Akzo monitors carbon disulfide, carbon tetrachloride, and thiocarbamates in groundwater at the Old

Chlorine Wastewater Treatment Pond, the LeMoyne Landfill and the Old Brine Mud Pond (Table F-2).

Carbon disulfide has remained below detection at all three source areas. Carbon tetrachloride was below

detection or detected below the cleanup goal of 5 µg/L. Akzo routinely monitors a fourth source area,

the former Halby Pond area, for cyanide and thiocyanate. Except for one instance in IW-5 (shallow

zone) in December 2013 (708 µg/L), the concentration of cyanide during the review period was detected

below the groundwater cleanup goal of 200 µg/L. However, the concentrations of thiocyanate

consistently exceeded the cleanup goal of 200 µg/L in IW-5, with concentrations ranging from 530 µg/L

to 3,700 µg/L. Concentrations started to decline in 2015 but still remain above the cleanup goal (Figure

6).

Figure 6: Thiocyanate Concentration Trend in IW-5 in the former LP OU2 Halby Pond

Akzo also collected five soil samples at multiple depths and groundwater from four wells (Figure G-9)

at the former Halby Pond area in September, October, November and December 2015. This data was

collected to address the 2011 FYR recommendation to evaluate whether soil flushing is warranted at this

area or if natural conditions are sufficient to flush contaminants from soil. The 2015 data indicate that

thiocyanate was detected in shallow and deep groundwater zones, MW-9 and MW-8, respectively,

above the cleanup goal of 200 µg/L (Table F-3). Soils at depth (15 feet to 40 feet) contained thiocyanate

well above the leachability-based cleanup goal of 0.47 milligrams per kilogram (mg/kg) in an area

located north of MW-8 and northeast of MW-9 (Table F-4, Figure G-9). These results (Appendix F)

suggest that thiocyanate in soil is impacting underlying groundwater in the former Halby Pond area and

additional characterization may be warranted to determine if additional source remediation is necessary.

CCP Site – OU2 Source Areas

Syngenta conducts groundwater monitoring of the shallow and deep groundwater zones to evaluate

thiocarbamate concentrations at the OU2 source areas at the CCP Site – the North Landfill, South

Landfill and former ONP.

0

500

1000

1500

2000

2500

3000

3500

4000

1/2

6/2

01

0

4/1

3/2

01

0

7/1

6/2

01

0

10

/7/2

01

0

1/2

0/2

01

1

4/2

5/2

01

1

7/2

8/2

01

1

10

/3/2

01

1

1/2

7/2

01

2

4/2

0/2

01

2

7/1

6/2

01

2

10

/7/2

01

2

1/1

4/2

01

3

4/1

/20

13

7/8

/20

13

11

/21

/20

13

03

/13

/20

14

9/1

5/2

01

4

01

/22

/20

15

05

/22

/20

15

Thio

cyan

ate

(µg/

L)

Sample Date

Concentration Cleanup Goal

30

Based on the data review, groundwater cleanup goal exceedances for thiocarbamates appears limited to

the shallow zone. Pebulate, vernolate, cycloate and molinate were detected above the ROD cleanup

goals in three OU2 CCP monitoring wells located downgradient from the source areas (Table 11). The

contaminant trends show that concentrations of thiocarbamates have fluctuated above the ROD cleanup

goals generally in the summer with decreases below cleanup goals in the fall. The trends are depicted for

molinate for all source areas in Figure F-3, and the remaining thiocarbamates for the ONP, North

Landfill and South Landfill in Figures F-4, F-5 and F-6, respectively.

Due to the observed fluctuations of contamination above cleanup goals since the groundwater treatment

system was shut down in 2012, the EPA requested a rebound study in 2014 for four shallow wells,

MW-13R, MW-16, MW-25 and MW-26, and one deep well, MW-24. The study included additional

monitoring in July 2014, November 2014, May 2015 and October 2015. The groundwater monitoring

results at the CCP OU2 indicated that thiocarbamates in general show a generalized decline in the

shallow zone. However, due to continued fluctuations of several thiocarbamates above cleanup goals in

May 2015 and October 2015, Syngenta should continue to monitor groundwater contamination to ensure

that wells MW-13R, MW-16, and MW-26 continue to show a consistent decline in contaminant

concentrations and that all thiocarbamates stabilize below cleanup goals.

Table 11: CCP OU2 Summary of Thiocarbamate Exceedances

COC

Cleanup

Goal

(µg/L)

Old Neutralization Pond

(MW-16)

North Landfill

(MW-13R)

South Landfill

(MW-26)

FOD above

Cleanup

Goal

Range of

Detections a

(µg/L)

FOD

above

Cleanup

Goal

Range of

Detections a

(µg/L)

FOD

above

Cleanup

Goal

Range of

Detections a

(µg/L)

Cycloate 7 8/14 1.1 - 140 1/14 1.4 - 10 3/14 1.6 - 83

Molinate 14 5/14 1.5 - 140 8/14 2.4 - 77 7/14 1.2 - 270

Pebulate 7 4/14 2.1 - 27 -- -- 1/14 1 – 22

Vernolate 7 6/14 1.4 - 160 4/14 1 - 19 3/14 3.4 – 96

Notes:

a. Range of detections is only provided for those COCs that exhibited at least one detection above the goal.

FOD = frequency of detection

µg/L – micrograms per liter.

The EPA and ADEM approved the Sampling Plan in March 2016 and Syngenta collected seven

composite samples from the biopile in April 2016 in support of designing a final remedy for this area.

The soil borings were advanced to a depth of 4 feet below ground surface at the seven soil borings

SB-01, SB-02, SB-03, SB-04, SB-05, SB-06 and SB-07 (Figure F-7). The analytical results were

compared against the Performance Standards from the 2012 ESD to evaluate the need for a RCRA cap

(Table 12). Three of the five thiocarbamates (vernolate, molinate and cycloate) were reported at

concentrations greater than the Without RCRA Cap Performance Standard at borings SB-03, SB-04 and

SB-05. Molinate was also reported at concentrations greater than the Without RCRA Cap Performance

Standards in SB-02 and SB-07. None of the soil samples were reported at concentrations that exceed the

With RCRA Cap Performance Standards for any of the analytes.

31

Table 12: Evaluation of CCP OU2 2016 Biopile Soil Sample Results

COC

2012 ESD Performance

Standard (mg/kg)

Biopile Soil Results (mg/kg)

Without

RCRA Cap

With

RCRA

Cap

SB-01

SB-02

SB-03

SB-04

SB-05

SB-06

SB-07

Cycloate 36.35 10,648 1.4 17 130 48 55 11 35

EPTC 283.70 83,106 0.58 17 95 40 48 7.4 33

Molinate 16.39 4,803 0.11 29 110 42 80 5.9 44

Pebulate 3,215 941,971 0.087 3.3 20 6.8 7.6 1.6 4.6

Vernolate 31.3 9,170 0.48 13 92 33 35 8 25

Bold – value exceeds Without RCRA Cap Performance standard.

mg/kg – milligrams per kilogram.

6.5 Sites Inspection

The site inspection took place on December 10, 2015. Participants included the EPA RPM Deborah

Cox, the EPA site attorney Jade Rutland, and the EPA contractors Johnny Zimmerman-Ward and Claire

Marcussen (Skeo Solutions). Additional participants included Austin Pierce (ADEM), Terry Bassett

(Akzo), Ken Rike (Syngenta), and personnel from Akzo and Syngenta contractors. The sites inspection

began at Akzo’s Company office, where participants watched a health and safety film and met to discuss

ongoing O&M activities at both Sites prior to conducting the site inspections. The site inspections

checklist and photographs are provided in Appendices D and E, respectively.

The tour began at the inactive CCP Site at the biopile (OU2) area located in the CCP Site’s southeast

corner. The biopile contains excavated material from the ONP mixed with fly ash. It is currently covered

with a geosynthetic material to temporarily contain the waste until the soil is moved back to the ONP.

Participants then observed the groundwater extraction system (OU1), including all associated piping and

recovery well CC-14. The system was shut down in June 2012 due to maintenance issues. Currently,

groundwater data are being collected to determine if the system is no longer warranted. The participants

then viewed the South and North Landfills – observed to be secured within a locked fence – as well as

well-vegetated covers and landfill vents. Participants then visited the former ONP, a deep and heavily

vegetated depression adjacent to a former wastewater secondary concrete containment basin. The

inspection of the CCP Site ended with observations of the OU3 construction staging area. All

monitoring wells appeared to be in good working condition and were secured with locks.

The tour of the LP Site began at the northern end of the OU3 in-situ cap, designated as location 25+00,

to the southern end, identified as monitoring location 00+00. The inspection proceeded along the entire

length of the OU3 cap and included observations of Ponds C, B and A as well as associated water

control structures. Pond C contained water. Ponds B and A were primarily dry with a few wet areas.

South of the OU3 remedy, pooling of water was observed south of the water control features adjacent to

the access road to the eastern portions of the LP Site. Participants then visited the OU1 GWIP area at the

LP Site and associated aeration equipment and discharge points from IW 1, 2, 3, 4, 6 and 7. Participants

visited the OU2 areas of the LP Site, including the Lemoyne Landfill, the former chlorine plant

wastewater treatment pond and former old brine mud pond. The three features were surrounded by

secured fencing and were well vegetated. Participants viewed IW 1, 2, 3, 6 and 6R. All wells appeared

to be in good working condition and monitor wells were secured with locks.

32

Skeo Solutions staff visited the designated site repository, the Satsuma Public Library, located at 5466

Old Highway 43 in Satsuma, Alabama, as part of the site inspection. Documents were available for both

Sites in compact disc format.

6.6 Interviews

The FYR process included interviews with parties affected by the Sites, including the current

landowners and regulatory agencies involved in site activities or aware of the Sites. The purpose was to

document the perceived status of the Sites and any perceived problems or successes with the phases of

the remedy implemented to date. Some of the interviews took place during the sites inspection on

December 10, 2015 while some occurred by email. The interviews are summarized below. Appendix C

provides the complete interviews.

Deborah Cox, the EPA RPM, stated that the LP Site is focused on cleanup, and maintenance activities

are progressing toward remedial goals. LCDR Cox is pleased with the current performance of the

remedies at the LP Site. At the CCP Site, the project is refocusing on cleanup and maintenance. LCDR

Cox indicated that the current performance of the OU1 remedy at CCP is under review while the remedy

for OU2 is progressing with the biopile relocation expected to occur next fiscal year. LCDR Cox stated

she was not aware of any complaints by the surrounding community regarding site cleanup and that the

EPA maintains ties with the community and has kept them informed through public meetings on remedy

progress.

Austin Pierce, ADEM Project Manager, indicated that the remedy implementation for all three OUs is

addressing environmental concerns at the Sites. He stated that the recent OU3 cap construction was

successfully completed. Mr. Pierce was not aware of any complaints or inquiries from residents in the

past five years and is comfortable with the institutional controls in place at the Sites.

Philip Hicks of Hull, Inc., the O&M contractor for OU3 at the LP/CCP Site, indicated that remedial

construction was implemented in accordance with the remedial action work plan and he expects that the

remedy should perform as planned to meet site RAOs over time. Mr. Hicks stated that baseline data has

been collected. Once long-term monitoring begins, the effectiveness of the remedy can be evaluated.

Terry Bassett with Akzo, the PRP for the LP Site, stated that the remedy at OU3 has recently been

constructed and that she was not aware of any effects on the local community other than a slight increase

in truck traffic for delivery of materials. She is not aware of any community complaints raised during

OU3 remedy construction. Ms. Bassett indicated that all potential groundwater contaminant sources are

contained on the facility’s property and all OU2 remedies have been completed, except for the former

Halby Pond area, which is currently still being evaluated. Ms. Bassett expects performance evaluations

to begin for OU3 in 2016.

James Rike with Syngenta, the PRP for the CCP Site, stated that the CCP Site is closed and secure and

no activities are occurring other than remediation activities. Mr. Rike is not aware of any effects of the

CCP Site on the surrounding community. Mr. Rike also indicated that the rebound study demonstrates

that groundwater conditions are stable and supports a monitored natural attenuation approach for

impacted groundwater. He also indicated that the biopile area is pending relocation to the excavated area

from which the soils had originated prior to biotreatment.

Brian Kittrell of Sovereign Consulting, Inc. is the project manager contractor for all sampling activities

for OU1 and OU2 at the LP Site. Mr. Kittrell believes the remedies currently in place have been well

33

implemented and the data collected to date confirms that there is decreasing trends in the contaminant

levels across the LP Site. Mr. Kittrell has not encountered any O&M difficulties over the last five years

and has optimized sampling efforts during the annual plume sampling by using low flow sampling

techniques to reduce the amount of purge water requiring disposal and decontamination.

Deepu Dethan of Environmental Resources Management Southwest, Inc. is the O&M contractor for

OU1 and OU2 at the CCP Site. Mr. Dethan believes the remedy is effective and will be able to meet the

cleanup goals set in the 2012 ESD. Mr. Dethan indicated that the recent rebound study supports that the

area of impacted groundwater is stable. He also indicated that there are no O&M personnel at the CCP

Site other than routine inspections to ensure the CCP Site remains secure. Mr. Dethan stated that

recovery well CC-14 has failed, leading to the need for the rebound study, which concluded that further

active groundwater remediation was not warranted.

