FIVE-YEAR REVIEW REPORT · FIVE-YEAR REVIEW REPORT ... DOCUMENT REVIEW 22 DATA REVIEW 22 ......

FIVE-YEAR REVIEW REPORT

SECOND FIVE-YEAR REVIEW REPORTFOR

STAUFFER CHEMICAL (COLD CREEK PLANT) SITE,STAUFFER CHEMICAL (LEMOYNE PLANT) SITE

BUCKS and AXIS,MOBILE COUNTY, ALABAMA

EPA ID: ALD008161176 & ALD095688875

Prepared By:

U.S. Army Corps of EngineersMobile District

109 Saint Joseph StreetMobile, Alabama 36602

Approved by: Date:

BeVerlyHlBanisterActing DirectorWaste Management DivisionU.S. Environmental Protection Agency, Region 4

10436075

Second Five-Year Review Report, Stauffer Chemical Company sites. Cold Creek Plant and LeMoyne Plant, Bucks andAxis, Alabama

TABLE OF CONTENTS

LIST OF ACRONYMS, SYMBOLS, AND ABBREVIATIONS iv EXECUTIVE SUMMARY vi FIVE-YEAR REVIEW SUMMARY FORM vii

I. INTRODUCTION 1

II. SITE CHRONOLOGY 2

III. BACKGROUND 3 PHYSICAL CHARACTERISTICS 3 LAND AND RESOURCE USE 4 HISTORY OF CONTAMINATION 5 INITIAL RESPONSE 5 BASIS FOR TAKING ACTION 7

Contaminants 7 Risk Assessment 7

IV. REMEDIAL ACTIONS 8 REMEDY SELECTION 9 REMEDY IMPLEMENTATION 10 OPERATION AND MAINTENANCE 11

Cold Creek 11 LeMoyne 13 Total O&M Costs 15

V. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW 16

VI. FIVE-YEAR REVIEW PROCESS 17 ADMINISTRATIVE COMPONENTS 17 ADDITIONAL FIVE-YEAR REVIEW COMPONENTS 17 DOCUMENT REVIEW 22 DATA REVIEW 22

Contingency Plan 22 Groundwater Elevations and Potentiometric maps 23 Contaminant Concentrations 25

SITE INSPECTION 27 INTERVIEWS 27

Stauffer Chemical Company Five-Year Review.doc i December 2005


VII. TECHNICAL ASSESSMENT 28 QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THEDECISION DOCUMENTS? 28

Remedial Action Performance 28 System Operations 29 Opportunities for Optimization 29 Early Indicators of Potential Issues 31 Implementation of Institutional Controls and Other Measures 31

QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA,CLEANUP LEVELS, AND REMEDIAL ACTION OBJECTIVES USED AT THE TIME OF THE REMEDY STILL VALID? 32

Changes in Standards 33 Changes in Exposure Pathways 33 Changes in Toxicity and Other Contaminant Characteristics 33 Changes in Risk Assessment Methods 34 Expected Progress Towards Meeting RAOs 34

QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO QUESTION THE PROTECTIVENESS OF THE

REMEDY? 34 TECHNICAL ASSESSMENT SUMMARY 34

VIII. ISSUES 35

IX. RECOMMENDATIONS AND FOLLOW-UP ACTIONS 36

X. PROTECTIVENESS STATEMENT 38

XL NEXT REVIEW 38

LIST OF TABLES

Table 1 - Chronology of Site Events 2 Table 2 - Potential Areas of Source Contamination and Downgradient Groundwater Data 8 Table 3 - Groundwater Clean Up Goals, from ROD 9 Table 4 - O&M Costs 15 Table 5 - Actions Taken Since the Last Five-Year Review 18 Table 6 - Acordis wells to obtain groundwater elevations 24 Table 7 - Thiocarbamate concentrations, October 2004, Syngenta MW-16 25 Table 8 - Issues 35 Table 9 - Recommendations and Follow-Up Actions 36

Stauffer Chemical Company Five-Year Review.doc ii December 2005


LIST OF FIGURES (Attachment 2)

Figure 1 - Location map of Stauffer Chemical Company Sites, North Mobile County A2-3 Figure 2 - November 2000 potentiometric map A2-5 Figure 3 - November 2004 potentiometric map A2-7 Figure 4 - May 2005 potentiometric map A2-9 Figure 5 - May 2005 potentiometric map, by Sovereign Consulting, created by Surfer A2-11 Figure 6 - Cold Creek/LeMoyne site map showing approximate locations of source areas A2-13 Figure 7 - Process Flow Diagram of treatment train for IW-1 through IW-4, LeMoyne Plant A2-15 Figure 8 - Process Flow Diagram of treatment train for IW-5, LeMoyne Plant A2-17 Figure 9 - Process Flow Diagram of treatment train for CC-14, Cold Creek Plant A2-19 Figure 10 - Molinate concentration graph, CC-14 extraction well, Cold Creek A2-21 Figure 11 - Groundwater elevations in selected wells at Syngenta (Cold Creek),

Halby, and vicinity A2-23 Figure 12 - Groundwater elevations in selected wells east of Cold Creek and LeMoyne A2-25 Figure 13 - Groundwater elevations in selected wells at Akzo Nobel A2-27 Figure 14 - CS2 and CC14 concentrations, 2000-2004 in IW-1 A2-29 Figure 15 - CS2 and CC14 concentrations, 2000-2004 in IW-2 A2-31 Figure 16 - CS2 and CC14 concentrations, 2000-2004 in IW-3 A2-33 Figure 17 - CS2 and CC14 concentrations, 2000-2004 in IW-4 A2-35 Figure 18 - CC14 concentrations, 2000-2004 in MW-5, 'upgradient' well, LeMoyne

Landfill A2-37 Figure 19 - CN and SCN concentrations, 2000-2004 in IW-5 A2-39

LIST OF ATTACHMENTS

Attachment 1 - List of Documents Reviewed A1-1 Attachment 2 - Figures A2-1 Attachment 3 - Site Inspection Check List A3-1 Attachment 4 - Interview Records A4-1 Attachment 5 - Photographs A5-1

Stauffer Chemical Company Five-Year Review.doc iii December 2005


LIST OF ACRONYMS, SYMBOLS, AND ABBREVIATIONS

% percent, percentageADEM Alabama Department of Environmental Management AOC area of concern ARARs Applicable or Relevant and Appropriate Requirements ADPH Alabama Department of Public Health CA Corrective Action CC Cold CreekCCl4, CCl4 carbon tetrachloride CDM Camp, Dresser & McKee CERCLA Comprehensive Environmental Response Compensation and Liability ActCFR Code of Federal Regulations CN total cyanideCNA Courtaulds North AmericaCOCs contaminants of concernCS2 carbon disulfideDMR discharge monitoring report EA Endangerment AssessmentEPA Environmental Protection Agency EPTC thiocarbamate, ethyl dipropylthiocarbamate, EptamERM Environmental Resources Management (Consultant for Syngenta) ERT Environmental Research and Technology, Inc., consultant for RI and EA ESD Explanation of Significant Differences (EPA term for ROD amendment) FS Feasibility Studygpm gallons per minuteGPS Geographic Positioning SystemGTS Groundwater Treatment SystemGWIP Groundwater Improvement Pond HA Health AssessmentHCC Halby Chemical Companykg kilogramsLHA Lifetime Health Advisory LLC Limited Liability CompanyMARCAM Akzo Nobel internal database for tracking O&M (name for acryonym is the software

company)MCA monochloroacetic acidMCL maximum contaminant level MGD million gallons per day mg/1, mg/L milligrams/literMODFLOW groundwater modeling program used by the PRP's for these sites N NorthNaSH sodium hydrosulfide (chemical produced by Akzo Nobel) n/a not applicable

Stauffer Chemical Company Five-Year Review.doc iv December 2005


NCP National Contingency PlanNPDES National Pollutant Discharge Elimination System Permit NPL National Priorities List O&M Operation and Maintenance OU-1 Operable Unit 1 OU-2 Operable Unit 2 OU-3 Operable Unit 3 pH potential of hydrogen POC point of complianceppb parts per billion ppm parts per million PRP, PRPs potentially responsible party, potentially responsible parties (for SCC sites, the PRPs

are Akzo Nobel Functional Chemicals LLC and Syngenta Crop Protection, Inc.) RA remedial actionRAGS Risk Assessment Guidance for Superfund RAOs Remedial Action ObjectivesRCRA Resource Conservation and Recovery ActRD remedial designRD/RA remedial design/remedial action RFA RCRA Facility Assessment RfD Reference Dose RI Remedial Investigation (all references are to final RI) RI/FS Remedial Investigation/Feasibility Study ROD Record of DecisionRPM Regional Project Manager (EPA) SCC Stauffer Chemical CompanySCN= thiocyanate SWMU solid waste management unitµg/L, ug/L micrograms per literURS URS CorporationU.S. United StatesUSACE, COE U.S. Army Corps of Engineers WWT wastewater treatment

Stauffer Chemical Company Five-Year Review.doc v December 2005


EXECUTIVE SUMMARY

Operable Unit 1 (OU-1) addresses groundwater contamination at the former Stauffer ChemicalCompany's Cold Creek Plant and adjacent LeMoyne Plant located in Mobile County, Alabama. TheCold Creek Plant (now owned by Syngenta Crop Protection, Inc.) has a Bucks, Alabama mailingaddress and the LeMoyne Plant (now owned by Akzo Nobel, Inc.) has an Axis, Alabama address.The remedy for OU-1 is to pump and treat the groundwater. Groundwater monitoring is alsorequired to ensure the contaminated groundwater is captured, with no off-site migration. The pumpand treat systems were in place prior to the signing of the OU-1 Record of Decision (ROD), withadditional extraction wells added since the ROD was signed. The trigger for this five-year reviewwas the initial five-year review for OU-1 signed in June 2000.

OU-1 and OU-3 are common operable units at the Stauffer Chemical Company (SCC) NPL sites.OU-1 addresses groundwater contamination beneath the sites. OU-3 addresses mercurycontamination in the sediment and surface water of the Cold Creek Swamp located adjacent to theplants. The implementation of the OU-1 remedial action was completed in September, 1996. Theremedial design for OU-3 has not been approved. LeMoyne Plant, OU-2 addresses remediation ofsubsurface soil in the closed Halby Pond. The remedy involves flushing the affected soil with waterto move the contamination into the groundwater and to accelerate the natural breakdown ofcontamination. Cold Creek Plant OU-2 addresses the ex-situ bioremediation of soil and debrisexcavated from a closed impoundment. The remedial actions for both OU-2's are underway. Duringthe next five-year review, OU-2 operational data will be reviewed to determine the protectiveness ofthese remedies.

This five-year review determined that the OU-1 remedy is functioning as intended by the (ROD)except for the operation of extraction well IW-4. The goal at the completion of the remedial action isto meet the groundwater cleanup standards outlined in the ROD (Table 3 of this document) at thedesignated detection monitoring wells and the extraction wells. Groundwater monitoring shouldcontinue for 30 years or until the ROD cleanup standards have been achieved.

The remedy at OU-1 appears to be protective of human health and the environment in the short termsince there is no evidence of currently complete exposure pathways to contaminated groundwater.Operational data for the LeMoyne OU-2 and the Cold Creek OU-2 remedial actions will beevaluated during the next Five Year Review to determine their protectiveness. The potentiometricmaps developed and reviewed since 1999 indicates the system maintains an inward gradient.Monitoring data indicate the remedy for OU-1 is functioning as required, except for IW-4. Apotential environmental risk is present due to groundwater contamination near LeMoyne Landfilland the fact that groundwater flow from the sites is now towards Mobile River. In order to verifyprotectiveness, groundwater monitoring should continue until 2022, or until ARAR's are met. Thegoal is to meet the groundwater cleanup values listed in Table 3 at each of the designated detectionmonitoring wells and the extraction (intercept) wells. In order for the remedy to remain protective inthe long term, the recommendations identified in this Five-Year Review need to be addressed.

Stauffer Chemical Company Five-Year Review.doc vi December 2005

Second Five-Year Review Report. Stauffer Chemical Company sites. Cold Creek Plant and LeMoyne Plant, Bucksand Axis. Alabama

FIVE-YEAR REVIEW SUMMARY FORM

Site name (from WasteLAN): Stauffer Chemical Company LeMoyne and Cold Creek

EPA ID (from WasteLAN): ALD008161176 and ALD095688875

Region: 4 State: AL City/County: Axis, AL/Mobile•Fjlf'*,'fT[ '.

NPL status: D [^Final \~\ Deleted Qother (specify)

Remediation status (choose all that apply): LjUnder Construction IXlOperating | Icomplete

Multiple OUs?' Construction completion date: 1994

Has site been put into reuse? IXlYES I IMP

Lead agency: IX! EPA [""[state FlTribe Oother Federal Agency

Author name: Laura Roebuck

Author title: Geologist Author affiliation: U.S. Army Corps of Engineers

Review period:" 4 / 4/ 2005 to 7/1/2005

Date(s) of site inspection: _4_ /14 / 2005

Type of review:[X] Post-SARA I I Pre-SARA I I NPL-Removal onlyI | Non-NPL Remedial Action Site | | NPL State/Tribe-lead| | Regional Discretion

Review number: 1 (first) M 2 (second) M 3 (third) M Other (specify)

Triggering action:[_jActual Remedial Action On-site Construction (OU-2)^Construction CompletionQother (specify)

jActual Remedial Action Start at OU# NAJPrevious Five-Year Review Report (OU-1)

Triggering action date (from WasteLAN): 06/02/2000 (OU-1)

Due date (five years after triggering action date): 06/02/2005* ["OU" refers to operable unit.]** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.

Stnuffer Chemical Company Five-Year Review.doc December 2005

Second Five-Year Review Report, Stauffer Chemical Company sites, Cold Creek Plant and LeMoyne Plant, Bucksand Axis, Alabama

Five-Year Review Summary Form, cont'd.

Issues:

1. The use of more data points in developing potcntiometric maps and groundwater modeling.2. Relocating intercept and monitoring wells as necessary, based on better establishment of groundwaier flow direction

and future monitoring.a) Extraction well IW-4 is no longer capturing contaminated groundwater from LeMoyne Landfill as

designed.b) MW-19 and MW-20 may not be downgradient of GWIP.c) The plume near LeMoyne Landfill is not delineated as MW-5. an 'upgradient' well shows CC14 concentrations

above the cleanup goal. Groundwater/surface water interface in area of Landfill not understood.3. Groundwater analytical reporting l imits for carbon letrachloride are the same as the cleanup criteria.4. Excessive carbon changes in carbon adsorption system.5. Cause for decreasing contaminant concentrations in extraction well IW-3 since mid 2001.6. Permanent well identification tagging.7. Contaminant plume map is needed for better assessment of the impact of the changes in groundwater flow and

effectiveness of contaminant capture in the future.8. Operational data for LeMoyne OU-2 and Cold Creek OU-2 for evaluating their protectiveness are not available as the

remedial actions are underway.9. LM-6 (LeMoyne) production water well is a new potential exposure pathway, as this well may now be downgradient

of Cold Creek.10. Vapor intrusion concerns in areas near the plumes are not addressed.

Recommendations and Follow-up Actions:

1. Groundwater level readings should be obtained in more wells throughout the SCC and Acordis sites. This includesensuring all wells used for the development of potemiometric maps are in good working order with accuratemeasuring point elevations.

2. After better establishing groundwater flow direction with continued monitoring, intercept and/or monitoring wellsmay need to be relocated, to include, but not limited to:

a) Determine proper placement of IW-4.b) Relocate MW-19 and MW-20 downgradient of GWIP.c) Conduct site investigations near LeMoyne Landfill to delineate vertical and lateral extent of theplume. Determine groundwater/surface water interface in this area to evaluate possible discharge of contaminatedgroundwater to Mobile River.

3. Revise the analytical program for groundwater samples to improve reporting l imits such that the reporting limits arelower than the cleanup criteria. Recommend adjusting the reporting l imit of carbon tetrachloride to 2.5 ug/L or less.

4. Determine remedy for excessive fouling of carbon columns in Cold Creek GTS. As part of this investigation, the wellwater should be tested using Biological Activity Reaction Test (BART) kit to determine the type and activity level ofbacteria in the well, particularly if the problem is Fe bacteria. Sufficient testing should be conducted to determine thewater chemistry for tailoring an effective treatment process of the well, filter pack, and/or formation, as needed. Asample of the fouling on the carbon should also be analyzed to determine the chemical composition, to assist indetermining corrective action.

5. Evaluate extraction well FW-3 for possible relocation.6. Prepare dye stamped aluminum or stainless steel id tags with well information for each well. (See page A3-13 for

details.) Affix (via pop rivets or similar) to exterior casing.7. Construct plume maps on an annual or alternating annual basis.8. During the next Five-Year Review, operational data for the LeMoyne OU-2 and Cold Creek OU-2 should be

evaluated for their protectiveness.9. LM-6 water quali ty sampling and analysis should include site specific contaminants (e.g. thiocarbamates).10. Per the November 2002 EPA guidance on vapor intrusion, the PRP's should evaluate the potential for vapor intrusion

and determine if a potential risk exists at their respective sites.

IXStauffer Chemical Company Five-Year Review.doc December 2005

Second Five-Year Review Report, Stauffer Chemical Company sites, Cold Creek Plant and LeMoyne Plant, Bucksand Axis, Alabama

Five-Year Review Summary Form, cont'd.

Protectiveness Statement: The remedy at OU-1 appears to be protective of human health and theenvironment in the short term since there is no evidence of currently complete exposure pathways tocontaminated groundwater. Operational data for the LeMoyne OU-2 and the Cold Creek OU-2 remedialactions wi l l be evaluated during the next Five Year Review to determine their protectiveness. Thepotentiometric maps developed and reviewed since 1999 indicates the system maintains an inward gradient.Monitoring data indicate the remedy for OU-1 is functioning as required, except for extraction well IW-4. Apotential environmental risk is present due to groundwater contamination near LeMoyne Landfill , and thefact that groundwater flow from the sites is now towards Mobile River. A potential human health risk ispresent from LM-6 production water, as this well is now possibly dovvngradient of the Cold Creek Plant site.A potential human health risk for vapor intrusion exists in buildings near the contaminant plumes. In order toverify protectiveness, groundwater monitoring should continue unti l or unti l the ROD cleanup standardshave been achieved . The goal is to meet the groundwater cleanup values listed in Table 3 at each of thedesignated detection monitoring wells and the extraction (intercept) wells. In order for the remedy to remainprotective in the long term, the recommendations identified in this Five-Year Review need to be addressed.

