Third Five-Year Review Report

for

National Southwire Aluminum Superfund Site

1627 State Highway 271 North

Hawesville

Hancock County, Kentucky

List of Acronyms .......................................................................................................................1

Executive Summary ..................................................................................................................3

Five-Year Review Summary Form...........................................................................................5

1.0 Introduction.........................................................................................................................7

2.0 Site Chronology ...................................................................................................................8

Table 1: Chronology of Site Events......................................................................................8

Table 2: Sampling and Reporting During FYR Period.........................................................9

3.0 Background .......................................................................................................................10

3.1 PHYSICAL CHARACTERISTICS......................................................................................10

3.2 LAND AND RESOURCE USE .........................................................................................11

3.3 HISTORY OF CONTAMINATION ....................................................................................11

3.4 INITIAL RESPONSE ......................................................................................................12

3.5 BASIS FOR TAKING ACTION ........................................................................................12

4.0 Remedial Actions...............................................................................................................13

4.1 REMEDY SELECTION...................................................................................................13

4.2 REMEDY IMPLEMENTATION ........................................................................................16

Table 3: Timeline of Remedial Action Activities.................................................................16

4.3 OPERATION AND MAINTENANCE.................................................................................17

Table 4: Operation and Maintenance Activity Summary by Unit........................................17

Table 5: Annual O&M Costs .............................................................................................18

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

Table 6: Progress on Recommendations from the 2006, Second FYR.................................19

5.1 RECOMMENDATION 1..................................................................................................20

5.2 RECOMMENDATION 2..................................................................................................20

5.3 RECOMMENDATION 3..................................................................................................20

5.4 RECOMMENDATION 4..................................................................................................22

5.5 RECOMMENDATION 5..................................................................................................22

5.6 RECOMMENDATION 6..................................................................................................23

5.7 RECOMMENDATION 7..................................................................................................23

5.8 RECOMMENDATION 8..................................................................................................23

6.0 Five-Year Review Process .................................................................................................24

6.1 ADMINISTRATIVE COMPONENTS..................................................................................24

6.2 COMMUNITY INVOLVEMENT .......................................................................................24

6.3 DOCUMENT REVIEW ...................................................................................................24
6.4 DATA REVIEW............................................................................................................25

6.5 SITE INSPECTION ........................................................................................................29

Table 7: Deed Documents from Hancock County Public Records Office............................29

Table 8: IC Summary Table...............................................................................................30

6.6 INTERVIEWS ...............................................................................................................31

7.0 Technical Assessment........................................................................................................32

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

DOCUMENTS?............................................................................................................32

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

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

SELECTION STILL VALID? .........................................................................................33

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

QUESTION THE PROTECTIVENESS OF THE REMEDY? ...................................................34

7.4 TECHNICAL ASSESSMENT SUMMARY...........................................................................34

8.0 Issues ..........................................................................................................................35

Table 9: Current Issue for the National Southwire Aluminum Superfund Site ....................35

9.0 Recommendations and Follow-up Actions .......................................................................36

Table 10: Recommendation to Address Current Issue at the National Southwire Aluminum

Superfund Site ...................................................................................................................36

10.0 Protectiveness Statements ...............................................................................................37

11.0 Next Review .....................................................................................................................38

Figures (follow Text)

Figure 1: National Southwire Aluminum Superfund Site Vicinity Map

Figure 2: Operable Unit No. 1 Well Locations

Figure 3: Operable Unit No. 2 Focus Areas

Figure 4: North and South Plume Extraction Volumes and Average Free Cyanide

Concentrations

Figures 5 - 8: Free Cyanide Trends in North and South Plume Extraction and Monitoring Wells

Figure 9: Operable Unit No. 2 Groundwater Monitoring

Figure 10: South Slurry Pond Groundwater Monitoring

Figure 11: Site Plan with Institutional Controls

Appendices (follow Figures)

Appendix A: List of Documents Reviewed

Appendix B: Press Notices

Appendix C: Site Inspection Checklist

Appendix D: Photographs from Site Inspection Visit
1 AUGUST 2011

List of Acronyms

AOC Administrative Order on Consent

ARAR Applicable or Relevant and Appropriate Requirements

BRA Baseline Risk Assessment

CD Consent Decree

Century Century Aluminum of Kentucky, LLC

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

COC Contaminant of Concern

EPA United States Environmental Protection Agency

ERA Ecological Risk Assessment

EW Extraction Well

FS Feasibility Study

FYR Five Year Review

GETS Groundwater Extraction and Treatment System

GWTP Groundwater Treatment Plant

IC Institutional Control

IRA Interim Remedial Action

IROD Interim Record of Decision

KDWM Kentucky Division of Waste Management

Kg Kilogram

KPDES Kentucky Pollutant Discharge Elimination System

L Liter

mg Milligram

MW Monitoring Well

NCP National Contingency Plan

NPL National Priorities List

NSA National Southwire Aluminum

NTCRA Non-Time Critical Removal Action

O&M Operations and Maintenance

OSWER Office of Solid Waste and Emergency Response

OU1 Operable Unit No. 1

OU2 Operable Unit No. 2

PA Preliminary Assessment

PAH Polycyclic Aromatic Hydrocarbon

PCB Polychlorinated Biphenyl

PRP Potentially Responsible Party

PSVR Performance Standards Verification Report

QA/QC Quality Assurance/Quality Control

RAO Remedial Action Objective

RBDA Refractory Brick Disposal Area

RD Final Remedial Design

RD/RA Remedial Design/Remedial Action

RI/FS Remedial Investigation/Feasibility Study
2 AUGUST 2011

ROD Record of Decision

RPM Remedial Project Manager

SDWA Safe Drinking Water Act

Site National Southwire Aluminum Superfund Site

Southwire Southwire Company

SOW Statement of Work

TBC To-Be-Considered Criteria

TSCA Toxic Substances Control Act

URS URS Corporation
3 AUGUST 2011

Executive Summary

Introduction

The United States Environmental Protection Agency (EPA) Region 4 conducted this review of

the remedy at the National Southwire Aluminum Superfund Site (Site) in Hawesville, Hancock

County, Kentucky, with support from URS Corporation. This Five Year Review (FYR) was

conducted from March to July of 2011. EPA Region 4 is the lead agency for developing and

overseeing implementation of the remedy for the Potentially Responsible Party (PRP)-financed

cleanup at the Site. The PRP is the former Site owner, Southwire Company (Southwire). The

Kentucky Division of Waste Management (KDWM), as the support agency representing the

Commonwealth of Kentucky, has reviewed supporting documentation and provided input to

EPA during the FYR process. This is the third FYR for the Site. The triggering action for this

statutory review is the completion date of the second FYR (September 14, 2006).

The Site is located within an area of an active primary aluminum reduction facility. The Site is

located 4 miles northwest of the town of Hawesville. The plant area, including adjacent

agricultural land, is 1,100 acres. The aluminum reduction activities take place in a 475 acre area

east of State Route 334 and north of Route 271. The major plant features include a number of

manufacturing and service buildings, three former waste disposal impoundments, one active

wastewater impoundment, three former waste disposal landfills, a potliner accumulation

building, and a drainage ditch. The Site is situated on the west bank of the Ohio River.

There were two primary historic practices that contributed to the contamination at the Site. These

included the removal, replacement, and disposal of spent potliners in an uncontrolled manner and

the use of polychlorinated biphenyl (PCB) heat transfer fluids as part of pitch operations. These

activities adversely affected the Site soil and groundwater.

Remedial activities at the Site are complete. The Site achieved construction completion status

when the Preliminary Close Out Report was signed in September 2008. A Remedial Action

Report addressing the remedial action activities associated with Operable Unit No. 1 (OU1) and

Operable Unit No. 2 (OU2) was prepared by URS Corporation (URS) on behalf of Southwire in

May 2011. The remedial activities at OU1 were related to groundwater remediation and the

remedial activities at OU2 were related to soil remediation. The EPA and KDWM have

indicated that all remedial action construction activities, including the implementation of

institutional controls, were performed in compliance with the Record of Decision (ROD) and in

accordance with the Final Remedial Design (RD). A Final Close Out Report has been prepared

to document the completion of the remedial action activities and it is anticipated to be finalized

in 2011.

Remedial Action Objectives

As presented in the ROD and clarified in the Statement of Work (SOW) for the Site, the

Remedial Action Objectives (RAOs) consisted of the following:

 Minimize direct contact by Site workers and the public with soil containing excessive

levels of PCBs,
4 AUGUST 2011

 Minimize direct contact by Site workers and the public with soil containing excessive

levels of polycyclic aromatic hydrocarbon (PAH) compounds,

 Minimize transport of contaminated soil by erosion to water courses, including the Ohio

River,

 Minimize potential leaching of total PCBs to Site groundwater from areas of high PCB

concentration in Site soils, both surficial and subsurficial,

 Remediate groundwater contaminated with elevated levels of cyanide, and

 Prevent deterioration of the Old South Slurry Pond containment cap/cover system.

Technical Assessment

According to the data reviewed, the Site inspections, and the other components of this FYR, the

remedy is functioning as intended by the ROD. There have been no changes to the physical Site

that would affect the protectiveness of the remedy. The performance standards identified in the

ROD have been met through the remedial action activities. There are no identified changes to

toxicity factors or to the risk assessment methodologies that would significantly affect the

protectiveness of the remedy. There is no other information that calls the protectiveness of the

remedy into question.

Conclusion

The remedial action for the National Southwire Aluminum Superfund Site consisted primarily of

groundwater and soil remediation. All remedial activities at the Site are complete, the cleanup

requirements have been met and the remedial action is protective of human health and the

environment.
5 AUGUST 2011

Five-Year Review Summary Form

SITE IDENTIFICATION

Site name (from WasteLAN): National Southwire Aluminum

EPA ID (from WasteLAN): KYD049062375

Region: 04 State: KY City/County: Hawesville / Hancock

SITE STATUS

NPL status: X Final Deleted Other (specify) ____________________________

Remediation status (choose all that apply): Under Construction Operating X Complete

Multiple OUs?* X YES NO Construction completion date: February 1995 (OU1),

August 2008 (OU2)

Has site been put into reuse? YES X NO Continues to operate as an aluminum reduction facility.

REVIEW STATUS

Lead agency: X EPA State Tribe Other Federal Agency

Author name: Alicia Shull / Femi Akindele

Author title: Project Managers Author affiliation: URS Corporation /

EPA Region 4

Review period**: 03/01/2011 to 07/07/2011

Date(s) of site inspection: 03/17/2011, 03/23/2011, 03/29/2011, 04/29/2011 (see Section 6.5)

Type of review:

X Post-SARA Pre-SARA NPL-Removal only

Non-NPL Remedial Action Site NPL State/Tribe-lead

Regional Discretion

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

Triggering action:

Actual RA Onsite Construction at OU# Actual RA Start at OU#

Construction Completion X Previous Five-Year Review Report

Other (specify)

Triggering action date (from WasteLAN): 09/14/2006

Due date (five years after triggering action date): 09/14/2011

* [“OU” refers to operable unit.]

** [Review period should correspond to the actual start and end dates of the Five-Year Review

in WasteLAN.]
6 AUGUST 2011

Five-Year Review Summary Form, Continued

Issue:

The review of Site conditions and information during the FYR period has led to the identification

of one potential issue at the Site. The remedial activities at the Site are complete and the cleanup

requirements have been met. The groundwater monitoring requirements associated with

Operable Unit No. 1 (OU1), Operable Unit No.2 (OU2) and the Non-Time Critical Removal

Action (NTCRA) South Slurry Pond are also complete and/or approaching completion.

Following completion of the required groundwater monitoring, the monitoring wells should be

properly abandoned under the provisions of the Commonwealth of Kentucky to prevent a

potential surface conduit to groundwater. Information on the groundwater monitoring schedule

can be found in Sections 4.3 and 7.1.

Recommendation:

The recommendation developed as part of this FYR period is summarized in the table below.

Issue /

Improvement

Recommendations/

Follow-Up Actions

Party

Responsible

Oversight

Agency

Milestone

Date

Affects

Protectiveness?

(Yes or No)

Current Future

Completion of

Groundwater

Monitoring

Activities

Properly Abandon

Monitoring Wells

when Monitoring

Complete

Southwire EPA /

KDOW /

KDWM

06/01/2012 No Yes

Protectiveness Statement:

The remedial action for the National Southwire Aluminum Superfund Site consisted primarily of

groundwater and soil remediation. All remedial activities at the Site are complete, the cleanup

requirements have been met and the remedial action is protective of human health and the

environment.
7 AUGUST 2011

1.0 Introduction

The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of

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

the environment. The methods, findings, and conclusions of FYRs are documented in Five-Year

Review reports. In addition, FYR reports identify issues found during the review, if any, and

document recommendations to address them.

The U.S. Environmental Protection Agency (EPA) prepares FYRs pursuant to the

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

121 and the National Contingency Plan (NCP). CERCLA Section 121 states:

“If the President selects a remedial action that results in any hazardous substances,

pollutants, or contaminants remaining at the site, the President shall review such remedial

action no less often than each five years after the initiation of such remedial action to

assure that human health and the environment are being protected by the remedial action

being implemented. In addition, if upon such review it is the judgment of the President

that action is appropriate at such site in accordance with section [104] or [106], the

President shall take or require such action. The President shall report to the Congress a

list of facilities for which such review is required, the results of all such reviews, and any

actions taken as a result of such reviews.”

EPA interpreted this requirement further in the NCP, specifically in 40 Code of Federal

Regulations (CFR) Section 300.430(f)(4)(ii), which states:

“If a remedial action is selected that results in hazardous substances, pollutants, or

contaminants remaining at the site above levels that allow for unlimited use and

unrestricted exposure, the lead agency shall review such actions no less often than every

five years after the initiation of the selected remedial action.”

EPA Region 4 conducted the review of the remedy at the National Southwire Aluminum (NSA)

Superfund Site (Site) in Hawesville, Hancock County, Kentucky, with support provided by URS

Corporation (URS). This FYR was conducted from March to May of 2011. EPA Region 4 is the

lead agency for developing and overseeing implementation of the remedy for the Potentially

Responsible Party (PRP)-financed cleanup at the Site. The PRP is the former Site owner,

Southwire Company (Southwire). The Kentucky Division of Waste Management (KDWM), as

the support agency representing the Commonwealth of Kentucky, has reviewed supporting

documentation and provided input to EPA during the FYR process.

This is the third FYR for the National Southwire Aluminum Superfund Site. The triggering

action for this statutory review is the completion date of the second FYR (September 14, 2006).