Resident 1 was interviewed after the site inspections. The resident was aware of the environmental

issues at the Sites and felt the EPA has kept the community well informed. Resident 1 stated that the

Sites are being taken care of, the cleanup occurred quickly and has not had any adverse effects on the

local community.

Resident 2 was interviewed after the site inspections. The resident was aware of the environmental

issues at the Sites. Resident 2 expressed concerns on the integrity of the cover and its adequacy in

preventing contamination from reaching groundwater. Resident 2 also was concerned that sampling

efforts have not adequately addressed contamination and wanted to know if confirmatory samples have

been collected. Resident 2 indicated that the Sites have not had any adverse effects on the local

community and would like more frequent communication from the EPA on site conditions (e.g.,

quarterly).

7.0 Technical Assessment

7.1 Question A: Is the remedy functioning as intended by the decision documents?

LP and CCP OU1

The OU1 groundwater treatment system at the LP Site is treating residual groundwater contamination.

IW-3 and IW-4 were replaced with new intercept wells, IW-6R and IW-7, which have been operating to

capture the groundwater contamination along with intercept wells IW-1 and IW-2. Groundwater is then

treated through the air stripper manifold system into the GWIP and finally discharged to surface water.

Groundwater monitoring data from MW-19 near the GWIP had routinely been below detection for

carbon tetrachloride up through October 2011. However, starting in November 2011, carbon

tetrachloride began to be detected and the concentrations have steadily increased from below the MCL

of 5 µg/L to above the MCL in January 2012 (6.01 µg/L) and higher concentrations in October 2015

(25.9 µg/L). The cause of this increase over the last five years should be investigated to determine if any

additional response action is warranted at the GWIP area.

The groundwater remedy for OU1 at the CCP Site was functioning as intended by the decision

documents up until June 2012 when the system was shut down due to maintenance issues with

extraction well CC-14. At the request of the EPA in 2014, Syngenta completed two additional years of

groundwater monitoring data in October 2015 for four shallow wells (MW-13R, MW-16, MW-25,

MW-26) and one deep well (MW-24) to evaluate contaminant rebound since the treatment system was

shut down in 2012. The additional groundwater monitoring results indicate continued fluctuations of

several thiocarbamates above cleanup goals in May 2015 and October 2015 and support the need for

34

Syngenta to continue monitoring groundwater contamination to ensure that wells MW-13R, MW-16 and

MW-26 continue to show a consistent decline in contaminant concentrations and that all thiocarbamates

stabilize below cleanup goals.

The need for institutional controls was not identified in the OU1 decision documents. However, the

Consent Decree required the implementation of institutional controls in the form of a list of deed

restrictions while the OU1 remedy was being completed, including restricting property use that would

affect the integrity of the groundwater treatment system and the installation of groundwater wells prior

to completion of the selected remedy. Those institutional controls have been implemented for both Sites.

LP Site OU2

Groundwater monitoring results for the three of the four source areas at OU2 at the LP Site (Old

Chlorine Wastewater Treatment Pond, LeMoyne Landfill and Old Brine Mud Pond) demonstrate that

the concentration of carbon disulfide and carbon tetrachloride are below detection or below the cleanup

goals. Groundwater sampling at the former Halby area indicate that cyanide and thiocyanate exceed

groundwater cleanup goals in several locations and soil samples collected in 2015 indicate thiocyanate

exceeds the ROD leachability-based cleanup goal in three of the five sample locations primarily at

depth. These results indicate cyanide and thiocyanate require ongoing monitoring to determine if

additional source remediation may be warranted in this area.

CCP Site OU2

The remedy for OU2 at the CCP Site has not been completed as specified in the decision documents.

Groundwater monitoring is occurring. However, contaminated material excavated from the ONP has not

been treated to cleanup goals protective of groundwater. The contaminated material remains in a biopile

at the CCP Site. The EPA and ADEM approved the Sampling Plan in March 2016 and Syngenta

collected seven composite samples from the biopile in April 2016 in support of designing a final remedy

for this area. Once the final remedy has been implemented, the need for institutional controls will be

determined.

The decision documents for OU2 at the LP Site and the CCP Site identified the need for institutional

controls to protect the integrity of the remedies and place restrictions on land use. The final remedies for

several source areas at OU2 at both Sites have not been implemented. Therefore, institutional controls

have not yet been implemented. Currently, both Sites are secure and access controlled.

CCP and LP OU3

The PRPs have completed remedy construction at OU3 and an ICIAP is currently being finalized. The

PRP began O&M activities, including long-term monitoring in 2016. The next FYR will evaluate the

monitoring results over the next FYR period to determine if the OU3 remedy is functioning as intended.

7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels and remedial

action objectives (RAOs) used at the time of remedy selection still valid?

The exposure assumptions and RAOs have not changed. Further, groundwater ARARs have not changed

for the two COCs that had MCLs (carbon tetrachloride and mercury) in 1989. The cleanup goals for

remaining groundwater COCs were health-based levels. To evaluate whether any changes to toxicity

values since the 1989 OU1 RODs could affect groundwater cleanup goals, the goals were compared to

the EPA’s regional screening levels (RSLs) (Appendix H). As shown in Table H-1, the groundwater

cleanup goal of 200 µg/L for cyanide and thiocyanates exceeds the noncancer hazard quotient (HQ) of

1.0. The cleanup goal of 200 µg/L was a drinking water health advisory established by the EPA based

35

on a noncancer reference dose of 0.0006 mg/kg/day and standard default exposure assumptions of

ingesting 2 liters of water per day for a 70 kilogram adult with a relative source contribution from other

sources of 20 percent. In 1992 the EPA established an MCL for cyanide of 200 µg/L, which is

equivalent to the 1989 OU1 ROD health-based cleanup goal. The EPA has conducted a review of the

cyanide MCL in 2003 and determined that it was not appropriate to change the MCL at that time since

the EPA was still conducting a risk assessment on this contaminant. In 2010 the EPA has established an

inhalation toxicity value for cyanide by adopting the value from hydrogen cyanide of 0.0008 mg/m3.

Based on the oral reference dose of 0.0006 mg/kg/day and the inhalation toxicity value of 0.0008 mg/m3

the EPA has established a 2016 tap water RSL (1.5 µg/L) that is much more stringent than the MCL of

200 µg/L. Due to the large discrepancy in the RSL and the cleanup goal, it is recommended that the EPA

reassess whether the groundwater and leachability-based cleanup goals for cyanide require revision.

Since the 1989 ROD, toxicity values have changed for thiocyanates. In 1989, the toxicity was assumed

to be equivalent to that of cyanide so the cleanup goal of 200 µg/L was adopted as the cleanup goal for

thiocyanates. The 1999 OU2 LP ROD developed a groundwater target level of 3,500 µg/L based on

provisional toxicity value (oral reference dose) of 0.1 mg/kg/day for use in developing leachability

based soil cleanup goals. However, in 2006 the EPA developed another provisional peer reviewed oral

toxicity value (oral reference dose) for thiocyanates of 0.0002 mg/kg/day; which the EPA uses to

establish a 2016 tap water RSL of 4 µg/L. The tap water RSL is much more stringent than the 1989

ROD cleanup goal of 200 µg/L or the provisional groundwater target level of 3,500 µg/L. Based on the

availability of current oral toxicity values for thiocyanates the EPA should reassess whether the

groundwater and leachability-based cleanup goals for these two compounds require revision.

According to the 2012 OU2 ESD for the CCP Site, cleanup goals for subsurface soil COCs ethyl

dipropylthiocarbamate (EPTC), cycloate, molinate, pebulate and vernolate were revised to account for

treatability data from the biopile operation. The OU2 leachability-based soil cleanup goals at the CCP

Site were evaluated to determine if they are protective based on direct exposure. The screening-level risk

evaluation indicates that the cleanup goals are protective for an industrial exposure because each value is

equivalent to a noncancer HQ well below 1.0 (Table H-2).

The soil cleanup goal of 8.5 mg/kg for thiocyanate is protective for residential and industrial exposures

because the EPA’s residential and industrial RSLs for soil are 16 mg/kg and 230 mg/kg, respectively.

The cyanide leachability-based cleanup goal of 0.47 mg/kg (based on the most current MCL) is also

protective of residential and industrial exposures because the EPA’s residential and industrial RSLs for

soil are 2.7 mg/kg and 12 mg/kg, respectively.

7.3 Question C: Has any other information come to light that could call into question the

protectiveness of the remedy?

No other information has become available that could call into question the remedy’s protectiveness.

7.4 Technical Assessment Summary

The groundwater remedy for OU1 at the CCP Site was functioning as intended by the decision

documents until June 2012 when the system was shut down due to maintenance issues with extraction

well CC-14. The EPA is requiring two additional years of groundwater monitoring data to determine if

the OU1 treatment system needs to be turned back on or whether additional response action is warranted

at the CCP Site. The groundwater treatment system at OU1 on the LP Site continues to treat

contaminated groundwater. However, MW-19 at the GWIP detected carbon tetrachloride above the

36

cleanup goal starting in November 2011 and the concentration is steadily increasing. The cause of this

increase over the last five years should be evaluated to determine the cause of this increase in the

vicinity of the GWIP. In addition, based on the availability of current oral toxicity values for cyanide

and thiocyanates the EPA should reassess whether the groundwater and leachability-based cleanup goals

for these two compounds require revision.

The remedy for the OU2 source areas at the LP Site and the CCP Site has not been completed.

Groundwater monitoring is occurring; contaminated material excavated from the ONP at the CCP Site

has been placed in a biopile. The EPA and ADEM approved the Sampling Plan in March 2016 and

Syngenta collected seven composite samples from the biopile in April 2016 in support of designing a

final remedy for this area. Once the final remedy has been implemented, the need for institutional

controls will be determined. Groundwater sampling at the former Halby area, part of OU2 at the LP Site,

indicates that cyanide and thiocyanates exceed groundwater cleanup goals in several locations and soil

samples collected in 2015 indicate thiocyanates exceeds the ROD leachability-based cleanup goal,

primarily at depth. The EPA and ADEM will evaluate this data to determine if additional response

action is warranted at this area. In the interim, the OU2 source areas at the LP Site and the CCP Site are

secure and access controlled; the need for additional institutional controls will be determined once final

remedies are identified for these areas.

The PRPs have completed remedy construction at OU3 and an ICIAP is currently being finalized. The

PRP began O&M activities, including long-term monitoring in 2016. The next FYR will evaluate the

monitoring results over the next FYR period to determine if the OU3 remedy is functioning as intended.

The exposure assumptions, RAOs, toxicity and ARARs have not changed and remain valid.

8.0 Issues, Recommendations and Follow-up Actions

Table 13: Issues and Recommendations Identified in the FYR

OU(s): OU1 LP Issue Category: Remedy Performance

Issue: Carbon tetrachloride concentrations are increasing in MW-19 at the GWIP to levels above the groundwater cleanup goal for the LP Site.

Recommendation: Further investigate to determine the cause of the increasing carbon tetrachloride concentrations at the GWIP and address as necessary.

Affect Current Protectiveness

Affect Future Protectiveness

Implementing Party

Oversight Party

Milestone Date

No Yes PRP EPA/State 07/20/2021

OU(s): OU1 and OU2 at LP

Issue Category: Remedy Performance

Issue: Toxicity values for cyanide and thiocyanates have become more stringent since the 1989 OU1 ROD and 1999 OU2 ROD were issued.

Recommendation: Reassess the groundwater and leachability-based soil cleanup goals for cyanide and thiocyanates.

Affect Current Protectiveness

Affect Future Protectiveness

Implementing Party

Oversight Party

Milestone Date

No Yes EPA/State EPA/State 07/20/2021

37

The following additional item though not expected to affect protectiveness, warrants additional follow

up:

Once the OU2 remedies have been finalized at the LP Site and the CCP Site, submit O&M plans

for monitoring remedy effectiveness.

9.0 Protectiveness Statements

Table 14: Protectiveness Statements

Operable Unit: OU1 LP and CCP

Protectiveness Determination: Short-term Protective

Addendum Due Date (if applicable): Click here to enter date.

Protectiveness Statement: The remedy for OU1 currently protects human health and the environment because groundwater monitoring continues at the CCP Site and treatment and monitoring continues at the LP Site. In addition, on-site contamination is not migrating off site. For the remedy to be protective over the long term, the cause of the increased carbon tetrachloride concentrations at the GWIP requires further investigation and response if warranted and cleanup goals for cyanide and thiocyanates need reassessment.

Operable Unit: LP OU2

Protectiveness Determination: Will be Protective

Addendum Due Date (if applicable): Click here to enter date.

Protectiveness Statement: The remedy for LP OU2 is expected to be protective of human health and the environment upon completion. In the interim, remedial activities completed to date have adequately addressed all exposure pathways that could result in unacceptable risk at LP OU2.

Operable Unit: CCP OU2

Protectiveness Determination: Will be Protective

Addendum Due Date (if applicable): Click here to enter date.

Protectiveness Statement: The remedy for CCP OU2 is expected to be protective of human health and the environment upon completion. In the interim, remedial activities completed to date have adequately addressed all exposure pathways that could result in unacceptable risk at CCP OU2.

Operable Unit: OU3 LP and CCP

Protectiveness Determination: Protective

Addendum Due Date (if applicable): Click here to enter date.

Protectiveness Statement: The remedy for OU3 protects human health and the environment because the cap has eliminated exposure to contaminated sediments and performance monitoring will be conducted over the next five years to ensure the remedy continues to be protective.

10.0 Next Review

The next FYR will be due within five years of the signature/approval date of this FYR.