Other Comments:

Remedial design for the LeMoyne OU-3 has not been approved and will not be addressed in this Five-YearRevievv.

Stauffer Chemical Company Five-Year Review.doc December 2005


SECOND FIVE-YEAR REVIEW REPORT STAUFFER CHEMICAL (COLD PLANT) SITE

STAUFFER CHEMICAL (LEMOYNE PLANT) SITE BUCKS AND AXIS, ALABAMA

I. INTRODUCTION

The U.S. Army Corps of Engineers (USACE) was tasked by the U.S. Environmental ProtectionAgency (EPA) to conduct a five-year review of the remedial action implemented at the StaufferChemical Company sites (SCC) in Axis and Bucks, Alabama, to evaluate the protectiveness of thesite remedy for Cold Creek Plant and LeMoyne Plant, for OU-1, groundwater. The five-year reviewwas conducted from April to July 2005. This report documents the results of the review.

This five-year review is to evaluate the performance of the remediation system installed forOperable Unit One (OU-1), the ground water operable unit, at the SCC sites. The Cold Creek Plantsite and the LeMoyne Plant site were placed on the National Priorities List (NPL) in September 1983and were ranked number 221 and number 467, respectively. Past disposal practices at both sitesresulted in groundwater contamination, that was discovered in the early 1970's when contaminantswere detected in on-site and off-site wells. The Cold Creek Plant site is now owned by SyngentaCrop Protection, Inc. Syngenta is the potentially responsible party (PRP) for the Cold Creek Plantsite. In the last five-year review, Zeneca was the site owner and PRP. The LeMoyne Plant site isowned by Akzo Nobel Inc., and operated by Akzo Nobel Functional Chemicals LLC. Akzo Nobel isthe PRP for this site.

The primary purpose of the five-year review is to determine whether the site remedy remainsprotective of human health and the environment. In addition to presenting the findings andconclusions of the review, deficiencies are identified, and corrective actions are recommended. Thefive-year review documents the evaluation of the site remedy, operation and maintenance (O&M)activities, and the continued appropriateness of RAOs at the site.

This five-year review is prepared pursuant to the Comprehensive Environmental ResponseCompensation and Liability Act (CERCLA) § 121 and the National Contingency Plan (NCP).CERCLA § 121 states the following:

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 remedialaction no less often than each five years after the initiation of such remedial action to assurethat human health and the environment are being protected by the remedial action beingimplemented. In addition, if upon such review it is the judgment of the President that actionis appropriate at such site in accordance with section [ 104] or [ 106], the President shalltake or require such action. The President shall report to the Congress a list of facilities forwhich such review is required, the results of all such reviews, and any actions taken as aresult of such reviews.

This requirement is interpreted further in the NCP; 40 Code of Federal Regulations (CFR) §300.430(f)(4)(ii) states the following:

Stauffer Chemical Company Five-Year Review.doc 1 December 2005


If a remedial action is selected that results in hazardous substances, pollutants, orcontaminants remaining at the site above levels that allow for unlimited use and unrestrictedexposure, the lead agency shall review such action no less often than every five years afterthe initiation of the selected remedial action.

This five-year review is the second review for the SCC sites, also known as the Cold Creek Plantand LeMoyne Plant sites. The trigger for this statutory review was the first five-year review forOU-1 signed in June 2000. The initial trigger for OU-1 was the completion of the remedial actions in1994. This five-year review is required for the reason that contaminants remain at the site abovelevels that allow for unlimited use and unrestricted exposure.

II. SITE CHRONOLOGY

The site chronology has been summarized based on the EPA Administrative Record and documentslisted in Attachment 1. Table 1 presents the chronology of events for the SCC sites.

Table 1 Chronology of Site Events

Event Date

Industrial Process Began at the Sites 1953

Contamination found in wells 1970's

Install Monitor Wells 1973

Hydrogeologic Investigation 1977

Install Pump and Treat System 1980

Site Assessment Alabama Dept. of Public Health 1982

Sites are Listed on National Priorities List September 1983

Camp, Dresser & McKee (COM) conducts initial sampling May 1985

RCRA Permit becomes effective for LeMoyne Plant October 9, 1986

Akzo/ICI complete RI May 1988

Draft FS report submitted, requires modifications July 1988

OU-1 ROD issued September 27, 1989

OU-1 Consent Order April 25, 1990

FS Report accepted May 4, 1990

OU-1 RD Work Plan September 7, 1990

OU-1 Preliminary Design Report January 1992

Final Phase II Intercept Well Design Report July 14, 1992

IW-4 , IW-5 & CC-14 Installed December 10, 1992 Stauffer Chemical Company Five-Year Review.doc 2 December 2005


OU-3 ROD issued September 17, 1993

OU-1 Remedial Action completed 1994

OU-2 Cold Creek Plant ROD issued August 16, 1995

OU-2 Cold Creek Plant RA Workplan approved September 28, 1998

OU-2 LeMoyne Plant ROD issued March 18, 1999

First 5-Year Review June 2000

OU-2 LeMoyne Plant RA Workplan approved September 29, 2003

III. BACKGROUND

The following subsections present background information for the SCC sites including physicalcharacteristics, land resource use, history of contamination, initial response, and basis for takingaction.

PHYSICAL CHARACTERISTICS

The SCC sites are in Axis and Bucks, Alabama, about 20 miles north of Mobile, Alabama on USRoute 43. SCC sites consist of the LeMoyne Plant, now owned by Akzo Nobel, Inc., operated byAkzo Nobel Functional Chemicals LLC, and the adjacent Cold Creek Plant now owned by SyngentaCrop Protection, Inc. The two sites cover approximately 950 acres. Cold Creek Plant encompassesabout 220 acres and the LeMoyne Plant encompasses about 730 acres.

The SCC sites are bounded by Mobile River on the east, Highway 43 on the west, North MobileCounty Industrial Complex and the former Courtaulds North America (CNA) property on the south.This property was also owned by Acordis, and is now owned by Mobile County. The site is boundedto the north by US Amines. Alabama Power Company borders Akzo Nobel property on the northeastern portion of the property. The area is primarily industrial with a few residential communitieswithin a few miles of the site. Access to both sites is from Highway 43 to the west (see Figure 1 inAttachment 2).

Surface elevations range from 10 to 45 feet above mean sea level. An unnamed tributary flows northacross the property and then through Cold Creek Swamp, which discharges into Mobile River.Surface water drainage is either toward the swamp or the river and is governed by a drainage dividebetween the two. Mobile River flows south towards the Gulf of Mexico.

Surface runoff from the eastern part of Cold Creek Plant drains to Cold Creek Swamp, whichborders the plant to the east. Surface runoff (non-process stormwater) on the active portions of ColdCreek Plant is either captured by the plant drainage systems or drains to Cold Creek Swamp.Rainwater over the plant is also captured and is collected in a rainwater collection pond. This wateris used for supplementing water needs of the plant. Surface drainage (non-process stormwater) fromthe western part of LeMoyne Plant is toward the unnamed tributary which flows north toward ColdCreek Swamp. The eastern part of LeMoyne is adjacent to and drains toward Mobile River.Flooding potential at these sites is considered minimal.



The site lies in the Southern Pine Hills Section of the East Gulf Coastal Plain PhysiographicProvince. Within the Southern Pine Hills Section, the underlying sedimentary units are overlain byMiocene estuarine deposits of interbedded sands and clays, and in some areas the younger PlioceneCitronelle Formation of sand and gravel. The site is underlain by low river terrace and alluvialdeposits approximately 85 to 130 feet thick. The deposits are generally clean, unconsolidated, fine tovery coarse-grained sands that contain some interbedded, discontinuous clayey seams and somegravelly zones. The upper sands have moderate to low permeability. Lower sands are cleaner,coarser and more angular with depth. These sands comprise the primary water source as they exhibithigher permeabilities and transmissivities. A discontinuous, weathered, clay layer up to 20' thick, onthe western part of the Cold Creek site separates the surficial aquifer into two water-bearing zones.The bluish gray very fat thick Miocene clay lies about 120 to 135 feet below ground surface and actsas a confining layer below the shallow aquifer.

Prior to industrialization, the regional groundwater flow in the surficial aquifer was towards the east,towards Mobile River. Groundwater levels were between 0 and 20 feet below ground surface. WhenCourtaulds was operating and extracted large quantities of groundwater, the water table was loweredbetween 25 and 75 feet below ground surface. Due to the local influence of pumping at Courtauldsand from the interceptor wells on the southern part of the LeMoyne site, groundwater flowedtowards these wells (to the south-southeast). However, since Courtaulds completely ceasedgroundwater extraction in early 2002, groundwater flow is equilibrating, and seems to be flowingtowards Mobile River again.

Potentiometric maps for the area were developed from groundwater elevation data collected overboth sites over the past few years. The contour maps are generated by interpretation between a finitenumber of data points, so the contour lines should be considered to represent a generalized view ofthe groundwater gradient and not absolute contour lines. For Figures 2, 3, and 4 of this report, thecontours were prepared by hand by USACE, on a site map provided by Akzo Nobel. Apotentiometric map from data collected in November 2000 was developed, presented as Figure 2 inAttachment 2. This map shows the groundwater gradient towards the south, towards the Courtauldspumping wells. Figure 3 in Attachment 2 shows the potentiometric map for the sites in November2004 showing the regional groundwater gradient towards Mobile River. Figure 4 in Attachment 2shows the potentiometric map for the sites in May 2005 also showing the regional gradient towardsMobile River. Groundwater level data from some wells on the property south of Akzo Nobel, NorthMobile County Industrial Complex, formerly owned by Courtaulds and Acordis, were obtained andused for the May 2005 map. The Mobile County property wells were added to the site map byUSACE, using well location information from McCrory and Williams surveyors. Figure 5 inAttachment 2 is the Surfer-generated contour map created by Sovereign Consulting for Akzo Nobel.

LAND AND RESOURCE USE

The land surrounding the SCC sites is predominantly industrial, related to chemical processing andelectrical power generation. The Alabama Power Company Barry Steam Generating Plant is locatednorth of the site (i.e. north of Cold Creek). Timber production (southern pine) is the other major landuse in the immediate vicinity. Most land east of the project site (across Mobile River) isundeveloped river bottom swamp with some timber harvesting. Some small residential communitiesare within a few miles of the site.



HISTORY OF CONTAMINATION

The SCC sites, LeMoyne plant and Cold Creek plant, are located approximately 20 miles north ofMobile, Alabama on U.S. Highway 43. The LeMoyne plant manufactures multi-product organic andinorganic chemicals including carbon disulfide, sulfuric acid, sulfur chlorides, monochloroaceticacid (MCA), sodium hydrosulfide (NaSH) and Crystex®, a proprietary sulfur compound. Pastproduction at the plant included carbon tetrachloride, chlorine, and caustic soda (sodium hydroxide).Agricultural pesticides and herbicides, including thiocarbamates, are manufactured at the ColdCreek plant.

The LeMoyne plant started operations in 1953 under the ownership of SCC and is currently ownedby Akzo Nobel Inc., and operated by Akzo Nobel Functional Chemicals LLC. From 1965 to 1974while owned and operated by SCC, waste from the plant was placed in an unlined landfill located onthe eastern side of the property. The waste included brine muds, plant refuse, used samples, andabsorption oil. The LeMoyne Landfill was closed in 1975 with an impermeable membrane cap andside-wall liner.

Waste waters from the LeMoyne plant processes were held in ponds. All of the ponds, except forLeCreek, were clay lined and are closed. LeCreek is a membrane lined pond and is an activewastewater treatment plant. The membrane lined ponds were installed in the 1970's to replace theclosed and inactive ponds. Only one of these ponds, LeCreek, is currently used. The New Brine MudPond is closed and regulated by a RCRA permit.

From 1965 to 1974, a small area on the western side of the LeMoyne plant was leased, by SCC, tothe Halby Chemical Company (HCC), which manufactured dye chemicals including sodiumhydrosulfide. Witco, Inc. purchased the HCC plant in 1974 and continued to operate the plant until1979. Waste products and effluent were held in an on-site pond and eventually discharged to ColdCreek Swamp. The pond is now closed and filled.

The Cold Creek plant began operation in 1966 under the ownership of SCC and is currently ownedby Syngenta Crop Protection, Inc. Until 1974, solid wastes were placed in two disposal sites referredto as the Cold Creek North and South Landfills. The wastes stored in the Cold Creek landfills werewater treatment plant sludges, used sand blasting sand, generator coke, incinerator ash, and filtratewaste. The landfills were closed in 1974 with geomembrane caps and side wall liners. A clay-linedlagoon was used to store and neutralize waste water until 1975. The lagoon was closed in 1978 andreplaced with a membrane lined lagoon that is used to hold non-process waste water and stormwaterfrom the process units.

INITIAL RESPONSE

In the early 1970's, contamination was detected in on-site and off-site wells. The off-site wells arelocated on the adjacent former CNA property that is the southern boundary of the LeMoyne site.This property is now called North Mobile County Industrial Complex. Due to the continued declinein the quality of the groundwater, seven monitoring wells were placed along the southern boundaryof the LeMoyne site to monitor ground water quality. In late 1980, three groundwater extractionwells were installed along the southern boundary of the LeMoyne site. These wells discharged to anair stripper manifold system at the Ground Water Improvement Pond (GWIP). The system wasapproved by the Alabama Water Improvement Commission, which is now the Alabama Departmentof Environmental Management (ADEM).



An assessment of both sites was conducted in 1982 by the Alabama Department of Public Health(ADPH) in response to submissions made by SCC to the House Committee on Interstate Commerce(the Eckhardt Survey). At ADPH's request, additional monitoring wells were installed around theCold Creek Landfills. Data from the existing monitoring wells and the newly installed monitoringwells formed the basis for the EPA placing the sites on the NPL, which ranks hazardous waste sitesunder the provisions of CERCLA. Both sites were transferred from the proposed list to the final NPLlist in September 1983.

In November 1984, EPA Region 4 sent a general notice letter to SCC notifying the company ofpotential liability for the contamination at the SCC sites. COM, under contract to the EPA,performed preliminary sampling in May 1985 to assist in preparation of a Work Plan for theRemedial Investigation/Feasibility Study (RI/FS). SCC contracted to conduct the RI/FS under aconsent agreement with the EPA, and Akzo/ICI completed the RI in May 1988. A draft FS reportwas submitted by Akzo/ICI in July 1988. EPA required modifications to the report in letters sent inSeptember and November 1988 and January 1989. A final FS report was submitted in June 1989.This report was reviewed by EPA and was partially disapproved. An amended final FS report wassubmitted to EPA in April 1990. EPA approved the amended final FS report , with respect to theground water operable unit (OU-1), on May 4, 1990. The results of the RI/FS indicated that:

• Several ponds containing contaminated soils and/or sludges are located at the sites, • Ground water contaminated with carbon tetrachloride, carbon disulfide, thiocarbamates, and

thiocyanate is present on the LeMoyne site. Thiocarbamates were detected in the groundwater at the Cold Creek Site,

• Carbon tetrachloride, carbon disufide, and thiocarbamates were found in wells at the adjacentCNA property.

Community interest in the SCC Sites has been limited. Several news articles concerning the siteshave been printed in the Mobile Press Register and the Advertiser. A Community Relations Plan wascompleted in September, 1985. On July 13, 1989, documents related to remedy selection at the sites,including the RI/FS Study and Proposed Plan, were made available by the EPA to the public at theRegion 4 EPA offices in Atlanta, Georgia and the Toulminville Branch Library in Mobile, Alabama.This began a 30-day public comment period to solicit public opinion on the proposed remedialaction at the SCC Sites. A public meeting was conducted on July 27, 1989, at which EPA presentedthe RI/FS report and Proposed Plan and answered citizens' questions. The Mobile CountyCommissioners and County Administrator were briefed prior to the meeting.

On September 27,1989, EPA issued the ROD for Operable Unit One, and on April 25, 1990, aConsent Order executed by Akzo, ICI and the United States was entered by the U.S. District Courtfor the Southern District of Alabama. The Consent Order addresses remedial design/remedial action(RD/RA) for OU-1 and incorporates the ROD and the Statement of Work for the RD/RA tasks. TheRD component of the work is described in the RD Work Plan for the SCC Sites which wassubmitted to the EPA on September 7, 1990, (Geraghty & Miller, Inc. 1990). Included in the RDWork Plan is the Scope of Work for the groundwater modeling. The results of the groundwatermodeling studies identified the requirements for three additional groundwater extraction wells; twoat LeMoyne, IW-4 and IW-5, and one at Cold Creek, CC-14. The groundwater modeling was alsoused to select the pumping rates for the extraction wells. The remedial actions were completed in1994 by the Potentially Responsible Parties (PRPs) with EPA oversight. Additional remedial actionsare underway at the Old Neutralization Pond (Cold Creek Site, OU-2) and at the Halby Pond(LeMoyne site, OU-2).



BASIS FOR TAKING ACTION

The basis for taking action at the SCC sites relates to groundwater contamination caused by historicdisposal practices. Groundwater is the primary source of drinking water for the area. AnEndangerment Assessment (EA) and a Health Assessment (HA) were produced in 1988 and 1989respectively. These assessments discussed risk issues associated with the groundwatercontamination.

Contaminants

The results of the (final) RI/FS indicated that several ponds containing contaminated soils and/orsludges exist at the sites. Groundwater contaminated with carbon tetrachloride, carbon disulfide,thiocarbamates, and thiocyanate is present on the LeMoyne site. Thiocarbamates were detected inthe groundwater at the Cold Creek site. Carbon tetrachloride, carbon disulfide, and thiocarbamateswere found in wells at the adjacent Courtaulds property.

Fourteen potential contaminant source areas were investigated during the RI. Table 2 shows themajor contamination found in soil samples collected from beneath each potential source, the range ofconcentrations of each major contaminant, and the levels of any contaminants in the nearestdowngradient well samples. This information is contained in Table 8.1 of the RI.