The FYR is required due to the fact that hazardous substances, pollutants, or contaminants

remain at the Site above levels that allow for unlimited use and unrestricted exposure. The Site

consists of two Operable Units, both of which are addressed in this FYR.
8 AUGUST 2011

2.0 Site Chronology

The following table lists the dates of important events for the National Southwire Aluminum

Superfund Site. Table 1 provides a chronology of the Site events and Table 2 provides a

summary of the sampling and reporting conducted during the FYR Period.

Table 1: Chronology of Site Events

Event Date

NSA Manufacturing Operations Begin May 1969

NSA Monitoring Well Installation May 1978

Leaching Discovered Beneath North Pond June 1979

United States Environmental Protection Agency (EPA) Site

Discovery / Identification

August 1980

Kentucky Division of Waste Management (KDWM)

Preliminary Assessment

February 1986

KDWM Site Investigation May 1986

Expanded Site Investigation April 1991

Interim Final Listing April 1991

EPA Proposes Site for National Priorities List (NPL) July 1991

Administrative Order on Consent (AOC) for Completion of a

Remedial Investigation / Feasibility Study

October 1992

RI/FS Commencement October 1992

RI/FS Completion February 1993

Interim Record of Decision (ROD) and Statement of Work

(SOW) for Interim Remedial Action (IRA) - Operable Unit

No. 1 (OU1)

February 1993

Consent Decree (CD) for the Remedial Design /Remedial

Action (RD/RA) IRA

February 1994

Site placed on NPL May 1994

Explanation of Significant Differences (OU1) July 1994

OU1 IRA Commencement May 1994

OU1 IRA Design and Construction Complete February 1995

AOC for Non-Time Critical Removal Action (NTCRA) at

South Slurry Pond

October 1995

NTCRA Begins at South Slurry Pond October 1995

NTCRA Completed at South Slurry Pond November 1996

Remedial Investigation (RI) Report for OU1 and Operable

Unit No. 2 (OU2)

May 1998

Feasibility Study (FS) Report for OU1 and OU2 June 1998

OU1 Final Construction Inspection July 1998

EPA Notification of Commissioning Completion for OU1 July 1998

Final ROD issued (OU1 and OU2) July 2000

Final SOW issued (OU1 and OU2) November 2001

1st Five-Year Review August 2001
9 AUGUST 2011

Event Date

Final CD (OU1 and OU2) October 2004

2nd Five-Year Review September 2006

Final Remedial Design Submittal approved by EPA for OU2 June 2006

OU2 Construction Commencement June 2007

OU2 Construction Completion August 2008

OU2 Construction Completion Report approved by EPA -

OU2 Operational and Functional

September 2008

EPA Preliminary Close Out Report Approved November 2008

Leachate Treatment System Operation Complete (OU2) August 2009

MW204D Assessment Activities Completed (continuous

purge test) and OU1 GETS Operation Discontinued to allow

Groundwater to reach Equilibrium

January 2010

Performance Standards for OU1 Achieved following May

2010 Annual Groundwater Monitoring activities (three

quarterly and one annual event below 0.2 mg/L free

cyanide). The Performance Standards Verification Report is

updated to include the monitoring data through May 2010.

May 2010

Environmental Covenants Restricting Groundwater and Land

Use Approved by EPA and Kentucky and Recorded in

Hancock County

November 2010

Remedial Action Report Approved by EPA and Kentucky

(includes OU1 Performance Standards Verification Report)

September 2011

Table 2: Sampling and Reporting During FYR Period

Event Date

Bi-weekly OU1 Groundwater Treatment Plant (GWTP)

effluent monitoring

2006 to January 2010

Monthly OU1 extraction well Monitoring 2006 to January 2010

Quarterly sampling of five (5) OU1 monitoring wells 2006 to January 2010

Annual sampling of thirty-two (32) OU1 monitoring wells 2006 to January 2010

Quarterly sampling of five (5) OU2 monitoring wells 2009 to Present

Semi-Annual OU2 O&M Site Inspections 2009 to Present

Semi-Annual OU2 Wetlands Monitoring 2009 to Present

Quarterly and annual sampling of South Slurry Pond

monitoring wells (four (4) quarterly and six (6) annual wells)

2006 to Present

Annual South Slurry Pond O&M Site Inspection 2006 to Present

Annual O&M Report Preparation 2009 to Present

Monthly Progress Reports 2006 to Present
10 AUGUST 2011

3.0 Background

3.1 Physical Characteristics

The Site is located in Hancock County, Kentucky within an area of an active primary aluminum

reduction facility. The Site is located 4 miles northwest of the town of Hawesville. The plant

area, including adjacent agricultural land, is 1,100 acres. The aluminum reduction activities take

place in a 475 acre area east of State Route 334 and north of Route 271. The major plant

features include a number of manufacturing and service buildings, three former waste disposal

impoundments, one active wastewater impoundment, three former waste disposal landfills, a

potliner accumulation building, and a drainage ditch. Adjacent facilities include the Southwire

Rod and Cable Mill to the southeast of the Site and the Big Rivers Power Plant to the northwest

of the Site. The Big Rivers Power Plant supplies electrical power to the Site. Public access to the

plant is restricted by a chain-link fence and access to the plant area is controlled by a guardhouse

off of Route 271. The Site is situated on the west bank of the Ohio River. A Site vicinity map is

provided in Figure 1.

In April 2001, Southwire transferred ownership of the production facilities and the majority of

the former National Southwire Aluminum property to Century Aluminum of Kentucky, LLC

(Century). Century now operates the manufacturing plant. Southwire has retained responsibility

for completion of the remedy (as PRP) and ownership of a small parcel on the northwestern part

of the plant property that contains inactive impoundments (referred to as “Southwire Outlot”).

During the Site investigation activities a total of seven (7) areas of concern were identified.

These areas, documented in the Record of Decision (ROD) for the Site, are as follows:

1) Green Carbon PCB Spill Area (central plant)

2) Refractory Brick Disposal Areas (west of State Route 334)

3) Taylors Wash Landfill (eastern plant)

4) Drum Storage Area (southern plant)

5) PCB Soil Stockpile Area (eastern plant)

6) Site-wide Groundwater

7) South Slurry Pond (northern plant)

The remedial action components related to Site-wide Groundwater are depicted on Figure 2. The

remaining six (6) areas of concern are depicted on Figure 3.

The Site is located in a sparsely populated area. Land use in the Site vicinity is mainly industrial

or agricultural. No residential development is present in the immediate vicinity of the Site. The

majority of residents near the Site live across the Ohio River in Tell City, Indiana or

approximately 30-miles west in Owensboro, Kentucky.

The only environmentally sensitive areas identified during the Site investigation activities were

wetland areas in the vicinity of the Refractory Brick Disposal Areas (RBDAs).
11 AUGUST 2011

3.2 Land and Resource Use

The Site is currently owned by Century and operated as an aluminum reduction facility.

Continued use of the Site for this purpose is likely for the foreseeable future. As indicated in

the ROD, the use of the facility for any purpose other than industrial is not practical. Groundwater

at the Site is used only for industrial purposes.

Groundwater at the Site was previously used as a potable water source, but this use was

discontinued in 1986 after the water supply wells were found to contain concentrations of

metals slightly exceeding background concentrations. The 2006 FYR Report indicated that the

closest residential groundwater well is located approximately 0.5-miles south of the Site and

that within a 4-mile radius of the Site, several municipal water companies and several private

wells utilize groundwater as a potable source. Most of these groundwater users are located

across the Ohio River from the Site and monitoring activities do not indicate that contaminants

are migrating from the Site toward these potable water sources.

Institutional Controls (ICs) for the facility were specified in the ROD. ICs in the form of

Environmental Covenants were prepared for the Site and were recorded in Hancock County in

November 2010. More information regarding the ICs can be found in Section 6.5.

3.3 History of Contamination

The Site has been in operation since 1969, as a primary aluminum reduction facility. There were

two primary historic practices that contributed to the contamination at the Site, including the

removal, replacement, and disposal of spent potliners in an uncontrolled manner and the use of

polychlorinated biphenyl (PCB) heat transfer fluids as part of pitch operations. These historic

practices are described below.

In order to produce the primary aluminum, a series of carbon-lined vessels are used to reduce

alumina ore. Cyanide is produced as an impurity in the carbon linings of reduction vessels called

"pots" during the production process and total cyanide resides in the potliners at levels up to

2,500 mg/kg. The pots are operated continuously until the carbon liner begins to burn through.

Once a pot begins to experience burn-through, it is taken out of service and replaced with a

reconditioned pot. The decommissioned pot is prepared for use again by removing and replacing

the potliner. The historic management and landfill practices of spent potliners are believed to

have contributed to cyanide in groundwater at the facility. Since 1973, potliner removal and

replacement activities have occurred at a designated building. The spent potliners are now

disposed of off-site as hazardous waste (K088).

Another primary activity in the production process is the production of anodes used in the

aluminum reduction process. The primary materials used in the manufacturing of anodes are

green carbon and a tar-like material referred to as pitch. The pitch must be heated in order to be

transferred to the manufacturing area and utilized in the process. During the 1970s, PCB heat

transfer fluids were employed to heat the pitch during unloading activities from railcars and three

storage tanks. Spills of heat transfer fluid in the 1970s are believed to have contributed to PCB

contamination of soils in the vicinity of the railcar unloading area, pitch heater building, and
12 AUGUST 2011

pitch storage tanks. Other non-PCB heat transfer fluids continue to be used at the facility to heat

pitch during railcar or tanker truck unloading and to maintain the temperature of the three pitch

storage tanks. The system was certified PCB-free in 1982.

Enforcement activities were initiated in 1985. A Preliminary Assessment (PA) was completed on

February 25, 1986, by KDWM, under the EPA CERCLA Preliminary Assessment / Site

Investigation Cooperative Agreement with EPA Region 4. This assessment indicated that the Site

had significant contamination, further studies were warranted, and the Site was a good candidate

for the NPL. In 1990 and 1991, samples from surface soils, subsurface soils, sediments,

surface waters, monitoring wells, industrial wells, and some private wells were collected

during the EPA Preliminary Field Investigation as reported in the Interim Final Listing Site

Inspection Report by NUS Corporation. An EPA Administrative Order on Consent (AOC) for a

Remedial Investigation / Feasibility Study (RI/FS) of the entire Site was completed in 1992.

After intervening investigations, removals, enforcement actions, and evaluations of the effects of

continuous groundwater treatment, the RI/FS was finalized in 1999. The RI/FS supported the

completion of the ROD in 2000.

3.4 Initial Response

During the RI/FS, cyanide was detected in Site groundwater. An Interim Record of Decision

(IROD) related to cyanide in groundwater was issued in 1993, and a Consent Decree (CD) was

issued in 1994. The CD required NSA to design, construct, and operate a groundwater

extraction and -treatment system (GETS) with the goal of reducing the toxicity and mobility of

(cyanide) concentrations in groundwater from the north and south plumes, and to discharge the

treated water to the Ohio River via a Kentucky Pollutant Discharge Elimination System

(KPDES) permit. This remedial design / remedial action (RD/RA) component is referred

to as OU1. This plan was implemented to provide immediate remedial action to treat the

groundwater at the Site. The design and construction of the extraction wells, as well as the

treatment plant, were fast-tracked and the systems were operational in February 1995.

An EPA AOC was signed in 1995, for a Non-Time-Critical Removal Action (NTCRA) at the

former South Slurry Pond. The construction activities began in October 1995 and were

completed in November 1996. The South Slurry Pond has been permanently closed since

November 1996.

3.5 Basis for Taking Action

The ROD indicates that actual or threatened releases of hazardous substances from the Site, if

not addressed through response actions, may present a continuing imminent and substantial

endangerment to public health, welfare and the environment. The RI/FS and ROD primarily

identified potential endangerment to human health and the environment due to the presence of

PCBs and polycyclic aromatic hydrocarbons (PAHs) in soil and cyanide in groundwater.
13 AUGUST 2011

4.0 Remedial Actions

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

protection of human health and the environment and compliance with Applicable or Relevant

and Appropriate Requirements (ARARs). A number of remedial alternatives were considered for

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

evaluation criteria that are specified in Section 300.430(f)(5)(i) of the NCP. The nine criteria

include:

1) Overall Protectiveness of Human Health and the Environment

2) Compliance with ARARs

3) Long-Term Effectiveness and Permanence

4) Reduction of Toxicity, Mobility or Volume of Contaminants through Treatment

5) Short-term Effectiveness

6) Implementability

7) Cost

8) State Acceptance

9) Community Acceptance

4.1 Remedy Selection

The 1993 IROD was specific to the remediation of cyanide in groundwater. The IROD selected and

required the implementation of the following remedy:

 Extraction of contaminated alluvial aquifer ground water.

 Treatment of contaminated ground water.

 Discharge of treated ground water to the Ohio River (in accordance with KPDES

requirements).

 Proper disposal of all sludge generated via the pump and treat action (in accordance with

RCRA requirements).

The 2000 ROD identified seven (7) areas of concern based on the results of the RI/FS and the

associated Baseline Risk Assessment (BRA) and Ecological Risk Assessment (ERA). These

seven (7) focus areas and the selected remedy presented in the ROD for each area is as follows:

1) Green Carbon PCB Spill Area (central plant) - Land-use and ground water use deed

restrictions; surface and subsurface “hot spot” removal to off-site secure landfill;

rerouting utilities, where necessary; installation of a low permeability multimedia cap;

operational controls to limit physical contact; monitoring of groundwater for PCBs;

material with lower level PCB contamination disposed under the new Taylors Wash

Landfill cap and cover.

2) Refractory Brick Disposal Areas (west of State Route 334) - Land-use and groundwater

use deed restrictions; install soil erosion cap, establish a grass cover, and install fencing

with warning signs. Remove layer of sediment from lengths of the Drainage Ditch and

Muddy Gut Tributary and dispose under the new Taylors Wash Landfill cap and cover or

dispose off-site with other PCB soils.
14 AUGUST 2011

3) Taylors Wash Landfill (eastern plant) - Deed restrictions; collection and treatment of

leachate utilizing a new force main from the Landfill to the existing groundwater

treatment plant; install RCRA Subtitle D multi-media cap and cover; install fencing with

warning signs.

4) Drum Storage Area (southern plant) - Determine PCB and other COC concentrations of

‘hotspots’; excavate ‘hot spots’ and dispose of contaminated material under the new

Taylors Wash Landfill cap; cover excavations with clean fill and appropriate surface

treatment.

5) PCB Soil Stockpile Area (eastern plant) - Excavate one foot of existing surface soils over

the entire Area and dispose under the Taylors Wash Landfill cap after confirming PCB

concentrations; install erosion cap over Area and establish grass cover.