38

A-1

Appendix A: List of Documents Reviewed

Akzo Nobel Chemicals Inc. LeMoyne Plant. Groundwater Intercept and Treatment Systems Operations

and Maintenance Plan. Prepared by Akzo Nobel Chemicals Inc. Revised July 30, 2010.

Akzo Nobel Chemicals Inc. LeMoyne Plant. Groundwater Intercept and Treatment Systems Operations

and Maintenance Data. Prepared by Akzo Nobel Chemicals Inc. Revised July 30, 2010.

Akzo Nobel Chemicals Inc. Draft Institutional Control Implementation and Assurance Plan. Prepared by

Hull and Associates, Inc. August 2015.

Akzo Nobel Chemicals Inc. LeMoyne Plant. OU1 and OU2 Monthly Progress Reports from 2011 to

2015. Prepared by Akzo Nobel Chemicals Inc. January 2010 through January 2016.

Akzo Nobel Chemicals Inc. LeMoyne Plant and Cold Creek Plant OU3 Monthly Progress Report.

January 6, 2016.

CERCLA Information System Site Information accessed from website:

http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0400144. Accessed December 22, 2015.

CERCLA Information System Site Information accessed from website:

http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0400306. Accessed December 22, 2015.

EPA Record of Decision: Stauffer Chemical Co. (Cold Creek Plant) EPA ID: ALD095688875 OU1

Prepared by U.S. EPA Region 4. September 27, 1989.

EPA Record of Decision: Stauffer Chemical Co. (Cold Creek Plant) EPA ID: ALD095688875 OU2.

Prepared by US. EPA Region 4. August 16, 1995.

EPA Explanation of Significant Differences: Stauffer Chemical Co. (Cold Creek Plant) EPA ID:

ALD095688875 OU2. Prepared by US. EPA Region 4. June 28, 1999.

EPA Record of Decision: Stauffer Chemical Co. (LeMoyne Plant) EPA ID: ALD008l6ll76 OU1.

Prepared by US. EPA Region 4. September 27, 1989.

EPA Record of Decision: Stauffer Chemical Co. (LeMoyne Plant) EPA ID: ALD008l6ll76 OU3.

Prepared by US. EPA Region 4. September 17, 1993.

EPA Record of Decision: Stauffer Chemical Co. (LeMoyne Plant) EPA ID: ALD008161176 OU2.

Prepared by U.S. EPA Region 4. March 18, 1999.

EPA Interim Amended Record of Decision: Stauffer Chemical Co. (LeMoyne Plant and Cold Creek

Plant) EPA ID: ALD008161176 and ALD095688875 OU3. Prepared by U.S. EPA Region 4. September

30, 2010.

EPA Explanation of Significant Differences: Stauffer Chemical Co. (Cold Creek Plant) EPA ID:

ALD095688875 OU2. Prepared by US. EPA Region 4. August 29, 2012.

A-2

EPA Initial Five-Year Review for OU-1, Groundwater Operable Unit. Prepared for US. EPA Region 4.

Prepared by U.S. Army Corps of Engineers. June 6, 2000.

EPA Second Five-Year Review Report for Stauffer Chemical Co. (Cold Creek Plant) Site, Stauffer

Chemical Co. (LeMoyne Plant) Site. Prepared by US. Army Corps of Engineers. December 21, 2005.

Syngenta Cold Creek Plant, Stauffer Operable Unit 1 Annual Monitoring Reports 2011 through 2015.

Prepared by Syngenta. July 2011 through January 2015.

Syngenta Cold Creek Plant, Stauffer OU2: Biopile Sampling and Remedial Design Development

Timeline. Prepared by ERM. May 26, 2015.

Syngenta Cold Creek Plant, Stauffer OU2: Summary of Biopile Sampling at the Cold Creek Plant,

Operable Unit. Prepared by ERM. June 6, 2016.

Syngenta Cold Creek Plant, Stauffer Operable Unit 2 Monitoring Report. Prepared by Syngenta. January

14, 2016.

Syngenta Action Plan for Second Five-Year Review Report. Project No. 0014596. Prepared by ERM.

May 9, 2006.

Syngenta Cold Creek Plant, Stauffer Operable Unit 2 O&M Plan for Biopile Treatment System.

December 2001.

United States District Court Consent Decree, United States of America v. Akzo Chemicals, Inc. and ICI

Americas, Inc. Recorded May 25, 1990.

Zeneca Inc. Cold Creek Plant, Stauffer Operable Unit 1 O&M Plan, Groundwater Treatment System.

June 1994.

Zeneca Inc. Cold Creek Plant, Stauffer Operable Unit 2 O&M Plan, Old Neutralization Pond. Prepared

by EA Engineering, Science, and Technology. April 1998.

B-1

Appendix B: Press Notice

U. S. Environmental Protection Agency, Region 4

Announces a Five-Year Review for the Stauffer Chemical Company (Cold Creek Plant)

and the Stauffer Chemical Company (Lemoyne Plant) Superfund Sites,

Bucks and Axis, Mobile County, Alabama

Purpose/Objective: The U.S. Environmental Protection Agency (EPA) is conducting a Five-Year Review of the remedies

for the Stauffer Chemical Company (Cold Creek Plant) Superfund site (CCP Site) in Bucks, Alabama and the Stauffer

Chemical Company (Lemoyne Plant) Superfund site (LP Site) in Axis, Alabama. The purpose of the Five-Year Review is to

ensure that the selected cleanup actions effectively protect human health and the environment.

Site Background: The CCP Site includes approximately 220 acres in Bucks, Alabama and is located adjacent to the LP Site,

which includes 720 acres in Axis, Alabama. Beginning in 1966, Stauffer Chemical Company began manufacturing

agricultural chemicals at the Cold Creek Plant. An unknown amount of sludge and solid wastes containing herbicides and

pesticides were placed in waste disposal areas that were closed with geo-membrane caps and side-wall liners in 1974. A

clay-lined lagoon was used for wastewater neutralization until 1975. The lagoon was closed in 1978 and replaced with a

membrane-lined pond that holds non-process wastewater and storm water from process units at the CCP Site. Stauffer

Chemical Company began manufacturing bulk organic and inorganic chemicals at the Lemoyne Plant in 1953. Between 1965

and 1974, waste from plant operations, including brine muds, refuse, used samples and absorption oil, were placed in an

unlined landfill. The Alabama Water Improvement Commission required the landfill to be closed with an impermeable

membrane cap and side-wall liner in 1975. Wastewaters from the Lemoyne Plant were held in clay-lined ponds at the LP

Site. During the 1970s, the clay-lined ponds were replaced with membrane-lined ponds. Chemical dyes were also

manufactured on a portion of the LP Site from 1965 to 1979. Waste products and effluents from the operations were

discharged to Cold Creek Swamp and held in on-site ponds that were later closed and filled.

In the 1970s, disposal practices at both sites resulted in ground water contamination; contaminants were detected in on-site

and off-site wells. Using results from a hydrogeological investigation performed in 1980 by the site owners/operators, three

interceptor wells and an air stripper were installed at the Lemoyne Plant to address the ground water contamination.

Following an assessment completed by the Alabama Department of Public Health in 1982, EPA listed the CCP Site and the

LP Site on the National Priorities List in September 1984. The primary contamination at the CCP Site is the presence of

thiocarbamate herbicides in soil and carbon tetrachloride, carbon disulfide, thiocarbamates and thiocyanate in ground water.

The primary contamination at the LP Site is the presence of contaminants in pond soil and sludge and carbon tetrachloride,

carbon disulfide, thiocarbamates and thiocyanate in ground water.

Selected Remedy: In 1989, EPA signed the Record of Decision (ROD) for operable unit one (OU1) at both Sites. The ROD

selected the remedy to address ground water contamination at both the CCP Site and the LP Site. The OU1 remedy consisted

of the continued operation of the Site’s ground water interceptor and treatment system; installation of additional extraction

wells; modifications to the existing ground water treatment system; and monitoring of effluent, ground water concentrations

and pumping rates. EPA’s 1993 ROD for OU3 addressed surface water and sediment contamination in portions of Cold

Creek Swamp at both sites. The selected remedy consisted of excavation and on-site burial of contaminated soil and sediment

beneath a multi-layered cap. EPA issued a proposed plan in 2008 to amend the selected remedy for OU3, which included the

installation of an on-site (in-situ) capping technology and an enhanced monitoring program for the swamp. In 1995, EPA’s

ROD for OU2 at the CCP Site addressed potential ground water contamination in source areas. The remedy included

bioremediation of contaminated soil, backfilling, and capping of the Old Neutralization Pond; maintaining the cap for Cold

Creek North Landfill and Cold Creek South Landfill; and continued ground water monitoring. In 1999, EPA issued an

B-2

Explanation of Significant Differences for the CCP Site’s OU2 remedy, expanding the cleanup to include the excavation of

highly contaminated soil from the Old Neutralization Pond. In 1999, EPA’s ROD for OU2 at the LP Site addressed source

contamination in subsurface soil. The remedy consisted of institutional controls; construction of a soil flushing system;

annual soil monitoring soil to ensure contaminant migration into ground water for treatment; and the periodic reporting of

monitoring results to EPA.

Five-Year Review Schedule: The National Contingency Plan requires that remedial actions that result in any hazardous

substances, pollutants or contaminants remaining at the Superfund Sites above levels that allow for unlimited use and

unrestricted exposure be reviewed every five years to ensure the protection of human health and the environment. The fourth

of these Five-Year Reviews for the CCP Site and the LP Site will be completed by September 2016.

EPA invites community participation in the Five-Year Review process: EPA is conducting the Five-Year Reviews to

evaluate the effectiveness of the CCP Site and LP Site remedies and to ensure that the remedies remain protective of human

health and the environment. As part of the Five-Year Review process, EPA staff are available to answer any questions about

the Sites. Community members who have questions about the Sites or the Five-Year Review process, or who would like to

participate in a community interview, are asked to contact:

Deborah Cox, Remedial Project Manager Darriel Swatts, Community Involvement Coordinator

Phone: 404-562-8317 Phone: 404-562-8834

E-mail: cox.deborah@epa.gov E-mail: swatts.darriel@epa.gov

Mailing Address:

EPA Region 4

61 Forsyth St. SW

Atlanta, GA 30303-8960

CCP Site and LP Site information is also available at the local document repository, located at the Satsuma Public Library,

5466 Old Highway 43, Satsuma, Alabama, 36572, and online at

http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0400144 for the CCP Site and

http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0400306 for the LP Site.

C-1

Appendix C: Interview Forms

Stauffer Chemical Co. (Cold Creek)

Superfund Site (CCP Site)

Five-Year Review Interview Form

Site Name: Stauffer Chemical Co. (Cold Creek) EPA ID No.: ALD008161176 &

ALD095688875

Interviewer Name: Affiliation:

Subject Name: Deb Cox Affiliation:

Subject Contact Information:

Time: Date: 2/16/16

Interview Location:

Interview Format (circle one): In Person Phone Mail Other: Email

Interview Category: EPA Remedial Project Manager

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities

(as appropriate)?

The project is refocusing on site cleanup and maintenance activities.

2. What have been the effects of the CCP Site on the surrounding community, if any?

Close ties with the surrounding community are maintained. The community is kept informed on

remedy progress during public meetings. The most recent public meeting was held on December 2,

2014, to discuss the construction for OU3 Cold Creek Swamp and answer any questions.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial

activities since the implementation of the cleanup?

No.

4. What is your assessment of the current performance of the remedy in place at the CCP Site?

The current performance of the remedy will be analyzed during this FYR. The intercept well for OU1

stopped operation in 2012. This FYR will analyze whether or not rebound has occurred. The O&M

manuals will be updated following this FYR. The remedy for OU2 is progressing with the biopile

relocation anticipated in the next fiscal year.

5. Are you comfortable with the status of the institutional controls at the CCP Site? If not, what are the

associated outstanding issues?

Yes. Institutional controls for OU3 are currently being established.

6. Are you aware of any community concerns regarding the CCP Site or the operation and management

of its remedy? If so, please provide details.

No.

7. Do you have any comments, suggestions or recommendations regarding the management or

operation of the remedy for the CCP Site?

The site team is a professional group focused on protecting human health and the environment.

C-2

Stauffer Chemical Co. (LeMoyne)

Superfund Site (LP Site)

Five-Year Review Interview Form

Site Name: Stauffer Chemical Co. (LeMoyne) EPA ID No.: ALD008161176 &

ALD095688875

Interviewer Name: Affiliation:

Subject Name: Deb Cox Affiliation:

Subject Contact Information:

Time: Date: 2/16/16

Interview Location:

Interview Format (circle one): In Person Phone Mail Other: Email

Interview Category: EPA Remedial Project Manager

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities

(as appropriate)?

The project is focused on cleanup and maintenance activities are progressing toward remedial

goals.

2. What have been the effects of the LP Site on the surrounding community, if any?

Close ties with the surrounding community are maintained. The community is kept informed on

remedy progress during public meetings. The most recent public meeting was held on December 2,

2014, to discuss the construction for OU3 Cold Creek Swamp and answer any questions.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial

activities since the implementation of the cleanup?

No.

4. What is your assessment of the current performance of the remedy in place at the LP Site?

The current performance of the remedy is good. Due to the complexity of site issues, the remedy

requires considerable O&M, which the Stauffer LeMoyne management team is providing.