Figure 6 in Attachment 2 shows the locations of the source areas. Of the fourteen potential sourceareas addressed during the RI, only five were considered to be a groundwater contaminant source.The five sources of contamination were found to be LeMoyne Landfill, Cold Creek OldNeutralization Pond, Halby Pond, Old Carbon Tetrachloride Plant Wastewater Treatment Pond andthe Old CS2 Plant Wastewater Treatment Pond.

Risk Assessment

An EA and a HA were produced in the late 1980's. The EA final report is dated May 1988. This EAwas a risk assessment of the site conditions at that time. This assessment reported that no riskappeared to exist from exposure to contaminated groundwater at the sites, because none of thecontaminants had been detected in any of the drinking water wells in the immediate vicinity of thesite. It also determined that it would be highly unlikely that future exposure to contaminatedgroundwater would occur, because a permit is required for the installation of a potable water wellfrom the state of Alabama, and it was highly unlikely that a permit would be granted given thedocumented groundwater contamination at the sites.

The HA final report, January 1989, concluded that this site is of potential health concern because ofthe potential risk to human health resulting from possible exposure to hazardous substances atconcentrations that may result in adverse health effects. Humans could be exposed primarily tomercury contamination via incidental ingestion of the sediments and ingestion offish in Cold CreekSwamp. Thus, the high levels of mercury in Cold Creek Swamp and fish could pose a significantpublic health threat via oral exposure. Several recommendations were made to protect public health,in terms of continued groundwater capture and treatment, restrict fishing and access to Cold CreekSwamp, the evaluation of recreational uses, and groundwater monitoring. This assessment did notconsider these sites for follow-up health studies, because it did not conclude that human exposure toon-site or off-site contaminants was occurring nor had occurred in the past.



The potential for environmental risk is present due to the threat of migration of groundwater fromthe sites to Mobile River and LeMoyne Swamp. The area is a natural habitat for a variety ofinvertebrates, amphibians, reptiles, fish, birds and mammals. One species of concern is the AlabamaRed-Bellied turtle, which is endangered.

IV. REMEDIAL ACTIONS

The following subsections present the remedial actions for the SCC sites including remedy selection,remedy implementation, and O&M.



REMEDY SELECTION

The ROD for the OU-1 groundwater operable unit at the SCC sites was signed on September 27,1989. The groundwater operable unit is the initial operable unit at the sites. Each site has a sitespecific OU-2. These OUs are comprised of the Solid Waste Management Units (SWMU's) such asthe Cold Creek Old Neutralization Pond and Halby Pond. Cold Creek Swamp is OU-3 and allecological concerns for this swamp are addressed in that OU. The selected remedy for OU-1 is topump and treat the groundwater and site monitoring of the groundwater. The response actions forOU-1 were implemented to protect public health and the environment by controlling the migrationof contaminated groundwater in the surficial aquifer, the primary source of water for industrial anddomestic users located in the Mobile River Valley. The ROD requires a contingency plan if pumpingof the Courtaulds wells is terminated. The U.S. EPA has determined that the off-site migration ofcontaminated groundwater is one of the principal threats at these sites. The major components of theselected remedy are:

• Modify existing groundwater intercept and treatment system; install additional monitoringand extraction wells;

• Continue extracting groundwater from the surficial aquifer via existing and additionalextraction wells;

• Monitor groundwater movement at the site to determine the adequacy of the remedial action; • Conduct treatability studies as appropriate for source treatment of RCRA SWMUs and

CERCLA disposal sites; and, • Abandon wells no longer required for site monitoring.

The ROD requires groundwater monitoring at the sites for 30 years. The goal at the completion ofthe entire remedial action is to meet the groundwater cleanup goals in the monitoring and extractionwells. The treatment system will be turned off when the groundwater contamination has beenreduced below the clean-up levels listed in Table 3.

Table 3 Groundwater Clean Up Goals, from ROD

Contaminant of Concern Goal (µg/L) Basis

Carbon Disulfide 700 LHA

Carbon Tetrachloride 5 MCL

Cyanide 200 LHA

Mercury 2 MCL

Thiocyanates 200* LHA

Thiocarbamate Herbicides**

Butylate 350 LHA

Cycloate 7*** LHA

EPTC 210 LHA

Molinate 14 LHA

Pebulate 7*** LHA

Vernolate 7** LHAStauffer Chemical Company Five-Year Review.doc 9 December 2005


MCL - Maximum Contaminant Level LHA - Lifetime Health Advisory, based on Reference Dose (RfD) 70 kg human w/2liter/day water consumption, 20% relative source contribution * No Agency health-based number exists for thiocyanates. The LHA for the more toxiccyanide is used. ** These cleanup goals could be increased a maximum of fourfold pending an EPAOffice of Drinking Water decision to revise the LHA values for. these carbamateherbicides that allows a drinking water source to contribute up to 80% of the RfD. *** No Agency-verified RfD's for these chemicals; the cleanup goal is based on the RfDfor Vernolate (the most toxic carbamate at the site).

REMEDY IMPLEMENTATION

The OU-1 Remedial Design Work Plan was submitted on September 7, 1990, and the PreliminaryRemedial Design Report was issued in January 1992. The groundwater modeling performed duringthe preliminary RD was used to select the locations for the three additional intercept wells and thepumping rates for the extraction wells. The design was finalized in the Final Phase II Ground WaterIntercept System at the SCC sites report prepared by Geraghty & Miller and dated August 14, 1992.

At the SCC sites there are three separate pump and treat systems and three treatment trains. Onesystem is comprised of extraction wells IW-1, IW-2, IW-3, and IW-4 that discharge to the GroundWater Improvement Pond. The second system is IW-5, at the Halby Pond and its discharge systemand the third system is well CC-14 and its associated treatment system. See Figures 7, 8, and 9 inAttachment 2 for process flow diagrams of each treatment train.

Installed in 1980, the basic Ground Water Intercept system consisted of the three groundwaterintercept wells, IW-1, IW-2 and IW-3, and the GWIP installed at the southern boundary of theLeMoyne site and the GWIP. These wells were installed to capture contaminated groundwater at thesite, prevent the migration of contaminated water off site and to capture contaminated groundwaterthat had migrated south of the site onto the adjacent CNA property.

As a result of the remedial design, the system was modified to include intercept wells IW-4,downgradient of the LeMoyne Landfill, IW-5, near Halby pond (both at the LeMoyne site), andintercept well CC-14 at the Cold Creek site. These wells, IW-5 and CC-14, were designed andinstalled to help speed up the remediation process because they intercept the contaminatedgroundwater close to the source area. The contaminated water would not have to be pulled across thesite to the original intercept wells. IW-4 was installed to capture potential plume from LeMoyneLandfill which had not been previously addressed.

LeMoyne intercept wells one through four discharge through the air stripper manifold system intothe GWIP and finally to surface water. IW-5, at the Halby Pond, discharges to the plants' wastewatertreatment plant and is eventually discharged to surface water. Well CC-14, at the Cold Creek site,discharges into a two column carbon treatment system and is discharged to surface water. Thecarbon column is switched from lead to lag column when the effluent tested is 5 parts per billion(ppb) molinate or higher. Over the past couple of years, the carbon columns are fouling out morefrequently, necessitating more changes from lead to lag column. The discharge streams for all of theextraction wells are monitored to insure that the requirements of the respective National PollutantDischarge Elimination System Permit (NPDES) are not violated.



The remedial action was completed in 1994. There have been no enforcement documents since theROD. On the Cold Creek site only, for OU-2, some excavated material from the Old NeutralizationPond was sent to Emelle for disposal. Most of the excavated material was mixed with fly-ash anddeposited in what is now known as the OU-2 Biopile (photograph 2 in Attachment 5). A spill ofcaustic soda in May 2002 also at Cold Creek resulted in 3 or 4 roll-offs of contaminated dirt that wasdisposed of at Emelle. Material contaminated with Dowtherm was disposed of during a constructionproject. There have been no CERCLA or non-CERCLA removals or responses at LeMoyne since theROD.

The systems have been working as designed since implementation, except for IW-4. IW-4 wasdesigned to capture contaminated groundwater from LeMoyne Landfill. Since the termination ofCourtaulds pumping in 2001 and 2002, groundwater flow direction has changed, and IW-4 is no longer capturing contaminated groundwater from the landfill as designed (see Figure 17 inAttachment 2). IW-3 does not appear to be capturing contaminated groundwater either, since thetermination of Courtaulds pumping in 2001 and 2002, as indicated by the decreasing trend incontaminant concentrations (see Figure 16 in Attachment 2).

OPERATION AND MAINTENANCE

O&M of the systems at Cold Creek site (Syngenta, formerly Zeneca) and LeMoyne site (AkzoNobel) are performed by in-house staff. Both sites are active chemical plants and the requiredmaintenance personnel are readily available.

The sites are operational chemical plants and proprietary products and processes are present at thesites. Site security is well maintained. Access to the sites requires viewing a safety video, a signingin procedure and an escort while on site. The sites are well protected from vandalism andunauthorized access.

O&M activities are conducted for OU-1 in accordance with the associated O&M plans. Detailsspecific to each site are presented below.

Cold Creek

O&M Overview O&M requirements for Cold Creek OU-1 are outlined in the O&M manual entitled' Zeneca Cold Creek Plant, Groundwater Treatment System' dated June 1994 Revised. O&M of thesystems includes monitoring the carbon adsorption beds, checking the equipment and associatedinstruments monthly, residual spent carbon handling, cleaning of the well on an as-needed basis,with documented recordkeeping. The site O&M manual includes a safety plan and emergencyprocedures. The O&M manual also explains the basis, purpose and intent of the groundwatertreatment system. The Groundwater Treatment System (GTS) is designed to remove Ordram(molinate) contamination from the groundwater in the area near the South Firewater Pond. Thecontamination source is believed to be the Old Neutralization Pond, north of the South FirewaterPond. Groundwater samples collected downgradient of the Old Neutralization Pond, showedmolinate concentrations in excess of the EPA cleanup goal of 14 micrograms per liter (µg/L). Inorder to accelerate the capture and removal of contaminated groundwater in this area, this GTS wasinstalled. The 'intercept' well, CC-14 was installed in 1992 by Geraghty and Miller in accordancewith the Final Phase II Intercept Well Design Report, designed for a pumping rate of 150 gallons perminute (gpm). This was the optimum discharge rate determined to be sufficient in capturing thecontaminated groundwater plume, according to a capture zone analysis. A centrifugal pump was



installed in the well to pump the water from the well. A set of guard filters were installed upstreamof the carbon adsorption towers to collect solids in the groundwater before processing through thecarbon bed. The system has two 10 foot diameter carbon beds operated in series so contaminant'breakthrough' can be checked after passing through the system. A flow meter with control roommonitoring is an integral part of the system, with alarms for flow issues, filter plugging, or othermalfunctions.

Carbon Adsorption System The carbon absorption beds are monitored for 'breakthrough' afterdischarge water from CC-14 is processed. Breakthrough is defined as having an outlet concentrationof 5 ppb molinate. When this occurs, the 'lead' carbon column is changed out, and becomes the ' lag'carbon column. The spent carbon is removed promptly, with a new carbon charge installed. Theguard filters are replaced after becoming plugged. Preventive maintenance is performed monthly,and the daily flow rate is reported to ADEM. The molinate concentration of the groundwater influentis monitored monthly. The efficiency of the carbon treatment is monitored by sampling the effluentfrom the system monthly. The effluent is discharged to the wastewater treatment plant, and allowedto co-mingle, before being discharged to Mobile River. ADEM Discharge Monitoring Reports(ADEM DMR's) are provided monthly to ADEM for the wastewater effluent discharged to thesurface water. A Discharge Monitoring Report containing daily GTS flow, minimum and maximumpH, monthly molinate concentration in the influent and effluent, and system downtime, aresubmitted semi-annually to the EPA Regional Project Manager (RPM). These discharge reportswere made available by the PRP for this five year review.

O&M Data At the Cold Creek site the carbon adsorption system underwent the first carbon reloadand tank switch in 1999 since the system went on line. The original carbon charge lasted 5 yearsbefore break through. The system design assumed an influent concentration of 200 ppb but theactual influent concentration the first five years was about 20 ppb, with the highest recorded at 31ppb. However, since 2000, the molinate concentrations increased from the concentrations of the firstfive years. See Figure 10 in Attachment 2 for a graph of molinate concentrations for 2000 to April2005. The highest influent molinate concentration recorded since 2000 is 82 µg/L in April 2004.

Each tank contains 20,000 pounds of carbon. The influent lines feeding the carbon columns areprotected by particulate filters that are changed on a weekly basis due to iron encrustation. Over thepast few years, the carbon column change-outs have become more frequent resulting in additionalO&M expense.. See Figure 10 in Attachment 2. Iron in the groundwater is suspected to be the causeof the frequent fouling of the carbon. The cost of a new carbon column is $13,000. Syngenta staff isconcerned about the frequency of the carbon changes and the associated costs, and are investigatingoptions for reducing. Other O&M activities the past 5 years include routine changes of bags in theguard filters, painting, guard filter repairs, well maintenance as needed, and replacement offlowmeter and transmitter.

The system is fed by extraction well CC-14, with discharge ranging from approximately 80 to 150gpm from a review of the records from January 2000 to February 2005. There has been a decrease inflow in the past few years. In reviewing flow records since 2000 to March 2005, the lowest flows of70 gpm were recorded in March and October 2004. In 2001 and 2002, the flows mainly rangedbetween 138 and 152 gpm. The target discharge rate is around 150 gpm, as determined by thecapture zone analysis. When the discharge rates show a decreasing trend, the pump and/or well areacid cleaned, and the flow rate (i.e. discharge) increases afterwards, but quickly drops back off tolower yields. This is particularly true for 2003 and 2004. The system averaged 3 or 4 down times peryear before year 2000 and each down time was less than 24 hours. In reviewing the records from



January 2000 through April 2005, down time was more frequent, with most down time under 24hours. There are numerous documented occasions since January 2000 when the system was downfor over 24 hours (January 2000, October 2000, December 2000, January 2001, July 2001,December 2002, June 2003, August 2003, February 2004, July 2004 and September 2004). Someminor down times are attributable to low availability of treated waste water with which to mix thedischarge from the GTS. In July 2004, a large 'cleaning' project was conducted. Griner DrillingServices was contracted to clean (with chemicals) the discharge line from well CC-14 to the carboncolumns and the well itself. The line was clogged with iron encrustation. This cleaning processinvolved several treatments, from July 12 through July 26, 2004. The cost for this cleaning wasaround $5,000.

LeMoyne

O&M Overview At the LeMoyne (Akzo) site system O&M are also conducted by on-site personnelas part of normal plant operations. O&M requirements for LeMoyne OU-1 is outlined in the O&Mplan entitled 'Operation and Maintenance Plan for the Groundwater Intercept and TreatmentSystems' dated July 1, 1996 revised February 23, 1998. The O&M plan explains the design of thetwo groundwater treatment systems, the daily operations of the systems, monitoring and control,regulatory requirements, well closure procedures, flow test and analysis procedures for the interceptwells, and guidelines for acid cleaning of lines, pumps, and wells. The O&M Plan includes a safetyplan and emergency procedures. The two systems are designated as the 'Groundwater InterceptSystem' and the 'Halby Intercept Well System'. The Groundwater Intercept System includes interceptwells IW-1, IW-2, IW-3, and IW-4, along with the GWIP, and all associated instrumentation, pipingand equipment. The GWIP has a working capacity of 3 to 4 million gallons of water. It is doublelined with a 30 mil PVC lower liner and a 36 mil reinforced chlorinated polyethylene upper liner.The water enters the pond through twelve, 1.5-inch stainless steel full cone spray nozzles. Eachnozzle is rated at 179 gpm at a pressure of 45 psi. This first stage of aeration removes the majority ofthe volatile organic compounds (VOC's). Additionally, up to four, mechanical direct drive floatingaerators, each driven by a 25 HP electric motor are used in the GWIP system to provide additionalVOC removal. The Halby Intercept Well System includes intercept well IW-5 and all associatedinstrumentation, piping, and equipment. Both systems discharge through the Plant's NPDESpermitted water effluent system.

O&M Tracking, Documentation At LeMoyne both internal and external labor perform operationsand maintenance on the groundwater system. These activities are tracked in a system calledMARCAM that houses all costs along with internal maintenance performed. External maintenance istracked through purchase orders and invoices for work performed under the purchase orderauthority. The orders contain basic details of work accomplished and the invoices identify whichsegment of the work was completed. Detailed paperwork of the O&M records for Akzo Nobel(LeMoyne) for the period January 2000 through December 2004 were provided by the PRP for thisreview.

Groundwater Intercept System This is a 'pump and treat' system, with 4 wells, originally designedwith 3 wells, to capture contaminated groundwater. The discharge water is treated in theGroundwater Improvement Pond, before being discharged to Mobile River. One well, IW-4, is onthe Courtaulds property, based on model predictions for best capture of the LeMoyne Landfillplume. The contaminants of concern (COCs) of this system are carbon tetrachloride, and carbondisulfide. The groundwater clean-up goals are 5 ppb for CCl4 (carbon tetrachloride) and 700 ppb forCS2 (carbon disulfide). The wells are screened in the lower aquifer, from about 70 to 120 feet below



ground surface. IW-1 target discharge rate is 324 gpm, IW-2 is 362 gpm, IW-3 is 360 gpm and IW-4is 350 gpm. Daily O&M activities include monitoring of the pumps, pipes, the GWIP in terms ofspray nozzles, aerators, flow meters, sampler, pond level and leak observation. The flow rates aremeasured daily by site personnel and the water is continuously sampled. In addition, there is a localpressure gauge on the water inlet line and a local level indicator for the pond level. Monthlymaintenance of vibration monitoring of the pumps is conducted, to determine trends. Groundwaterdischarge samples from each well, and notes on flow and pressure are checked monthly. Thesamples are analyzed for CCl4 CS2, pH, iron, chlorides and conductivity. MW-19 and 20 are purgedand sampled monthly. Other work is done on an 'as needed' and annual basis.