6) Site-wide Groundwater - Impose deed restrictions for groundwater use where not already

imposed; continue groundwater extraction and treatment as required by April 14, 1994

RD/RA Consent Decree ( operate and maintain Ground Water Extraction and Treatment

System); monitor Site-wide groundwater and Ground Water Treatment System KPDES

discharge; investigate soils under Spent Potliner Accumulation Building.

7) South Slurry Pond (northern plant) - Maintain existing cap and cover; impose land-use,

deed restrictions for all four ( 4 ) ponds; monitor groundwater as a part of the Site-wide

ground water monitoring.

The ROD was completed in July 2000, and the CD was entered in U.S. District Court on March 8,

2004. Remedial action objectives (RAOs) were developed for the Site as a result of the RI/FS

findings in order to aid in the development and screening of the remedial alternatives considered

in the ROD. The RAOs presented in the ROD and clarified in the Statement of Work (SOW) for

the seven (7) focus areas, consisted of the following:

 Minimize direct contact by Site workers and the public with soil containing excessive

levels of PCBs,

 Minimize direct contact by Site workers and the public with soil containing excessive

levels of PAH compounds,

 Minimize transport of contaminated soil by erosion to water courses, including the Ohio

River,

 Minimize potential leaching of total PCBs to Site groundwater from areas of high PCB

concentration in Site soils, both surficial and subsurficial,

 Remediate groundwater contaminated with elevated levels of cyanide, and

 Prevent deterioration of the Old South Slurry Pond containment cap/cover system.

The first focus area concerned the Site-wide groundwater (OU1), which was addressed by the

1993 IROD and then the 2000 ROD. The remedial action associated with OU1 primarily

consisted of the design and operation of the GETS. The GETS design included an extraction well

network consisting of six (6) total wells installed in the cores of the north and south plumes to

maximize the withdrawal of cyanide-contaminated groundwater. The groundwater treatment plant

(GWTP) was designed to remove iron-complexed cyanide using ferrous precipitation and settling.

The treatment process involved five basic steps: cyanide precipitation, cyanide solids removal,
15 AUGUST 2011

ferric iron precipitation, iron solids removal, and dewatering of the combined sludge from the

two solids removal steps. The GETS was designed to discharge treated groundwater to the Ohio

River under the terms of a KPDES Permit. In addition, the Performance Standards Verification

Plan (PSVP) developed as part of the IRA RD included a system of thirty-seven (37)

groundwater monitoring wells sampled on a quarterly or annual basis for total and free cyanide.

The second focus area concerned the South Slurry Pond Closure/Post-Closure activities which

were addressed during the 1995 and 1996 NTCRA. The objective of the NTCRA was to cap air

pollution control sludge and reduce lateral infiltration into the previously closed Potliner

Disposal Area (North Pond). The closure of the South Slurry Pond involved the installation of a

cap, including a synthetic membrane liner and vegetated soil cover. The selected remedy for the

South Slurry Pond described in the 2000 ROD consists of maintaining the existing cap and

cover, imposing land-use deed restrictions and monitoring groundwater. For this reason, the cap

and cover system are inspected annually, groundwater is monitored (see Section 7.1) and the area

was included in the Environmental Covenants recorded in November 2011.

The remaining five focus areas identified in the ROD were associated with OU2 and primarily

related to remediation of soils containing elevated concentrations of PCBs or PAHs. The OU2

RD activities commenced in 2004 after execution of the CD. The selected remedy presented in

the ROD specific to the five focus areas was further clarified during the remedial design process

and in the approved 2006 Final Remedial Design (2006 RD). The remedial activities are

summarized below:

 Green Carbon PCB Spill Area: The remedial activities in the Green Carbon Area

primarily required the excavation and removal of materials (mainly soils) potentially

contaminated with PCBs from depths of 2- to 14-feet. Removed materials were required

to be disposed at an appropriate location after material characterization activities were

completed. During excavation, confirmatory samples were also required to be collected.

A multi-layer cap was required in the deep excavation areas (up to 14-feet). Clean fill

materials and ultimately pavement (concrete or asphalt) were required to be installed

above the multi-layer cap. In shallow excavation areas (up to 2-feet), clean fill materials

and/or concrete pavement were required to be installed.

 Drum Storage Area: The remedial activities in the Drum Storage Area primarily required

the excavation of soil materials potentially contaminated with PCBs or PAHs to depths of

up to 2-feet. Removed materials were required to be disposed at an appropriate location

after material characterization activities were completed. During excavation,

confirmatory samples were also required to be collected. Clean fill materials were

required to be placed in the excavation areas.

 Refractory Brick Disposal Areas: The remedial activities in the RBDAs primarily

required the regrading of existing materials and the installation of a 2-foot soil cap with a

minimum 1-percent slope.

 PCB Soil Stockpile Area: The remedial activities at the PCB Soil Stockpile Area

primarily required the installation of a 2-foot soil cap with a minimum 1-percent slope.

 Taylors Wash Landfill: The remedial activities at the Taylors Wash Landfill primarily

required the regrading of excavated soils with PCB concentrations less than 25 mg/Kg

from the Green Carbon and Drum Storage Areas and the installation of a multi-layer cap

(meeting Resource Conservation and Recovery Act (RCRA) Subtitle D requirements).
16 AUGUST 2011

The ROD also required the collection and treatment of leachate from the landfill for a

period of one year, or until other established criteria were met.

In addition to the cleanup activities described above, the ROD required the installation of fencing

at the Taylors Wash Landfill and the RBDAs and the installation of warning signs to prevent

digging or excavation at the Green Carbon Area, RBDAs, PCB Soil Stockpile Area and Taylors

Wash Landfill. The ROD also required that ICs be put in place to restrict groundwater and land

use at the Site.

4.2 Remedy Implementation

The remedial action and removal activities at the Site are complete. The Site achieved

construction completion status when the Preliminary Close Out Report was signed in September

2008. A Remedial Action Report addressing the remedial activities associated with OU1 and

OU2 was prepared by URS on behalf of Southwire in May 2011. The remedial activities at OU1

were related to groundwater remediation and the remedial activities at OU2 were related to soil

remediation. The EPA and KDWM have indicated that all remedial action construction activities,

including the implementation of ICs, were performed in compliance with the ROD and in

accordance with the RD documents. In addition, the groundwater treatment activities associated

with OU1 were completed in May 2010 when performance standards were achieved. EPA has

prepared a draft Final Close Out Report (2011) to document the completion of remedial action

construction and the completion of groundwater treatment activities. There have been no

significant issues identified related to the performance of the remedial action since

implementation.

At the time of the Second FYR (2006), OU1 and South Slurry Pond were in the operation and

maintenance (O&M) phase. Since the Second FYR, the OU2 remedial action construction

activities have been completed and OU2 O&M has commenced. OU1 O&M continued until

May 2010 when performance standards associated with that unit were achieved. South Slurry

Pond O&M activities are on-going. More specific information related to the timeline of remedial

activity implementation is included in the following Table 3:

Table 3: Timeline of Remedial Action Activities

Unit Event Date

OU1:

Groundwater

Interim ROD / CD 1993 / 1994

Remedial Design 1994

GETS Construction Complete 1995

GETS Operation 1995 - 2010

OU1 O&M / Performance Monitoring 1995 - May 2010

OU2: Soils ROD / CD 2000 / 2004

Remedial Design 2004 - 2006

Construction 2006 - 2008

OU2 O&M / Performance Monitoring 2009 - Present

NTCRA: South

Slurry Pond

NTCRA AOC 1995

Construction 1995 - 1996

South Slurry Pond O&M / Performance Monitoring 1997 - Present
17 AUGUST 2011

4.3 Operation and Maintenance

Southwire is conducting long-term monitoring and maintenance activities in accordance with the

2008 Operations and Maintenance Manual for OU1, OU2 and South Slurry Pond Remedial

Action Activities (O&M Manual). Prior to 2008, O&M activities were conducted in accordance

with unit-specific plans for OU1 and South Slurry Pond. In 2008, to include the OU2 O&M

plan, a Site-wide comprehensive O&M Manual was developed. There were no significant

changes to the O&M activities for OU1 or South Slurry Pond as a result of the development of

the single O&M Manual. Instead, the goal was to provide a global document for use by both

management and operation/maintenance personnel. The primary activities constituting the Site

O&M are summarized below:

Table 4: Operation and Maintenance Activity Summary by Unit

Unit O&M Activity Anticipated or

Actual Completion

Date

OU1:

Groundwater

Maintain GETS Operability January 2010

Bi-Weekly Discharge Monitoring January 2010

Monthly Extraction Well Monitoring January 2010

Quarterly and Annual Groundwater Monitoring May 2010

OU2: Soils Leachate Treatment System Operation August 2009

Quarterly Groundwater Monitoring (Green Carbon) March 2012

Semi-Annual Wetlands Monitoring December 2014

Inspect Cap/Cover Systems for Erosion, Settlement

of Other Signs of Significant Damage

2039

Inspect Fences/Gates for Breaches, Confirm

Warning Signs in Place

2039

Observe Stormwater Systems for Operability 2039

NTCRA: South

Slurry Pond

Groundwater Monitoring 2027

Inspect Cap/Cover Systems for Erosion, Settlement

of Other Signs of Significant Damage

2027

Inspect Fences/Gates for Breaches, Confirm

Warning Signs in Place

2027

Observe Stormwater Systems for Operability 2027

To date, the O&M activities have been properly implemented and documented. The results of

the OU1, OU2 and South Slurry Pond groundwater and/or treated effluent discharge monitoring

activities have been documented in the Monthly Progress Reports required by the CD.

Maintenance at the GETS that required temporary system shut-down was documented in the

Monthly Progress Reports. The results of O&M activities in 2009 and 2010 were also

documented in the Annual O&M Report prepared for the Site-wide activities and maintained at

the Site in accordance with the 2008 O&M Manual.

Table 4 indicates that several of the required O&M activities at the Site are complete. The

completion of the OU1 O&M activities was documented in the 2011 Remedial Action Report
18 AUGUST 2011

and associated Performance Standards Verification Report (PSVR). The completion of the

Leachate Treatment System Operation was documented in a 2009 report. The GETS System and

Leachate Treatment System are scheduled to be decommissioned before December 2011.

Decommissioning of these systems may allow for beneficial reuse of the tanks and/or equipment

and the reuse of the GWTP building by the current Site owner for other operational purposes.

The groundwater monitoring wells associated with OU1 are also scheduled to be

decommissioned in 2011. The O&M Manual will be updated in 2011 to reflect the completion

of these O&M activities.

The actual O&M costs at the Site during this FYR period are as shown in the table below:

Table 5: Annual O&M Costs

Year Actual Cost

(rounded to the nearest $1,000)

2006 $375,000

2007 $443,000

2008 $695,000

2009 $1,218,000

2010 $275,000

2011

(through May)

$43,000

The annual O&M costs estimated in the ROD totaled $1,203,125. This cost estimate included

$525,000/year for GWTP operations (OU1), $31,500 for OU2 O&M, $131,000/year for leachate

treatment operations (OU2) and a total of a 75% mark-up for miscellaneous (25%), engineering

(20%), and contingency (30%).

The costs related to O&M for 2006 and 2007 were primarily related to GETS (OU1) operations.

OU1 operation continued through January 2010. The high O&M costs in 2009 are attributed to

significant repairs at the aging groundwater treatment plant. OU2 O&M began in 2009 after

completion of the remedial activities for that unit. The leachate treatment system (OU2)

operated from July 2008 to August 2009. Costs associated with annual South Slurry Pond O&M

activities are also included in the total costs presented above.

Given these considerations, there do not appear to be any unanticipated or unusually high O&M

costs during this review period. The 2011 Final Close Out Report prepared by EPA estimates

annual O&M costs of approximately $72,000 for future O&M activities related to OU2 and the

South Slurry Pond.

At this time, there are no known issues related to O&M implementation. O&M activities at the

Site will continue in accordance with the requirements of the ROD and SOW through the

duration indicated in Table 4.
19 AUGUST 2011

5.0 Progress Since the Last Five-Year Review

The protectiveness statement from the Second FYR for the National Southwire Aluminum Site

stated the following:

“The interim remedy is considered to be protective in the short term, as there is no

evidence of current exposure. For the remedy to be protective in the long-term,

groundwater modeling should be conducted to evaluate the plume capture of the

extraction and treatment system. It is recommended that final remedial action objectives

be clearly identified. The remedies for all areas of concern have not been implemented;

therefore, site-wide protectiveness may depend on the requirements of the final ROD,

either in the short term or the long term.”

The Second FYR included eight (8) issues and recommendations. Each recommendation and the

current status are discussed below.

Table 6: Progress on Recommendations from the 2006, Second FYR

Section Recommendation Party

Responsible

Target

Milestone

Date

Action Taken and Outcome Date of

Action

9.1 Formally update

OU1 O&M Plan Southwire 12/06

Complete - OU1 O&M Plan

updated as part of Site-wide

O&M Manual development

11/08

9.2

Continue to operate

GETS through

another FYR

period

Southwire 8/11

Complete - GETS operated

until performance standards

achieved

1/10

9.3

Evaluate effects of

South Plume

extraction well

closure

Southwire 1/07

Complete - Evaluation

conducted and documented

in Performance Standards

Verification Report

7/09

9.4

Follow-up on

KPDES Permit

renewal

Southwire 1/07

Complete - KPDES Permit

issued by Kentucky

Division of Water

11/06

9.5

Preparation of

Supplemental

Decision

Document

EPA /

KDWM 1/07

Complete - Not required,

addressed in ROD and other

Site documents

7/09

9.6 Sample ditch

sediment Southwire 1/07

Complete - Sediment

sampling activities

conducted during the 2005

Preliminary Design

activities

7/05
20 AUGUST 2011 

Section Recommendation Party 

Responsible 

Target 

Milestone 

Date 

Action Taken and Outcome Date of 

Action 

9.7 

Evaluate 

preventative 

maintenance for 

aging GETS 

Southwire 1/07 

Complete - GETS 

inspected, maintained as 

needed, and operated 

through 2010 

1/10 

9.8 

Implement OU2 

remedial actions Southwire 8/08 

Complete - Construction 

activities implemented 

following approval of OU2 

Remedial Design in 2006 

6/08 

5.1 Recommendation 1 

Recommendation 1 from 2006, Second FYR: “Formally update the operations and 

maintenance manual to include new contacts, changes in operations, and pretreatments to 

Clarifier CL-1, flow controls and general operations. The new maintenance manual should 

document history and reasons behind changes for future reviews.” 