5. Are you comfortable with the status of the institutional controls at the LP Site? If not, what are the

associated outstanding issues?

Yes. Institutional controls for OU3 are currently being established.

6. Are you aware of any community concerns regarding the LP Site or the operation and management

of its remedy? If so, please provide details.

No.

7. Do you have any comments, suggestions or recommendations regarding the management or

operation of the remedy for the LP Site?

The site team is a professional group focused on protecting human health and the environment.

C-3

Stauffer Chemical Co. (LeMoyne and

Cold Creek) Superfund Sites

Five-Year Review Interview Form

Site Name: Stauffer Chemical Co.

(LeMoyne and Cold Creek)

EPA ID No.: ALD008161176 &

ALD095688875

Interviewer Name: Johnny Zimmerman-

Ward Affiliation: Skeo Solutions

Subject Name: Resident 1 Affiliation: Resident

Subject Contact Information:

Time: 4:30 P.M. Date: December 10, 2015

Interview Location: Residence

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Residents

1. Are you aware of the former environmental issues at the Sites and the cleanup activities that have

taken place to date?

Yes. I have worked there over 40 years.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities

(as appropriate)?

They have done a good job. They hit it hot and fast around the first of the year.

3. What have been the effects of the Sites on the surrounding community, if any?

Most people don’t know anything about it.

4. Have there been any problems with unusual or unexpected activities at the Sites, such as emergency

response, vandalism or trespassing?

No.

5. Has EPA kept involved parties and surrounding neighbors informed of activities at the Sites? How

can EPA best provide site-related information in the future?

Yes, through the CAP. If something comes up, they stay in contact with the plant. If I have problems,

I ask questions and get quick answers.

6. Do you own a private well in addition to or instead of accessing city/municipal water supplies? If so,

for what purpose(s) is your private well used?

No.

7. Do you have any comments, suggestions or recommendations regarding any aspects of the project?

No, it is well run.

C-4

Stauffer Chemical Co. (LeMoyne and

Cold Creek) Superfund Sites

Five-Year Review Interview Form

Site Name: Stauffer Chemical Co.

(LeMoyne and Cold Creek)

EPA ID No.: ALD008161176 &

ALD095688875

Interviewer Name: Johnny Zimmerman-

Ward Affiliation: Skeo Solutions

Subject Name: Resident 2 Affiliation: Resident

Subject Contact Information:

Time: 5:00 P.M. Date: December 10, 2015

Interview Location: Residence

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Residents

1. Are you aware of the former environmental issues at the Sites and the cleanup activities that have

taken place to date?

Yes. I have participated in the community meetings since the beginning.

2. What is your overall impression of the project, including cleanup, maintenance and reuse activities

(as appropriate)?

It’s not cleaned up, just has a cover on it. It is like having a rattlesnake in the yard with a hat over it.

It’s okay if the hat doesn’t move or the snake doesn’t get out below it. The mercury is sky high at the

Sites and they placed a cover over it; what if it gets into the groundwater? How will the cap work

over a long time? Are the sampling locations appropriate? Have the wetlands been swamped? We’re

aware it is an industrial complex and that sometimes bad things happened and we know that the

EPA and ADEM do not have enough money to police as much as they should. We have seen other

companies doing things wrong and only getting a slap on the wrist. It is like the fox guarding the hen

house. We can’t be sure of what is happening because the EPA and ADEM don’t have funding to be

doing their own, confirmatory sampling. So many things have happened in last 50 years at the Sites,

way before the EPA existed, such as burying contamination on site and pumping contaminated water

into the river, but a lot has improved over the last 20-30 years. With the community meetings, we

have been able to ask questions and get answers sometimes.

3. What have been the effects of the Sites on the surrounding community, if any?

We won’t know until something happens, and maybe nothing ever will, but what about 50 years from

now? We need to be good stewards.

4. Have there been any problems with unusual or unexpected activities at the Sites, such as emergency

response, vandalism or trespassing?

I haven’t heard of any.

5. Has EPA kept involved parties and surrounding neighbors informed of activities at the Sites? How

can EPA best provide site-related information in the future?

No. It would be great if they would come and speak quarterly at our community meetings to give us

an update. We get updates from facility managers, but we would like an update from the EPA as

well. We would like sampling completed by the EPA or ADEM as we can’t be 100 percent sure the

facilities are accurate. I’m skeptical because I’ve worked in these fields and seen a lot of things.

C-5

6. Do you have any comments, suggestions or recommendations regarding any aspects of the project?

I would like an update from the EPA approximately every quarter at the community meetings, as

well as independent sampling performed at the Sites. I would also like the EPA to require that all

employees working with chemicals get heavy metal blood sampling.

C-6

Stauffer Chemical Co. (LeMoyne and

Cold Creek) Superfund Sites

Five-Year Review Interview Form

Site Name: Stauffer Chemical Co.

(LeMoyne and Cold Creek)

EPA ID No.: ALD008161176 &

ALD095688875

Interviewer Name: Affiliation:

Subject Name: Philip Hicks, P.E. Affiliation: Hull and Assoc., Inc.

Subject Contact Information:

Time: Date: 12/11/15

Interview Location:

Interview Format (circle one): In Person Phone Mail Other: Email

Interview Category: O&M Contractor for OU3

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities

(as appropriate)?

The remedial construction was implemented in accordance with the remedial action work plan. The

completed work should perform as planned and we anticipate improving trends for meeting the

remedial action objectives.

2. What is your assessment of the current performance of the remedy in place at the Sites?

The stormwater flow through the system is being adequately controlled and the overall cap integrity

has been maintained.

3. What are the findings from the monitoring data? What are the key trends in contaminant levels that

are being documented over time at the Sites?

Thus far, only the baseline data has been collected and analyzed. Now that the remedial

construction has been completed, the subsequent monitoring will be completed as scheduled in the

Performance Standards Verification Plan.

4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and

activities. Alternatively, please describe staff responsibilities and the frequency of site inspections

and activities if there is not a continuous on-site O&M presence.

An O&M program has been developed and now that the remedial construction has been completed,

the periodic post-capping O&M will be implemented. Cap performance monitoring will be

conducted quarterly for the first two years, and biannually for the next two years.

5. Have there been any significant changes in site O&M requirements, maintenance schedules or

sampling routines since start-up or in the last five years? If so, do they affect the protectiveness or

effectiveness of the remedy? Please describe changes and impacts.

After completion of the cap performance monitoring over the four-year post-capping period, the

protectiveness and effectiveness will be evaluated and modified accordingly, if needed.

6. Have there been unexpected O&M difficulties or costs at the Sites since startup or in the last five

years? If so, please provide details.

Currently, there have not been any O&M activities implemented.

7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe

changes and any resulting or desired cost savings or improved efficiencies.

Currently, there have not been any O&M activities implemented.

C-7

8. Do you have any comments, suggestions or recommendations regarding O&M activities and

schedules at the Sites?

None currently.

C-8

Stauffer Chemical Co. (LeMoyne and

Cold Creek) Superfund Sites

Five-Year Review Interview Form

Site Name: Stauffer Chemical Co.

(LeMoyne and Cold Creek)

EPA ID No.: ALD008161176 &

ALD095688875

Interviewer Name: Affiliation:

Subject Name: Hull and Associates

Representative

Affiliation:

Subject Contact Information:

Time: Date: 12/11/15

Interview Location:

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Potentially Responsible Parties (PRPs)

1. What is your overall impression of the remedial activities at the Sites?

The remedial construction was implemented in accordance with the remedial action work

plan.

2. What have been the effects of the Sites on the surrounding community, if any?

There were minimal effects to the community during the remedial construction. May have

been a very slight increase of truck traffic for delivery of materials, but the area is already

occupied by heavy industrial truck traffic.

3. What is your assessment of the current performance of the remedy in place at the Sites?

The completed work should perform as planned and we anticipate improving trends for

meeting the remedial action objectives.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial

action from residents since implementation of the cleanup?

We are not aware of any complaints or inquiries.

5. Do you feel well-informed regarding the Sites’ activities and remedial progress? If not, how

might EPA convey site-related information in the future?

We feel well-informed of site activities and we believe the EPA has appropriately

conveyed all site-related information to us, and us to them, in a timely manner.

6. Do you have any comments, suggestions or recommendations regarding the management or

operation of the remedy at the Sites?

At the current time we do not have any additional comments, suggestions, or

recommendations, other than those identified in the post-remedial action implementation

plans (i.e., PSVP and O&M Plan).

C-9

Stauffer Chemical Co. (LeMoyne and

Cold Creek) Superfund Sites

Five-Year Review Interview Form

Site Name: Stauffer Chemical Co.

(LeMoyne and Cold Creek)

EPA ID No.: ALD008161176 &

ALD095688875

Interviewer Name: Claire Marcussen Affiliation: Skeo Solutions

Subject Name: Austin Pierce Affiliation: ADEM

Subject Contact

Information:

334-274-4168; austin.pierce@adem.state.al.us

Interview Format (circle one): In Person Phone Mail Other: Email

Interview Category: State Agency

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities

(as appropriate)?

The project is going well, and the involved parties are conducting cleanup activities in a safe

manner. The project team works really well together.

2. What is your assessment of the current performance of the remedy in place at the Sites?

The remedy is addressing the environmental concerns at the Sites. Specifically, the recent OU3 cap

construction was a success.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial

activities from residents in the past five years?

No.

4. Has your office conducted any site-related activities or communications in the past five years? If so,

please describe the purpose and results of these activities.

I have made site visits for OU1, OU2 LeMoyne, OU2 Cold Creek, and OU3, in which construction

and sampling activities were observed. I have also toured the corrective action part of the facility

under its RCRA Post-Closure Permit. RCRA inspections have been conducted by the Department’s

compliance section.

5. Are you aware of any changes to state laws that might affect the protectiveness of the Sites’ remedy?

No.

6. Are you comfortable with the status of the institutional controls at the Sites? If not, what are the

associated outstanding issues?

Yes.

7. Are you aware of any changes in projected land use(s) at the Sites?

No.

8. Do you have any comments, suggestions or recommendations regarding the management or

operation of the remedy at the Sites?

No.

C-10

Stauffer Chemical Co. (LeMoyne)

Superfund Site (LP Site)

Five-Year Review Interview Form

Site Name: Stauffer Chemical Co.

(LeMoyne)

EPA ID No.: ALD008161176 &

ALD095688875

Interviewer Name: Affiliation:

Subject Name: Brian Kittrell Affiliation: Sovereign Consulting, Inc.

Subject Contact Information: 826 Lakeside Dr. Mobile, AL 36693

Time: Date: 02/16/16

Interview Location:

Interview Format (circle one): In Person Phone Mail Other: Email

Interview Category: O&M

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities

(as appropriate)?

Site personnel have done a great job of implementing remedial efforts at the LP Site. Systems

installed at the LP Site have been well maintained with minimal down time.

2. What is your assessment of the current performance of the remedy in place at the LP Site?

The remedies that are currently in place have been well implemented and management has been

very focused on cleanup goals.

3. What are the findings from the monitoring data? What are the key trends in contaminant levels that

are being documented over time at the LP Site?

The data collected to date confirms that there is decreasing trends in the contaminant levels across

the LP Site, which suggests that the remedial efforts by Akzo as implemented are achieving the

cleanup goals.

4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and

activities. Alternatively, please describe staff responsibilities and the frequency of site inspections

and activities if there is not a continuous on-site O&M presence.

Yes. There is continuous on-site O&M presence. Terry Bassett is responsible for all CERCLA

activities on the LP Site and performs weekly and monthly inspections to confirm all operations are

being completed as implemented. Sylvia Williams is responsible for all RCRA activities and

performs weekly and monthly inspections as well.

5. Have there been any significant changes in site O&M requirements, maintenance schedules or

sampling routines since start-up or in the last five years? If so, do they affect the protectiveness or

effectiveness of the remedy? Please describe changes and impacts.

No, there have been no changes over the last five years.

6. Have there been unexpected O&M difficulties or costs at the LP Site since startup or in the last five

years? If so, please provide details.

No.

7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe

changes and any resulting or desired cost savings or improved efficiencies.

Yes. For the annual plume sampling event there are approximately 100 wells sampled using

conventional sampling methods (three well case volumes purged prior to sampling). Due to the

C-11

amount of purge water that had to be disposed of, Akzo personnel looked at cost savings for this

project. Low-flow sampling method reduced the amount of water that required disposal and

decontamination time, which provided a substantial cost saving to the project.

8. Do you have any comments, suggestions or recommendations regarding O&M activities and

schedules at the LP Site?

No. All O&M activities have been well maintained by plant personnel.

C-12

Stauffer Chemical Co. (LeMoyne and

Cold Creek) Superfund Sites

Five-Year Review Interview Form

Site Name: Stauffer Chemical Co.

(LeMoyne and Cold Creek)

EPA ID No.: ALD008161176 &

ALD095688875

Interviewer Name: Affiliation:

Subject Name: Terry Bassett Affiliation: AkzoNobel LeMoyne Plant

Subject Contact Information: 251.675.1310 ext. 209

Time: Date: 01/25/2016

Interview Location:

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: O&M

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities

(as appropriate)?

All three units (OUs 1, 2 and 3) are in compliance. No applicable reuse activities for any of the

three. All required maintenance is performed as needed, or as scheduled.

2. What is your assessment of the current performance of the remedy in place at the Sites?

OU1: all potential groundwater contaminant sources are contained on property. All OU2 activities

are complete except Halby. OU3 has just been completed; performance evaluations will begin in

2016.