A review of the How data for 2000 through 2004 for IW-1, 2, 3, 4, and 5 was conducted. For IW-1,the average monthly flow was near the target discharge rate most of the time. For IW-2, the averagemonthly flow was near the target discharge rate for January 2000 through March 2003. In April2003 and May 2003, the well was down for more than 50% of the time. The flow rate for theremainder of the year was near the target rate, except for December. In 2004, the average monthlyflow rate overall was lower than in previous years, averaging between 80 and 90 percent of thetarget rate. For IW-3, the contaminant concentrations had a decreasing trend beginning in 2001,although the discharge rate had not changed. The start of the decreasing trend coincides with thetermination of Courtaulds groundwater extraction. IW-3 had problems maintaining the targetdischarge rate of 360 gpm beginning in 2003. IW-3 was down most of the time between August2003 and January 2004. Then between February 2004 and November 2004, the average monthlydischarge flow rate was less than 90% of the target discharge rate most of the time. It was down theentire month of December 2004. For IW-4, the average monthly discharge was near the target ratefrom January 2000 to November 2002. Beginning in January 2003 through December 2004, the flowwas approximately 80 to 90% of the target flow rate. Most of the average monthly discharge ratesfrom May 2003 through August 2004 were below the 'action' discharge flow rate of 305 gpm.

Aside from mechanical break downs, the primary maintenance problem at the LeMoyne site isencrustation of the well screens in wells IW-1, 2 & 3 and the discharge pipeline for well IW-4. Thescreens in wells 1 thru 3 are encrusted with a carbonate material causing a loss of efficiency in thesystem. The O&M Plan has specific procedures for the acid cleaning of the wells and protocols fortesting the gains in system efficiency after cleaning the well screens and pumps. IW-4 is affected byiron encrustation, particularly in the discharge line from the well to the GWIP. The discharge linehas been equipped with clean out ports at 500 foot intervals along the line. IW1 to 4 are equippedwith non-totalizing flow meters which are read daily by the shift supervisor. Well flows are totalizedat the GWIP.

The inner liner of the GWIP has been damaged by the suction at the manifold system. ADEM andEPA Region 4 are aware of the damaged liner. To maintain a check on the integrity of the outerpond liner, monitoring wells MW-19 and MW-20 are sampled monthly. The rationale being that ifcontamination is discovered in these heretofore clean wells then the outer liner has failed. Theprevious method of sampling whereby the extraction wells were shut down for one week per monthfor the MW-19 and 20 sampling has been terminated. Dedicated samplers were installed in bothwells, so the extraction wells are not shut down for the monthly sampling. Monitoring wells MW-19and MW-20 are located adjacent to the GWIP.

Halby Intercept Well System This well, IW-5, was added through the CERCLA process, to interceptcontaminants near the source, instead of pulling the contaminants across the site to IW-1, IW-2, andIW-3. This groundwater is discharged to the LeCreek wastewater treatment pond. The COCs of this



system are cyanide and thiocyanate. The groundwater clean-up goals are 200 µg/L for cyanide (CN-) and 200 µg/L for thiocyanate (SCN=). The daily O&M activities include pump monitoring,valves, piping, and aerators. Three times a week, the effluent is sampled for COCs. Pumpmaintenance is conducted as part of the flow testing, and on an as-needed basis. IW-5 is equippedwith a non-totalizing flow meter, which is read daily by the shift supervisor. For IW-5, from January2000 through February 2002, the average monthly discharge rate was slightly above the target flowrate of 83 gpm. From March 2002 to June 2004, the monthly average discharge rate was slightlybelow the target flow rate for most of the months. The monthly average discharge rate from July2004 to December 2004 was at the target discharge rate.

Total O&M Costs

Estimated total annual O&M costs from the FS for LeMoyne were $235,000 for the OU-1 remedy.Estimated O&M costs for Cold Creek were not provided. O&M costs presented in Table 4 for 2000through 2004 were provided by the PRPs.

The costs for Cold Creek/Syngenta in Table 4 reflect major expenditures (such as carbonreplacement), EPA oversight, new well installation, estimated labor and estimated power costs.Because the system is not complex and the site is an operational chemical plant, most of the minorcosts, such as the bags in the guard filters, are included in regular operational costs. Major costs arecharged against an established corporate reserve for remediation expense. The remainder of theO&M costs are included in the daily plant operations.

The costs for LeMoyne/Akzo Nobel in Table 4 reflect estimated power, estimated sampling andanalysis, and other unspecified O&M, excluding EPA oversight.

A direct comparison to the FS estimated costs is not possible since some O&M costs are included indaily plant operations, and in the case of LeMoyne, may be incorporated into the O&M for otherOU's at the site.

Table 4 O&M Costs

Years Total Cost Rounded to Nearest $1,000a

From To Cold Creek/Syngentab LeMoyne/Akzo Nobelc

2000 2001 $338,000 $226,000

2001 2002 $28,000 $216,000

2002 2003 $45,000 $241,000

2003 2004 $125,000 $244,000

2004 2005 $60,000 $274,000aMay not be reflective of total O&M costs, as some costs may be incorporated in dailyplant operations. bIncludes major expenditures, EPA oversight, estimated labor and electricity. cIncludes estimated electrical costs of $132K per year to operate GWIP and the interceptwells. Excludes all EPA oversight. Includes estimated costs of $1,500 per year forsampling and other unspecified O&M.



The OU-3 ROD was issued on September 17, 1993. The ROD calls for , among other things, theexcavation of contaminated soil from the Transition Zone area of the Cold Creek Swamp anddisposing the soil in the Upper Arm Swamp Zone. The Upper Arm would be capped. A proposal toamend the ROD to require the use of a new and invocative capping technology is under review.

The Cold Creek Plant OU-2 ROD was issued on August 16, 1995. The ROD calls for the excavationof a closed impoundment and bioremediation of the contaminated soils. The Remedial Actionworkplan was approved in 1998. The impoundment was excavated and a biopile was constructed .Treatment of the soil is underway.

The LeMoyne Plant OU-2 ROD was issued on March 18, 1999. The ROD calls for enhanced soilflushing to treat contaminated soil in the former Halby Pond Area. The Remedial Action Work Planwas approved in 2003.

V. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW

The protectiveness statement from the initial five-year review for the SCC sites was included afterthe Review Signature Cover page, from EPA signed June 02, 2000, and stated the following:

The remedy at OU-1 appears to be protective of human health and the environment. The water leveldata collected as a part of this site inspection indicates that the system maintains an inward gradientand appears to be capturing the plume. Without any long term water level data or any monitoringwell sample data, it is not possible to evaluate the performance of the system.

EPA provided recommendations for the following:

• Redevelop and function test all monitoring wells; • Collect a complete round of groundwater level measurements and construct a potentiometric

map of the sites; • Use the new data to calibrate the groundwater model (MODFLOW) and check model

predictions; • Designate detection monitoring/point of compliance (POC) wells; • Start quarterly collections of groundwater levels on all, or selected, wells and maintain

current plots of readings and an updated potentiometric map. All water levels should becollected on the same day;

• Institute a quarterly sampling program for POC wells; • Install dedicated samplers at MW-19 & MW-20 with system operating, analyze DI samples

for contamination; • Institute a review program to see if any monitoring wells can be closed/abandoned; • At the next scheduled maintenance install a drop tube in well CC-14; • Maintain access to wells in Cold Creek Swamp, and; • Locate, label and protect monitoring wells on CNA property.

EPA noted the following deficiencies:

• All monitoring wells at Cold Creek (Zeneca*) and CNA do not have locking steel protectivecasings or bollards; *(Zeneca is now owned by Syngenta)

• Monitoring wells at some locations are not labeled with well numbers, date drilled, depth,etc.;



• Monitoring wells are not being sampled to verify the progress of the cleanup; • Shutting down extraction well system at Akzo Nobel to collect samples from MW-19 &

MW-20.

Table 5 outlines the actions taken since the last five year review, with respect to recommendations inthe last five year review.

VI. FIVE-YEAR REVIEW PROCESS

The second five-year review was conducted by the USACE under guidance of the EPA RPM for theSCC sites. The five-year review process consisting of administrative and additional components,document review, data review, site inspection, and interviews, is described in the followingsubsections.

ADMINISTRATIVE COMPONENTS

The SCC sites five-year review was led by Laura Roebuck of the USACE, Mobile District. RossMcCollum, USACE Mobile District, led the initial five-year review for these sites.

During the week of 4 April 2005, Keith West of ADEM, Terry Bassett of Akzo Nobel and NickBurrows of Syngenta, the PRP's, and Mike Arnett, the EPA RPM were notified of the initiation ofthe five-year review for the SCC sites. At this same time, a site visit date of 14 April 2005 wasestablished as part of the five-year review process.

ADDITIONAL FIVE-YEAR REVIEW COMPONENTS

EPA requested the SCC sites five-year review include taking a round of water level readings byUSACE or the PRP on the same day or within 2 days, including a potentiometric map of both sites; acomprehensive groundwater evaluation; amount of extraction of IW-1, IW-2, IW-3, IW-4, and IW-5.EPA also stated this 5 year review should aim to satisfy the following objectives:

• Evaluation of the hydraulic control of the plume; • The effectiveness of the extraction system; • The protectiveness of human health and the environment.

Groundwater level readings were taken over the sites by the PRPs, on April 14, 2005. Uponanalyzing the results and plotting on a map, it was discovered that an insufficient number of waterlevel readings were obtained for the development of an accurate potentiometric map. The PRPsagreed to take additional water level readings in more wells, including the pumping wells over thesites, and wells on the former Acordis property, south of Akzo Nobel. One of the deficit areas ofwater level readings is south of Akzo Nobel's property line, formerly Acordis and Courtaulds, whichis now the property of North Mobile County Industrial Complex, owned by Mobile County.Arrangements were made with Mobile County to obtain water levels from select monitoring wellson their property. This will aid in the production of a better and more definitive potentiometric map.Rounds of water level readings over both sites, including additional wells on the North MobileCounty Industrial Complex, were taken on May 12, 2005, and in June and July 2005.


Second Five-Year Review Report, Stauffer Chemical Company sites. Cold Creek Plant and LeMoyne Plant, Bucks and Axis, Alabama

Table 5: Actions Taken Since the Last Five-Year ReviewIssues from

Previous Review Recommendations/Follow-up Actions

PartyResponsible

Action Taken and Outcome Date of Action

Monitoring wells Redevelop andfunction testmonitoring wells

Akzo Nobel All monitoring wells were redeveloped and tested. Records of this activity were/are available forreview on site. The water levels and well depths were taken before development. The wells werethen surged until sediment in the wells and on the well screens was removed. Surging continueduntil discharge water was clear. The turbidity, pH, and conductivity of the water was tested toassure stabilization. Water levels and well depths were remeasured after development. Thedrawdown and recovery of the wells were good. Comparison of water level readings for each wellin each measuring event indicates wells are still in good shape. Therefore, this action has achievedthe desired results.

October 2000& 2005

Syngenta No action taken. Syngenta stated in a follow-up letter to EPA dated May 2 2001 that Syngentaagreed that all monitoring wells must have sufficient recharge to yield representative samples, andthey will observe recharge rates during the sampling of the detection monitoring wells and replaceor redevelop any well having insufficient recharge. On April 11, 2005 Syngenta stated that theirmonitoring wells have good recharge, and they believe the wells are adequate.

n/a

Potentiometricmap

Construct apotentiometric map

Akzo Nobel/Syngenta

A round of water level readings was taken in many monitoring wells at both sites in November2000, and a potentiometric map was created. Since then, water levels have been taken at leastonce a year, except for 2001. Several potentiometric maps were developed by the consultants,using Surfer software.

November 2000

New modelpredictions

Use the new data tocalibrate the model,and check modelpredictions

Akzo Nobel Water level readings collected in June 2004 were used to calibrate the model, and the modelpredictions checked. This was provided to ADEM. A hard copy of the groundwater flow mapgenerated from this new data was provided during the site visit on April 14, 2005. The water levelreadings taken in May 2005 are being used to calibrate the model, to check groundwater flowsfrom various simulated pumping scenarios. This version is in draft form, and will provide moredetail of the groundwater flow in the area. The June 2004 model results provide more regionalgroundwater flow information covering the sites. Akzo Nobel is also planning to install moremonitoring wells around LeMoyne Landfill in 2005. The information gathered and resultsobtained from this effort will also be input into the model.

June 2004; andMay 2005(draft)



Issues fromPrevious Review

Recommendations/Follow-up Actions

PartyResponsible


Syngenta In a letter to EPA dated May 2, 2001, Syngenta stated that the water level readings taken by theCorps in June 1999 that enabled the Corps to state that 'the system appears to have maintainedhydraulic capture of the plume' and 'based on the elevations collected, the system appears to befunctioning as designed', and the potentiometric map created from the Nov 2000 groundwaterelevations is sufficient and appropriate to demonstrate continuing capture of the plumes. Syngentafurther stated that they will utilize a potentiometric map to determine the need for any futuremodifications to the intercept systems that may be appropriate due to changes in groundwaterwithdrawals within the sites and the nearby surrounding area.

n/a

POC wells Designate detection/POC wells

Akzo Nobel POC wells designated for OU-2. They are O-58, MW-3, and NM-1. They are designated in theO&M plan for OU-2, submitted in August 2001. They are also specified in the consent decree.They are sampled once a year. Semi-annual sampling is also conducted on wells NM-1, NM-2,O-55, O-58, MW-1, MW-2, MW-3, MW-4, MW-5, and MW-6. This has been conducted sincebefore 1999, and was an EPA requirement during the study of OU-2. No POC wells aredesignated for OU-1.

n/a

Syngenta POC wells are designated for OU-2, for the North Landfill, and Old Neutralization Pond. Newmonitoring wells were installed for the South Landfill due to the change in groundwater flowcaused by the termination of groundwater extraction from Courtaulds (property to the south ofLeMoyne) closure the end of 2001. The new wells were installed October/November 2003. NoPOC wells are designated for OU-1.

October/November 2003

Quarterlygroundwater levelreadings

Begin takinggroundwater levelreadings quarterlyon monitoring wells;maintain currentplots of readings andupdatedpotentiometric maps

Both sites Many rounds of water level readings have been taken, and many potentiometric maps produced.Groundwater level readings covering both sites have not been taken quarterly since the last 5-yearreview. Potentiometric maps were produced in November 2000, July 2002, March 2003, May2003, November 2003, May 2004, November 2004, April 2005, and May 2005 (covering bothsites). The May 2005 map included additional groundwater elevations from wells on the Acordisproperty.

October 2000

Akzo Nobel Akzo Nobel has taken monthly groundwater level readings of their wells (approximately 41 wells)since October 1999.





PartyResponsible


Syngenta In a letter to EPA dated May 2, 2001, Syngenta stated they propose to review area groundwaterwithdrawals on an annual basis. When there are significant changes in withdrawal patterns and/orrates, they will participate with the PRPs to reconstruct the potentiometric map and evaluatepollutant capture for the potentially affected groundwater intercept systems. However, manypotentiometric maps (created by Surfer) have been produced (listed above) since 2000.

Quarterlysampling of POCwells

Institute a quarterlysampling program forPOC wells

Akzo Nobel Akzo Nobel has been conducting semiannual sampling and analysis on wells NM-1, NM-2,MW-1, MW-2, MW-3, MW-4, MW-5, MW-6, O-55 and O-58 for many years (at least since April2000). They have also been conducting annual sampling and analysis (as a separate action) onwells O-58, NM-1 and MW-3 since 2002. Quarterly sampling is not conducted.

n/a

Syngenta Syngenta has been sampling semiannually since 2001. In a letter to EPA dated May 2, 2001,Syngenta stated they feel semiannual sampling of the POC wells is sufficient to evaluate theefficacy of the closure of the three waste management units that require long-term monitoring.Quarterly sampling is not conducted.

n/a

MW-19 and 20sampling

Install dedicatedsamplers inMW-19and MW-20;and analyze D1samples forcontamination

Akzo Nobel Dedicated samplers were installed. This action achieved the desired results, as the intercept wellsare no longer shut down monthly for long periods (days), to conduct sampling.

October 2000

Monitoring wellclosure

Institute a reviewprogram to determineif any monitoringwells can be closed/abandoned

Akzo Nobel A review was conducted before 2000, and it was determined that two wells could be closed. O-6and O-20 were closed in January 1999. Since then, it has been determined that O-7, O-71, andO-72, and some other RCRA wells need to be closed. After the ADEM RCRA FacilityAssessment (RFA) investigation is completed, Akzo Nobel will review all the existing wells toevaluate which of these are no longer necessary for monitoring programs, and can therefore beclosed. This evaluation and investigation is tentatively planned to be completed this year. Thenthe corrective measures implementation report is planned to be completed in 2006 or 2007. Thewells presently identified as needing closure are scheduled to be closed out with the other wellsthat will be identified as described above. In summary, all identified wells (current andsoon-to-be-identified) will be closed under the same action, due to the high cost of closing out/abandoning wells. EPA/ADEM closure procedures are outlined in OU#1 O&M plan.

n/a





PartyResponsible


Syngenta In a letter to EPA dated May 2, 2001, Syngenta stated that all their wells are used, whether forsampling or groundwater elevations. Syngenta proposed to perform annual reviews of allmonitoring wells and plug and abandon any that do not provide relevant detection monitoring,groundwater elevation or other useful data. In another letter and report to EPA dated January 28,2003, Syngenta reports an evaluation of the groundwater monitor well network and proposedchanges. The abandonment of four wells was proposed, due to concerns over well integrity andwell construction. The proposed wells, O-5, O-26, MW-13 and MW-14 were abandoned inFebruary and October 2003.

January 2003

CC-14 waterlevels

Install a drop tube inCC-14

Syngenta A drop tube was currently in CC-14 at the time of the first 5 year review, as stated in a letter toEPA dated May 2, 2001.

n/a

Cold CreekSwamp wellsaccess

Maintain access towells in Cold CreekSwamp

Akzo/Syngenta In a letter to EPA dated May 2, 2001 , Syngenta contends that reasonable access to these wellsexists, and they will continue to provide reasonable access under normal weather conditions.

n/a

CNA wells Locate, identify andprotect the CNAwells

Akzo/Syngenta The PRPs located the CNA wells that were identified during the 1999 COE site visit for the firstEPA 5 year review. These wells were shortly thereafter labeled, protected with protective casingsand where necessary with protective posts, locked, and identified. The protective casings andposts were painted safety yellow. Photos of representative wells were taken during the site visit,and implemented actions achieved the desired results. (Photographs 13 and 14 in Attachment 5.)