The O&M Manual for OU1 was updated as part of the development of the Site-Wide O&M 

Manual (to also include OU2 and NTCRA South Slurry Pond) in 2008. O&M for OU1 is 

complete. Recommendation 1 is considered complete.

5.2 Recommendation 2 

Recommendation 2 from 2006, Second FYR: “Given the changes in operations, and some 

increasing trends near the source zone of the north plume, we recommend the GETS continue to 

operate at least through another review period. Also, statistical trend analysis and plots should 

be performed in the future.”

The GETS operated through 2010 when the performance standards for OU1 were achieved. The 

Performance Standards Verification Report (PSVR) provides detailed information regarding data 

trends in the north plume and documents achievement of the performance standards. This 

document was first submitted in July 2009 and was formally updated in 2011 to include 

monitoring data through May 2010. Recommendation 2 is considered complete. 

5.3 Recommendation 3 

Recommendation 3 from 2006, Second FYR: “Evaluation of the effects of the South Plume 

Extraction Well closure should be officially conducted. A thorough groundwater modeling study 

should be included to test the results of this remedial action and report on plume capture. 

3a. A report should be presented to provide formal documentation of the history and 

rationale leading to that closure and post closure effects on the protectiveness of the 

decision. The review should re-visit risk based implications pertaining to detected 

concentrations in nearby wells. A decision to remain closed or re-open should be 

discussed and determined by USEPA, KDEP and the PRP, collectively. 
21 AUGUST 2011

3b. Specifically, changes in cyanide concentrations in the north plume and at certain

groundwater monitoring wells near the Taylors Wash Landfill should be evaluated with

respect to the changes in extraction well rates at south and north plume extraction wells

and the subsequent closure of the south plume extraction wells.

3c. Reviewers suggest that the reasons for the sudden drops in cyanide concentrations to

0.001 mg/L at MW-104, MW-105, MW-111, and MW-IP8 be investigated and discussed.”

The operational statuses of the south plume extraction wells (EW-12 and EW-13) were

documented in the Monthly Progress Reports prepared for the Site. The PSVR provides

documentation supporting discontinued operation of the south plume extraction wells and a

thorough review and evaluation of the groundwater monitoring and extraction well analytical

data collected during OU1 operation. Based on the Technical Assessment provided in the

Second FYR, it is evident that the reviewers were concerned that discontinued use of the south

plume extraction wells indicated that the OU1 remedy was not functioning as intended. The

information provided in the PSVR in response to this recommendation demonstrates that

discontinued collection from the south plume allowed for greater capture and treatment from the

more contaminated north plume. Specific responses to these recommendations are provided

below.

With respect to 3 and 3a, the PSVR indicates that the south plume extraction and monitoring

well free cyanide concentrations were below the performance standard of 0.2 mg/L throughout

the entire system operation. The PSVR also indicates that extracted groundwater flows from the

south plume were used to manage the influent concentrations of cyanide from the north plume in

order to optimize GWTP performance and ultimately meet the established KPDES permit

discharge limits. The PSVR evaluates north plume free cyanide trends as pumping rates from

the north plume extraction wells were increased and the south plume extraction well pumping

rates were decreased and ultimately discontinued. A clear correlation between increased north

plume capture and decreases to free cyanide concentrations is demonstrated, especially from

1997 to 2000 when concentrations decreased by a factor of 6. The discontinued use of the south

plume extraction wells allowed for system optimization and greater capture in the more

significantly contaminated north plume. Figure 4 depicts the cumulative volume of groundwater

collected from each plume and the average free cyanide concentrations from the north and south

plume extraction wells.

With respect to 3b, north plume trends are evaluated in the PSVR. In general, a review of the

analytical results indicates stable to decreasing trends in the north plume well groupings from

2001 to 2010. These trends may be attributed to increases in north plume capture rates (1997 to

2010), closure of the former South Slurry Pond (1996), and repairs to the former Potliner

Disposal Area (North Pond) cap system in 2001. Isolated fluctuations occurred at some

monitoring wells after 2001, such as at the monitoring wells near the Taylors Wash Landfill.

The changes at the monitoring wells near the Taylors Wash Landfill are discussed in the PSVR

and are attributed to preliminary design studies at the landfill in 2005 and OU2 construction

activities at the landfill through 2008.

With respect to 3c, the reviewers suggested that low reported concentrations at specific wells be

evaluated. The identified wells are located in both the north and south plume well groupings.
22 AUGUST 2011

The PSVR evaluated analytical data trends in the north and south plume well groupings on a

long-term and continuous basis in order to support achievement of the performance standards.

Due to quantitation limitations associated with the WAD cyanide analytical methodology, data

reproducibility at these low levels was challenging. The reported analytical results in the

identified wells are two orders of magnitude less than the performance standard and efforts

related to further evaluation would not have been material in support of assessing the

achievement of the RAO for OU1 (remediation of groundwater with elevated levels of cyanide).

In summary, a review of data from the south plume during this FYR period demonstrates that

free cyanide trends in the south plume monitoring wells did not increase as a result of

discontinued extraction well operation and supports the findings of the PSVR. Furthermore,

increased pumping from the north plume correlates with decreases in free cyanide concentrations

in that plume. Recommendation 3 is considered complete.

5.4 Recommendation 4

Recommendation 4 from 2006, Second FYR: “Follow up on KPDES permit renewal. The 1998

KPDES permit allowed discharge of 0.119 mg/L for free cyanide and 1.0 mg/L for total cyanide,

and although the site is not required to have a permit, the “advantages” mentioned but not listed

in the 2000 Final ROD (page 8) are not relevant if the permit is not renewed. The permit

application has been submitted, but still remains in review, per discussion with the KDEP

permitting office.”

The Kentucky Division of Water (KDOW) issued a KPDES Permit to Century on September 22,

2006, with an effective date of November 1, 2006. The permit is set to expire on October 31,

2011. Since OU1 is complete and functional, groundwater treatment plant effluent discharged to

permitted Outfall 010 has been discontinued. Century’s environmental manager indicated that

the KPDES permit renewal application has been submitted and that Outfall 010 has not been

included in the renewal application. Recommendation 4 is considered complete.

5.5 Recommendation 5

Recommendation 5 from 2006, Second FYR: “A supplemental decision document should be

produced to clearly identify all COCs with clearly identified clean-up goals. The 1993 Interim

ROD leaves room for discrepancies, and no formal statements were made to address specific

goals in the 2000 Final ROD or in the 2006 Remedial Design. A formal decision should be

made to address, clearly define, and formally document the issue of final goals for metals and

fluoride in groundwater for this site. For example, as applied now, the cleanup goal is 0.2 mg/L

for free cyanide (per 1993 ROD).”

For cyanide, the clean-up goal specified in the 1993 IROD and again in the 2000 ROD

(Statement of Work) is 0.2 mg/L free cyanide, the SDWA maximum contaminant level (MCL)

for the contaminant of concern (COC) associated with OU1. For fluoride, the ROD indicates

that the selected remedy for the South Slurry Pond consists of maintaining the existing cap and

cover, imposing land-use deed restrictions and monitoring groundwater. Maintenance of the

cover system and groundwater monitoring activities are conducted as part of the Site O&M
23 AUGUST 2011

activities. For metals, the ROD indicates that “it seems unlikely that the expenditure of

resources on an area-wide sampling and cleanup effort would bring a measurable improvement

to eco[logical] risk with regard to metals.” Land and groundwater use deed restrictions were

recorded in Hancock County in the form of Environmental Covenants in November 2010.

Recommendation 5 is considered complete.

5.6 Recommendation 6

Recommendation 6 from 2006, Second FYR: “The ditch sediment and water should be sampled

to evaluate the possibility of overflow from the adjacent and active slurry pond during inclement

weather. The noted offsite samples should be reported regularly as they occur in monthly

reports. If not already included in the final remedial design, we recommend the data collected

and included for the site documentation.”

The active slurry pond is operated and maintained by the current property owner, Century.

Century’s environmental manager has indicated that the active slurry pond is appropriately

maintained and does not overflow. Further, sediment sampling of the Site ditches was completed

and documented in the 2005 Preliminary Design Submittal. These studies indicated that

remediation of the ditches is not warranted. Recommendation 6 is considered complete.

5.7 Recommendation 7

Recommendation 7 from 2006, Second FYR: “Due to the aging nature of some of the GETS

components, a specialist in extraction system maintenance should be contacted to examine

preventative maintenance options for the facility.”

A review of the Monthly Progress Reports indicates that the GETS was appropriately maintained

as needed to facilitate continued operation. The OU1 remedial activities are now complete and

GETS operation has been discontinued. Recommendation 7 is considered complete.

5.8 Recommendation 8

Recommendation 8 from 2006, Second FYR: “Implement remedy for the six areas of concern in

OU2 as planned.”

The remedial action activities for OU2 were conducted from 2006 to 2008 as documented in the

2008 Construction Completion Report. Recommendation 8 is considered complete.
24 AUGUST 2011

6.0 Five-Year Review Process

6.1 Administrative Components

EPA Region 4 initiated the FYR in March 2011 and scheduled its completion for September

2011. The EPA review team was led by Femi Akindele of EPA, Remedial Project Manager

(RPM) for the National Southwire Aluminum Superfund Site, and also included support from the

EPA attorney, EPA Office of Public Affairs and Outreach, the EPA FYR Coordinator, and URS,

consultants to Southwire. On April 25, 2011, EPA held a scoping call with the review team to

discuss the Site and items of interest as they related to the protectiveness of the remedy currently

in place. A review schedule was established that consisted of the following:

 Community notification;

 Document review;

 Data collection and review;

 Site inspection;

 Local interviews; and

 Five-Year Review Report development and review.

6.2 Community Involvement

On May 5, 2011, a public notice was published in the Hancock County Clarion (local

newspaper) announcing the commencement of the Five-Year Review process for the National

Southwire Aluminum Superfund Site, providing contact information at EPA, and inviting

community participation. The public did not provide any comments or questions in response to

the public notice. The press notice is available in Appendix B. In addition, interviews were

conducted by the EPA Office of Public Affairs and Outreach as discussed in Section 6.6.

The Five-Year Review report will be made available to the public once it has been finalized.

Copies of this document will be placed in the designated public repository at the Hancock Public

Library currently located at the Courthouse Square. On April 29, 2011, as part of the Site

inspection process, URS staff visited the Hancock County Library to review the repository for

necessary updates. In response, URS provided a DVD to the Hancock County Library on May

19, 2011 containing electronic copies of the information that could not be located during the Site

visit. Upon completion of the FYR, a public notice will be placed in the Hancock County

Clarion to announce the availability of the final FYR report in the Site document repository.

6.3 Document Review

This FYR included a review of relevant, Site-related documents including the ROD, remedial

action reports, and recent monitoring data. A complete list of the documents reviewed can be

found in Appendix A.

ARARs Review

Section 121 (d)(2)(A) of CERCLA specifies that Superfund RAs must meet any federal

standards, requirements, criteria, or limitations that are determined to be legally Applicable or
25 AUGUST 2011

Relevant and Appropriate Requirements (ARARs). ARARs are those standards, criteria, or

limitations promulgated under federal or state law that specifically address a hazardous

substance, pollutant, contaminant, RA, location, or other circumstance at a CERCLA site. ToBe-Considered criteria (TBCs) are non-promulgated advisories and guidance that are not legally

binding, but should be considered in determining the necessary level of cleanup for protection of

human health or the environment. While TBCs do not have the status of ARARs, EPA's

approach to determining if a RA is protective of human health and the environment involves

consideration of TBCs along with ARARs. Chemical-specific ARARs are specific numerical

quantity restrictions on individually listed contaminants in specific media. Examples of

chemical-specific ARARs include the Maximum Contaminant Levels (MCLs) specified under

the Safe Drinking Water Act (SDWA) as well as the ambient water quality criteria that are

enumerated under the Clean Water Act. Because there are usually numerous contaminants of

potential concern for any site, various numerical quantity requirements can be ARARs.

The final remedy selected for this Site was designed to meet or exceed all chemical-specific

ARARs and meet location- and action-specific ARARs, as documented in the ROD and further

considered during the RD development. The chemical-specific ARARs identified in the selected

remedy within the ROD for the groundwater at this Site is the SDWA MCL for free cyanide (0.2

mg/L). Kentucky primary drinking water standards are the same as federal primary drinking

standards for the identified contaminant of concern. The chemical-specific ARARs identified in

the selected remedy within the ROD for soils at this Site is the Toxic Substances Control Act

(TSCA) for PCBs. Other chemical-, action- and location-specific ARARs identified in the ROD

for this Site are further considered in the approved 2006 RD.

A review of the ARARs for this Site, including the SDWA, TSCA, Kentucky Environmental

Performance Standards, RCRA, National Pollutant Discharge Elimination System, etc. were

conducted as part of this FYR. The review did not identify more stringent standards,

requirements or criteria that could affect the protectiveness of the selected remedy.

6.4 Data Review

This section presents the findings of the information reviewed during the FYR. The information

included operational data for OU1, environmental monitoring data for OU1, OU2, and the

NTCRA South Slurry Pond, and data collected during the remedial action implementation

activities for OU2.

Operable Unit No. 1 - Groundwater

The data collected and reviewed during this FYR period for OU1 are summarized below. For

reference, the documents that provide the data are summarized in bracketed text [ ]:

 Extraction Well Operation [Monthly Progress Reports]

 GWTP Operation [Monthly Progress Reports]

 GWTP KPDES-Permitted Effluent Discharge [Monthly Progress Reports]

 Monthly Extraction Well Sampling Results [Monthly Progress Reports and PSVR]

 Quarterly and Annual Groundwater Monitoring Well Sampling Results [Monthly

Progress Reports and PSVR]
26 AUGUST 2011

 MW-204D Continuous Purge Test Sampling Results [MW-204D Assessment Activities

Report, attachment to Remedial Action Report]

The environmental monitoring requirements for OU1 were established in the O&M Manual. A

review of the Monthly Progress Reports for OU1 indicates that the north plume extraction wells

and the GWTP operated until January 2010 when system operation was discontinued as part of

the MW-204D continuous purge assessment activities. The system was shut-down for short

durations during this FYR period when maintenance and repairs were required.

A review of the GWTP effluent analytical data indicates that KPDES-permitted discharge limits

for the specified outfall (Outfall 010) were exceeded on one occasion. The total suspended

solids limit was briefly exceeded in late 2008 (10% over daily maximum and 2% over monthly

average). Otherwise, the effluent concentrations were in compliance with the KPDES permit

discharge limits during the period in review.