3. What are the findings from the monitoring data? What are the key trends in contaminant levels that

are being documented over time at the Sites?

OU1 and OU2: Monitoring data show that trends are toward cleanup goals. OU3 has just been

completed; performance evaluations will begin in 2016.

4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and

activities. Alternatively, please describe staff responsibilities and the frequency of site inspections

and activities if there is not a continuous on-site O&M presence.

O&M is available on site, via site maintenance or contracted work. All required maintenance is

performed as needed, or as scheduled, depending on which area is responsible for which activity.

OU3 has just been completed; performance evaluations will begin in 2016.

5. Have there been any significant changes in site O&M requirements, maintenance schedules or

sampling routines since start-up or in the last five years? If so, do they affect the protectiveness or

effectiveness of the remedy? Please describe changes and impacts.

No changes for any required sampling or maintenance activities.

6. Have there been unexpected O&M difficulties or costs at the Sites since start-up or in the last five

years? If so, please provide details.

OU1: IW-6 intercept well casing failed in 2014 and had to be replaced with new IW-6R intercept

well. All other activity costs have continued to be approximately the same.

7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe

changes and any resulting or desired cost savings or improved efficiencies.

No required O&M or sampling activities have allowed for any optimization or cost savings.

C-13

8. Do you have any comments, suggestions or recommendations regarding O&M activities and

schedules at the Sites?

Suggest continuing same activities to minimize costs and maximize life of equipment.

C-14

Stauffer Chemical Co. (Cold Creek)

Superfund Site (CCP Site)

Five-Year Review Interview Form

Site Name: Stauffer Chemical Co. (Cold

Creek)

EPA ID No.: ALD008161176 &

ALD095688875

Interviewer Name: Affiliation:

Subject Name: Deepu Dethan Affiliation: ERM

Subject Contact Information:

Time: Date: 03/07/16

Interview Location:

Interview Format (circle one): In Person Phone Mail Other: Email

Interview Category: O&M

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities

(as appropriate)?

The site is secure and continues to be monitored. Results of analyses from the Rebound Study

indicate the area of impacted groundwater is stable.

2. What is your assessment of the current performance of the remedy in place at the CCP Site?

Syngenta believes that the current remedy in place is effective and will be able to meet the cleanup

standards set in the ESD from August 2012.

3. What are the findings from the monitoring data? What are the key trends in contaminant levels that

are being documented over time at the CCP Site?

Syngenta submitted an updated data evaluation report “Addendum to Post Ground Water Extraction

System Shutdown Assessment” dated February 8, 2016, that reviews the data trends for the past two

years since the submittal of the “Post Ground Water Extraction System Shutdown Assessment

Report” in April 2014. The general data trend shows that the reported concentrations for COCs are

decreasing or are non-detect at the monitoring locations, with the exception of a few anomalous

spikes in 2013.

4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and

activities. Alternatively, please describe staff responsibilities and the frequency of site inspections

and activities if there is not a continuous on-site O&M presence.

There are no O&M personnel located at the CCP Site since there are no ongoing activities. The

CCP Site is routinely inspected to ensure that it remains secure.

5. Have there been any significant changes in site O&M requirements, maintenance schedules or

sampling routines since start-up or in the last five years? If so, do they affect the protectiveness or

effectiveness of the remedy? Please describe changes and impacts.

Syngenta has been remediating groundwater at the Cold Creek Facility (the Facility) in Bucks,

Alabama, since 1993. Over this time, an estimated one billion gallons of groundwater have been

removed and the associated mass of COCs in groundwater has declined significantly. These efforts

were undertaken to restore groundwater beneath the Facility to levels that are consistent with RAOs

outlined in the 1993 ROD for groundwater. Review of groundwater concentration data from 2005 to

2012 indicates that concentrations of COCs were generally consistent with the RAOs, suggesting

that the pump-and-treat remedy achieved what was expected and more groundwater remediation is

not necessary to ensure the protection of human health and the environment.

C-15

In July 2012, Syngenta engaged the EPA and ADEM in a discussion on the merits of conducting a

groundwater rebound study to assess whether or not the concentrations of COCs would remain

stable over time without the benefit of the groundwater pump and treat system. With EPA and

ADEM concurrence, Syngenta conducted a rebound study in 2012 to review the site-specific

evidence of the stability of groundwater concentrations after shutting down the recovery well

(CC-14).

Based on the results of this rebound study, the EPA determined that additional semiannual sampling

would be required for two years through the end of 2015 to evaluate the additional data and

determine a path forward. Syngenta completed this study and submitted an updated data evaluation

report “Addendum to Post Ground Water Extraction System Shutdown Assessment” dated February

8, 2016, to the EPA that reviews the data trends for the past two years since the submittal of the

“Post Ground Water Extraction System Shutdown Assessment Report” in April 2014.

6. Have there been unexpected O&M difficulties or costs at the CCP Site since startup or in the last

five years? If so, please provide details.

Yes. The one recovery well on site failed. This led to the implementation of the Rebound Study, which

concluded that further active groundwater remediation was not warranted. There have been no

unexpected costs.

7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe

changes and any resulting or desired cost savings or improved efficiencies.

The recovery well (CC-14) and groundwater treatment system was shut down in 2012 and a rebound

study was conducted. Results were submitted to the EPA.

8. Do you have any comments, suggestions or recommendations regarding O&M activities and

schedules at the CCP Site?

Continue to monitor and report groundwater conditions on a regular basis.

C-16

Stauffer Chemical Co. (Cold Creek)

Superfund Site (CCP Site)

Five-Year Review Interview Form

Site Name: Stauffer Chemical Co.

(LeMoyne and Cold Creek)

EPA ID No.: ALD008161176 &

ALD095688875

Interviewer Name: Affiliation:

Subject Name: James K. Rike Affiliation: Syngenta Crop Protection

Subject Contact

Information:

Time: Date: 02/22/16

Interview

Location:

Interview Format (circle one): In Person Phone Mail Other: Email

Interview Category: Potentially Responsible Parties (PRPs)

1. What is your overall impression of the remedial activities at the CCP Site?

The CCP Site is closed and secure. There are no activities except for remediation activities.

The CCP Site is surrounded by a fence with locked gates.

2. What have been the effects of the CCP Site on the surrounding community, if any?

No effects to my knowledge.

3. What is your assessment of the current performance of the remedy in place at the Site?

A Rebound Study has just been completed. It demonstrates that site groundwater conditions

are stable and supports a monitored natural attenuation approach for impacted ground

water. A project is pending to relocate material back to the excavated hole that it came from.

The material underwent bioremediation several years ago and is presently stable on site

beneath an HCPE cover.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial

action from residents since implementation of the cleanup?

No.

5. Do you feel well-informed regarding activities and remedial progress at the CCP Site? If not,

how might the EPA convey site-related information in the future?

Yes.

6. Do you have any comments, suggestions or recommendations regarding the management or

operation of the remedy for the CCP Site?

Site studies support a more sustainable approach to the groundwater remediation, which

would include monitored natural attenuation.

D-1

Appendix D: Site Inspection Checklist

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Stauffer Chemical Co. (Cold Creek

Plant) and Stauffer Chemical Co. (LeMoyne Plant) Date of Inspection: 12/10/15

Location and Region: Bucks and Axis, AL; Region 4 EPA ID: ALD095688875 and ALD008161176

Agency, Office or Company Leading the Five-Year

Review: EPA Region 4 Weather/Temperature: 72 degrees F, sunny

Remedy Includes: (Check all that apply)

Landfill cover/containment Monitored natural attenuation

Access controls Groundwater containment

Institutional controls Vertical barrier walls

Groundwater pump and treatment

Surface water collection and treatment

Other:

Attachments: Inspection team roster attached Site map attached

II. INTERVIEWS (check all that apply)

1. O&M Site Manager Terry Bassett, Ph.D.

Name

Akzo Nobel, Manager of Remedial

Action

Title

1/25/2016

Date

Interviewed at site at office by email

Problems, suggestions Report attached:

2. O&M Staff James Rike

Name

Syngenta, Remediation Manager

Title

2/22/2016

Date

Interviewed at site at office by email

Problems/suggestions Report attached:

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). Fill in all that apply.

Agency EPA

Contact LCDR. Deborah Cox, P.E.

Name

RPM

Title

02/16/2016

Date

404-562-8317

Phone No.

Problems/suggestions Report attached:

Agency ADEM

Contact Austin Pierce

Name

Project

Manager

Title

01/27/2016

Date

334-274-4168

Phone No.

Problems/suggestions Report attached:

Agency

Contact

Name

Title

Date

Phone No.

Problems/suggestions Report attached:

4. Other Interviews (optional) Report attached:

Philip Hicks – Hull and Associate, Inc.

D-2

Hull and Associates Representative

Terry Bassett – AkzoNobel

Brian Kittrell – Sovereign Consulting, Inc.

Deepu Dethan – ERM

James K. Rike – Syngenta Crop Protection

Nearby residents

III. ON-SITE DOCUMENTS AND 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: Available for Akzo Nobel and Syngenta

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:

3. O&M and OSHA Training Records Readily available Up to date N/A

Remarks:

4. Permits and Service Agreements

Air discharge permit Readily available Up to date N/A

Effluent discharge Readily available Up to date N/A

Waste disposal, POTW Readily available Up to date N/A

Other permits: Readily available Up to date N/A

Remarks: LP Site still has an active discharge. The groundwater treatment system at the CCP Site is

inoperable.

5. Gas Generation Records Readily available Up to date N/A

Remarks:

6. Settlement Monument Records Readily available Up to date N/A

Remarks:

7. Groundwater Monitoring Records Readily available Up to date N/A

Remarks:

8. Leachate Extraction Records Readily available Up to date N/A

Remarks:

9. Discharge Compliance Records

Air Readily available Up to date N/A

Water (effluent) Readily available Up to date N/A

Remarks:

D-3

10. Daily Access/Security Logs Readily available Up to date N/A

Remarks:

IV. O&M COSTS

1. O&M Organization

State in-house Contractor for state

PRP in-house Contractor for PRP

Federal facility in-house Contractor for Federal facility

2. O&M Cost Records

Readily available Up to date

Funding mechanism/agreement in place Unavailable

Original O&M cost estimate: Breakdown attached

Total annual cost by year for review period if available

From:

Date

To:

Date

Total cost

Breakdown attached

From:

Date

To:

Date

Total cost

Breakdown attached

From:

Date

To:

Date

Total cost

Breakdown attached

From:

Date

To:

Date

Total cost

Breakdown attached

3. Unanticipated or Unusually High O&M Costs during Review Period

Describe costs and reasons: IW-6 had to be replaced in 2014 at the LP Site and the biopile cover had to

be replaced several years ago due to hurricane damage.

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A

A. Fencing

1. Fencing Damaged Location shown on site map Gates secured N/A

Remarks: Fencing surrounds both site properties and gates are secured unless authorized personnel are

accessing site areas.

B. Other Access Restrictions

1. Signs and Other Security Measures Location shown on site map N/A

Remarks: Access signs are posted along fencing. At the active LP Site security guards are present at the

entry gate to prevent unauthorized access.

D-4

C. Institutional Controls (ICs)

1. Implementation and Enforcement

Site conditions imply ICs not properly implemented Yes No N/A

Site conditions imply ICs not being fully enforced Yes No N/A

Type of monitoring (e.g., self-reporting, drive by): self-reporting

Frequency: Daily on-site presence

Responsible party/agency: Syngenta and Akzo Nobel

Contact

Name Title Date Phone no.

Reporting is up to date Yes No N/A

Reports are verified by the lead agency Yes No N/A

Specific requirements in deed or decision documents have been met Yes No N/A

Violations have been reported Yes No N/A

Other problems or suggestions: Report attached (see Section 6.3)

2. Adequacy ICs are adequate ICs are inadequate N/A

Remarks: Proprietary, governmental and enforceable ICs for OU3 have been drafted in the 2015 ICIAP.

However, all OU3 ICs have not yet been implemented; the PRP is in the process of doing so. OU1 ICs

have been established. OU2 ICs have not yet been established; a final remedy has not yet been

implemented. Following remedial design and remedy implementation, appropriate ICs can be

implemented for OU2.

D. General

1. Vandalism/Trespassing Location shown on site map No vandalism evident

Remarks:

2. Land Use Changes On Site N/A

Remarks:

3. Land Use Changes Off Site N/A

Remarks:

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A

1. Roads Damaged Location shown on site map Roads adequate N/A

Remarks:

B. Other Site Conditions

Remarks:

D-5

VII. LANDFILL COVERS Applicable N/A

A. Landfill Surface

1. Settlement (low spots) Location shown on site map Settlement not evident

Arial extent: Depth:

Remarks:

2. Cracks Location shown on site map Cracking not evident

Lengths: Widths: Depths:

Remarks:

3. Erosion Location shown on site map Erosion not evident

Arial extent: Depth:

Remarks:

4. Holes Location shown on site map Holes not evident

Arial extent: Depth:

Remarks:

5. Vegetative Cover Grass Cover properly established

No signs of stress Trees/shrubs (indicate size and locations on a diagram)

Remarks:

6. Alternative Cover (e.g., armored rock, concrete) N/A

Remarks:

7. Bulges Location shown on site map Bulges not evident

Arial extent: Height:

Remarks:

8. Wet Areas/Water Damage Wet areas/water damage not evident

Wet areas Location shown on site map Arial extent:

Ponding Location shown on site map Arial extent:

Seeps Location shown on site map Arial extent:

Soft subgrade Location shown on site map Arial extent:

Remarks:

9. Slope Instability Slides Location shown on site map

No evidence of slope instability

Arial extent:

Remarks:

B. Benches Applicable N/A

(Horizontally constructed mounds of earth placed 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.)