October 2001



DOCUMENT REVIEW

This second five-year review consisted of a review of relevant documents including decisiondocuments, monitoring reports and maps, site inspection reports, and O&M records. Attachment 1provides a list of all documents reviewed for this effort.

DATA REVIEW

Historical water level readings and Surfer-generated potentiometric maps were reviewed. Since theshutdown of Courtaulds' production wells in 2000, 2001 and 2002, groundwater flow direction haschanged. The remedial investigation, remedial design, and ROD were based on groundwater flowdirection towards the south. The ROD states that a contingency plan is necessary if pumping of theCourtaulds wells is terminated. Groundwater elevations have increased up to approximately 24 feetin some areas. Historical data for groundwater contaminant concentrations in the POC and extractionwells were reviewed through December 2004, or April 2005 for some wells, based on currentARARs for the sites. On the Cold Creek Plant site, contaminant concentrations were relatively lowin the POC wells, but still exceeding groundwater clean-up goals, compared to analyses on samplescollected in October 2004, where extremely high concentrations were detected. Molinateconcentration in the extraction well is still high, well above the cleanup goal of 14 µg/L. However,in comparing to groundwater elevations and monitoring of other wells in the vicinity, the extractionsystem seems to be containing the plume. On the LeMoyne Plant site, contaminant concentrations inIW-1, 2, 3, 4, and 5 still exceed the groundwater clean-up goals, in analytical data reviewed forJanuary 2000 to December 2004. The potentiometric maps indicate that for IW-1, IW-2, and IW-3,the system is containing the plume. See 'Operations and Maintenance' subsection, in Section IV,Remedial Actions for additional O&M data.

Contingency Plan

At the September 1999 meeting of the first five-year review, EPA, Zeneca (now Syngenta) and AkzoNobel agreed to conduct a capture zone analysis if any changes occurred in the groundwater system,including changes to the Acordis (Courtaulds) operation. The capture zone analysis would determineif the groundwater capture systems were adequate. The contingency plan was also discussed in aMay 2, 2001 letter from Syngenta (formerly Zeneca) to EPA. The PRPs agreed (p. 2) thatpotentiometric maps would be used to determine the need for any future modifications to theintercept systems that may be appropriate due to changes in groundwater withdrawals within thesites and the nearby surrounding area. The PRPs also proposed to review area groundwaterwithdrawals on an annual basis. When significant changes occurred in withdrawal patterns and/orrates, potentiometric maps would be reconstructed and pollutant capture by the groundwaterintercept systems would be evaluated. After the 2001/2002 shutdown of the Courtaulds (Acordis)production wells, the contingency plan was put into action. Akzo Nobel and Syngenta obtained sitedata to define groundwater movement at each site. Akzo Nobel submitted a site-specificgroundwater model to ADEM as part of its' response to a RCRA Corrective Action. Currently AkzoNobel is fine-tuning this same model for overall site evaluation. Upon completion, Akzo Nobel willsubmit the results to EPA and ADEM. Syngenta did relocate monitoring wells in 2003 based onchanges in the groundwater flow due to the termination of Courtaulds groundwater extraction. Thedetails of this modification are outlined in Syngenta's January 13, 2004 report to EPA. Akzo Nobelis currently gathering additional data for the model. New monitoring wells will be installed east ofthe LeMoyne Landfill. Data gathered from this action will be used in the model. Groundwater



equilibration over the sites occurred in 2003, therefore data gathering and modeling results are stillunderway.

Groundwater Elevations, and Potentiometric Maps

In the 1980's and 1990's, during which time the remedial investigation and remedial design weredeveloped, the groundwater flow direction on the sites was strongly influenced by the groundwaterextraction to the south, at Courtaulds. The groundwater flow direction on Cold Creek and LeMoynesites was to the south towards the Courtaulds production wells. However, since the last five-yearreview, Courtaulds shut down their 14 production wells in 2001 and 2002, which produced 8 to 10million gallons per day (MOD). Ten of the 14 wells were shut down between June and October2001. Two production wells on Tencel's property, adjacent to Courtaulds, were shut down inDecember 2001, but restarted some time later when the plant reopened. Due to 8 to 10 MOD ofgroundwater no longer being extracted south of the sites, the regional groundwater flow direction onAkzo's and Syngenta's properties changed from south towards the Courtaulds pumping wells, backto the natural groundwater gradient towards Mobile River, east-southeast of the sites. (See Figures 3,4 and 5 in Attachment 2.) Localized groundwater flow regimes are created by pumping andextraction wells on each site. Prior to the termination of Courtaulds groundwater extraction, this wasnot the case.

In reviewing the potentiometric maps through April 2005, it was determined there were insufficientdata points/water level readings for the area east of the sites to Mobile River, and south of theproperty line, which falls on the northern part of N. Mobile County Industrial Complex.Arrangements were made with Mobile County and Environmental Strategies Consulting LLC to takewater level readings from wells on the northeastern part of the Mobile County property. Water levelreadings from additional wells on the LeMoyne Plant site and the Cold Creek Plant site, includingthe pumping wells, were also planned. On May 12, 2005, another round of water level readings wastaken on all three sites. The increased number of readings was intended to assist in the developmentof a more accurate potentiometric map, which is necessary in determining the potential for offsitegroundwater migration. With the historical number of readings taken (pre May 2005), it would bedifficult to determine with certainty the flow of the groundwater east of the sites, and south of thesites. The potentiometric maps generated by Surfer provided by the consultants to the PRPs through2004, may not be showing the true groundwater elevation contour lines, due to the small number ofreadings, particularly east and south of the sites. Unfortunately, the May 2005 round of water levelreadings did not include many more usable data points than previous water level readings events.

The May 2005 potentiometric map has data gaps on the Acordis/Mobile County property and theeastern part of Akzo Nobel's property (LeMoyne) that should be filled in for future potentiometricmaps and groundwater modeling. For the June and July 2005 readings, additional wells wereincluded that do not appear on the May 2005 map. Accurate grid coordinates, measuring pointelevations and well logs should be obtained for the Acordis wells in Table 6 below. It isrecommended that these wells be incorporated into the quarterly water level readings events andgroundwater models for determining placement of new extraction and monitoring wells. The futurewater level readings for the development of quarterly potentiometric maps should be taken in thesame wells as the May 12, 2005 readings, the Acordis wells, additional Syngenta (Cold Creek Plant)piezometers, and all the pumping wells. All other known available good wells for readings in thearea, including any other wells in good shape south of the LeMoyne site, should also be taken andincorporated in future groundwater modeling and the development of potentiometric maps.



Table 6 Acordis wells to obtain groundwater elevations

Monitoring wells Process wells Observation wells

MW-1 PW-5 OW-1

MW-2 PW-6 OW-7

MW-4 PW-9

MW-6 PW-13

MW-7

MW-10

MW-15

MW-21

MW-23

MW-24

MW-26

MW-29

MW-30

The May 2005 and November 2004 maps indicate the possibility of a groundwater elevation high,northeast of the GWIP. This groundwater elevation high cannot be confirmed nor delineated with theexisting information. It is recommended that O-50, O-51, and O-52 be redeveloped, cleaned, and/orresurveyed for ensuring the proper functioning of the wells, to better determine the groundwaterflow direction in this area. Anomalous groundwater elevation readings for P-13 on Cold Creek sitewere observed for many of the water level reading events. It would be worth investigating the sourceof the anomaly.

In reviewing groundwater elevation change on the sites since Courtaulds terminated 8 to 10 MODgroundwater extraction, through April 14, 2005, groundwater elevations rose dramatically.Elevations increased from about 11' in wells O-23 and MW-6 east and northeast of LeMoyneLandfill, respectively, and close to Mobile River; 14' in the northern part of Syngenta's site (farthestnorth from Courtaulds pumping wells); and approximately 18' to 24' in wells on Akzo's property.The equilibrium of the change in flow and elevation seems to have been attained in 2003. SeeFigures 11, 12, and 13 in Attachment 2. The groundwater elevations of selected wells in localizedareas were graphed. These graphs show the increase in groundwater elevation in the area, since thetermination of Courtaulds groundwater extraction in 2001/2002.

The regional groundwater flow now appears to be towards Mobile River, with localized groundwaterflow regimes caused by pumping wells. As a result, IW-4 is probably capturing groundwater fromthe south and/or southwest, as opposed to capturing contaminated groundwater from the northeast,from LeMoyne Landfill, as intended by the remedial design. This theory correlates with the trend ofdecreasing contaminant concentrations in IW-4 and NM-1, since mid 2001, as discussed below. Thischange in flow also has an effect on the placement of monitoring wells including detection and POC



wells. At the time of installation of MW-19 and MW-20, groundwater flow in this area wassouthward. MW-19 and MW-20 were installed south of the GWIP for monitoring for potentialcontaminant leaks due to the breach in the GWIP liner. These wells should be relocateddowngradient of the GWIP.

Contaminant concentrations Cold Creek Plant (Syngenta) Overall, the concentrations in the groundwater on this site wererelatively low or non-detects in the POC wells, until October 2004, when a large increase incontaminant concentrations (thiocarbamates) occurred in MW-16, a downgradient shallow well, justupgradient of the intercept well, CC-14. The analytical results for the October 2004 sampling ofMW-16 are shown in Table 7, as compared to the clean-up goals. In comparing to a potentiometricmap of this area, and observing the low concentrations in the remaining POC wells in the immediatevicinity, it appears that the groundwater extraction system is effectively capturing and containing theplume. Additional monitoring wells were installed in 2003 due to the change in groundwater flow.Some wells were also abandoned at the same time. The groundwater extracted from CC-14 isprocessed through the carbon adsorption treatment system. Molinate concentrations of this water areanalyzed monthly before the inlet of the system, and checked at the outlet. During the first five-yearreview period, the molinate concentrations were around 20 ppb, with the highest recorded level at 31ppb. The molinate concentrations were higher during this review period (2000 to 2004) than theprevious five-year review period (1995-1999). The molinate concentrations ranged in values up to82 ppb since the last five year review. See Figure 10 in Attachment 2 for a graph of molinateconcentrations for this five-year review period. The highest molinate concentration was 82 µg/L inApril 2004. The concentrations still exceed the clean-up goal of 14 µg/L.

Table 7 Thiocarbamate concentrations, October 2004

Cold Creek (Syngenta) MW-16, downgradient, shallow well Thiocarbamate Concentration, µg/L Cleanup goal, µg/L

Esprocarb < 1 n/a

Molinate 218 14

Butylate 27 350

EPTC 117 210

Prosulfocarb 7 n/a

Cycloate 207 7

Vernolate 22 7

Pebulate 64 7

LeMoyne Plant (Akzo Nobel) In reviewing the contaminant concentrations in the intercept wells,except for IW-4, contaminants still exceed the cleanup goals. POC wells are not designated forOU-1, so the analytical results for the intercept wells and the OU-2 POC and other sampled wellswere reviewed. Graphs of contaminant concentrations were prepared for MW-5, and each interceptwell. See Figures 14 through 19 in Attachment 2. For IW-1 and IW-2, the clean up goals wereexceeded for each sampling event for the past five years (January 2000 through December 2004,



Figures 14 and 15 in Attachment 2). Analytical results for RFA Area of Concern (AOC)(specifically AOC-A Vertical Storage Tank #4) carbon disulfide data for nested wells O-36 (deeperwell) and O-37 near IW-1 and IW-2 were reviewed. In November and December 2003, the carbondisulfide concentrations were 378,000 µg/L for O-36 and 232,000 µg/L for O-37. A spill of carbondisulfide occurred near, these wells in the 1990's. These concentrations far exceed the cleanup goalof 700 µg/L for carbon disulfide. For IW-1, the carbon disulfide concentration for late 2003 wasaround 8,000 µg/L. For IW-2, the concentration was between 6,000 and 16,000 µg/L. (See Figures14 and 15 in Attachment 2.) For IW-3, carbon disulfide concentration was below the clean up goalfor most of the same period. Only for several months from late 2000 to mid 2001 did the carbondisulfide concentration exceed the clean up goals. For carbon tetrachloride concentration in IW-3,the clean up goal was exceeded during the entire period. However, a decreasing trend in bothconcentrations was observed for IW-3, beginning in mid 2001, coinciding with the start of thetermination of Courtaulds groundwater extraction. See Figure 16 in Attachment 2. This trend is anindication that IW-3 is not capturing contaminated groundwater as designed. This could be due tothe termination of Courtaulds pumping with the resultant change in groundwater flow direction, andthe increased groundwater elevation of about 24' in this area. For IW-4, carbon disulfideconcentration was negligible during the entire period. See Figure 17 in Attachment 2. For the carbontetrachloride concentration, the clean up goal was exceeded during most of the period. The IW-4graph shows the decreasing trend in carbon tetrachloride since mid 2001, which correlates with thetheory that IW-4 is no longer functioning as designed (i.e. capturing the groundwater from the area,LeMoyne Landfill, as intended by the remedial design) due to the change in groundwater flow.NM-1 is a POC well that was installed as a LeMoyne Landfill downgradient well. Decreasingcarbon tetrachloride concentration is also observed in this well since mid 2001, from 41.8 µg/L inApril 2001 to < 5.0 µg/L in the October 2001 through April 2004 sampling events. MW-5 wasinstalled as an 'upgradient' well from LeMoyne Landfill, although in 2000 this well showed carbontetrachloride concentrations of 235 µg/L, with a clean up goal of 5 µg/L. This concentrationdecreased sharply in 2001, and continued to decrease through the October 2004 sampling event. SeeFigure 18 in Attachment 2. These trends indicate that the plume may be moving elsewhere, as aresult of the termination of Courtaulds groundwater extraction and the resultant change ingroundwater flow direction to the east. NM-2 is a monitoring well near LeMoyne Landfill, and itslocation with respect to the landfill is now probably cross gradient. For half of the sampling eventssince April 2000, carbon tetrachloride concentrations exceeded the clean-up goals, with 18 µg/Lbeing the highest concentration level. A trend in contaminant concentration from 2000 to 2004 wasnot observed for NM-2. For IW-5, the thiocyanate concentrations exceeded the cleanup goals forevery sampling event from late 2002 to end of December 2004, while the concentrations for cyanideexceeded the clean up goals for only a few sampling events from mid 200J to mid 2003. See Figure19 in Attachment 2. Decreasing contaminant concentration trends since 2001 are not observed inIW-1, IW-2, and IW-5, as they are for IW-3 and IW-4 (see Figures 14, 15, 16, 17, and 19 inAttachment 2).

The results for other monitoring wells were also reviewed. For the three OU-2 POC wells, NM-1,MW-3, and O-58, the annual sampling results for the years 2002, 2003 and 2004 resulted in nondetects for all thiocarbamate sampling events except for 2. The contaminant levels in these 2 eventswere well below the clean up goals. Carbon tetrachloride concentrations in MW-3, a downgradientshallow well, west of the Old Brine Mud Pond, showed a decreasing trend of 7 µg/L in 2002, 5.2µg/L in 2003, and a non detect in 2004. This decreasing trend correlates with the semi-annualsampling trend for carbon tetrachloride discussed below.



Carbon tetrachloride concentrations for 2000 through 2004 were reviewed for the other monitoredwells that are sampled semi-annually. For MW-5, as discussed above, a decreasing trend inconcentration is observed, from 235 µg/L in April 2000 to 45.7 µg/L in October 2004. A sharpdecrease in the trend occurred after the October 2001 sampling event. This coincides with thetermination of Courtaulds pumping. MW-5 was installed as an upgradient deeper screened well, butis now probably cross gradient. MW-3 showed a decreasing trend from 26.7 µg/L in April 2000 to anon detect in October 2003. This is a downgradient shallow well. MW-1, MW-2, MW-4, and MW-6were predominantly non-detects. Site investigations should be conducted near LeMoyne Landfill todelineate the carbon tetrachloride plume and extent of contamination. Mercury was monitored inMW-2, MW-3, O-55 and O-58. Only a few events showed detections, all well below the clean upgoal of 2 µg/L.

MW-19 and MW-20 were installed downgradient of the GWIP to monitor for possible leaks in theGWIP liner due to a breach. These wells are sampled and analyzed monthly for carbon disulfide andcarbon tetrachloride. Contaminants have not been detected in MW-19 and MW-20. However, due tothe change in groundwater flow direction, these wells may no longer be downgradient of the GWIP.

SITE INSPECTION

The site inspection was conducted on 14 April 2005. Attendees included Nick Burrows (Syngenta,Cold Creek), Paul Stefan [Environmental Resources Management (ERM), consultant to Syngenta],Terry Bassett (Akzo Nobel, LeMoyne), Sylvia Williams (Akzo Nobel, LeMoyne), Laura Roebuck(USACE), and Ross McColIum (USACE). The purpose of the inspection was to assess theprotectiveness of the remedy. Notes and observations from the site inspection were recorded on theSite Inspection Check List provided in Attachment 4. Photographs were taken by Laura Roebuckand are provided in Attachment 5.

The fencing around the property was undamaged and functional. All locks and gates are in properworking condition. Warning signs are posted along the fence line. The access roads on site aremaintained and in good condition.

Many groundwater monitoring wells, extraction wells, and piezometers were seen during the siteinspection. All appear to be in good condition. The monitoring wells are identified, have protectivecasings, are locked, are painted yellow, and where necessary have protective posts. The new bio-pilecover at Syngenta was observed. The carbon adsorption treatment system was visited, with lots ofiron staining on the apparatus and on the concrete surface in the immediate vicinity. The unnamedtributary, the Groundwater Improvement Pond, the New Brine Mud Pond, LeMoyne swamp, MobileRiver, and the North Mobile County Industrial complex wells (aka CNA wells) were among thefeatures surveyed. Photos of many wells and other features are provided in Attachment 5.

The O&M activities are supporting the remedy at the SCC sites, and unexpected changes in O&Mscope or cost have not occurred to suggest ineffectiveness of the remedy.

INTERVIEWS

During the five-year review process, the PRPs and the state regulator for the sites were interviewedin April, May and June 2005 concerning the SCC sites. The issues discussed were the change ingroundwater flow direction due to the termination of Courtaulds groundwater extraction (primarily



in 2001); the amount of extraction from the 'intercept' wells on both sites; the problems that the excessive iron in the groundwater is causing in the lines and in the wells; IW-4 no longer 'capturing'the remedial design intentions due to the change in groundwater flow direction; and the possibleaddition of newly placed wells to enhance capture of the contaminants and monitoring wells due tothe change in groundwater flow direction since the last five-year review.