The O&M Manual requires monthly sampling of the extraction wells. A review of the available

extraction well analytical data indicates that the concentrations of free cyanide have been below

the specified performance standard (0.2 mg/L) throughout the FYR period.

The O&M Manual required quarterly sampling of five (5) monitoring wells and annual sampling

of thirty-two (32) monitoring wells for total and free cyanide until the OU1 performance

standards were achieved (37 total wells). A review of the quarterly and annual groundwater

monitoring well analytical data during this FYR period indicates stable or decreasing trends in

most of the north and south plume monitoring wells. In addition, the monitoring results from

most wells indicate that the concentrations of free cyanide were at or below the OU1

performance standard for free cyanide (0.2 mg/L) during the review period.

The only notable exceptions were at north plume wells MW-104, MW-204D and MW-215. The

exceedances at MW-215 are discussed in the PSVR and are attributed to the OU2 Taylors Wash

Landfill remedial action activities. The concentrations of free cyanide at MW-215D have been

below the performance standard since March 2009. The exceedances at MW-204D were

discussed with EPA and led to the development of the MW-204D Assessment Work Plan and the

continuous purge test that was conducted in January 2010. The concentrations of free cyanide at

MW-204D have been below the performance standard since May 2009, including all samples

collected as part of the continuous purge activities. The concentrations of free cyanide at MW104 have been below the performance standard since May 2009.

The concentrations of free cyanide in the north and south plume extraction and monitoring wells

are depicted in the trend graphs included as Figures 5-8. The performance standard was achieved

in all monitoring wells from August 2009 through May 2010.

The data reviewed for this FYR period supports the following conclusions:

 The OU1 GWTP and extraction wells were appropriately operated and maintained.

 Monitoring data was collected for the required parameters, and at the frequency specified,

in the O&M Manual.
27 AUGUST 2011

 The data demonstrates general compliance with the specified OU1 performance standard

during the FYR period. The data supports the completion status of OU1.

 The data demonstrates general compliance with the KPDES permit during the FYR

period.

 No significant issues related to the implementation or protectiveness of the remedy have

been identified.

Operable Unit No. 2 - Soils

The data reviewed during this FYR period for OU2 are summarized below. For reference, the

documents that provide the data are summarized in bracketed text [ ]:

 Remedial Action Quality Control / Quality Assurance (QA/QC) Documentation

[Monthly Progress Reports and Construction Completion Report]

 Quarterly Groundwater Monitoring Well Sampling Results [Monthly Progress Reports]

 Semi-Annual Wetlands Monitoring [Wetlands Monitoring Reports]

 Semi-Annual O&M Inspections [Annual O&M Reports]

The OU2 remedial construction activities were conducted from 2006 to 2008. A substantial

amount of data was collected as part of the quality control / quality assurance requirements

documented in the 2006 RD. The information consists of, but is not limited to, material

certifications, air monitoring data, groundwater monitoring and extraction well analytical

data, treatment system discharge analytical data, soil confirmation data, liner testing results,

waste characterization data, Site surveys, and field observations. A review of the information

indicates that the QA/QC requirements for the remedial action construction activities were met.

In November 2008, EPA issued a letter that approved the Construction Completion Report for

OU2 and classified the OU2 remedy at the Site as operational and functional.

The monitoring requirements for OU2 were established in the O&M Manual. A review of this

document indicates that the required monitoring was conducted as specified.

The O&M Manual requires the quarterly sampling of five (5) groundwater monitoring wells for

PCBs for a period of three years. A review of the data indicates that the sampling has been

performed and that PCBs have not been detected in any sample since groundwater monitoring

commenced in March 2009. A summary of the data is provided in Figure 9.

The O&M Manual requires semi-annual monitoring of wetlands in the RBDAs in order to assess

compliance with the Conceptual Wetlands Mitigation Plan provided in the 2006 RD and

achievement of the standards set forth in the Clean Water Act. A review of the wetlands

monitoring data indicates that the standards set forth in the Conceptual Wetlands Mitigation Plan

were generally met, with the exception of planted tree survival in certain locations. Wetlands

monitoring is required to continue through 2014.

The O&M Manual requires semi-annual inspections at each focus area in order to evaluate the

continued protection and effectiveness of the remedy. The inspections, and any findings or

recommendations, are presented in the Annual O&M Reports for the Site. In addition, any

repairs that have been made are documented in this report. A review of these reports indicates
28 AUGUST 2011

that inspections have been conducted and that minor repair activities, such as erosion control and

re-vegetation, have been implemented as needed. A review of this information indicates that the

O&M activities have been conducted appropriately and the remedy continues to function as

intended.

The data reviewed for this FYR period supports the following conclusions:

 The OU2 remedial activities achieved the QA/QC standards established in the 2006 RD.

 The required O&M activities (including Site inspections, groundwater monitoring and

wetlands monitoring) are being conducted in accordance with the O&M Manual.

 No significant issues related to the implementation or protectiveness of the remedy have

been identified.

NTCRA South Slurry Pond

The data reviewed during this FYR period for the NTCRA South Slurry Pond is summarized

below. For reference, the documents that provide the data are summarized in bracketed text [ ]:

 Quarterly and Annual Groundwater Monitoring Well Sampling [Monthly Progress

Reports]

 Annual O&M Inspections [Annual O&M Report]

The monitoring requirements for South Slurry Pond are provided in the O&M Manual. A review

of this document indicates that the required monitoring has been conducted as specified.

The O&M Manual requires the annual inspection of the South Slurry Pond cover system. These

inspections have been conducted and are documented in the Annual O&M Report for the Site.

No issues have been identified.

The O&M Manual also requires the quarterly sampling of four (4) wells and the annual sampling

of (6) wells for fluoride (10 total wells). Five (5) of the monitoring wells are located in the

central source area immediately downgradient from the South Slurry Pond. The concentrations

of fluoride in these wells during the FYR period generally appear to be stable, with the exception

of apparent data anomalies at MW-203D in 2006 and 2007. The RI/FS indicates that fluoride

mobility is limited by the precipitation of calcium fluoride. When the concentrations of fluoride

in the five (5) central source area wells are compared to the upgradient, sidegradient and

downgradient wells, the data supports the findings of the RI/FS. A summary of the data is

provided in Figure 10.

The data reviewed for this FYR period supports the following conclusions:

 The inspections of the South Slurry Pond cover system are being conducted in

accordance with the O&M Manual and no issues have been identified.

 The monitoring data supports the findings of the RI/FS.

 No significant issues related to the implementation or protectiveness of this removal

action have been identified.
29 AUGUST 2011

6.5 Site Inspection

Site inspection activities were conducted by various agencies on March 17, March 23, March 29

and April 29, 2011 for this FYR. The March 17, 2011 inspection was conducted by URS. The

March 23, 2011 inspection was conducted by EPA, Southwire, Century, and URS. The March

29, 2011 inspection was conducted by KDWM, Southwire, Century, and URS. The April 29,

2011 inspection was conducted by URS in order to review the documents available on-site, at the

Hancock County Public Library, and Hancock County Recorder’s Office. These activities are

documented in Appendix C, Site Inspection Checklist.

The Site inspections included a review of available Site information (including on-site

documents and records), access and institutional controls, current Site conditions, conditions of

installed landfill cover systems and a review of the current conditions of the OU2 focus areas and

South Slurry Pond. There were no significant issues identified during any of the Site visits. A

review of the on-site documents indicated that Southwire has been performing and documenting

the O&M activities as required by the O&M Manual.

URS staff conducted research at the Hancock County Recorder’s Office on April 29, 2011 and

found the following deed recording information pertaining to the Site.

Table 7: Deed Documents from Hancock County Public Records Office

Date Type of

Document Description Book # Page #

9/27/1967 Deed Southwire Company

Property Deed

72 396

9/5/2008 Quitclaim

Deed

Century Aluminum Property

Deed

141 47

11/24/2010 Environmental

Covenant

Southwire Company Outlot 145 38

11/24/2010 Environmental

Covenant

Century Aluminum Property 145 1
30 AUGUST 2011

The following Table 8 lists the primary ICs associated with areas of interest at the Site. The

attached Figure 11 also depicts the ICs in place at the Site.

Table 8: IC Summary Table

Property

Owner

OU or

Area of

Interest

Contaminated

Media

ICs

Required

by ROD?

IC Objective IC Instrument

Southwire

South

Slurry

Pond and

Former

Ponds

Groundwater

and Soil Yes

1. Restrict

groundwater use

for potable

purposes.

2. Restrict land

use for residential

purposes.

3. Prevent

disturbance of cap

systems.

November 2010

Environmental

Covenant

Century

Aluminum OU1 Groundwater Yes

Restrict

groundwater use

for potable

purposes Sitewide.

November 2010

Environmental

Covenant

Century

Aluminum

OU1 and

OU2

Groundwater

and Soil Yes

Restrict land use

for residential

purposes Sitewide.

November 2010

Environmental

Covenant

Century

Aluminum

OU2

Focus

Areas

Soil

Yes

(except for

Drum

Storage

Area)

Prevent

disturbance of cap

systems.

November 2010

Environmental

Covenant

Other controls in place at the Site include fencing and warning signs. A Site perimeter fence

controls access to the aluminum reduction plant area. Perimeter fences are also in place at the

Taylors Wash Landfill and the RBDAs associated with OU2. Warning signs are in place at all

OU2 focus areas to prevent digging or other disturbances to the cap systems in place at each of

those units. During the Site inspections, warning signs and perimeter fencing were observed to

be appropriately maintained and functioning as intended.
31 AUGUST 2011

6.6 Interviews

During the FYR process, interviews were conducted with the current landowners, local residents,

local officials, and regulatory agencies involved in Site activities. The purpose of the interviews

was to document the perceived status of the Site and any perceived problems or successes with

the phases of the remedy that have been implemented to date. The persons interviewed did not

offer any adverse comments that would affect the protectiveness of the remedy. The interviews

were conducted by the EPA Office of Public Affairs and Outreach in April and May 2011.
32 AUGUST 2011

7.0 Technical Assessment

This section provides a technical assessment of the Site based on the Site inspections, document

reviews and interviews discussed in Section 6.0.

7.1 Question A: Is the remedy functioning as intended by the decision documents?

The information collected as part of the FYR activities indicates that the remedy is complete and

functioning as intended by the decision documents. The answer to Question A is “Yes” as

supported by the following information.

Remedial Action Performance

The remedial action construction and operation activities at OU1 are complete. The remedial

action construction activities at OU2 are also complete. The documents reviewed as part of the

FYR (Appendix A), ARARs, risk assumptions and the observations of the Site inspections

indicate that the performance standards and cleanup goals have been achieved, and that the

remedial activities are effective and functioning as intended by the ROD.

For OU1, the monitoring data from operation of the GETS during the period of 1995 through

2010, has demonstrated that the ROD-specified performance standards for free cyanide have

been met and that the system effectively remediated the affected groundwater.

For OU2, the remedial action construction activities conducted from 2006 to 2008 achieved the

ROD-specified performance standards for PCBs and PAHs in soil through excavation and

disposal activities, and the installation of required cap systems at each of the five (5) focus areas.

This was demonstrated by data from Site construction and monitoring activities.

System Operations / O&M

The documents reviewed as part of the FYR (Appendix A) and the observations from the Site

inspections indicate that Southwire is implementing the required O&M activities and that the

O&M activities have been effective in maintaining the protectiveness of the remedy. The

documents also indicate that Southwire has performed maintenance activities as necessary. A

comparison of the ROD-estimated O&M costs to actual O&M costs indicates that there were no

significant discrepancies or unanticipated O&M costs during the review period as discussed in

Section 4.3.

Opportunities for Optimization

During this FYR period, one opportunity for optimization was identified relative to continued

groundwater monitoring at the South Slurry Pond. This includes revisions to the number of

groundwater monitoring wells and sampling frequency associated with this unit and is supported

by the data reviewed during this FYR period. The opportunity for optimization is consistent with

the selected remedy presented in the ROD and will result in cost savings related to on-going

O&M activities.

The removal activities for the NTCRA South Slurry Pond are complete. The O&M activities

related to the South Slurry Pond are required to continue through 2027 and include inspection of
33 AUGUST 2011

the cover system and groundwater monitoring for fluoride. The O&M Manual was developed in

1997 and specifies quarterly sampling for fluoride at four (4) wells and annual sampling at six

(6) wells (10 total wells). Five (5) of these wells are located in the central source area and five

(5) of these wells are located upgradient, sidegradient or downgradient to the central source area.

As described in Section 6.4, the data reviewed for this activity indicates that the analytical results

from the ten (10) monitoring wells have generally been stable during the FYR period. This

opportunity for optimization recommends that sampling continue on an annual basis at the five

(5) central source area wells and at one (1) upgradient and one (1) downgradient location (7 total

wells). This opportunity for optimization will continue to be protective of human health and the

environment and reduce the O&M costs associated with groundwater monitoring. The

groundwater monitoring wells that are no longer included in the NTCRA South Slurry Pond

monitoring should be properly decommissioned in order to prevent a potential surface conduit to

groundwater.

Early Indicators of Potential Issues

No early indicators of potential issues were identified during this FYR period.

Implementation of Institutional Controls

The ROD-specified ICs for this Site are in place and functioning (as described in Section 6.5).

The implementation of the ICs and the remedial action activities conducted at the Site are

adequate and appropriate to protect human health and the environment.

7.2 Question B: Are the exposure assumptions, Toxicity Data, Cleanup Levels, and Remedial

Action Objectives (RAOs) Used at the Time of Remedy Selection Still Valid?

The information collected and analyzed as part of the FYR activities indicates that the exposure

assumptions, Toxicity Data, Cleanup Levels, and RAOs used in development of the ROD are

still valid. The answer to Question B is “Yes” and this is supported by the information contained

below:

Changes in Standards and TBCs

The primary standards considered in development of the ROD RAOs and selected remedy were

related to cyanide in groundwater and PCBs in soils. For cyanide in groundwater, the

performance standard was developed based on the SDWA MCL for free cyanide. For PCBs in

soil, the performance standards were developed based on the self-implementing provisions of

TSCA. These standards have not changed and the current remedy provisions continue to be

protective at the Site.

Changes in Exposure Pathways

The ROD evaluated human and ecological exposure pathways. For human receptors (primarily

Site workers or visitors), inhalation, ingestion, and dermal exposures were evaluated. For

ecological receptors, ingestion, respiration, and direct contact exposures were evaluated. The

land use and expected land use at the Site has not changed, and no new human health or

ecological routes of exposure have been identified. In addition, no new contaminants or

contaminant sources have been identified. Based on this information, the potential exposure

pathway assumptions are still valid. In addition, ICs are in place to prevent exposure.
34 AUGUST 2011

Changes in Toxicity and Other Contaminant Characteristics

No changes in toxicity or other contaminant characteristics have been identified that could affect

the protectiveness of the remedy.