D-6

1. Flows Bypass Bench Location shown on site map N/A or okay

Remarks:

2. Bench Breached Location shown on site map N/A or okay

Remarks:

3. Bench Overtopped Location shown on site map N/A or okay

Remarks:

C. Letdown Channels Applicable N/A

(Channel lined with erosion control mats, 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 (Low spots) Location shown on site map No evidence of settlement

Arial extent: Depth:

Remarks:

2. Material Degradation Location shown on site map No evidence of degradation

Material type: Arial extent:

Remarks:

3. Erosion Location shown on site map No evidence of erosion

Arial extent: Depth:

Remarks:

4. Undercutting Location shown on site map No evidence of undercutting

Arial extent: Depth:

Remarks:

5. Obstructions Type: No obstructions

Location shown on site map Arial extent:

Size:

Remarks:

6. Excessive Vegetative Growth Type:

No evidence of excessive growth

Vegetation in channels does not obstruct flow

Location shown on site map Arial extent:

Remarks:

D. Cover Penetrations Applicable N/A

1. Gas Vents Active Passive

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks: Gas vents are present only at the North and South Landfills at the CCP Site; vents were not

D-7

warranted at the LeMoyne Landfill.

2. Gas Monitoring Probes

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

3. Monitoring Wells (within surface area of landfill)

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

4. Extraction Wells Leachate

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs maintenance N/A

Remarks:

5. Settlement Monuments Located Routinely surveyed N/A

Remarks:

E. Gas Collection and Treatment Applicable N/A

1. Gas Treatment Facilities

Flaring Thermal destruction Collection for reuse

Good condition Needs maintenance

Remarks:

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 N/A

1. Outlet Pipes Inspected Functioning N/A

Remarks:

2. Outlet Rock Inspected Functioning N/A

Remarks:

G. Detention/Sedimentation Ponds Applicable N/A

1. Siltation Area extent: Depth: N/A

Siltation not evident

Remarks:

2. Erosion Area extent: Depth:

Erosion not evident

D-8

Remarks:

3. Outlet Works Functioning N/A

Remarks:

4. Dam Functioning N/A

Remarks:

H. Retaining Walls Applicable N/A

1. Deformations Location shown on site 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

Area extent: Depth:

Remarks:

2. Vegetative Growth Location shown on site map N/A

Vegetation does not impede flow

Area extent: Type:

Remarks:

3. Erosion Location shown on site map Erosion not evident

Area 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

Area extent: Depth:

Remarks:

2. Performance Monitoring Type of monitoring:

Performance not monitored

Frequency: Evidence of breaching

Head differential:

Remarks:

IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable N/A

A. Groundwater Extraction Wells, Pumps and Pipelines Applicable N/A

D-9

1. Pumps, Wellhead Plumbing and Electrical

Good condition All required wells properly operating Needs maintenance N/A

Remarks: Akzo Nobel system is operating; IW-6 was replaced in 2014. Syngenta shut down their system

in 2012 and it has not been restarted. Extraction well CC-14 is inoperable and in disrepair; if system

needs to be restarted, a new extraction well would need to be installed.

2. Extraction 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:

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:

C. Treatment System Applicable N/A

1. Treatment Train (check components that apply)

Metals removal Oil/water separation Bioremediation

Air stripping Carbon adsorbers

Filters:

Additive (e.g., chelation agent, flocculent):

Others:

Good condition Needs maintenance

Sampling ports properly marked and functional

Sampling/maintenance log displayed and up to date

Equipment properly identified

Quantity of groundwater treated annually:

Quantity of surface water treated annually:

Remarks: The treatment train is operational at the LP Site. It has not been in operation at the CCP Site

since 2012.

2. Electrical Enclosures and Panels (properly rated and functional)

N/A Good condition Needs maintenance

D-10

Remarks:

3. Tanks, Vaults, Storage Vessels

N/A Good condition Proper secondary containment Needs maintenance

Remarks: The GWIP at the LP Site was operating appropriately; aerators were functioning and IW

discharge was working properly.

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

E. 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 and 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.

XI. 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 designed to accomplish (e.g., to contain contaminant

plume, minimize infiltration and gas emissions).

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.

O&M activities for OU1 include ongoing monitoring of groundwater at both Sites and routine

maintenance of the treatment system at the LP Site. O&M at OU2 includes groundwater monitoring.

Additional remediation may be warranted at several source areas. OU3 has not yet entered into O&M.

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

D-11

in the future.

The PRP conducted a rebound study to evaluate residual groundwater contamintion at OU2 at the CCP

Site. The results indicate that thiocarbamate concentrations show a generalized decline in the shallow

zone. However, due to continued fluctuations of several thiocarbamates above cleanup goals in May 2015

and October 2015, it is recommended that the PRP continue monitoring groundwater contamination to

ensure that wells MW-13R, MW-16 and MW-26 continue to show a consistent decline in contaminant

concentrations and that all thiocarbamates stabilize below cleanup goals.

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

OU1 at the CCP Site is currently undergoing evaluation to determine if the remedy requires additional

action beyond monitoring.

Sites inspection attendees are listed below.

D-12

E-1

Appendix E: Photographs from Sites Inspection Visit

CCP Site – OU2 Biopile

CCP Site – OU2 South Landfill

E-2

CCP Site – OU1 Recovery Well CC-14 (in the foreground)

CCP Site – OU1 Pump-and-Treat System (not currently operational)

E-3

CCP Site – OU2 LeCreek Pond

CCP Site – MW-15, Located Southeast of LeCreek Pond (locked and secured)

E-4

CCP Site – Former Old Neutralization Pond

CCP Site and LP Site – OU3 Cap and Water Control Structure (looking north)

E-5

Northern End of OU3 (cap location 25+00)

Southern Extent of OU3 Cap (location 0+00)

E-6

No Trespassing Sign at OU3

CCP Site – Locked Fence

E-7

Former Chlorine Wastewater Treatment Pond

Groundwater Improvement Pond (GWIP) with Aerators

E-8

Permitted Discharge Point for GWIP

Recovery Well IW-6R (in background) and Monitoring Well O-37 (in the foreground)

E-9

LP Site – OU2 LeMoyne Landfill

LP Site – OU2 Former Halby Pond Area

E-10

F-1

Appendix F: Detailed Groundwater and Soil Data Evaluation

The data evaluated for this FYR includes groundwater monitoring data collected between 2010 and 2015

at OU1 and OU2 at the LP Site and the CCP Site. Although the remedy for OU3 has reached

construction complete status, the PRPs have not yet entered into the O&M phase of the remedy.

Therefore, data review was limited to OU1 and OU2 for this FYR.

LP Site – OU1

Akzo monitors carbon disulfide and carbon tetrachloride in groundwater associated with the treatment

system that consists of interceptor wells that pump groundwater to the GWIP. Although there are several

carbon disulfide/carbon tetrachloride plumes at the LP Site, this FYR for OU1 at the LP Site focuses on

contamination at the GWIP since that is the area being addressed under OU1 of the CERCLA response

action. The PRP collects monthly samples from two wells downgradient of the GWIP (O-52 and

MW-19) and analyzes the samples for carbon disulfide and carbon tetrachloride. The data reviewed for

this FYR include data from January 2010 through December 2015.

MW-19 (shallow zone) and O-52 (deep zone) at the GWIP were sampled monthly during the past five

years. Carbon disulfide and carbon tetrachloride were primarily below detection limits for all samples

collected from O-52 except for one sample in December 2011, which had a detection of carbon disulfide

of 11.7 µg/L, well below the cleanup goal of 700 µg/L. MW-19 was consistently below or near detection

limits for both carbon disulfide and carbon tetrachloride through October 2011. In November 2011

carbon tetrachloride was detected in MW-19 at 3.37 µg/L. Carbon tetrachloride concentrations have

steadily increased from below the MCL of 5 µg/L to above the MCL (6.01 µg/L) in January 2012. Since

January 2012, the concentrations increased to a high of 29.5 µg/L in July 2015 (Figure F-1), with a

gradual decline to 24.1 µg/L in December 2015. The cause of this increase over the last five years

should be investigated to determine if additional response action is warranted at the GWIP area. The

location of the GWIP carbon tetrachloride plume in the shallow aquifer based on data collected in 2010

versus 2015 is included in Appendix G in Figures G-1 and G-2, respectively.

Figure F-1: Carbon Tetrachloride Concentration Trend in MW-19 near the LP GWIP

0

5

10

15

20

25

30

35

10

/7/2

01

11

1/1

7/2

01

11

2/1

3/2

01

11

/27

/20

12

2/1

7/2

01

23

/14

/20

12

4/2

0/2

01

25

/9/2

01

26

/8/2

01

27

/17

/20

12

8/1

0/2

01

29

/12

/20

12

10

/12

/20

12

11

/6/2

01

21

2/7

/20

12

1/1

8/2

01

32

/13

/20

13

3/1

5/2

01

34

/2/2

01

35

/7/2

01

36

/4/2

01

37

/12

/20

13

8/8

/20

13

9/1

1/2

01

31

0/1

1/2

01

31

1/7

/20

13

12

/13

/20

13

1/3

0/2

01

42

/18

/20

14

03

/12

/20

14

04

/08

/20

14

05

/28

/20

14

06

/13

/20

14

07

/11

/20

14

08

/06

/20

14

09

/19

/20

14

10

/07

/20

14

11

/07

/20

14

12

/05

/20

14

01

/23

/20

15

02

/13

/20

15

03

/13

/20

15

04

/10

/20

15

05

/19

/20

15

06

/03

/20

15

07

/10

/20

15

08

/04

/20

15

09

/16

/20

15

10

/06

/20

15

12

/10

/20

15

Car

bo

n T

etra

chlo

rid

e (µ

g/L)

Sample DateMW-19 MCL=5 µg/L

F-2

RCRA Sources Contributing to Groundwater Contamination

Three additional shallow carbon tetrachloride groundwater plumes are present at the LP Site. The largest

carbon tetrachloride plume with the highest carbon tetrachloride concentrations occurs in the vicinity of

AOC A (characterized by shallow wells O-45, O-47 and MW-30 as well as deep wells O-44 and O-46)

and AOC M (characterized by shallow wells O-29 and O-39 as well as deep wells O-30 and O-36)

where contamination extends from the shallow zone to the deep zone (Figures G-1 and G-2). The

highest carbon tetrachloride concentrations at AOC A were detected in MW-30 (shallow zone) at

616,000 µg/L (February 2015) and at AOC M in O-29 (shallow zone) at 200,000 µg/L (June 2010). The

concentrations in the deep wells (O-44 and O-45) are much lower, with the maximum of 1,390 µg/L

observed in O-45 in November 2015.

The concentrations of carbon tetrachloride are variable over the FYR period, with the overall size of the

shallow plumes at the two AOCs shrinking between 2010 and 2015 (Figures G-1 and G-2). The two

AOCs are not part of the CERCLA remedy; however, the corrective actions conducted at these two

AOCs compliment the CERCLA OU1 remedy for the LP Site. Two smaller carbon tetrachloride plumes

occur at the LP Site with much lower concentrations than observed at AOCs A and M; one plume is

localized around wells O-65 (shallow zone)(56.5 µg/L in April 2015). However, based on the 2010

shallow plume (Figure G-1), it appears this area is likely part of the larger plume associated with AOCs

A and M. The second smaller plume is located downgradient of the LeMoyne Landfill in the vicinity of

shallow well O-23 (23 ug/L in April 2015) but below detection further downgradient in MW-33 before

discharging to the Mobile River.

A single plume of carbon disulfide is also present at the LP Site. It underlies AOC A and AOC M

(Figures G-5 through G-8). The highest carbon disulfide AOC A was detected in MW-30 (shallow zone)

at 460,000 µg/L (March 2010) and the highest carbon disulfide at AOC M was 609,000 µg/L in O-36

(deep zone)(August 2014). The concentrations over time appear to be variable, with no apparent trends

observed within the two AOCs.

Appendix G (Figures G-1 through G-4) show groundwater plumes for carbon tetrachloride in the

shallow versus deep zones in 2010 and 2015, respectively. Carbon disulfide plumes for both the shallow

and deep wells in 2010 and 2015 are presented in Appendix G (Figures G-5 through G-8). The

contaminant plume concentrations are higher in the shallow wells and more widespread (Figures G-1,

G-2, G-5 and G-6) than the plumes depicted using the deeper wells (Figures G-3, G-4, G-7 and G-8).

CCP Site – OU1

Monthly sampling data from the groundwater treatment system at the CCP Site from January 2011

through June 2012 were reviewed for molinate (Table F-1). The highest molinate concentrations were

observed in the samples collected from the inlet of the lead carbon tower of 49 µg/L in April 2011 and

45 µg/L in April 2012, respectively; however, the groundwater was treated to a concentration below

detection for molinate in all of the outlet samples. On June 12, 2012, the treatment system was shut

down due to repairs warranted for the well pump and problems with the interceptor well casing, CC-14.