The PRPs and state regulator interviewed expressed satisfaction with the remedy, O&M, monitoringresults, and rapport between all of the involved parties. A few issues were raised, as mentionedabove.

The issue of the increased carbon fouling and associated cost of the carbon adsorption system onSyngenta's site is being addressed by Syngenta staff. The excessive iron in the groundwater issuspected to be the cause of the frequent fouling.

VII. TECHNICAL ASSESSMENT

The following Questions A, B, and C were answered to provide a technical assessment of the siteremedy.

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

Remedial Action Performance

The remedy for OU-1 at the SCC sites is functioning as designed to protect human health and theenvironment except IW-4. This conclusion is based on the review of site documents, groundwaterand monitoring data, ARARs, risk assumptions, and results from the site inspection. Operationaldata for evaluating the protectiveness of the remedial actions for OU-2 at Cold Creek and OU-2 atLeMoyne are not available as the remedial actions are underway.

The remedial action for OU-1 appears to be functioning as intended except for IW-4 and IW-3. IW-4was designed to capture groundwater contamination from LeMoyne Landfill. Due to the change ingroundwater in the area since Courtaulds terminated 8 to 10 MOD groundwater extraction, thegroundwater flow direction changed, which affects the proper placement of IW-4. The trend ofdecreasing carbon tetrachloride concentrations from spring 2001 through 2004 correlates with thistheory. The trend of decreasing contaminant concentration levels in IW-3 combined with theincrease of approximately 24' in the groundwater elevation and change in groundwater flow mayindicate that this well is not at the optimum location to capture the plume.

Due to the presence of contamination in MW-5, which is north-northeast of LeMoyne Landfill (not a'downgradient' well), indicates that contamination is not being captured in this area and thatcontamination may migrate to the river. The groundwater treatment system at Cold Creek, and IW-1,IW-2, and IW-5 at LeMoyne appear to be capturing contaminated groundwater. From a review ofthe potentiometric maps, it appears that IW-1 and IW-2 are preventing southward offsite migrationof contaminated groundwater. The contaminant concentrations do not appear to be decreasing inthese intercept wells.



System Operations and O&M

The site inspection, document review, and interviews with the PRPs demonstrated the O&Mactivities have been conducted in accordance with the ROD and O&M Plans. All O&Mrequirements are adequate for the site and are being implemented properly. No unexpected changeshave occurred in cost or scope of the O&M to suggest compromised effectiveness of the remedy.

Frequent fouling of the carbon columns in the Cold Creek carbon adsorption system is costly. Thecause of fouling needs to be determined and a method to reduce the fouling implemented. Seediscussion below in "Opportunities for Optimization" that addresses this issue.

Opportunities for Optimization

Opportunities for optimization were identified during this review.

For IW-1, IW-2, and IW-3, the mutual interference of these wells, and the resulting effects on thenearby monitoring wells, made it impossible to evaluate the well efficiency of any of these interceptwells, as well as the zone of influence of each intercept well. For IW-4, the groundwater influencefrom Mobile River had an effect (interference) on the monitoring wells in the vicinity, so anevaluation was not possible. An evaluation of both would be helpful in establishing optimumextraction rates, after intercept well relocations.

The change in groundwater flow direction towards Mobile River indicates that additional monitoringwells may need to be located to determine the effectiveness of the groundwater treatment systems.Quarterly groundwater level readings across Cold Creek, LeMoyne and the Mobile County propertywells should be taken. More wells across the three sites should be used for developingpotentiometric maps, as discussed in 'Data Review' in Chapter VI. This includes the groundwaterelevations in all pumping wells. These readings should be used in future groundwater modeling andthe development of quarterly potentiometric maps. All wells included in future groundwater levelreadings events for the development of potentiometric maps and modeling data should be in goodworking order with accurate measuring point elevations. Groundwater modeling and potentiometricmaps should be used to determine new well placement. MW-19 and MW-20 need to be relocateddowngradient of the GWIP. All wells included in the development of future potentiometric mapsshould be cleaned and redeveloped as necessary. All wells without accurate measuring pointelevation surveys should be resurveyed for same.

This change in groundwater flow direction may also necessitate the relocation of intercept wells.New intercept well locations should be determined by analysis of potentiometric maps andgroundwater modeling. Well efficiency and the zone of influence for each intercept well should alsobe determined for establishing optimum pumping rates.

The vertical and lateral extent of the groundwater plumes at the LeMoyne Landfill are not fullydefined. The groundwater/surface water interface in the area of the Landfill are also not fullyunderstood. Due to the presence of carbon tetrachloride in 'upgradient' (now cross gradient) wellMW-5, east of LeMoyne Landfill, site investigations should be conducted to delineate the plume.Monitoring wells should be installed to monitor contaminant concentrations. Decreasing carbontetrachloride concentration is observed during the period of record reviewed, from April 2000 toDecember 2004. A sharp decrease in the concentration trend is noted after the October 2001sampling event, coinciding with the termination of Courtaulds groundwater extraction, indicating



that the plume may have moved. Corrective action measures should be established after delineation,and after the groundwater/surface water interface in the area is understood.

IW-4 does not appear to be capturing the groundwater as intended by the remedial design.According to Sovereign's groundwater model, and the November 2004 and May 2005 potentiometricmaps, IW-4 appears to be capturing groundwater from the Mobile County property (formerCourtaulds and Acordis property), instead of groundwater downgradient of the LeMoyne Landfill.Actual groundwater flow direction should be established to properly locate the new intercept welland monitoring wells. The decreasing contaminant concentration trend in IW-3 that began mid 2001,at the time when the Courtaulds pumping ceased, should be investigated, to determine if IW-3 isproperly located and capturing the plume, as intended. In reviewing the flow records for IW-3, achange in discharge rate was not observed in 2001 to account for the decreasing contaminantconcentrations. IW-3 may also need to be relocated to a more optimum location.

The reporting limit for most of the carbon tetrachloride analysis is 5 µg/L. The clean up goal forcarbon tetrachloride is also 5 µg/L. The reporting limit for carbon tetrachloride for future analysisshould be lower, no more than 2.5 µg/L. Good practice and Department of Defense requirements forproject reporting limits should be no more than half of the regulatory value (i.e. cleanup goal). Thereporting limits for the other analytes exhibit good practice values.

The frequent fouling of the carbon in the Cold Creek GTS is very costly. Syngenta staff is lookinginto remedies. Excessive iron in the groundwater is suspected to the cause. The groundwaterdischarge rate should be evaluated to determine if the amount of discharge can be reduced whilecontinuing to capture the plume. Intercept well efficiency and a measure of the zone of influencewas attempted as part of this review. However, there was not enough information at this level ofeffort to determine. An analysis of a sample of the fouling on the carbon to determine itscomposition may aid in correcting the problem. It should also be analyzed to determine if it iscalcium or iron. The cleaning method that has been used over the years may have becomeineffective. A change in well rehabilitation may improve operation of the well and/or system. Ifiron-reducing bacteria are becoming established in the well, filter pack and surrounding formation,acid treatment alone may not control the regrowth of iron bacteria and they can eventually result incomplete plugging of the aquifer around the well. As a first step, the well water could be tested usinga Biological Activity Reaction Test (BART) kit to determine the type and activity level of anybacteria in the well.

Groundwater contaminant plume maps should be developed annually or in alternating years to betterunderstand the impact of the changes in groundwater flows and to assess the effectiveness of thesystem at capturing the plume.

Permanent labeling of the monitoring wells by dye stamping on stainless steel or aluminumidentification (id) plate with all well information is recommended. These id labels should be affixedto the outer casing, on the exterior, by pop rivets. The well identification information should include:

• Well number/name • Measuring point elevation • Well depth • Screened interval (feet and elevation) • Date installed



Early Indicators of Potential Issues

The change in groundwater flow direction and the increase in groundwater elevation (by up to 24' insome locations) in the area affects the proper placement of intercept wells, particularly IW-4 andIW-3, and monitoring/POC/detection wells.

The change in groundwater flow direction also presents a potential environmental risk for MobileRiver and LeMoyne Swamp. The groundwater flow direction from the sites is now towards MobileRiver. Proper placement of monitoring/POC/detection wells is recommended for monitoring forcontamination downgradient of the source areas.

MW-5 was installed as an upgradient (deeper zone) well for LeMoyne Landfill, however, for theperiod of record reviewed for this five year review from 2000 through 2004, the carbon tetrachlorideconcentrations were very high. The highest concentration was 235 µg/L in April 2000 decreasing to45.7 µg/L in October 2004, which is still above the clean up goal of 5 µg/L. LeMoyne Landfill is thesource area nearest to Mobile River. This high contamination level in MW-5 indicates a potentialenvironmental risk. The groundwater/surface water interface in this area is also not fully understoodto be able to evaluate the potential for possible discharge of contaminated groundwater to MobileRiver and/or LeMoyne Swamp.

The increased frequency of carbon change outs at the Cold Creek Groundwater Treatment System iscostly. Excessive levels of iron in the groundwater is suspected to be the cause of the rapid foulingout of the carbon charges.

Implementation of Institutional Controls and Other Measures

Institutional controls include in-house operational guidelines and procedures, the stipulations forproperty use in the OU-1 Consent Decree (1990), and ADEM drinking water regulations. Some ofthe controls and measures are discussed here.

At the present time, individual exposure via the ingestion of contaminated groundwater is notoccurring. Cold Creek (Syngenta) supplies its own drinking water under ADEM permits from wellsCC-11 and 13 on the western part of the property. They are upgradient of the groundwatercontamination. ADEM samples and analyzes the water. All analyses are within limits, most belowdetection level. Three monitoring wells, P-12, P-13, and O-27, act as sentinel wells between the siteareas of groundwater impact and the water supply wells. These wells have been analyzed twice forthiocarbamates and once for volatiles. Analyses results have been below detection levels. Thesentinel wells will continue to be monitored on a periodic basis.

LeMoyne (Akzo Nobel) uses LeMoyne Public Water Supply for all drinking fountains, sinks inbathrooms, kitchens, breakrooms, toilets and showers, except emergency showers and eyewashstations. Some industrial type sinks on loading racks and in some shops are not on this 'city' water.LeMoyne has three water supply wells on site that are used for production/process water andemergency showers and eyewash stations. These are identified as LM-6, LM-7, and LM-10. For welllocations, see Figures 2, 3, 4, and 5. These wells are analyzed for constituents that need to bemanaged for production water quality, but not site-specific contaminants. LM-7 and LM-10 wellsare identified in the ROD as drinking water wells for 230 employees. There are no cross-connectionsbetween the city water supply and the production well water supply.



Plant operational controls are in place for any connections from city water back to production wellwater. A plant procedure called 'Management of Change', also known as 'MOC', is required tochange a system. All departments within the plant identified as requiring input to any specificproposed change is required to thoroughly review the proposal to determine if the proposed changewould be detrimental to the operations. All appropriate departments must sign off on the proposedchange with the plant manager providing final signature for final approval. An approved 'MOC'would be required for making connections currently supplied by municipal water back to productionwell water.

In the OU-1 Consent Decree in 1990, paragraph 25 prohibits certain activities by any future ownersat the sites, including:

1. Interference with the performance of the Work*; 2. Use of the property in a manner which would adversely affect the integrity of the

groundwater intercept and treatment system or the function of any groundwater monitoringsystem required in accordance with the Consent Decree;

3. Placement of any drinking water wells on the property prior to the completion of the Work; 4. Placement of drinking water wells into any solid waste management unit on the property.

*The 'Work' as referenced above in item no. 1 means the pre-design, remedial design, constructionand implementation, including operation and maintenance, and monitoring of the response actiondescribed for the groundwater OU-1 in the ROD, and any modifications, and in any schedules orplans required to be submitted pursuant to the Scope of Work. Akzo Nobel (LeMoyne) and Syngenta(formerly IC, Cold Creek) completed their requirement to file a notice of consent decree shortly afterissuance.

Although the 1988 EA stated it was unlikely that the State of Alabama in this case would permit adrinking water well in this area, this was not the case at that time, nor is it the case today. The Stateof Alabama would not deny a permit for a drinking water well in the area. The State of Alabamarequires a Notice of Intent to Drill a Well (ADEM Form 60, May 2002) to be submitted by the welldriller 10 days prior to a well being drilled. Once the well is completed, the well driller must submita Certification of Completion (also ADEM Form 60, May 2002) to the State (ADEM). ADEMinputs this data into their database and sends a copy of the certificate of completion to MobileCounty Health Department. For larger municipal wells, a permit to drill a well would not be denied,but the raw water quality from any completed well in any area must meet state guidelines fordrinking water before the well can be used. If the water analysis detects contamination below theMCL for any constituent, water sampling and analysis may be required more frequently. If the rawwater quality exceeds a MCL, treatment of the water to meet State guidelines would be requiredbefore the well water could be used.

No activities were observed that would have violated the institutional controls. No new uses ofgroundwater were observed. The site access controls are strict, and fencing with signs surround thesites. Some areas are further restricted by locked gates.

QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA,CLEANUP LEVELS, AND REMEDIAL ACTION OBJECTIVES USED AT THETIME OF THE REMEDY STILL VALID?



Changes in Standards

RAOs established in the ROD were also reviewed and compared to current ARARs. The cleanuplevels established in the ROD have not changed for the SCC sites. (See Table 3 of this document,which is Table 8.1 in the ROD.) A comparison was made of the 1989 ROD MCL values used ascleanup criteria for the sites. The only changes made to MCL values since 1989 was thepromulgation of an MCL for cyanide, 200 µg/L. However, the new MCL for cyanide is the same asthe cleanup goal listed in Table 8.1 of the ROD (Table 3 in this document). The listed cleanupcriteria of 200 ppb for cyanide is, therefore, still considered protective. No further evaluation of thecyanide cleanup level is required per EPA's five-year review guidance.

Changes in Exposure Pathways

The COCs remain the same, as well as the land and human usage of resources. A new ecologicalexposure route is the flow of groundwater from the sites to Mobile River and LeMoyne Swamp. Aset of nested wells are cross gradient of LeMoyne Landfill, the source area closest to Mobile River.The analytical results for these two wells, MW-5 and MW-6, for 2000 through 2004 were reviewed.The results show a decreasing trend in carbon tetrachloride in MW-5, a well screened in the deeperzone of the surficial aquifer. Carbon tetrachloride concentration was 235 µg/L in April 2000, withdecreasing values to 45.7 µg/L in October 2004. This concentration level is still well above thecleanup goal of 5 µg/L for carbon tetrachloride. MW-6, a well screened in the shallower zone of thesurficial aquifer, was predominantly non detects, although the reporting limit of 5 µg/L is the sameas the cleanup goal. A full understanding of the groundwater flow direction, its relationship to thecorrect location of monitoring and intercept wells, and the groundwater/surface interface in the areais necessary to evaluate the potential for possible discharge of contaminated groundwater to thesurface water.

Water from production wells. LM-7, and LM-10 (LeMoyne) is not a new exposure pathway. WellsLM-7 and LM-10 are identified in the ROD as drinking water wells for 230 employees, althoughthese wells are no longer used as drinking water wells. City water from LeMoyne Public WaterSupply is used for domestic water at LeMoyne Plant. Water from production well LM-6 (LeMoyne)may be a new exposure pathway. Due to the change in groundwater flow direction in the last fewyears, LM-6 may now be downgradient of contaminated groundwater from Cold Creek Plant site.See Figures 2 through 6 for the location of LM-6, southwest of Cold Creek Plant. LM-6 is notmonitored for any site-specific contaminants (i.e. thiocarbamates). This production well, and LM-7provide most of the production water for Akzo Nobel plant operations. LM-10 is used as a back-upwell. In addition to being used for production water, water from these wells are also used for someindustrial type sinks, emergency showers, eyewash stations, and a car wash. As a result, this wellwater is a potential exposure risk to plant workers.

Vapor intrusion in buildings near the contaminant plumes is also a new potential exposure pathway.In November 2002, EPA published new guidance on vapor intrusion. Evaluations may be necessaryto determine if vapor intrusion issues per the EPA guidance document poses a new risk to humanhealth at each site.

Changes in Toxicity and Other Contaminant Characteristics

Toxicity factors and other characteristics for COCs have not changed at the site to affect theprotectiveness of the remedy. Reference Doses (RfDs) and Cancer Slope Factors (SF) listed in ROD



Table 6.1 (1989) were compared to current values found in IRIS, HEAST and ReregistrationEligibility Decisions (R.E.D.). Values listed for most COPCs in the Table were essentiallyunchanged. The LHA for butylate has not changed. Newly identified RfDs for cycloate and pebulatedo not bring into question the protectiveness of toxicity factors used in the ROD.

Changes in Risk Assessment Methods

Standardized risk assessment technologies have not changed in a way that could affect theprotectiveness.

Expected Progress Towards Meeting RAOs

Thirteen years of a 30 year groundwater monitoring period have elapsed, and from this review it isunknown if the remedy is progressing as expected. Monitoring of the groundwater should continueto assess the progress of the remedy, and should continue until ARAR's are met.

QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THATCOULD CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY?

No other information has been identified during this five-year review that calls into question theprotectiveness of the remedy. A potential environmental risk to Mobile River and LeMoyne Swampis present due to the change in groundwater flow from the sites to Mobile River. It appears thatgroundwater is being contained by the intercept wells, except for IW-4. IW-3 also appears to nolonger be capturing contaminated groundwater as intended by the remedial design, as indicated bythe decreasing trend in contaminant concentration since 2001. LeMoyne Landfill is the source areain closest proximity to Mobile River. MW-5 was installed as an 'upgradient' well to LeMoyneLandfill, a deeper screened well. However, this well is probably cross gradient now. This well hascarbon tetrachloride contaminant concentrations above the clean-up goals. However, the shallowerzone nested well, MW-6, shows no carbon tetrachloride contamination (above 5 µg/L) from October2001 through 2004. Groundwater use is restricted, and site access is restricted. The communities andresidences that use groundwater in the immediate area are upgradient of the groundwater flowdirection of the sites.