Changes in Risk Assessment Methods

Changes in risk assessment methodologies are not expected to affect the protectiveness of the

remedy.

Expected Progress toward Meeting RAOs

The remedial actions required at the Site were completed in 2010, and the RAOs have been met.

7.3 Question C: Has Any Other Information Come to Light That Could Call Into Question

the Protectiveness of the Remedy?

No new human health or ecological issues related to the Site were identified during this FYR.

No natural disasters have impacted the Site. There has also been no other information identified

at the Site that calls into question the protectiveness of the remedy. The answer to Question C is

“No”.

7.4 Technical Assessment Summary

According to the data reviewed, the Site inspections and the other components of this FYR, the

remedy is functioning as intended by the decision documents for the Site. There have been no

changes to the physical Site that would affect the protectiveness of the remedy. The performance

standards and cleanup goals for the Site have been met through the remedial action activities.

There are no identified changes to toxicity factors or to the risk assessment methodologies that

would significantly affect the protectiveness of the remedy. There is no other information that

calls into question the protectiveness of the remedy.
35 AUGUST 2011

8.0 Issues

The review of Site conditions and information during the FYR period has led to the identification

of one potential issue at the Site. The remedial activities at the Site are complete and the cleanup

requirements have been met. The groundwater monitoring requirements associated with

Operable Unit No. 1 (OU1), Operable Unit No.2 (OU2) and the Non-Time Critical Removal

Action (NTCRA) South Slurry Pond are also complete and/or approaching completion.

Following completion of the required groundwater monitoring, the monitoring wells should be

properly abandoned under the provisions of the Commonwealth of Kentucky to prevent a

potential surface conduit to groundwater. Information on the groundwater monitoring schedule

can be found in Sections 4.3 and 7.1.

Table 9: Current Issue for the National Southwire Aluminum Superfund Site

Issue

Affects Current

Protectiveness

(Yes or No)

Affects Future

Protectiveness

(Yes or No)

Inactive Groundwater Monitoring Wells

Provide a Potential Surface Conduit to

Groundwater

No Yes
36 AUGUST 2011

9.0 Recommendations and Follow-up Actions

Section 8.0 presents a potential issue at the Site related to inactive groundwater monitoring wells.

It is recommended that groundwater monitoring wells at the Site be properly abandoned under

the provisions of the Commonwealth of Kentucky after the monitoring requirements are

completed.

Table 10: Recommendation to Address Current Issue at the National Southwire Aluminum

Superfund Site

Issue /

Improvement

Recommendations/

Follow-Up Actions

Party

Responsible

Oversight

Agency

Milestone

Date

Affects

Protectiveness?

(Yes or No)

Current Future

Completion of

Groundwater

Monitoring

Activities

Properly Abandon

Monitoring Wells

when Monitoring

Complete

Southwire EPA /

KDOW /

KDWM

06/01/2012 No Yes
37 AUGUST 2011

10.0 Protectiveness Statements

The remedial action for the National Southwire Aluminum Superfund Site consisted primarily of

groundwater and soil remediation. All remedial activities at the Site are complete, the cleanup

requirements have been met and the remedial action is protective of human health and the

environment.
38 AUGUST 2011

11.0 Next Review

This is a statutory Site that requires ongoing FYRs as long as waste remains on site, prohibiting

unrestricted use and unlimited exposure. The next FYR will be due within five years of the

signature/approval date of this FYR.
Quadrangle Location

KY

IN

N

BASE MAP SOURCE: USGS 7 1/2 minute

topographic quadrangle map Tell City,

Indiana-Kentucky 1961, photorevised 1980.

SCALE IN FEET

0 4000 8000

FIGURE 1

SITE VICINITY MAP

JOB NO. 14946586

NATIONAL SOUTHWIRE ALUMINUM

SUPERFUND SITE

Hawesville, Hancock County, Kentucky

SITE

NSA - 14946586.00400 - CONSTRUCTION COMPLETION REPORT - CHECKED BY
Old South

Slurry

Pond

(Closed)

OHIO RIVER

STATE ROUTE 271

STATE ROUTE 334

Hancock Field

Potliner

Disposal

Area

(Closed))

New

Slurry

Pond

IIIIIIIII

I I I I I I

I I I I IIIIIIIIII I I I I

I I I I I I I IIIIIIIIIIIII

East Slurry Disposal

Area (Closed)

Taylors Wash

Drainage Ditch

105 N

MW-203S

MW-203I NSA-5

MW-204D

MW-6 MW-5

MW-208I

3

5

4

MW-210I

Pitch Heater

Building

Pitch Storage

Tanks

Spent Potliner

Accumulation Building

Cooling

Tower

MW-214

MW-215

MW-7

MW-209I

MW-8

PCB Spill

Investigation Area

Standpipe

Historic Refractory

Brick Disposal Area

(Inactive)

11

Creek

NSA-1

Drum Storage

and Painting Area

MW-213I

102

104

112

107

Ground Water

Treatment Plant

MW-203D

MW-212I MW-211I

MW-201I

MW-201D

111

110

MW-217

BASE MAP SOURCE: Compiled from site

plan from NSA, November 1984; and well

locations from survey data from Johnson,

Depp & Quisenberry, April 1992 and

December 1993.

APPROXIMATE SCALE IN FEET

0 800 1600

FIGURE 2

SITE EXTRACTION WELL AND

MONITORING WELL LOCATIONS

JOB NO. 14946586

NATIONAL SOUTHWIRE ALUMINUM

SUPERFUND SITE

Hawesville, Hancock County, Kentucky

NSA  14946586.00400  CONSTRUCTION COMPLETION REPORT  CHECKED BY

12

MW-201S

109

EW-12

EW-13

EW-2 EW-4

EW-1 103 EW-3

I I I I I I I I I I I I I I I I I I I I I I I I I III I I IIIIIIIII I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I

IIIIIIIII I

I I I I I I I I I I I I I I I I I I I I I I I I I I I I I

I I I

I I I I I I I I I I I I I I I I I I I I I I I I I I I I I

106

PCB Soil Stockpile Area

Current Refractory

Brick Disposal Area

(Inactive)

South Plume

North Plume

Up Gradient

Booster Station

IIII

LEGEND:

Fence

Railroad Spur

Intermittent Ditch or Creek and Flow Direction

Monitoring Well Location

Extraction Well Location

Groundwater Flow Direction

NOTES:

 MW-207A abandoned during the 2007 construction activities.

 Three new monitoring wells were installed in the south plume for

 OU2 monitoring in late 2007.
Taylors Wash

Landfill

Current

RBDA

I I I I I I I I I I I I I I I I I I I I I I I I I III I I IIIIIIIII I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I

IIIIIIIII I

I I I I I I I I I I I I I I I I I I I I I I I I I I I I I

I I I

I I I I I I I I I I I I I I I I I I I I I I I I I I I I I

N

OHIO RIVER

STATE ROUTE 271

STATE ROUTE 334

Hancock Field

Potliner

Disposal

Area

(Closed)

New

Slurry

Pond

IIIIIIIII

I I I I I I

I I I I IIIIIIIIII I I I I

I I I I I I I IIIIIIIIIIIII

Spent Potliner

Accumulation

Building

BASE MAP SOURCE: Compiled from site

plan from NSA, November 1984.

APPROXIMATE SCALE IN FEET

0 800 1600

Drainage Ditch

NOTE: Drum Storage and Painting Area

and PCB Spill Investigation Area are

separate areas of investigation.

PCB Soil

Stockpile Area

Muddy Gut Creek

Historic

RBDA

Green Carbon

Area

Pitch Storage

Tanks

Groundwater

Treatment Building

LEGEND:

Fence

Railroad Spur

Intermittent Ditch or Creek and Flow Direction

IIII

FIGURE 3

OPERABLE UNIT NO. 2 FOCUS AREAS

JOB NO. 14946586

NATIONAL SOUTHWIRE ALUMINUM

SUPERFUND SITE

Hawesville, Hancock County, Kentucky

Old South

Slurry

Pond

(Closed)

NSA - 14946586.00400 - CONSTRUCTION COMPLETION REPORT - CHECKED BY

Drum Storage

Area

Leachate

Pretreatment System
0

200400600800

1,0001,2001,4001,600

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 20

Cumulative Volume Extracted Groundwater (Million Gallons)

FIGURE 4

NORTH AND SOUTH PLUME EXTRACTION VOLUMES AND 

AVERAGE FREE CYANIDE CONCENTRATIONS

South Plume Extraction Volume North Plume Extraction Volume South Plume Free Cyanide No

Notes: 1) South plume extraction well operation was discontinued in 2005. As a result, extraction well analytical samples from south plume we

2) Groundwater treatment plant operation was discontinued on January 18, 2010. As a result, extraction well analytical samples were n

Performance Standard = 0
FIGURE 5A

FIGURE 5B

FIGURE 5

Extraction Well 

Trend Graphs

NATIONAL SOUTHWIRE ALUMINUM

FREE CYANIDE (WAD) CONCENTRATIONS IN NORTH PLUME EXTRACTION WELLS 

(1995-2010)

0.001

0.010

0.100

1.000

10.000

6/1/19956/1/19966/1/19976/1/19986/1/19996/1/20006/1/20016/1/20026/1/20036/1/20046/1/20056/1/20066/1/20076/1/20086/1/20096/1/2010

Sample Date

Free Cyanide (mg/L)

EX-1 EX-2 EX-3 EX-4

Performance 

Standard = 0.2 mg/L

Closure of South 

Slurry Pond - 1997

FREE CYANIDE (WAD) CONCENTRATIONS IN SOUTH PLUME EXTRACTION WELLS 

(1995-2010)

0.001

0.010

0.100

1.000

10.000

6/1/19956/1/19966/1/19976/1/19986/1/19996/1/20006/1/20016/1/20026/1/20036/1/20046/1/20056/1/20066/1/20076/1/20086/1/20096/1/2010

Sample Date

Free Cyanide (mg/L)

EX-13 EX-12

Performance 

Standard = 0.2 mg/L

Closure of South 

Slurry Pond - 1997
FIGURE 6A

FIGURE 6B

FIGURE 6

Quarterly and North Plume 

Monitoring Well Trend 

Graphs

NATIONAL SOUTHWIRE ALUMINUM

FREE CYANIDE (WAD) CONCENTRATIONS IN NORTH PLUME - 

ANNUAL WELLS FROM 1995-2010

0.001

0.010

0.100

1.000

10.000

Jun-95 Jun-96 Jun-97 Jun-98 Jun-99 Jun-00 Jun-01 Jun-02 Jun-03 Jun-04 Jun-05 Jun-06 Jun-07 Jun-08 Jun-09 Jun-10

Sample Date

Free Cyanide (mg/L)

NSA-5 MW-106 MW-107 MW-109 MW-203D MW-203S MW-204D MW-5 MW-6

Performance Standard 

= 0.2 mg/L

Closure of South 

Slurry Pond - 1997

FREE CYANIDE (WAD) CONCENTRATIONS IN NORTH AND SOUTH PLUME - 

QUARTERLY WELLS FROM 1995-2010

0.001

0.010

0.100

1.000

10.000

Jun-95 Jun-96 Jun-97 Jun-98 Jun-99 Jun-00 Jun-01 Jun-02 Jun-03 Jun-04 Jun-05 Jun-06 Jun-07 Jun-08 Jun-09 Jun-10

Sample Date

Free Cyanide (mg/L)

MW-102 MW-103 MW-104 IP-5

Performance 

Standard = 0.2 mg/L

Closure of South 

Slurry Pond - 1997
FIGURE 7

North Plume Monitoring 

Well Trend Graphs

NATIONAL SOUTHWIRE ALUMINUM

FIGURE 7A

FIGURE 7B

FREE CYANIDE (WAD) CONCENTRATIONS IN NORTH FAR FIELD AREA FROM 1995-2010

0.001

0.010

0.100

1.000

10.000

Jun-95 Jun-96 Jun-97 Jun-98 Jun-99 Jun-00 Jun-01 Jun-02 Jun-03 Jun-04 Jun-05 Jun-06 Jun-07 Jun-08 Jun-09 Jun-10

Sample Date

Free Cyanide (mg/L)

MW-105 MW-111 MW-201D MW-201I MW-201S MW-211I MW-212I

Performance Standard = 0.2 mg/L

Closure of South 

Slurry Pond - 1997

FREE CYANIDE (WAD) CONCENTRATIONS IN CENTRAL SITE AREA FROM 1995-2010

0.001

0.010

0.100

1.000

10.000

Jun-95 Jun-96 Jun-97 Jun-98 Jun-99 Jun-00 Jun-01 Jun-02 Jun-03 Jun-04 Jun-05 Jun-06 Jun-07 Jun-08 Jun-09 Jun-10

Sample Date

Free Cyanide (mg/L)

MW-110 MW-210I MW-213I MW-214S MW-215 MW-217

Performance Standard = 0.2 mg/L

Closure of South 

Slurry Pond - 1997
FIGURE 8

South Plume Monitoring 

Well Trend Graphs

NATIONAL SOUTHWIRE ALUMINUM

FIGURE 8A FREE CYANIDE (WAD) CONCENTRATIONS IN SOUTH PLUME - 

ANNUAL WELLS FROM 1995-2010

0.001

0.010

0.100

1.000

10.000

Jun-95 Jun-96 Jun-97 Jun-98 Jun-99 Jun-00 Jun-01 Jun-02 Jun-03 Jun-04 Jun-05 Jun-06 Jun-07 Jun-08 Jun-09 Jun-10

Sample Date

Free Cyanide (mg/L)

IP-3 IP-4 IP-8 IP-11 MW-207A

Performance Standard = 0.2 mg/L

Closure of South 

Slurry Pond - 1997

FREE CYANIDE (WAD) CONCENTRATIONS IN SOUTH PLUME - 

UPGRADIENT WELLS FROM 1995-2010

0.001

0.010

0.100

1.000

10.000

Jun-95 Jun-96 Jun-97 Jun-98 Jun-99 Jun-00 Jun-01 Jun-02 Jun-03 Jun-04 Jun-05 Jun-06 Jun-07 Jun-08 Jun-09 Jun-10

Sample Date

Free Cyanide (mg/L)

IP-12 MW-208I MW-209I

Performance Standard = 0.2 mg/L

Closure of South 

Slurry Pond - 1997

FIGURE 8B
II I I IIIIIIIII I I

I

I

I

I

I I I I I I I I I I I I I I I I I I I I I I I I OHIO RIVER

IIIII

I

I

I

I

I

I

I

IIIIIIIIIIIII

N

APPROXIMATE SCALE IN FEET

0 400 800

IP-11

MW-220

MW-221

MW-222

MW-208I

FIGURE 9

OU2 MONITORING WELL LOCATIONS

AND DATA

Pitch Heater Building

Pitch Storage Tanks

Cooling

Tower

Drum Storage Area

Spent Potliner Accumulation Building

Green Carbon PCB Spill Area

Ground Water Treatment Building

IIIII

LEGEND:

FenceRailroad SpurOU2 Monitoring Well Location
N

South Slurry Pond

(Closed) OHIO RIVER

Potliner

Disposal

Area

(Closed))

New

Slurry

Pond

I

I

I

East Slurry Disposal Area (Closed)

MW-203I

MW-204D

MW-6

102

104

MW-203D 103

I I IIII I

I

I

I

I

I I I I I I I I I I I I I I I I I

I

I

I

I I I I I I 

MW-203S MW-5

APPROXIMATE SCALE IN FEET

0 500 1,000

FIGURE 10

SOUTH SLURRY POND

MONITORING WELL LOCATIONS AND

ANNUAL DATA

IIII

LEGEND:

FenceRailroad SpurIntermittent Ditch orCreek and Flow DirectionSouth Slurry PondMonitoring Well LocationGroundwater Flow Direction
N

BASE MAP SOURCE: Compiled from site plan fromNSA, November 1984; Surdex Corp. AerialPhotograph May, 1993; and HRG flyover, April 2001.