The interceptor well has not operated since the shutdown. However, due to the detections of four

thiocarbamates above cleanup goals in MW-16, as per the EPA recommendations (2014 Technical

Memorandum), Syngenta completed two years of additional monitoring in the vicinity of CC-14 to

determine if rebound is occurring and whether additional actions are warranted to address residual

groundwater contamination. These results are summarized below.

F-3

Table F-1: Monthly Groundwater Monitoring Data for Molinate at the CCP Site

Date

Lead

Carbon

Tower

Molinate Concentration (µg/L)

Inleta,b Outlet

6-Jan-11 T-2529-A 43 0

8-Feb-11 T-2529-A 34 0

3-Mar-11 T-2529-A 38 0

8-Apr-11 T-2529-A 49 0

5-May-11 T-2529-A 35 0

9-Jun-11 T-2529-A 26 0

5-Jan-12 T-2529-A 39 0

2-Feb-12 T-2529-A 28 0

1-Mar-12 T-2529-A 31 0

5-Apr-12 T-2529-A 45 0

17-May-12 T-2529-B 34 0

7-Jun-12 T-2529-B 37 0

Notes:

a. Groundwater Monitoring Report for the Treatment System,

January 1, 2011 to June 30, 2011. Prepared by Syngenta, July

2011.

b. Groundwater Monitoring Report for the Treatment System,

January 1, 2011 to June 30, 2012. Prepared by Syngenta, July

2012.

LP Site – OU2

Akzo monitors carbon disulfide, carbon tetrachloride and thiocarbamates in groundwater annually at

three source areas, the Old Chlorine Wastewater Treatment Pond (shallow zone monitoring well

MW-3), the LeMoyne Landfill (shallow zone monitoring wells NM-1 and MW-32), and the Old Brine

Mud Pond (shallow zone monitoring well O-58) (Table F-2). At all three areas, the concentration of

carbon disulfide was below detection while carbon tetrachloride was below detection or detected below

the cleanup goal of 5 µg/L. In addition, Akzo monitors the fourth source area, the former Halby Pond

area (shallow monitoring well IW-5), on a bi-monthly basis for cyanide and thiocyanate. Except for one

instance in December 2013, the concentration of cyanide over the review period was below the

groundwater cleanup goal of 200 µg/L. The December 2013 concentration was 708 µg/L. However, the

monthly concentrations prior to and after December 2013 were below detection (detection limit of 10

µg/L) or ranged from 15 µg/L to 87.2 µg/L. The concentrations of thiocyanate consistently exceeded the

cleanup goal of 200 µg/L in IW-5 µg/L, with concentrations ranging from 530 µg/L to 3,700 µg/L.

Concentrations started to decline in 2015 but still remain above the cleanup goal (Figure F-2). The

contaminants in IW-5 are pumped to the LeCreek Wastewater Pond Treatment System.

F-4

Table F-2: Summary of LP OU2 Groundwater Data

Sample Identifier Date Collected Analyte

Sample

Result

(µg/L)

Laboratory

Reporting

Limit

(µg/L)

MW-3 3/24/2010 carbon disulfide 1

MW-3 DUPLICATE 3/24/2010 carbon disulfide 1

MW 3 DUPLICATE 4/26/2011 carbon disulfide 5

MW-3 4/26/2011 carbon disulfide 5

MW-3 3/14/2012 carbon disulfide 5

MW-3 DUP 3/14/2012 carbon disulfide 5

MW-3 3/13/2013 carbon disulfide 5

MW-3 DUP 3/13/2013 carbon disulfide 5

MW-3 04/09/2014 carbon disulfide 5

MW-3 DUPLICATE 04/09/2014 carbon disulfide 5

MW-3 03/11/2015 carbon disulfide 5

MW-3 DUPLICATE 03/11/2015 carbon disulfide 5

MW-3 3/24/2010 carbon tetrachloride 1.75 0.5

MW-3 DUPLICATE 3/24/2010 carbon tetrachloride 1.8 0.5

MW-3 4/26/2011 carbon tetrachloride 1.14 1

MW 3 DUPLICATE 4/26/2011 carbon tetrachloride 1.24 1

MW-3 3/14/2012 carbon tetrachloride 2.5

MW-3 DUP 3/14/2012 carbon tetrachloride 2.5

MW-3 3/13/2013 carbon tetrachloride 2.50

MW-3 DUP 3/13/2013 carbon tetrachloride 2.50

MW-3 04/09/2014 carbon tetrachloride 2.5

MW-3 DUPLICATE 04/09/2014 carbon tetrachloride 2.5

MW-3 03/11/2015 carbon tetrachloride 2.5

MW-3 DUPLICATE 03/11/2015 carbon tetrachloride 2.5

MW-3 3/13/2013 mercury 0.2

MW-3 DUP 3/13/2013 mercury 0.2

MW-32 3/24/2010 carbon disulfide 1

MW-32 4/26/2011 carbon disulfide 5

MW-32 3/13/2013 carbon disulfide 5

MW-32 3/11/2015 carbon disulfide 5

MW-32 3/24/2010 carbon tetrachloride 49.1 0.5

MW-32 4/26/2011 carbon tetrachloride 1.53 1

MW-32 3/13/2013 carbon tetrachloride 2.50

MW-32 3/11/2015 carbon tetrachloride 2.5

NM-1 3/24/2010 carbon disulfide 1

NM-1 4/26/2011 carbon disulfide 5

NM-1 3/14/2012 carbon disulfide 5

NM-1 3/13/2013 carbon disulfide 5

NM-1 04/09/2014 carbon disulfide 5

NM-1 03/11/2015 carbon disulfide 5

NM-1 3/24/2010 carbon tetrachloride 1.68 0.5

F-5

Sample Identifier Date Collected Analyte

Sample

Result

(µg/L)

Laboratory

Reporting

Limit

(µg/L)

NM-1 4/26/2011 carbon tetrachloride 2.18 1

NM-1 3/14/2012 carbon tetrachloride 2.5

NM-1 3/13/2013 carbon tetrachloride 2.50

NM-1 04/09/2014 carbon tetrachloride 2.5

NM-1 03/11/2015 carbon tetrachloride 2.5

O-58 3/24/2010 carbon disulfide 1

O-58 4/26/2011 carbon disulfide 5

O-58 3/14/2012 carbon disulfide 5

O-58 04/09/2014 carbon disulfide 5

O-58 03/11/2015 carbon disulfide 5

O-58 3/24/2010 carbon tetrachloride 0.5

O-58 4/26/2011 carbon tetrachloride 1

O-58 3/14/2012 carbon tetrachloride 2.5

O-58 04/09/2014 carbon tetrachloride 2.5

O-58 03/11/2015 carbon tetrachloride 2.5

O-58 3/13/2013 mercury 0.2

Notes:

Blank – analyte below detection.

Figure F-2: Thiocyanate Concentration Trend in IW-5 in the LP OU2 former Halby Pond

Akzo also collected soil and groundwater from the former Halby Pond area in 2015 to determine the

extent of natural attenuation of thiocyanate and cyanide in each environmental medium. Groundwater

data were collected in September, October, November and December 2015 from wells that monitor the

former Halby Pond (shallow zone monitoring wells MW-8 and MW-9) and downgradient of this area

(monitoring wells O-79 and O-80) (Table F-3). These samples were collected to address the

recommendation from the 2011 FYR to evaluate whether soil flushing is warranted at the former Halby

Pond or if natural conditions are sufficient to flush contaminants from soil. The 2015 data (Table F-3)

indicate that thiocyanate was detected three times, once in MW-8 (460 µg/L in September) and twice in

MW-9 (420 µg/L in November and 2,400 µg/L in December). All thiocyanate detections exceed the

0

500

1000

1500

2000

2500

3000

3500

4000

1/2

6/2

01

0

4/1

3/2

01

0

7/1

6/2

01

0

10

/7/2

01

0

1/2

0/2

01

1

4/2

5/2

01

1

7/2

8/2

01

1

10

/3/2

01

1

1/2

7/2

01

2

4/2

0/2

01

2

7/1

6/2

01

2

10

/7/2

01

2

1/1

4/2

01

3

4/1

/20

13

7/8

/20

13

11

/21

/20

13

03

/13

/20

14

9/1

5/2

01

4

01

/22

/20

15

05

/22

/20

15

Thio

cyan

ate

(µg/

L)

Sample Date

Concentration Cleanup Goal

F-6

cleanup goal of 200 µg/L in these two wells, which are located upgradient of the former Halby Pond.

Although concentrations increased significantly at MW-9 in November and December, thiocyanate was

not detected in downgradient wells O-79 and O-80 in any of the four monitoring events. Cyanide was

detected twice, once in O-79 (10 µg/L in October) and once in MW-9 (13 µg/L in December), at

concentrations below the cleanup goal of 200 µg/L.

Table F-3: Summary of LP OU2 Former Halby Pond Groundwater Monitoring Data

Monitoring Well Sample Date Analyte Result (µg/L)

MW-8 09/18/2015 cyanide <10

MW-8 10/20/2015 cyanide <10

MW-8 11/03/2015 cyanide <10

MW-8 12/08/2015 cyanide <10

MW-8 09/18/2015 thiocyanate 460

MW-8 10/20/2015 thiocyanate <100

MW-8 11/03/2015 thiocyanate <100

MW-8 12/08/2015 thiocyanate <100

MW-9 09/18/2015 cyanide <10

MW-9 10/20/2015 cyanide <10

MW-9 11/03/2015 cyanide <10

MW-9 12/08/2015 cyanide 13

MW-9 09/18/2015 thiocyanate <100

MW-9 10/20/2015 thiocyanate <100

MW-9 11/03/2015 thiocyanate 420

MW-9 12/08/2015 thiocyanate 2,400

O-79 09/18/2015 cyanide <10

O-79 10/20/2015 cyanide 10

O-79 11/03/2015 cyanide <10

O-79 12/08/2015 cyanide <100

O-79 09/18/2015 thiocyanate <100

O-79 10/20/2015 thiocyanate <100

O-79 11/03/2015 thiocyanate <100

O-79 12/08/2015 thiocyanate <100

O-80 09/18/2015 cyanide <10

O-80 10/20/2015 cyanide <10

O-80 11/03/2015 cyanide <10

O-80 12/08/2015 cyanide <10

O-80 09/18/2015 thiocyanate <100

O-80 10/20/2015 thiocyanate <100

O-80 11/03/2015 thiocyanate <100

O-80 12/08/2015 thiocyanate <100

Notes:

a. Data obtained from Attachment 2 in Akzo Monthly Progress Report for November 2015.

Bold = thiocyanate detected above the cleanup goal of 200 µg/L.

Bold Italic = cyanide was detected but below the cleanup goal 200 µg/L.

The groundwater results from the four monitoring events demonstrate that COCs are not leaving the

former Halby Pond above cleanup goals; however, continued monitoring is necessary to ensure the

F-7

increased cyanide and thiocyanate concentrations in MW-9 are not migrating from the former Halby

Pond area. In addition, these data suggest there may be another source of thiocyanate contamination

upgradient of the former Halby Pond in the vicinity of MW-8 and MW-9.

In December 2015, Akzo collected soil samples from the former Halby area at five locations across

several depth intervals and analyzed them for cyanide and thiocyanate (Table F-4, Figure G-9). Cyanide

was below detection in all samples with a detection limit of 1 mg/kg. Although the detection limit

exceeds the OU2 LP ROD leachability-based cleanup goal of 0.47 mg/kg, cyanide concentrations in

groundwater in the former Halby area were well below the groundwater cleanup goal of 200 µg/L,

suggesting leaching from soil is not occurring at levels of concern for cyanide. However, thiocyanate

was detected above the ROD leachability-based cleanup goal of 8.5 mg/kg in three of the five sample

locations primarily at depth (15 feet to 40 feet) and thiocyanate in the groundwater within the former

Halby area also exceeds the cleanup goal of 200 µg/L. These results suggest that a source of thiocyanate

in the vicinity of MW-8 and MW-9 is impacting underlying groundwater adjacent to the former Halby

area. Groundwater requires ongoing monitoring to determine if additional source remediation is

warranted in this area.

Table F-4: Summary of December 2015 LP OU2 former Halby Soil Data

Sample Location Depth Interval (ft) Thiocyanate (mg/kg)

HP-SB-10 5-10 3.1

10-15 3.1

15-20 3.6

20-25 99.2

30-35 <1

HP-SB-12 0-5 2.7

5-10 <1

20-25 <1

HP-SB-14 5-10 <1

10-15 <1

15-20 63.4

20-25 472

25-30 459

30-35 80

35-40 131

HP-SB-15 20-25 474

25-30 414

HTP-3S 20-25 5.3

25-30 <1

Notes:

Bold = value exceeds the OU2 LP ROD soil cleanup goal of 8.5 mg/kg.

F-8

CCP Site – OU2

Syngenta conducts semi-annual groundwater monitoring of the shallow and deep groundwater zones to

evaluate thiocarbamate concentrations at the OU2 source areas at the CCP Site – the North Landfill, the

South Landfill and the former ONP. The data review focused on the shallow zone because this zone is

where exceedances of cleanup goals occurred; the review evaluated data collected from October 2010 to

October 2015. In 2014, the EPA requested that Syngenta conduct two years of additional semi-annual

monitoring for four shallow wells (MW-13R, MW-16, MW-25 and MW-26) and one deep well MW-24

to determine if rebound is occurring to evaluate whether additional response action is warranted in OU1.