TECHNICAL ASSESSMENT SUMMARY

According to the data review, site inspection, and interviews, the remedy for OU-1 is functioning asintended by the ROD, except for IW-4. Due to the change in groundwater flow at the site since theremedial design and the last Five Year Review, IW-4 is no longer capturing groundwater from thearea intended by the design. IW-3 does not appear to be optimally located to capture the plumeeither, as a result of a review of water quality analysis from this well over the last few years, whichindicates decreasing capture of contamination. Intercept and monitoring wells may need to berelocated as a result. Cold Creek Plant site relocated some of their monitoring wells as a result of thechange in groundwater flow direction. LeMoyne Plant site is planning to install more wells nearLeMoyne Landfill at time of press. The remedy for OU-1 seems to be containing the plume near thesource. The exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of theremedy are still valid. A potential environmental risk is present due to the change in groundwaterflow towards Mobile River since the last five-year review. MW-5, a deeper screened well, close toMobile River, shows carbon tetrachloride concentrations above clean up goals. However, the nested



well, MW-6, screened in the shallower zone of the aquifer, does not show carbon tetrachloride contamination above clean up goals. The groundwater/surface water interface in the area of theLeMoyne Landfill is not fully understood. This interface needs to be better understood to evaluatefor the potential for contaminated groundwater discharging to surface water. A potential humanhealth risk for workers exists due to the potential for vapor intrusion in structures near contaminantplumes, per EPA guidance on vapor intrusion of November 2002. A potential human health risk forworkers exists due to the location of LM-6 production well. Due to the change in groundwater flowdirection over the last few years, this well is now possibly downgradient of the Cold Creek Plantsite. This well water is not monitored for site-specific contaminants, and is used for Akzo Nobelproduction water and in some industrial type sinks, a car wash, emergency showers, and eyewashstations. No other information was found during the five-year review of the SCC sites to indicate theremedy is not protective.

The remedial actions for OU-2 at Cold Creek and OU-2 at LeMoyne are in progress. Therefore,during the next Five Year Review, operational data for these actions should be evaluated for theirprotectiveness.

VIII. ISSUES

Table 8 presents issues to be addressed for ensuring protectiveness at the SCC sites.

Table 8 Issues

IssueCurrently Affects

Protectiveness(Yes/No)

Affects FutureProtectiveness

(Yes/No)

Quarterly potentiometric maps, using more data points. No Yes

Relocating intercept and monitoring wells as necessary. FW-4 is no longercapturing contaminated groundwater from LeMoyne Landfill as designed.MW-19 and MW-20 may not be downgradient of GWIP. The plume nearLeMoyne Landfill is not delineated, as MW-5, an 'upgradient' well, showsCCl4 concentrations above the clean up goal. Groundwater/surface interfacein this area is not understood.

No Yes

Reporting limit of 5 µg/L for CCl4 is too high. No No

Excessive carbon changes in Cold Creek carbon adsorption system. No No

Decreasing contaminant concentrations in IW-3 since mid 2001. No Yes

Permanent well identification tagging. (See page A3-13 for details) No No

Contaminant plume map is needed for assessing the impact of the changes ingroundwater flow and effectiveness of contaminant capture.

No No

Operational data for LeMoyne OU-2 and Cold Creek OU-2 for evaluatingtheir protectiveness are not available as the remedial actions are underway.

No Yes

LM-6 (LeMoyne) production well is a new potential exposure pathway, asthis well may now be downgradient of the Cold Creek Plant site.

No Yes

Vapor intrusion concerns in areas near the plumes are not addressed. No Yes Stauffer Chemical Company Five-Year Review.doc 35 December 2005


IX. RECOMMENDATIONS AND FOLLOW-UP ACTIONS

Table 9 provides recommendations and follow-up actions to address the issues presented in SectionVIII, and other deficiencies.

Table 9 Recommendations and Follow-Up Actions

Issue Recommendations/Follow-up Actions PartyResponsible

OversightAgency

MilestoneDate

AffectsProtectiveness?

(Yes/No)

Current Future

The use of more datapoints in developingpotentiometric maps.

Groundwater level readings should be obtainedin more wells throughout the SCC and Acordissites. This includes ensuring all wells used forthe development of potentiomctric maps are ingood working order with accurate measuringpoint elevations.

PRPs EPA December2007

No Yes

Relocating intercept andmonitoring wells asnecessary, based onbutter establishment ofgroundwater flowdirection and futuremonitoring.

After better establishing groundwater flowdirection with continued monitoring, interceptand/or monitoring wells may need to berelocated.

PRPs EPA June 2007 No Yes

IW-4 is no longercapturing contaminatedgroundwater fromLeMoyne Landfill.

Determine proper placement of IW-4. PRPs EPA December2007

No Yes

MW-19 and MW-20may no longer bedowngradient of GWIP.

Relocate MW-19 and MW-20 downgradient ofGWIP.


Plume near LeMoyneLandfill is not delineatedas MW-5, an'upgradient' well showsCCI4 concentrationsabove clean-up goal.Groundwater/surfacewater interface in thisarea is not understood.

Conduct site investigations near LeMoyneLandfill to delineate vertical and lateral extentof the plume. Determine groundwater/surfacewater interface in this area to evaluate possibledischarge of contaminated groundwater toMobile River.


Reporting limit of 5µg/L for carbontetrachloride is too high.

Adjust reporting limit of CCl4 to no more than2.5 µg/L.

PRPs EPA June 2006 No No



Table 9 (continued) Recommendations and Follow-Up Actions

Issue Recommendations/Follow-up Actions PartyResponsible

OversightAgency

MilestoneDate

AffectsProtectiveness?

(Yes/No)

Current Future

Excessive carbonchanges in carbonadsorption system.

Determine remedy for excessive fouling ofcarbon columns in Cold Creek GTS. The wellwater should be tested using a BART kit todetermine the type and activity level of bacteriain the well, particularly if the problem is Febacteria. Sufficient testing should be conductedto determine the water chemistry for tailoring aneffective treatment process of the well, filterpack, and/or formation, as needed. A sample ofthe fouling on the carbon should also beanalyzed to determine the chemicalcomposition, to assist in determining correctiveaction. The sample should be analyzed todetermine if it is iron or calcium.


No No

Decreasing contaminantconcentrations in IW-3since mid 2001.

Evaluate IW-3 for possible relocation. PRPs EPA June 2007 No Yes

Permanent wellidentification tagging.

Prepare dye stamped aluminum or stainless steelid tags with well information for each well. (Seepage A3-13 for details.) Affix to exterior casingof each well.


No No

Lack of contaminantplume map.

PRP's construct plume maps on an annual oralternating annual basis.


No No

Operational data forOU-2 for evaluatingtheir protectiveness arenot available as remedialactions are underway.

During the next Five-Year Review, operationaldata for the LeMoyne OU-2 and Cold CreekOU-2 should be evaluated for theirprotectiveness.


No Yes

LM-6 (LeMoyne)production water well isa new potential exposurepathway, as this wellmay not bedowngradient of theCold Creek Plant site.

LM-6 water quality sampling and analysisshould include site specific contaminants (e.g.thiocarbamates).


Vapor intrusionconcerns in areas nearthe plumes arc notaddressed.

Per the November 2002 EPA guidance on vaporintrusion, the PRP's should evaluate thepotential for vapor intrusion and determine if apotential risk exists at their respective sites.




X. PROTECTIVENESS STATEMENT

The remedy at OU-1 appears to be protective of human health and the environment in the short termsince there is no evidence of currently complete exposure pathways to contaminated groundwater.Operational data for the LeMoyne OU-2 and the Cold Creek OU-2 remedial actions will beevaluated during the next Five Year Review to determine their protectiveness. The potentiometricmaps developed and reviewed since 1999 indicates the system maintains an inward gradient.Monitoring data indicate the remedy for OU-1 is functioning as required, except for IW-4. Apotential environmental risk is present due to groundwater contamination near LeMoyne Landfilland the fact that groundwater flow from the sites is now towards Mobile River. In order to verifyprotectiveness, groundwater monitoring should continue until 2022, or until ARAR's are met. Thegoal is to meet the groundwater cleanup values listed in Table 3 at each of the designated detectionmonitoring wells and the extraction (intercept) wells. In order for the remedy to remain protective inthe long term, the recommendations identified in this Five-Year Review need to. be addressed.

XI. NEXT REVIEW

The next five-year review for the Stauffer Chemical Company Sites is required to be completedwithin five years of the signature date of this report.


ATTACHMENT 1

LIST OF DOCUMENTS REVIEWED

Stauffer Chemical Company Five-Year Review.doc A1-1 December 2005


Documents Reviewed

Acordis. Well logs and other information on Acordis wells MW-1, MW-4, MW-6, MW-15, MW-21, and MW-26.

Akzo Nobel Functional Chemicals LLC. 2000-2004. ADEM Discharge Monitoring Reports. Monthly beginning January 2000 through December 2004.

Akzo Nobel Functional Chemicals LLC. 2000-2004. Groundwater Improvement Pond Source Sampling Records January 2000 to December 2004; Intercept Well Daily Flowrates records,

January 2000 to December 2004.

Akzo Nobel Chemicals, Inc. 1996. Groundwater Intercept and Treatment Systems, Operations and Maintenance Plan, 1 July 1996, revised February 23, 1998.

Akzo Nobel Functional Chemicals LLC and Syngenta Crop Protection, Inc. 2004. Groundwater Contour Map, prepared by URS, Mobile, Alabama, for May 4, 2004.

Akzo Nobel Functional Chemicals LLC. 2000. Groundwater Contour Map, prepared by URS,Mobile, Alabama, for November 7, 2000.

Akzo Nobel Functional Chemicals LLC and Syngenta Crop Protection, Inc. 2004. GroundwaterContour Map, prepared by URS, Mobile, Alabama, for May 4, 2004.

Akzo Nobel Functional Chemicals LLC. 2005. Groundwater Elevation Contour Map, prepared by Sovereign Consulting Inc., Robbinsville, NJ, for May 12, 2005.

Akzo Nobel Functional Chemicals LLC and Syngenta Crop Protection, Inc. 2000-2005. Water level readings for November 7, 2000, November 30, 2004, December 2, 2004, April 14, 2005, May

12, 2005, May 19, 2005.

Akzo Nobel Functional Chemicals LLC. 2002-2004. Groundwater sampling results for OU-2 annual sampling.

Akzo Nobel Functional Chemicals LLC. 2000-2004. Groundwater sampling results for OU-2 semi-annual sampling.

Akzo Nobel Functional Chemicals LLC. 2003-2004. Groundwater sampling results for carbon disulfide for RCRA CA for AOC M, Vertical 4. November 2003, December 2003, and October

2004.

Akzo Nobel Functional Chemicals LLC. 2000-2004. Groundwater sampling results for Intercept Wells, IW-1, IW-2, IW-3, IW-4, and IW-5.

Akzo Nobel Functional Chemicals LLC. 2000-2004. Operations and Maintenance System, Costs and Work Performed data, January 2000 to December 2004.

ATSDR. 1989. Health Assessment for Stauffer Chemical Company National Priorities List Sites, Mobile, Alabama, January 6, 1989.



EPA. 1989. EPA Superfund Record of Decision: Stauffer Chemical Company (LeMoyne Plant), EPA ID: ALD008161176, OU-1, Axis and Bucks, AL, September 27, 1989.

EPA. 1989. EPA Superfund Record of Decision: Stauffer Chemical Company (Cold Creek Plant), EPA ID: ALD095688875, OU-1, Axis and Bucks, AL, September 27, 1989.

EPA. 2001. Comprehensive Five-Year Review Guidance, EPA 540-R-01-007, OSWER No. 9355.7-03B-P, June 2001.

ERM. 2004. Well Installation and Sampling Report, Syngenta Crop Protection, Inc., Cold Creek Facility, Bucks, Alabama, January 13, 2004.

ERM. 2003. Evaluation of Monitor Well Network and Proposed Changes, Syngenta Crop Protection, Inc., Cold Creek Facility, Bucks, Alabama, April 4, 2003.

ERM. 2003. Notification and Work Plan for Well Plugging and Abandonment of Four Groundwater Wells, Syngenta's Cold Creek Facility, Bucks, Alabama, January 28, 2003.

ERT. 1988. Remedial Investigative Report for the Cold Creek/LeMoyne Site, Mobile County, Alabama.

ERT. 1988. Endangerment Assessment Report Cold Creek/LeMoyne Site, Mobile County, Alabama, May 1988.

Environmental Strategies Consulting LLC. 2005. Groundwater Monitoring Program, Quarterly Monitoring Program, Quarterly Report #1 of 12, Fourth Quarter 2004, May 12, 2005.

Syngenta Crop Protection, Inc. 1999-2004. ADEM Discharge Monitoring Reports. Monthly beginning December 1999 through December 2004.

Syngenta Crop Protection, Inc. 2001. Letter to EPA, Response to Initial Five-Year Review, May 2, 2001.

Syngenta Crop Protection, Inc. 2001-2004. POC groundwater well sampling and analysis records, April 2001 to October 2004.

Syngenta Crop Protection, Inc. 2002. Long Term Maintenance and Monitoring Plan, Cold Creek Superfund Site, OU-2, March 2002.

Syngenta Crop Protection, Inc. 2000-2005. Groundwater Treatment System Analytical Summary, and Monthly Data Sheets, January 2000 to April 2005.

USACE. 2000. Initial Five-Year Review, Stauffer Chemical Company Sites, Cold Creek Plant and LeMoyne Plant, for OU-1, June 2000.

Zeneca Agricultural Products. 1994. Zeneca Cold Creek Plant, Groundwater Treatment System, Operation and Maintenance Manual, June 1994, revised.


ATTACHMENT 2

FIGURES


North Mobile County

^ •,"'.. / ':i\ A '"̂ -̂• * / ' / . * • ' • . • ^ - * —

Staufteir ChsmicalxCompany SKiss

\J

Location Map

Stauftor CttsmJcol Company Sites Axto and Buchs, Alabama

Figure 1. Location map of Stauffer ChemicalCompany Sites, North Mobile County, Alabama

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ATTACHMENT 3

SITE INSPECTION CHECK LIST


Site Name: Stauffer Chemical CompanySites (Cold Creek and LeMoyne)Location and Region: Axis and Bucks,AlabamaAgency, office or company leading thefive-year review:U.S. Army Corps of Engineers

Date of Inspection: 14 April 2005

EPA ID: ALD095688875 (Cold Creek) &ALD008161 176 (LeMoyne)Weather/temperature:Very sunny, temps in the 60's, cool winds

I. SITE IN FORMATION

Remedy Includes (Check all that apply)I I RCRA cover/containment[~~1 Access controlsPI Institutional controls[XI Groundwater pump and treatmentI | Surface water collection and treatmentD Other

I I Monitored natural attenuationI I Groundwater containment[~~1 Vertical barrier walls (slurry wall)

[Xj Inspection team roster provided in five-year review reportIXI Site map provided in Attachment 2

II. INTERVIEWS (Check all that apply)

1. O&M Site Manager N/A

Interviewed I I at site I I at office |~~| by phone Phone no.Problems, suggestions; I I Report attached

2. O&IM Staff N/A

Interviewed | | at siteProblems, suggestions;

at office | | by phone Phone no.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 environmentalhealth, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in allthat apply.

Agency: Alabama Department of Environmental ManagementContact: Keith West ^ Environmental Engineer 5 April 2005 & 16 June 2005

Name Title DateProblems, suggestions: IXI Report provided in Attachment 4

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4. Other Interviews:

o Nick Burrowso Terry Bassett

IXI Reports provided in Attachment 4

PRP - SyngentaPRP - Akzo Nobel

April to June 2005April to June 2005

III. DOCUMENTS & RECORD VERIFIED (Check all that apply)

.1. O&M DocumentsKl O&M Manual1X1 As-built drawings1X1 Maintenance Logs

Remarks

Readily availableReadily availableReadily available

Up to dateUp to date D N/AUp to date Q N/A

2. Site-Specific Health and Safety Plan ^ Readily available [X] Up to date Q N/A

Contingency Plan/Emergency Response Plann N/ARemarks

Readily available IXI Up to date

3. O&M and OSHA Training Records [X] Readily available (XI Up to date Q N/A

Remarks

4. Permits and Service Agreements

I I Air Discharge Permit I I Readily available I I Up to date [XI N/A13 Effluent discharge [El Readily available [>3 Up to date O N/An Waste disposal, POTW D Readily available Q Up to date £3 N/AOOther permits I I Readily available I I Up to date 1X1 N/A

Remarks:

5. Gas Generation RecordsQ Readily available D Up to date [El N/ARemarks

6. Settlement Monument Recordsn Readily available D Up to dateRemarks

N/A

A3-4Stauffer Five-Year Revicw.doc Oecember 2005

7. Groundwater Monitoring Records[X] Readily available £3 Up to date D N/ARemarks: POC well, quality data, and water level readings and potentiometric maps

8. Leachate Extraction RecordsO Readily available I I Up to date 1X1 N/ARemarks

9. Discharge Compliance RecordsD Air D Readily available D Up to date [X] N/A[X] Water (effluent) [X] Readily available £<] Up to date D N/A

Remarks: ADEM discharge monitoring reports

IV. O&M COSTS

1. O&M OrganizationI I State in-house I I Contractor for State[X] PRP in-house D Contractor for PRPD Other

2. O&M Cost Records1X1 Readily available [XI Up to dateI | Funding mechanism/agreement in place[3 Original O&M cost estimate: $235,000 for LeMoyne

Total annual costs provided for 2000 through 2004. 1X3 Breakdown provided infive-year review report.

3. Unanticipated or Unusual ly High O&M Costs During Review PeriodDescribe costs and reasons: For Syngenta (Cold Creek), the carbon adsorptiontreatment system has experienced frequent fouling, particularly over the past year orso. The carbon for each column costs $13,000. Syngenta is looking into solutions tothis problem. The excessive iron in the groundwater is suspected to be causing thefrequent fouling.

V. ACCESS AND INSTITUTIONAL CONTROLS

A. Fencing

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1. Fencing damaged Q Location shown on map ^Gates secured [XI N/ARemarks: Fences in good condition.

B. Other Access Restrictions

1. Signs and other security measures | | Location shown on map | | N/ARemarks: Site security is well enforced. Access requires viewing a safety video, a si.gn-in

procedure, badge, and an escort while on site. The sites are well protected fromvandalism and unauthorized access.

C. Institutional Controls (ICS)

1. Implementation and enforcementSite conditions imply ICs not properly implemented I I Yes ^ No | | N/ASite conditions imply ICs not being fu l ly enforced Q Yes ^ No [ I N/A

Type of monitoring (e.g., self-repotting, drive by) The sites are operational facilitieswith day-to-day operations.Frequency Daily by onsite securityResponsible party/agency Svngenta and Akzo NobelContacts: Terry Bassett PRP - Akzo Nobel (251)675-1310

Nick Burrows PRP-Svngenta (251)675-0950Name Title Phone no.

Reporting is up-to-date ^Yes d]No ON/AReports are verified by the lead agency [>^Yes QNo I |N/A

Specific requirements in deed or decision documents are met IXlYesI |No| |N/AViolations have been reported OYesONo IOther problems or suggestions: I I Report attached

2. Adequacy ^ ICs are adequate I I ICs are inadequate Q N/ARemarks:

D. General

1. Vandalism/trespassing | | Location shown on site map [XI No vandalism evidentRemarks

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2. Land use changes on site 1X1 N/ARemarks

3. Land use changes off site ^ N/ARemarks

VI. GENERAL SITE CONDITIONS

A. Roads [X] Applicable I I N/A

1. Roads damaged Q Location shown on site map^ Roads adequate | | N/ARemarks: Access roads on the site are in good condition.

B. Other Site Conditions [j Applicable [Xj N/ARemarks

VII. SOIL COVERS/RCRA Cap D Applicable [EJNot Applicable

A. Cap Surface [~1 Applicable QNot Applicable

1. Settlement (Low spots) I I Location shown on site map I I Settlement not evidentAreal extent DepthRemarks

2. Cracks I I Location shown on site map | | Cracking not evidentAreal extent Widths DepthsRemarks

3. Erosion I I Location shown on site map | | Erosion not evidentAreal extent DepthRemarks

4. Holes I I Location shown on site map [ I Holes not evidentAreal extent DepthRemarks

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5. Vegetative Cover I I Grass | | Cover properly established I I No signs of stressRemarks

6. Alternative Cover (armorecRemarks

rock, concrete, etc.) [ | N/A

7. Bulges 1 1 Location shown on site map I I Bulges not evidentAreal extent HeightRemarks

8. Wet Areas/Water DamageI | Wet AreasI | Ponding1 I Seeps1 I Soft subgradeRemarks

I Wet areas/water damage not evident1 Location shown on site map Areal extent

1 I Location shown on site map Areal extentI 1 Location shown on site map Areal extentCH Location shown on site map Areal extent

9. Slope Instability1 I Slides | | Location shown on site map | | No evidence of slope instability

Areal extentRemarks

B. Benches C

C. Letdown Channels Q

D. Cover Penetrations Q

] Applicable [[]Not Applicable

] Applicable QNot Applicable

] Applicable ONot Applicable

E. Gas Collection and Treatment I I Applicable QNot Applicable

F. Cover Drainage Layer Q

1. Outlet Pipes Inspected QRemarks

] Applicable QNot Applicable

U Functioning QNot Applicable

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2. Outlet Rock Inspected | | Functioning []Not ApplicableRemarks

G. Retention/Sedimentation Ponds I I Applicable QNot Applicable

1. Siltation Areal extent Depth I [Not Applicable| | Siltation not evidentRemarks

2. Erosion Areal extent DepthI I Erosion not evidentRemarks

3. Outlet Works I I Functioning QNot ApplicableRemarks

4. Dam | | Functioning QNot ApplicableRemarks

H. Retaining Walls I I Applicable QNot Applicable

I. Perimeter Ditches/Off-Site Discharge I I Applicable QNot Applicable

VIII. VERTICAL BARRIER WALLS D Applicable IE1 Not ApplicableI I Location shown on site map (Figure 1 in Attachment 2)

1. Settlement | | No evidence of settlementAreal extent Depth

Remarks

2. Performance Monitoring | | Performance not monitoredType of MonitoringFrequency | | Evidence of breachingHead differentialRemarks

IX. GROUNDWATER/SURFACE WATER REMEDIES

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A. Groundwater extraction wells, pumps and pipelines1X1 Applicable | | Not Applicable

B. Surface water collection structures, pumps and pipelinesO Applicable IXI Not Applicable

1. Collection Structures, Pumps and ElectricalI I Good condition | | Needs O&M

Remarks

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and OtherAppurtenances

I I Good condition I I Needs O&MRemarks

3. Spare Parts and Equipment

I | Readily available | | Good ConditionI | Needs to be provided | | N/A

Remarks:

Requires upgrade

C. Treatment System Applicable Not Applicable

D. Monitoring Data

1. Monitoring Data|^ Is routinely submitted on time Is of acceptable quality

E. Monitored Natural Attenuation | | Applicable Not Applicable

1. Monitoring Wells (natural attenuation remedy) I I N/A|~l Properly secured/locked I I Functioning | | Routinely sampledI | Good condition | | All required wells located |~~| Needs O&M

Remarks:

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X. OTHER REMEDIES

Applicable [XI Not Applicable

XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

The groundwater intercept and treatment systems appear to be containing the plume andcapturing contaminants, except for IW-4. Decreases in contaminant concentrations are notevident from the records reviewed. Due to the change in groundwater flow direction sincethe last 5 year review, IW-4 does not appear to be capturing the groundwater from thesource area as intended.

B. Adequacy of O&M

O&M activities are adequate for the site. The site inspection demonstrated the O&Mactivities have been carried out in accordance with the ROD and O&M Plans. The O&Mactivities are supporting the remedy at the sites.

C. Early Indicators of Potential Remedy Problems

The change in groundwater flow direction and the increase in groundwater elevation (byup to 24' in some locations) in the area also effects the proper placement of intercept wells,particularly for IW-4 and possibly for IW-3, and monitoring/POC/detection wells.

The change in groundwater flow direction presents a potential environmental risk forMobile River. The groundwater flow direction from the sites is now towards MobileRiver. Proper placement of monitoring/POC/detection wells is recommended formonitoring for contamination downgradient of the source areas.

MW-5 was installed as an upgradient well for LeMoyne landfi l l , however, for the periodof record reviewed for this five year review from 2000 through 2004, the carbontetrachloride concentrations were very high. The highest concentration was 235 ug/L inApril 2000 decreasing to 45.7 ug/L in October 2004, which is stil l above the clean up goalof 5 ug/L. LeMoyne landf i l l is the source area nearest to Mobile River. This highcontamination content in MW-5 indicates a potential environmental risk.

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D. Opportunities for Optimization

Opportunities for optimization were identified during this review.

For I'W-1, IW-2, and IW-3, the mutual interference of these wells, and the resulting effectson the nearby monitoring wells, made it impossible to evaluate the well efficiency of anyof these intercept wells, as well as the zone of influence of each intercept well. For IW-4,the groundvvater influence from Mobile River had an affect (interference) on themonitoring wells in the vicinity, so an evaluation was not possible. An evaluation of bothwould be helpful in establishing optimum extraction rates, after intercept well relocations.

The change in groundwater flow direction towards Mobile River indicates that additionalmonitoring wells may need to be located to determine the effectiveness of the groundwatertreatment systems. Quarterly groundwater level readings across Cold Creek, LeMoyneand the Mobile County property wells should be taken. More wells across the three sitesshould be used for developing potentiometric maps, as discussed in 'Data Review' inChapter VI. This includes the groundwater elevations in all pumping wells. Thesereadings should be used in future groundwater modeling and the production of quarterlypotentiometric maps. All wells included in future groundwater level readings events forthe development of potentiometric maps and modeling data should be in good workingorder with accurate measuring point elevations. Groundwater modeling andpotentiometric maps should be used to determine new well placement. MW-19 and MW-20 need to be relocated downgradient of the GWfP. All wells included in the developmentof future potentiometric maps should be cleaned and redeveloped as necessary. All wellswithout recent measuring point elevation surveys should be resurveyed for same.

This change in groundwater flow direction may also necessitate the relocation of interceptwells. New intercept well locations should be determined by analysis of potentiometricmaps and groundwater modeling. Well efficiency and the zone of influence for eachintercept well should also be determined for establishing optimum pumping rates.

The vertical and lateral extent of the groundwater plumes at the LeMoyne Landfill are notfully defined. Due to the presence of carbon tetrachloride in 'upgradient' (now crossgradient) well MW-5, east of LeMoyne Landfi l l , site investigations should be conducted todelineate the plume. Monitoring wells should be installed to monitor contaminantconcentrations. Decreasing carbon tetrachloride concentration is observed from during theperiod of record reviewed, from April 2000 to December 2004. A sharp decrease in theconcentration trend is noted after the October 2001 sampling event, coinciding with thetermination of Courtaulds groundwater extraction, indicating that the plume may havemoved. Corrective action measures should be established after delineation.

IW-4 does not appear to be capturing the groundvvater as intended by the remedial design.According to Sovereign's groundwater model, and the November 2004 and May 2005potentiometric maps, IW-4 appears to be capturing groundwater from the Mobile Countyproperty (former Courtaulds and Acordis property), instead of groundwater downgradient

A3-I3SlaulTer Five-Year Review.doc December 2005

of the LeMoyne Landfi l l . Actual groundwater flow direction should be established toproperly locate the new intercept well and monitoring wells. The decreasing contaminantconcentration trend in IW-3 that began mid 2001, at the time when the Courtauld'spumping ceased, should be investigated, to determine if IW-3 is properly located andcapturing the plume, as intended. In reviewing the flow records for IW-3, a change indischarge rate was not observed in 2001 to account for the decreasing contaminantconcentrations. IW-3 may also need to be relocated to a more optimum location.

The reporting l imi t for most of the carbon tetrachloride analysis is 5 ug/L. The clean upgoal for carbon tetrachloride is also 5 ug/L. The reporting l imit for carbon tetrachloride forfuture analysis should be lower, no more than 2.5 ug/L. Good practice and Department ofDefense requirements for project reporting l imi ts should be no more than half of theregulatory value (i.e. cleanup goal). The reporting limits for the other analytes exhibit goodpractice values.

The frequent fouling of the carbon in the Cold Creek GTS is very costly. Syngenta staff islooking into remedies. Excessive iron in the groundwater is suspected to the cause. Thegroundwater discharge rate should be evaluated to determine if the amount of dischargecan be reduced while continuing to capture the plume. Intercept well efficiency and ameasure of the zone of influence was attempted as part of this review. However, there wasnot enough information at this level of effort to determine. An analysis of a sample of thefouling on the carbon to determine its composition may aid in correcting the problem. Thecleaning method that has been used over the years may have become ineffective. A changein well rehabilitation may improve operation of the well and/or system. If iron-reducingbacteria are becoming established in the well, filter pack and surrounding formation, acidtreatment alone may not control the regrowth of iron bacteria and they can eventuallyresult in complete plugging of the aquifer around the well. As a first step, the well watercould be tested using a Biological Activity Reaction Test (BART) kit to determine the typeand activity level of any bacteria in the well.

Groundwater contaminant plume maps should be developed annually or on alternatingyears to better understand the impact of the changes in groundwater flows and to assess theeffectiveness of the system at capturing the plume.

Permanent labeling of the monitoring wells by dye stamping on stainless steel oraluminum identification (id) plate with all well information is recommended. These idlabels should be affixed to the outer casing, on the exterior, by pop rivets. The wellidentification information should include:

Well number/nameMeasuring point elevation

. Well depth

. Screened interval (feet and elevation)

. Date installed

A3-13Slauffer Five-Yeor Revicw.doc December 2005

ATTACHMENT 4

INTERVIEW RECORDS


INTERVIEW RECORD

Site Name: Stauffer Chemical Company (LeMoyne Plant)

Subject: Five- Year Review

Type: ^Telephone [x]Visit BotherLocation of Visit: at Akzo Nobel, Axis, Alabama

EPA ID No.: ALD 008161 176

Dates: April to June 2005

^ Incoming [XI Outgoing

Contact Made By:

Name: Laura Roebuck Title: Geologist Organization: USAGE

Individual Contacted:

Name: Terry Bassett Title: Manager of Remedial Action

Telephone No: (251)675-1310Fax No: (251)679-4274E-Mail Address: [email protected]

Organization: Akzo NobelFunctional Chemicals LLC

Street Address: 1 3440 Highway 43 NorthCity, State, Zip: Axis AL 36505

Summary Of Conversation

Several different interview times and places occurred with Terry Bassett, of Akzo Nobel, via telephone,email, and during a meeting at the site on April 14, 2005. Below is a summary of the more pertinentconditions and plans for site.

Due to the termination of Courtaulds1 groundwater extraction in 2001 (and 2002), groundwater flowdirection has changed. As a result, the plumes are probably moving. There is evidence of this in lookingat the rise in groundwater elevation, potentiometric maps, modeling, and sampling and analysis resultsover the past few years. As a result in groundwater conditions, FW-4 does not appear to capturingcontaminated groundwater from LeMoyne Landfill. The capture of groundwater flowing fromLeMoyne Landfill wil l need to be evaluated. Monitoring wells may also have to be considered.

Drop tubes are installed in all pumping wells, and will be read along with the other water level readingsduring each reading event in the future. Several monitoring wells recommended by USAGE for waterlevel readings events have been redeveloped and will be resurveyed for measuing point elevation.

Already scheduled for August this year is the installation of new monitoring wells around LeMoyneLandfill to begin the process of delineating the plume.

Groundwater flow patterns on Akzo's property may change, if Syngenta has any significant pumpingchanges. Syngenta at Bucks is scheduled to close end of 2006.

Groundwater modeling is being performed on May 2005 groundwater elevation data using differentpumping scenarios. This is currently in progress.

When the ongoing RFA is completed, all monitoring wells on site wi l l be evaluated. All wellsdetermined not necessary for future monitoring, wil l be proposed for closure. A RCRA CorrectiveMeasures Implementation (CM1) is being developed for each of the units that require more action. TheCMI are scheduled to be completed in 2006 or 2007.

A4-3StautTer Fivc-Year Review.doc December 2005

INTERVIEW RECORD

Site Name: Stauffer Chemical Company (Cold Creek)

Subject: Five-Year Review

Type: ^Telephone [^Visit ^OtherLocation of Visit: Syngenta plant site, Bucks, AL

EPA ID No.: ALD095688875

Date: April to June 2005

^ Incoming [^ Outgoing

Contact Made By:



Name: Nick Burrows Title: Environmental Services Manager

Telephone No: (251)675-0950Fax No: (251)675-5948E-Mail Address: [email protected]

Organization: Syngenta CropProtection, Inc.

Street Address: Highway 43 NorthCity, State, Zip: Bucks, AL

Summary Of ConversationSeveral different interview times and places occurred with Nick Burrows, of Syngenta, viatelephone, email, and during a meeting at the site on April 14, 2005. Below is a summaryof the more pertinent conditions and plans for the site.

Frequent fouling of the carbon towers in the GTS is causing concern. The cost of carbonfor one change out is about $13,000. Excessive iron in the groundwater is the suspectedcause of the frequent fouling. Syngenta staff is looking into remedies, including thepossibility of reducing discharge, to reduce the amount of unnecessary (i.e. 'clean')groundwater going through the system. Syngenta is interested in reducing groundwaterextraction from CC-14, while maintaining effective capture.

Syngenta wi l l be closing plant operations at this site the end of 2006.

Due to the change in groundwater flow and conditions since the termination of Courtaulds'groundwater pumping, some monitoring wells were relocated in 2003. Some monitoringwells were also closed out at the same time. It took a few years for groundwater toequilibrate after Courtaulds terminated their pumping. The pumping of process water wellCC-13 creates localized groundwater flow on the Cold Creek (Syngenta) site.

Dr. Burrows believes the recent groundwater modeling results indicates continuedeffectiveness of the system.

One new product since 2000 is being produced, known as 'mesotrione', a herbicide forcorn.

A4-4Stau(Ter Five-Year Review.doc December 2005

Summary Of Conversation - (cont'd)

In November 2003, the groundvvater analysis of the monitoring wells looked very good;none exceeding clean-up goals. However, in October 2004, very high contaminantconcentrations were noted in many wells. This may be explained by the end of the droughtin early 2004.

An internal draft risk review proposal, if adopted, would essentially eliminate OU-2remediation. They would like to put the OU-2 biopile back into the Old NeutralizationPond, from whence it came, and cap. This has already been proposed to EPA. It is underreview for Explanation of Significant Differences (ESD).

Soil flushing is desired for the remedy for the Old Neutralization Pond (OU-2). The peak ofmolinate in 2004 may indicate that soil flushing is occurring.

In the last 5 years, only two BOD results above compliance (end of 2003) in the DMR's.Most of the treated effluent l imi ts are very low, making it safe to say that there are virtuallyno effects to surface water from the treated discharge.

Much of the O&M costs are absorbed into daily plant operations. However, a breakdownof QU-1 Q&M costs wil l be attempted for this five year review.

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Site Name: Stauffer Chemical(Cold Creek and LeMoyne)

Company EPA ID No.: Cold Creek ALD 095688875LeMoyne AID 008 161 176

Subject: Five-Year Review

Type: ^TelephoneLocation of Visit:

DVisit DOther

Time: 13:00

1 | Incoming ^

Date: June 16,2005

Outgoing

INTERVIEW RECORD

Contact Made By:



Name: Keith West Title: Environmental Engineer Organization: ADEM

Telephone No: 334-271-7754Fax No: 334-279-3050E-Mail Address: [email protected]

Street Address: 1400 Coliseum BlvdCity, State, Zip: Montgomery, AL 361 10-2059

Summary Of Conversation

Keith indicated no problems with OU-1 at Cold Creek and LeMoyne. Things are goingwell. Due to the change in groundwater flow at the sites from the termination of theCourtaulds' groundwater extraction, as long as the PRP's keep making adjustments asnecessary to the systems and the monitoring, particularly after getting updated groundwatermodeling results, things wi l l be OK. There are no problems to report.

OU-2 and OU-3 have problems. The OU-2 biopile at Syngenta never got the concentrationlevels down, so the proposed remedy is to put the biopile back into the Old NeutralizationPond and cap. This has not been approved. It is under review for ESD.

A new remedy for OU-3 at Cold Creek Swamp is proposed. It is called Agua Blok. Thelawyers are having a di f f icul t time with it, as it requires a new ROD.

OU-2 at LeMoyne is for Halby Pond. Soil flushing is the proposed remedy.

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ATTACHMENT 5

PHOTOGRAPHS


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