I I I I I IIIIIIIII

STATE ROUTE 271

STATE ROUTE 334

IIIIII

I I I I

I I I IIIIIIII I I

TaylorsWashLandfill

Spent Potliner Accumulation Building

Cooling Tower

Drum Storage Area

ow Direction

OHIO RIVER

Muddy Gut Tributary (Intermittent Flow)

ROUTE 3092

IIIIIIIIIIIII I I I I I I I I

I IIIIII I I I I I IIIIIIIIIIIIIIIIIIII I I I I

I IIIIII I

I I I I IIIIIIIIIIII I I I I

I I I

I

I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 

APPROXIMATE SCALE IN FEET

0 1000 2000

Ballfield

Southwire Company Outlot

New SlurryPond

PCB Soil

Stockpile Area

Hancock Field (Disused) Groundwater Treatment Building

Current Refractory

Brick Disposal Area

(Inactive)

Historic Refractory

Brick Disposal Area

(Inactive)

Green Carbon PCB Spill Area

Drainage Ditch

SOUTHWIRE  14949080.20115  CHECKED BY

NATIONAL SOUTHWIRE ALUMINUM

SUPERFUND SITE

Hawesville, Hancock County, Kentucky

FIGURE 4

SITE PLAN WITH

INSTITUTIONAL CONTROLS

JOB NO. 14949080

Approximate Limit of Sitewide Groundwater UseRestriction for Potable Purposes and Land UseRestriction for Residential PurposesApproximate Limits of Unit Specific Land Restriction
Appendix A: List of Documents Reviewed
A-1

ACOE, 2001. First Five-Year Review for the National Southwire Aluminum Superfund Site.

ACOE, 2006. Second Five-Year Review for the National Southwire Aluminum Superfund Site.

Dames & Moore. 1993. Remedial Investigation/Feasibility Study Work Plan.

Dames & Moore, 1994. Interim Remedial Action Groundwater Pumping and Treatment System

Remedial Design.

Dames & Moore. 1995. Interim Remedial Action Groundwater Pumping and Treatment System

Remedial Design Revised Draft Submittal VI (includes Performance Standards Verification

Report).

Dames & Moore, 1997. South Slurry Pond Operations and Maintenance Plan.

Dames & Moore. 1998. Final Construction Report for the Interim Remedial Action.

Dames & Moore. 1998. Revised Draft Remedial Investigation Report.

Dames & Moore, 1998. Feasibility Study.

EPA. 1993. Interim Record of Decision.

EPA. 2000. Final Record of Decision.

EPA. 2000. OSWER Directive 9320.2-09A-P Closeout Procedures for National Priorities List

Sites.

EPA. 2000. Statement of Work.

EPA, 2004. Consent Decree.

EPA. 2008. Preliminary Close Out Report.

EPA, 2011. Final Close Out Report.

URS, 2006 to Present. Monthly Progress Reports.

URS. 2006. Remedial Design / Remedial Action Final Design Submittal.

URS. 2008. Construction Completion Report.
A-2

URS. 2008. Operations and Maintenance Manual for OU1, OU2 and South Slurry Pond.

URS. 2009. Leachate System Operation Completion Report.

URS, 2009 to 2010. O&M Report.

URS. 2010. MW-204D Assessment Activities Report.

URS. 2011. Remedial Action Report (includes Performance Standards Verification Report,

Revision 1).
Appendix B: Press Notices
TELL CITY

Now h

Sto

A positive 

Gre

1st, 2nd 

Startin

Lasting 

May ap

on the hir

**N

Setup, R

when a

Correctional Medical Services

has excellent opportunities for

Per Diem RNs and LPNs at

the Branchville Correctional

Facility near Interstate 64.

No Bedside Nursing

Clinic Setting

Flexibility to

Work All Shifts

Potential

Unlimited Income!

Correctional healthcare offers

you ambulatory care setting,

lower acuity, less lifting and

more time for patient care.

8 hour and 12 hour shifts for

LPNs.

Contact:

Richard Wright

(812)843-5150

rwright@cmsstl.com

Visit us online at

www.cmsstl.com

EOE/AAP/DTR

jy y j

Purpose of Project: Purchase and install generator at South Hancock

County First Station; as well as, install three warning sirens in the

Boling Chapel, Easton and Roseville communities.

Project Location: The project is located in Hancock County; State of

Kentucky and census tract number 990300

Estimated Cost: $70,000

It has been determined that such request for release of funds will not

constitute an action significantly affecting the quality of human environment and, accordingly, the above-named county has decided not

to prepare an Environmental Impact Statement under the National

Environmental Policy Act of 1969 (PL 91-190.)

The reason for such decision, not to prepare such statement are as

follows: The project is to take place in a rural area that has already

been disturbed. The project will increase the safety and sanitary conditions for the local residents; no environmental problems relating to

this project were discovered during the environmental review.

An Environmental Review Record respecting the project has been

made by the above named county which documents the environmental review of the project and more fully sets forth the reasons why

such statement is not required. This Environmental Review Record is

on file at the above address and is available for public examination

and copying, upon request, in Hancock County Fiscal Court during

normal business hours. No further environmental review of such project

is proposed to be conducted prior to the request of release of Federal

funds.

All interested agencies, groups, and persons disagreeing with the

decision are invited to submit written comments for consideration by

the county to the Office of Judge/ Executive Jack B. McCaslin. Such

written comments should be received at the Office of the Judge/ Executive on or before May 23, 2011. All such comments will be considered and the county will not request the release of Federal Funds or

take any administrative action on the project prior to the date specified on the preceding sentence.

The Hancock County Fiscal Court will undertake the project described

above with Block Grant funds from the Kentucky Department for Local Government under Title I of the Housing and Community Development Act of 1974. The Hancock County Fiscal Court is certifying to the

State that the Hancock County Fiscal Court and Jack B. McCaslin in

his official capacity as Judge/ Executive consent to accept the jurisdiction of the Federal Courts if an action is brought to enforce responsibilities in relation to environmental review, decision making, and action; and that these responsibilities have been satisfied. The legal effect of the certification is that upon its approval of the Hancock County

Fiscal Court, the County may use Block Grant funds and the State

and HUD will have satisfied their responsibilities under the National

Environmental Policy Act of 1969. The State will accept an objection

to its approval only if it is on one of the following bases:

(a) The certification was not in fact executed by the County’s Certifying Officer.

(b) The County has failed to make one of the two findings pursuant to

S58.41 or to make a written determination decision required by

SS58.47, 58.53, or 58.64 for the project, as applicable.

(c) The County has omitted one or more of the steps set forth at Subparts F and G for the preparation and completion of an EA.

(d) No opportunity was given to the Advisory Council on Historic Preservation or its Executive Director to review the effect of the project on

a property listed on the National Register of Historic Places, or found

to be eligible for such listing by the Secretary of the Interior, in accordance with 36 CFR part 800.

(e) Objections have been made by a Federal Agency.

Objections must be prepared and submitted in accordance with the

required procedure (24 CFR part 58) and may be addressed to the

Kentucky Department for Local Government, Division of Community

Programs, 1024 Capital Center Drive, Suite 340, Frankfort, Kentucky

40601

Objections to the release of funds on bases other than those stated

above will not be considered by the State. No objection received after

June 8, 2011, will be considered by the State.

Jack B. McCaslin, Judge/ Executive

Hancock County Fiscal Court

PO Box 580

Hawesville, KY 42348

Bring the family in for a

great meal and the kids

can play Arcade Games,

Pinball and pool.

PIZZA

Call

927-8075

• Hot Wings

• Stroms

• Hamburgers

• Ice Cream

HOURS:Mon -Thurs 11-9,

Fri & Sat 11-10, Sun 3-9

ASPHALT

PAVING

☛ Driveways

☛ Parking Lots

☛ Streets

☛ Playgrounds

Free Estimates

Division of

Yager Materials, Inc.

OWENSBORO

PAVING CO., INC.

926-3611

OWENSBORO, KY

Master Page Even 1 5/4/11, 9:57 AM
Appendix C: Site Inspection Checklist 

 
Site Inspection Checklist - 1 

Site Inspection Checklist

I. SITE INFORMATION

Site name: National Southwire Aluminum Date of inspection: 3/17/2011, 3/23/2011. 4/29/2011 

Location and Region: Hawesville, Hancock County, 

Kentucky 

EPA ID: KYD049062375 

Agency, office, or company leading the five-year 

review: EPA Region 4 

Weather/temperature: Clear / Moderate 

Remedy Includes: (Check all that apply) 

X Landfill cover/containment Monitored natural attenuation 

X Access controls Groundwater containment 

X Institutional controls Vertical barrier walls 

X Groundwater pump and treatment 

 Surface water collection and treatment 

 Other______________________________________________________________________ 

_____________________________________________________________________________ 

Attachments: X Inspection team list (page 13) X Site map attached (Figure 2 of FYR Report) 

II. INTERVIEWS (Check all that apply) 

1. O&M site manager ____________________________ ______________________ ____________ 

Name Title Date 

 Interviewed G at site G at office G by phone Phone no. ______________ 

 Problems, suggestions; G Report attached ________________________________________________ 

 __________________________________________________________________________________ 

2. O&M staff ____________________________ ______________________ ____________ 

Name Title Date 

 Interviewed G at site G at office G by phone Phone no. ______________ 

 Problems, suggestions; G Report attached _______________________________________________ 

 __________________________________________________________________________________ 
Site Inspection Checklist - 2 

3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response 

office, police department, office of public health or environmental health, zoning office, recorder of 

deeds, or other city and county offices, etc.) Fill in all that apply. 

Agency ____________________________ 

Contact ____________________________ __________________ ________ ____________ 

Name Title Date Phone no. 

Problems; suggestions; G Report attached _______________________________________________ 

__________________________________________________________________________________ 

Agency ____________________________ 

Contact ____________________________ __________________ ________ ____________ 

Name Title Date Phone no. 

Problems; suggestions; G Report attached _______________________________________________ 

__________________________________________________________________________________ 

Agency ____________________________ 

Contact ____________________________ __________________ ________ ____________ 

Name Title Date Phone no. 

Problems; suggestions; G Report attached _______________________________________________ 

__________________________________________________________________________________ 

Agency ____________________________ 

Contact ____________________________ __________________ ________ ____________ 

Name Title Date Phone no. 

Problems; suggestions; G Report attached _______________________________________________ 

__________________________________________________________________________________ 

4. Interview Summary

During the FYR process, interviews were conducted with the current landowners, local residents, local officials, 

and regulatory agencies involved in Site activities. The purpose of the interviews was to document the perceived 

status of the Site and any perceived problems or successes with the phases of the remedy that have been 

implemented to date. The persons interviewed did not offer any adverse comments that would affect the 

protectiveness of the remedy. The interviews were conducted by the EPA Office of Public Affairs and Outreach 

in April and May 2011. 

 
Site Inspection Checklist - 3

III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

1. O&M Documents

X O&M manual X Readily available X Up to date N/A

X As-built drawings X Readily available X Up to date N/A

X Maintenance logs X Readily available X Up to date N/A

Remarks The 2008 Operations and Maintenance Manual For OU1, OU2 and South Slurry Pond

Remedial Action Activities is accessible and readily available.

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

Contingency plan/emergency response plan Readily available Up to date X N/A

Remarks URS Corporation developed a site-specific health and safety plan in 2008 for completion of

the O&M activities.

3. O&M and OSHA Training Records X Readily available X Up to date N/A

Remarks The annual O&M reports are readily available at the site.

4. Permits and Service Agreements

Air discharge permit Readily available Up to date X N/A

X Effluent discharge X Readily available X Up to date N/A

Waste disposal, POTW Readily available Up to date X N/A

Other permits_____________________ Readily available Up to date X N/A

Remarks When operating, the GWTP discharged treated effluent to the Ohio River under the terms of

the current KPDES Permit.

5. Gas Generation Records Readily available Up to date X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

6. Settlement Monument Records X Readily available X Up to date N/A

Remarks There is a settlement monument associated with the NTCRA South Slurry Pond.

7. Groundwater Monitoring Records X Readily available X Up to date N/A

Remarks The Groundwater Monitoring Records for OU1 and the South Slurry Pond are included in the

Monthly Progress Reports.

8. Leachate Extraction Records X Readily available X Up to date N/A

Remarks The OU2 leachate treatment system operated until August 2009. The leachate extraction

records were included in the Monthly Progress Reports.

9. Discharge Compliance Records

Air Readily available Up to date X N/A

X Water (effluent) X Readily available X Up to date N/A

Remarks When operating, the GWTP discharged treated effluent to the Ohio River under the terms of

the current KPDES Permit. The effluent compliance records were included in the Monthly Progress

Reports.