During the FYR monitoring period, four of the six thiocarbamates (pebulate, vernolate, cycloate and

molinate) were detected above ROD cleanup goals in three OU2 CCP monitoring wells downgradient

from the three source areas (Table F-5). The OU2 CCP data shows that concentrations of thiocarbamates

have fluctuated above ROD cleanup goals generally in the summer, with decreases below cleanup goals

in the fall. These fluctuations have occurred since the groundwater treatment was shut down in 2012.

The detailed summary by source area is provided below.

Table F-5: Summary of Thiocarbamate Exceedances in CCP OU2

COC

Cleanup

Goal

(µg/L)

Old Neutralization Pond

(MW-16)

North Landfill

(MW-13R)

South Landfill

(MW-26)

FOD above

Cleanup

Goal

Range of

Detections

FOD

above

Cleanup

Goal

Range of

Detections

(µg/L)a

FOD

above

Cleanup

Goal

Range of

Detections

(µg/L)a

Cycloate 7 8/14 1.1 - 140 1/14 1.4 - 10 3/14 1.6 - 83

Molinate 14 5/14 1.5 - 140 8/14 2.4 - 77 7/14 1.2 - 270

Pebulate 7 4/14 2.1 - 27 -- -- 1/14 1 - 22

Vernolate 7 6/14 1.4 - 160 4/14 1 - 19 3/14 3.4 - 96

Notes:

a. Range of detections is only provided for those COCs that exhibited at least one detection above the

goal.

FOD = frequency of detection.

Old Neutralization Pond

Monitoring well MW-16, located downgradient of the ONP, had the most frequent detections above

ROD cleanup goals of the four thiocarbamate COCs during the FYR period. The highest concentrations

for all four thiocarbamates were detected in May 2013, followed by a decrease since that time to

concentrations below detection or below cleanup goals in October 2015. Three of the four

thiocarbamates have the same cleanup goal, with the trends presented in Figure F-3. Molinate is

presented in Figure F-4.

F-9

Figure F-3: Thiocarbamate Concentrations in MW-16 (ONP) at CCP OU2

Figure F-4: Molinate Concentration Trends at CCP OU2

North and South Landfills

In MW-13R, located downgradient of the North Landfill, the concentrations of cycloate, pebulate and

vernolate exceeded the cleanup goal in 2011 and 2014 but declined to concentrations below the cleanup

goals or below detection by October 2015 (Figure F-5). Molinate concentrations show a generalized

increase since October 2010 through May 2015 and then declined to 24 µg/L in October 2015 but

remained above the cleanup goal of 14 µg/L (Figure 4).

The concentration trends in MW-26, downgradient of the South Landfill, showed the highest

concentrations of cycloate, pebulate and vernolate in July 2014 (Figure F-6). The highest molinate

concentrations were observed in April 2011, with a spike in July 2014. However all molinate

concentrations declined during the rebound period to below detection or below cleanup goals.

020406080

100120140160

Oct

-10

Jan

-11

Ap

r-1

1

Jul-

11

Oct

-11

Jan

-12

Ap

r-1

2

Jul-

12

Oct

-12

Jan

-13

Ap

r-1

3

Jul-

13

Oct

-13

Jan

-14

Ap

r-1

4

Jul-

14

Oct

-14

Jan

-15

Ap

r-1

5

Jul-

15

Oct

-15

Co

nce

ntr

atio

n (

µg/

L)

Sample Date

Cycloate Pebulate Vernolate Cleanup Goal=7 µg/L

0

50

100

150

200

250

300

Oct

-10

Jan

-11

Ap

r-1

1

Jul-

11

Oct

-11

Jan

-12

Ap

r-1

2

Jul-

12

Oct

-12

Jan

-13

Ap

r-1

3

Jul-

13

Oct

-13

Jan

-14

Ap

r-1

4

Jul-

14

Oct

-14

Jan

-15

Ap

r-1

5

Jul-

15

Oct

-15

Mo

linat

e C

on

cen

trat

ion

(µ

g/L)

Sample Date

MW-16 MW-26 MW-13R Cleanup Goal=14 µg/L

F-10

Figure F-5: Thiocarbamate Concentrations in MW-13R (North Landfill) at CCP OU2

Figure F-6: Thiocarbamates Concentrations in MW-26 (South Landfill) at CCP OU2

The groundwater monitoring results for OU2 at the CCP Site indicate that thiocarbamates show a

generalized decline in the shallow zone. However, due to continued fluctuations of several

thiocarbamates above cleanup goals in May 2015 and October 2015, Syngenta should continue to assess

groundwater conditions in wells MW-13R, MW-16 and MW-26 to show whether the decline in

contaminant concentrations continues and that all thiocarbamates stabilize below cleanup goals.

In April 2016 soil borings were advanced to a depth of 4 feet below ground surface at the seven

biopile soil borings SB-01, SB-02, SB-03, SB-04, SB-05, SB-06 and SB-07 (Figure F-7). The results are

summarized in Section 6.4.

02468

101214161820

Oct

-10

Jan

-11

Ap

r-1

1

Jul-

11

Oct

-11

Jan

-12

Ap

r-1

2

Jul-

12

Oct

-12

Jan

-13

Ap

r-1

3

Jul-

13

Oct

-13

Jan

-14

Ap

r-1

4

Jul-

14

Oct

-14

Jan

-15

Ap

r-1

5

Jul-

15

Oct

-15Co

nce

ntr

atio

n (

µg/

L)

Sample Date

Cycloate Pebulate Vernolate Cleanup Goal=7 µg/L

0

20

40

60

80

100

120

Oct

-10

Jan

-11

Ap

r-1

1

Jul-

11

Oct

-11

Jan

-12

Ap

r-1

2

Jul-

12

Oct

-12

Jan

-13

Ap

r-1

3

Jul-

13

Oct

-13

Jan

-14

Ap

r-1

4

Jul-

14

Oct

-14

Jan

-15

Ap

r-1

5

Jul-

15

Oct

-15

Co

nce

ntr

atio

n (

µg/

L)

Sample Date

Cycloate Pebulate Vernolate Cleanup Goal=7 µg/L

F-11

Figure F-7: Location of CCP OU2 Biopile Sample Locations

F-12

G-1

Appendix G: Contaminant Groundwater Plume Maps

Figure G-1: Carbon Tetrachloride in the Shallow Wells at LP OU1, November 2010

G-2

Figure G-2: Carbon Tetrachloride in the Shallow Wells at LP OU1, April 2015

G-3

Figure G-3: Carbon Tetrachloride in the Deep Wells at LP OU1, November 2010

M 3MOOO,OO

\ \ \

.,__ .. \ ... \ t. .. \

\ \ '1., _______ _ ..........

.......

__; ·-· .......... e :

-!: .

........ _J~~~~~~-l-~~~~~~e-~~~~~-+-~~~~~~l--~~~~~-+~~~~~~t-~~~~~-+~~~~~~t-~~~~~-t~~~~~~t-~~~~~--1

•

lJStOOO..Ot

PIEZ.OMETER

• ..1-reRCEPT W'EU.

A PRODUCTION V.S.l

1»6000,00 1$$7Nt.00

CARBON TETRACHLORIDE

.. tOO,OOOUQ'l.~ndup

.. 10,000I099,999U(II.

1,000 r.o9.999 ugA.

100to9991J9"l.

.. 10I0999U(II.

.. 5.010 9.9 uglL

1'-''l CARSON TETRACHLORJOE CONCf>ITRATICW<

(NO> NO'T DETECTED

,-. .. ·-· 1'40000,00 I JoUON,00

-lil

IJU000,00 ·-· IJlt0000,00 lJ.WCIOO.to

Sovereign Consulting Inc. 111-A NOf'lh Gold Oriv< Robbin<ville. NJ 08691 (609) 259-8200 Fax (609) 259-8288

Dttt 12t.W2010

CARBON TETRACHLORIDE CONCENTRATIONS IN GROUNDWATER

DEEP WELLS NOVEMBER 2010

AKZO NOBEL FUNCTIONAL CHEMICALS LLC LeMOYNE PLANT AXIS, ALABA.i'\/IA

G-4

Figure G-4: Carbon Tetrachloride in the Deep Wells at LP OU1, April 2015

G-5

Figure G-5: Carbon Disulfide in the Shallow Wells at LP OU1, November 2010

G-6

Figure G-6: Carbon Disulfide in the Shallow Wells at LP OU1, April 2015

G-7

Figure G-7: Carbon Disulfide in the Deep Wells at LP OU1, November 2010

G-8

Figure G-8: Carbon Disulfide in the Deep Wells at LP OU1 in April 2015

Nm,,cooo

w.n1occooo

W~JOOOOO

N3SlOC.O.OO

N)~to«>00-,1~~~~~~---<~~~~~~---<~~~~~~---<~~~~~~---<>--~~~~~---<>--~~~~~---<~~~~~~---<>--~~~~~---<>--~~~~~---<>--~~~~~---<>--~~~~~---<

! )n:oo.o, l!!.40000.00 l! JUOOC.00 l!ll.f.OGt'>O l! l l.60CO.OO

LEGEND

CARBON DISULFIDE .,. MONITORING \\~U

• PIEZOMETER -10.000 uo,\.andw Q INTERCEPT WELL

0 A6ANDONED INTERCEPT WELL 1,000 to 9,999 u~

A PROOUCTION WELL .. 700 I0999t,g.ll

..L &NAAIP

---- PLANT BOUNDARY LINE (334) CARBON DISULFIDE ~TION -m CARBON DISULFIDE

+· CND> NOT DETECTED CONCENTRATIONS IN GROUNDWATER Sovereign Consulting Inc. DEEP WELLS

111-A North Gold Drive APRlL 2015

0 ""' 800 F:EET Robbinsville, NJ 08691 AKZO NOBEL FUNCTIONAL CHEMICALS LLC (609) 259-8200 Fax (609) 259-8188

LeMOYNE PLANT APPRO.Xltl.A TE SCALE IN fEE1

M:~No. A..~10-012-0J Ti1t:Ail2015-CS2·Dfep..dwJ 0- 05'11ll<)lS AXIS, ALABAMA

G-9

Figure G-9: 2015 Soil Sample Locations at the LP OU2 Former Halby Pond Area

I ,. --i-----r-- ----,-- I I I - -,,-~

I t 0 I I I I I ' I . : I ! I 0 ; I I · ~ I e q I I

I " J I I l I

II I I le E I l I ,I ~~ I ! I ~ j 9illll!ICREPREIDm

I ARO IMPAClED

I !HP- $8-1 I BY-= RAllROAII

1------=:•t_-41 I J(LO~TIO~e ,J I 1 APPrOX. f '-'J I I 1 I I I r I ~ I I

87'

-HP-SB-9

,--~-SPRAY DOC, 0(

AJI.S

H-1

Appendix H: Risk Evaluation of Groundwater and Soil Cleanup Goals

Table H-1: Risk Evaluation of LP and CCP OU1 Groundwater Cleanup Goals

COC 1989 ROD Cleanup Goal

(µg/L)

EPA Tap Water RSLa (µg/L) Future Groundwater Use

1 x 10-6 Risk HQ=1.0 Riskb Noncancer HQc

Carbon

disulfide 700 -- 810 -- 0.8

Cyanide 200 1.5 133

Thiocyanate 200 (3,500)d -- 4 -- 50 (875)

Thiocarbamates

Butylate 350 -- 460 -- 0.8

Cycloate 7e -- 11 -- 0.6

EPTC 210 -- 380 -- 0.5

Molinate 14 -- 30 -- 0.5

Pebulate 7 -- 560 -- 0.01

Vernolate 7 -- 11 -- 0.6

Notes:

a. Current EPA RSLs are available at http://www2.epa.gov/risk/risk-based-screening-table-generic-tables

(accessed 02/29/16).

b. The cancer risks were calculated using the following equation, based on the fact that RSLs are derived

based on 1 x 10-6 risk:

Cancer risk = (1989 ROD cleanup goal ÷ Cancer tap water RSL) × 10-6

c. The noncancer HQ was calculated using the following equation:

HQ = (1989 ROD cleanup goal ÷ Non-cancer tap water RSL)

d. In 1989, the EPA adopted the health advisory level for cyanide for thiocyanate in the absence of toxicity

information for this group of compounds; however, in 1999, the EPA developed a health-based level of

3,500 µg/L based on a noncancer reference dose developed by the EPA at that time. Currently, the EPA’s

Integrated Risk Information System does not list a reference dose for thiocyanate.

e. No EPA-verified toxicity values available for this COC. Therefore, the ROD applied the toxicity of

vernolate to this COC, the most toxic thiocarbamate at the Sites.

HQ = noncancer hazard quotient

µg/L – micrograms per liter

Table H-2: Risk Evaluation of 2012 CCP OU2 Soil Performance Standards

COC

2012 Revised Performance

Standard without RCRA

Cap (mg/kg)a

Industrial RSLb (mg/kg) Industrial

HQ Noncancer Hazard Quotient (HQ) = 1.0c

Butylate NA 58,000 NA

Cycloate 36.35 1,200 0.03

EPTC 283.70 29,000 0.01

Molinate 16.39 1,600 0.01

Pebulate 3,215.00 58,000 0.05

Vernolate 31.30 1,200 0.03

Notes:

a. Values from Table 2 2012 OU2 CCP ESD.

b. Current EPA RSLs are available http://www2.epa.gov/risk/risk-based-screening-table-generic-tables

(accessed 02/29/2016).

c. None of the COCs were classified as carcinogenic. Therefore, a noncancer evaluation was performed.

mg/kg – milligrams per kilogram