10. Daily Access/Security Logs X Readily available X Up to date N/A

Remarks Site security is monitored at the guard house located at the main facility entrance. Visitors

and Contractors must sign in and out with each visit.
Site Inspection Checklist - 4

IV. O&M COSTS

1. O&M Organization

State in-house Contractor for State

PRP in-house X Contractor for PRP

Federal Facility in-house Contractor for Federal Facility

Other:

2. O&M Cost Records

X Readily available X Up to date

X Funding mechanism/agreement in place (PRP Led)

Original O&M cost estimate $1,203,125 From 2000 ROD

Total annual cost by year for review period if available

DATE DATE TOTAL COST

From 1/1/2006 To 12/31/2006 $375,407

From 1/1/2007 To 12/31/2007 $442,830

From 1/1/2008 To 12/31/2008 $695.000

From 1/1/2009 To 12/31/2009 $1,218,221

From 1/1/2010 To 12/31/2010 $274,427

From 1/1/2011 To 5/1/2011 $43,000

3. Unanticipated or Unusually High O&M Costs During Review Period

Describe costs and reasons: The ROD estimated annual O&M Costs included $525,000/year for GWTP

operations (OU1), $31,500 for OU2 O&M, $131,000/year for leachate treatment operations (OU2) and

a total of a 75% mark-up for miscellaneous (25%), engineering (20%) and contingency (30%).

The costs related to O&M for 2006 and 2007 were primarily related to GWTP (OU1) operations. OU1

operation continued through January 2010. The high O&M costs in 2009 are attributed to significant

repairs at the aging GWTP.

OU2 O&M began in 2009 after completion of the remedial activities for that unit.

The leachate treatment system (OU2) operated from July 2008 to August 2009.

Given these considerations and the mark-up associated with the ROD estimate, there do not appear to be

any unanticipated or unusually high O&M costs during this review period.

V. ACCESS AND INSTITUTIONAL CONTROLS X Applicable N/A

A. Fencing

1. Fencing damaged Location shown on site map Gates secured N/A

Remarks The operating facility is secured by a perimeter fence. Additional fence/gate systems are

located at specific focus areas: Taylor’s Wash Landfill, Refractory Brick Disposal Areas. Fencing and

gates are intact and operational.

B. Other Access Restrictions

1. Signs and other security measures Location shown on site map N/A

Remarks Warning signs are located at each of the five OU2 focus areas to prevent digging/disturbance

to the cap systems: Green Carbon PCB Spill Area, Taylor’s Wash Landfill, PCB Soil Stockpile Area,

Drum Storage Area and Refractory Brick Disposal Areas.
Site Inspection Checklist - 5

C. Institutional Controls (ICs)

1. Implementation and enforcement

Site conditions imply ICs not properly implemented Yes X No N/A

Site conditions imply ICs not being fully enforced Yes X No N/A

Type of monitoring (e.g., self-reporting, drive by) Self-Reporting

Frequency Annual

Responsible party/agency Site Owners: Southwire Company and Century Aluminum of Kentucky, LLC

Contact Paul Sims Corp. Env. Mgr, Southwire November 770-832-4679

Name Title Date Phone no.

Ken Sands Env. Mgr, Century November 270-685-2493

Name Title Date Phone no.

Reporting is up-to-date Yes No X N/A

Reports are verified by the lead agency Yes No X N/A

Specific requirements in deed or decision documents have been met X Yes No N/A

Violations have been reported Yes No X N/A

Other problems or suggestions:

The Institutional Controls (in the form of Environmental Covenants) were recorded in November 2010.

The first annual report is due to EPA Region 4 and KDWM in November 2012.

2. Adequacy X ICs are adequate ICs are inadequate N/A

Remarks The ICs prevent potable groundwater use, residential land use and cap disturbance at the five

OU2 focus areas.

D. General

1. Vandalism/trespassing Location shown on site map X No vandalism evident

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Land use changes on site X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Land use changes off siteX N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

VI. GENERAL SITE CONDITIONS

A. Roads X Applicable N/A

1. Roads damaged Location shown on site map X Roads adequate N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________
Site Inspection Checklist - 6

B. Other Site Conditions

Remarks

No significant issues were noted during the Site inspection.

VII. LANDFILL COVERS X Applicable N/A

A. Landfill Surface

1. Settlement (Low spots) Location shown on site map X Settlement not evident

Areal extent______________ Depth____________

Remarks____________________________________________________________

__________________________________________________________________

2. Cracks Location shown on site map X Cracking not evident

Lengths____________ Widths___________ Depths__________

Remarks____________________________________________________________

__________________________________________________________________

3. Erosion Location shown on site map X Erosion not evident

Areal extent______________ Depth____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

4. Holes Location shown on site map X Holes not evident

Areal extent______________ Depth____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

5. Vegetative Cover X Grass X Cover properly established X No signs of stress

Trees/Shrubs (indicate size and locations on a diagram)

Remarks__________________________________________________________________________

_________________________________________________________________________________

6. Alternative Cover (armored rock, concrete, etc.) N/A

Remarks The pavements installed in the Green Carbon PCB Spill Area are intact and functional.

7. Bulges Location shown on site map X Bulges not evident

Areal extent______________ Height____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

8. Wet Areas/Water Damage X Wet areas/water damage not evident

Wet areas Location shown on site map Areal extent______________

Ponding Location shown on site map Areal extent______________

Seeps Location shown on site map Areal extent______________

Soft subgrade Location shown on site map Areal extent______________

Remarks__________________________________________________________________________

_________________________________________________________________________________

9. Slope Instability Slides Location shown on site map X No evidence of slope instability

Areal extent______________

Remarks__________________________________________________________________________

_________________________________________________________________________________
Site Inspection Checklist - 7

B. Benches Applicable X N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope

in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined

channel.)

1. Flows Bypass Bench Location shown on site map X N/A or okay

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Bench Breached Location shown on site map X N/A or okay

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Bench Overtopped Location shown on site map X N/A or okay

Remarks__________________________________________________________________________

_________________________________________________________________________________

C. Letdown Channels Applicable X N/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side

slope of the cover and will allow the runoff water collected by the benches to move off of the landfill

cover without creating erosion gullies.)

1. Settlement Location shown on site map No evidence of settlement

Areal extent______________ Depth____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Material Degradation Location shown on site map No evidence of degradation

Material type_______________ Areal extent_____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Erosion Location shown on site map No evidence of erosion

Areal extent______________ Depth____________

Remarks__________________________________________________________________________

_________________________________________________________________________________
Site Inspection Checklist - 8

4. Undercutting Location shown on site map No evidence of undercutting

Areal extent______________ Depth____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

5. Obstructions Type_____________________ No obstructions

Location shown on site map Areal extent______________

Size____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

6. Excessive Vegetative Growth Type____________________

No evidence of excessive growth

Vegetation in channels does not obstruct flow

Location shown on site map Areal extent______________

Remarks__________________________________________________________________________

_________________________________________________________________________________

D. Cover Penetrations X Applicable N/A

1. Gas Vents Active Passive

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs Maintenance

X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Gas Monitoring Probes

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs Maintenance X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Monitoring Wells (within surface area of landfill)

Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs Maintenance X N/A

Remarks___________________________________________________________

_________________________________________________________________

4. Leachate Extraction Wells

X Properly secured/locked Functioning Routinely sampled Good condition

Evidence of leakage at penetration Needs Maintenance N/A

Remarks The leachate extraction well was used from July 2008 to August 2009 during operation of the

leachate treatment system. It is intact, locked and secured by the Taylor’s Wash Landfill unit fence.

5. Settlement Monuments X Located X Routinely surveyed N/A

Remarks A settlement monument at the NTRCA South Slurry Pond is surveyed every 5-years in

accordance with the O&M Manual for that unit.
Site Inspection Checklist - 9

E. Gas Collection and Treatment Applicable X N/A

1. Gas Treatment Facilities

Flaring Thermal destruction Collection for reuse

Good condition Needs Maintenance

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Gas Collection Wells, Manifolds and Piping

Good condition Needs Maintenance

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)

Good condition Needs Maintenance N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

F. Cover Drainage Layer X Applicable N/A

1. Outlet Pipes Inspected X Functioning N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Outlet Rock Inspected X Functioning N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

G. Detention/Sedimentation Ponds Applicable X N/A

1. SiltationAreal extent______________ Depth____________ N/A

Siltation not evident

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Erosion Areal extent______________ Depth____________

Erosion not evident

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Outlet Works Functioning N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

4. Dam Functioning N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________
Site Inspection Checklist - 10

H. Retaining Walls Applicable X N/A

1. Deformations Location shown on site map Deformation not evident

Horizontal displacement____________ Vertical displacement_______________

Rotational displacement____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Degradation Location shown on site map Degradation not evident

Remarks__________________________________________________________________________

_________________________________________________________________________________

I. Perimeter Ditches/Off-Site Discharge Applicable X N/A

1. Siltation Location shown on site map Siltation not evident

Areal extent______________ Depth____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Vegetative Growth Location shown on site map N/A

Vegetation does not impede flow

Areal extent______________ Type____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Erosion Location shown on site map Erosion not evident

Areal extent______________ Depth____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

4. Discharge Structure Functioning N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

VIII. VERTICAL BARRIER WALLS Applicable X N/A

1. Settlement Location shown on site map Settlement not evident

Areal extent______________ Depth____________

Remarks__________________________________________________________________________

_________________________________________________________________________________

2. Performance MonitoringType of monitoring__________________________

Performance not monitored

Frequency_______________________________Evidence of breaching

Head differential__________________________

Remarks__________________________________________________________________________

_________________________________________________________________________________
Site Inspection Checklist - 11

C. Treatment System X Applicable N/A GWTP operation complete January 2010.

1. Treatment Train (Check components that apply)

Metals removal Oil/water separation Bioremediation

Air stripping Carbon absorbers

Filters_________________________________________________________________________

Additive (e.g., chelation agent, flocculent)_____________________________________________

Others The GWTP treatment process involved five basic steps: cyanide precipitation, cyanide solids

removal, ferric iron precipitation, iron solids removal, and dewatering of the combined sludge from the

two solids removal steps. The GWTP discharged treated groundwater to the Ohio River under the terms

of a KPDES Permit.

X Good condition Needs Maintenance

X Sampling ports properly marked and functional

X Sampling/maintenance log displayed and up to date

X Equipment properly identified

Quantity of groundwater treated annually 115,654,200 gallons (2006); 124,590,200 gallons (2007);

143,213,700 gallons (2008); 136,885,800 gallons (2009); 7,238,654 gallons (January 2010)

Quantity of surface water treated annually 0 gallons

Remarks The GWTP was designed to operate for a period of 10-years. Required maintenance was

documented in the Monthly Progress Reports for the site. During the review period, more significant

maintenance was required to continue operation due to aging components.

2. Electrical Enclosures and Panels (properly rated and functional)

N/A X Good condition Needs Maintenance

Remarks__________________________________________________________________________

_________________________________________________________________________________

3. Tanks, Vaults, Storage Vessels

N/A X Good condition X Proper secondary containment Needs Maintenance

Remarks__________________________________________________________________________

_________________________________________________________________________________

4. Discharge Structure and Appurtenances

N/A X Good condition Needs Maintenance

Remarks__________________________________________________________________________

_________________________________________________________________________________

5. Treatment Building(s)

N/A X Good condition (esp. roof and doorways) Needs repair

X Chemicals and equipment properly stored

Remarks__________________________________________________________________________

_________________________________________________________________________________

6. Monitoring Wells (pump and treatment remedy)

X Properly secured/locked X Functioning X Routinely sampled X Good condition

X All required wells located Needs Maintenance N/A

Remarks The monitoring and extraction wells associated with the GWTP were generally in good

condition, operational and secured during the review period. Monitoring information was submitted

with the Monthly Progress Reports.

D. Monitoring Data

1. Monitoring Data

X Is routinely submitted on time X Is of acceptable quality

2. Monitoring data suggests:

X Groundwater plume is effectively contained X Contaminant concentrations are declining
Site Inspection Checklist - 12

D. Monitored Natural Attenuation

1. Monitoring Wells (natural attenuation remedy)

Properly secured/locked Functioning Routinely sampled Good condition

All required wells located Needs Maintenance X N/A

Remarks__________________________________________________________________________

_________________________________________________________________________________

X. OTHER REMEDIES

If there are remedies applied at the site which are not covered above, attach an inspection sheet describing

the physical nature and condition of any facility associated with the remedy. An example would be soil

vapor extraction. X N/A

XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

Describe issues and observations relating to whether the remedy is effective and functioning as designed.

Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume,

minimize infiltration and gas emission, etc.).

The OU1 remedial action objective was to “remediate groundwater contaminated with elevated levels of

cyanide” (2000 SOW). The performance standard for OU1 was established in the ROD as the MCL for

free cyanide, 0.2 mg/L. The 1995 Performance Standards Verification Plan for OU1defined quarterly

and annual monitoring wells and indicated that this standard would be met in at least three consecutive

quarterly and one annual round of sampling. The performance standards for OU1 were achieved in

May 2010 and documented in the 2011 Performance Standards Verification Report (URS). The OU1

remedial actions were effective in remediating groundwater.

The OU2 remedial action objectives were primarily related to minimizing direct contact to soils with

elevated levels of PCBs or PAHs (2000 SOW). The OU2 remedial construction activities were

substantially complete in June 2008 and documented in the 2008 Construction Completion Report

(URS). The OU2 remedial actions were effective in minimizing direct contact to potentially

contaminated soils and the remedy is functioning as intended.

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In

particular, discuss their relationship to the current and long-term protectiveness of the remedy.

The O&M activities appear to have been properly implemented during the review period. OU1 O&M

activities are complete. South Slurry Pond and OU2 O&M activities are on-going and are appropriate

for the long-term protectiveness of the remedy.
Site Inspection Checklist - 13

C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high

frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised

in the future.

There are no issues or observations that suggest that the remedy may be compromised in the future.

D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

A potential opportunity for optimization of the South Slurry Pond monitoring tasks has been identified

and is presented in Section 9.0 (Recommendations) of the Third Five Year Review Report.

SITE INSPECTION TEAM LISTING:

Femi Akindele, US EPA

Stephanie Y. Brown, US EPA (Interviews)

Ken Sands, Century

Paul Sims, Southwire

Alicia Shull, URS

Chris Davis, URS
Appendix D: Photographs from Site Inspection Visit 
OU1 Groundwater Treatment Plant

Site Inspection:
OU2 Green Carbon PCB Spill Area

O&M Site

Inspections:
OU2 PCB Soil Stockpile Area

O&M Site

Inspections:
OU2 Taylor’s Wash Landfill

O&M Site

Inspections:
OU2 Refractory Brick Disposal Areas

O&M Site

Inspections:

Current RBDA (left)

Historic RBDA (right)
NTCRA South Slurry Pond

O&M Site

Inspection: