### 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 P HYSICAL 

### C HARACTERISTICS 

### ......................................................................................10 3.2 L AND AND 

### R ESOURCE 

### U SE 

### .........................................................................................11 3.3 H ISTORY OF 

### C ONTAMINATION 

### ....................................................................................11 3.4 I NITIAL 

### R ESPONSE 

### ......................................................................................................12 3.5 B ASIS FOR 

### T AKING 

### A CTION 

### ........................................................................................12 4.0 Remedial Actions...............................................................................................................13 4.1 R EMEDY 

### S ELECTION 

### ...................................................................................................13 4.2 R EMEDY 

### I MPLEMENTATION 

### ........................................................................................16 Table 3: Timeline of Remedial Action Activities.................................................................16 4.3 O PERATION AND 

### M AINTENANCE 

### .................................................................................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 R ECOMMENDATION 

### 1..................................................................................................20 5.2 R ECOMMENDATION 

### 2..................................................................................................20 5.3 R ECOMMENDATION 

### 3..................................................................................................20 5.4 R ECOMMENDATION 

### 4..................................................................................................22 5.5 R ECOMMENDATION 

### 5..................................................................................................22 5.6 R ECOMMENDATION 

### 6..................................................................................................23 5.7 R ECOMMENDATION 

### 7..................................................................................................23 5.8 R ECOMMENDATION 

### 8..................................................................................................23 6.0 Five-Year Review Process .................................................................................................24 6.1 A DMINISTRATIVE 

### C OMPONENTS 

### ..................................................................................24 6.2 C OMMUNITY 

### I NVOLVEMENT 

### .......................................................................................24 6.3 D OCUMENT 

### R EVIEW 

### ...................................................................................................24

### 6.4 D ATA 

### R EVIEW 

### ............................................................................................................25

6.5 S ITE 

### I NSPECTION 

### ........................................................................................................29 Table 7: Deed Documents from Hancock County Public Records Office............................29 Table 8: IC Summary Table...............................................................................................30 6.6 I NTERVIEWS 

### ...............................................................................................................31 7.0 Technical Assessment........................................................................................................32 7.1 Q UESTION 

### A: I S THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION

DOCUMENTS 

### ?............................................................................................................32 7.2 Q UESTION 

### B: A RE THE EXPOSURE ASSUMPTIONS 

### , T OXICITY 

### D ATA 

### , C LEANUP 

### L EVELS 

### ,

AND 

### R EMEDIAL 

### A CTION 

### O BJECTIVES 

### (RAO S 

### ) U SED AT THE 

### T IME OF 

### R EMEDY 

### S ELECTION 

### S TILL 

### V ALID 

### ? .........................................................................................33 7.3 Q UESTION 

### C: H AS 

### A NY 

### O THER 

### I NFORMATION 

### C OME TO 

### L IGHT 

### T HAT 

### C OULD 

### C ALL 

### I NTO 

### Q UESTION THE 

### P ROTECTIVENESS OF THE 

### R EMEDY 

### ? ...................................................34 7.4 T ECHNICAL 

### A SSESSMENT 

### S UMMARY 

### ...........................................................................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 Visit1 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 Study2 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 Corporation3 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 Southwir e Aluminum EPA ID (from WasteLAN ) : KYD049062375 

### Region: 0 4 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: 03/1 7/2011, 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 20019 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 Present10 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, and12 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 - Present17 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 Report18 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 7/0520 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 developme nt 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 standar ds for OU1 were achieved. The Performance Standards Verification Report (PSVR) provides detailed information regarding data trends in the north plume and documents achievement of t he performance standards. This document was first submitted in July 2009 and was formally updat ed in 2011 to include monitoring data through May 2010. Recommendation 2 is consider ed 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 protectiv eness of the decision. The review should re-visit risk based implications pertai ning 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&M23 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 or25 AUGUST 2011



### Relevant and Appropriate Requirements (ARARs). ARARs are those standards, criteria, or limitations promulgated under federal or state law that specifically address a hazardoussubstance, 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 samplescollected 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 indicates28 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 145 130 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 potablepurposes Sitewide. November 2010

Environmental Covenant

Century Aluminum OU1 and

OU2 Groundwater

and Soil Yes Restrict land use for residentialpurposes 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 of33 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 Yes36 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 Yes37 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 

### SITENSA - 14946586.00400 - CONSTRUCTION COMPLETION REPORT - CHECKED BYOld 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

IIIIIIIIIIII

I

I

I I

I

I

I

I

I

IIIIIIIIIIIIII East Slurry Disposal Area (Closed)

Taylors Wash

Drainage Ditch N 105

MW-203S MW-203I NSA-5

MW-204D MW-5 MW-6

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, KentuckyNSA14946586.00400CONSTRUCTION COMPLETION REPORTCHECKED BY

12 MW-201S 109

EW-12 EW-13 EW-4 EW-2 EW-3 EW-1 103IIIIIIIIIIIIIIIIII I I I I I I I III I I IIIIIIIII I I I I I I IIIIIIIIIIIIIIIIIIIIIIIIIIIII I I I I I I I IIIIIIIII I I I I I I IIIIIIIIIIIIIIIII 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 RBDAIIIIIIIIIIIIIIIIII I I I I I I I III I I IIIIIIIII I I I I I I IIIIIIIIIIIIIIIIIIIIIIIIIIIII I I I I I I I IIIIIIIII I I I I I I IIIIIIIIIIIIIIIII 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

IIIIIIIIIII

I

I

I

I I

I

I

I

I

I

IIIIIIIIIIIIII 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 System00.20.40.60.811.21.41.602004006008001,0001,2001,4001,6001995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 **Average Free Cyanide Concentration (mg/L)**

**Cumulative Volume Extracted Groundwater (Million Gallons)** **FIGURE 4 NORTH AND SOUTH PLUME EXTRACTION VOLUMES AND** **AVERAGE FREE CYANIDE CONCENTRATIONS**South Plume Extraction VolumeNorth Plume Extraction VolumeSouth Plume Free CyanideNorth Plume Free CyanideNotes: 1) South plume extraction well operation wasdiscontinued in 2005. As a result, extraction wellanalytical samples from south plume were not collected after 2005.2) Groundwater treatment plant operation was discontinued on January 18, 2010. As a result, extractionwell analytical samples were not collected during2010.**Performance Standard = 0.2 mg/L Free Cyanide**FIGURE 5A

FIGURE 5B

FIGURE 5 Extraction Well Trend Graphs NATIONAL SOUTHWIRE ALUMINUM FREE CYANIDE (WAD) CONCENTRATIONS IN NORTH PLUME EX TRACTION WELLS (1995-2010)

0.001 0.010 0.100 1.000 10.000

6/1/19 95 6/1/1996 6/1/1997 6/1/1998 6/1/1999 6/1/ 2 000 6/1/ 2 001 6/ 1/2 002 6/ 1/2 003 6 / 1/2 004 6/1/2005 6/1/2006 6/1/2007 6/1/2008 6/1/ 2 009 6/1/ 2 010

Sample DateFree 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 EX TRACTION WELLS (1995-2010)

0.001 0.010 0.100 1.000 10.000

6/1/19 95 6/1/1996 6/1/1997 6/1/1998 6/1/1999 6/1/ 2 000 6/1/ 2 001 6/ 1/2 002 6/ 1/2 003 6 / 1/2 004 6/1/2005 6/1/2006 6/1/2007 6/1/2008 6/1/ 2 009 6/1/ 2 010

Sample DateFree Cyanide (mg/L)

EX-13 EX-12 Performance Standard = 0.2 mg/L Closure of South Slurry Pond - 1997FIGURE 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 DateFree 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 SOUT H 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 DateFree Cyanide (mg/L)

MW-102 MW-103 MW-104 IP-5 Performance Standard = 0.2 mg/L Closure of South Slurry Pond - 1997FIGURE 7 North Plume Monitoring Well Trend Graphs NATIONAL SOUTHWIRE ALUMINUM FIGURE 7A

FIGURE 7B FREE CYANIDE (WAD) CONCENTRATIONS IN NORTH FAR FIEL D 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 DateFree 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 A REA 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 DateFree 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 - 1997FIGURE 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 DateFree 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 DateFree Cyanide (mg/L)

IP-12 MW-208I MW-209I Performance Standard = 0.2 mg/L Closure of South Slurry Pond - 1997 FIGURE 8BI I I

I

IIII

I IIIIIIIIII

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 RIVERIIIIIIIII

I I I I I I I IIIIIIIIIIIII

NAPPROXIMATE SCALE IN FEET0400800IP-11MW-220MW-221MW-222MW-208IFIGURE 9OU2 MONITORING WELL LOCATIONSAND DATA Pitch Heater Building Pitch Storage Tanks

Cooling Tower Drum Storage Area Spent Potliner Accumulation Building

Green Carbon PCB Spill Area Ground Water Treatment BuildingIIIIILEGEND:FenceRailroad SpurOU2 Monitoring Well LocationNSouth Slurry Pond(Closed)

OHIO RIVERPotlinerDisposalArea(Closed))NewSlurryPond I

I I I I IEast Slurry Disposal Area (Closed)MW-203IMW-204DMW-6 Creek102104112MW-203D103IIII 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 St ate Route 334MW-5MW-203SAPPROXIMATE SCALE IN FEET0500 1,000FIGURE 10SOUTH SLURRY PONDMONITORING WELL LOCATIONS ANDANNUAL DATAIIIILEGEND:FenceRailroad SpurIntermittent Ditch orCreek and Flow DirectionSouth Slurry PondMonitoring Well LocationGroundwater Flow DirectionNBASE MAP SOURCE: Compiled from site plan fromNSA, November 1984; Surdex Corp. AerialPhotograph May, 1993; and HRG flyover, April 2001. I I I I I IIIIIIIIISTATE ROUTE 271 STATE ROUTE 334IIIIII I I I I

I I I IIIIIIII I ITaylorsWashLandfill Spent Potliner Accumulation Building Cooling TowerDrum Storage AreaLEGEND:Property BoundaryFenceRailroad TrackDrainage Ditch and Flow Direction

OHIO RIVER Muddy Gut Tributary (Intermittent Flow) ROUTE 3092

IIIIIIIIIIIII I I I I

II II IIIIIII

I I I I I IIIIIIIIIIIIIIIIIIII I I I I IIIIIII 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 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 IAPPROXIMATE SCALE IN FEET01000 2000 BallfieldSouthwire Company OutlotNew SlurryPondPCB SoilStockpile Area Hancock Field (Disused)

Groundwater Treatment BuildingCurrent RefractoryBrick Disposal Area(Inactive)Historic RefractoryBrick Disposal Area(Inactive)
Green Carbon PCB Spill Area Drainage DitchSOUTHWIRE14949080.20115CHECKED BYIIIIIIINATIONAL SOUTHWIRE ALUMINUMSUPERFUND SITEHawesville, Hancock County, KentuckyFIGURE 4SITE PLAN WITHINSTITUTIONAL CONTROLSJOB NO. 14949080Approximate 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 NoticesPAGE 16 The Hancock Clarion, Hawesville, Ky., May 5, 2011



# TELL CITY



# Now hiring for Summer Store Remodel. A positive friendly work environment with Great Career Opportunities. 

## 1st, 2nd and 3rd Shifts Available Starting at $ 

## 7 45 

## ~ 3 rd 

## shift $ 

## 7 95 

## Lasting Mid May to Mid August 

# May apply at Walmart.com or on the hiring Kiosk inside the store. **Note Please Select Setup, Remodel and Recycling

when applying for this position. 

# BUSINESS OPPORTUNITIES

**HELP WANTED** RURAL HOME CONSTRUCTION LOANS

C ALL L INDA B RY ANT (270) 684-6251 OR 1-800-844-1148 3445 W A THENS C ROSSING • O WENSBORO , KY 42301 Why survey out 5 acres? Why pay the expense for a survey? Why not use the equity you have in your acreage? Why not have a construction loan that is also your permanent loan? S AVE T IME AND S AVE M ONEY AT FARM CREDIT YOU CAN BUILD ON A LOT OR ACREAGE. Linda Bryant



## ThyssenKrupp Waupaca Human Resource Manager 9856 State Hwy. 66 Te ll City, IN 47586 THYSSENKRUPP WAUPACA, INC. , a fast paced manufacturer of gray and ductile iron castings, located in Tell City, Indiana, is accepting applications for summer employment. College or college bound students seeking summer employment are encouraged to apply.

Applicants must be 18 years of age, and av ailable to work 12-hour shifts. Day and night shift openings will be filled.

Applicants may apply in person at ThyssenKrupp Waupaca, Inc. , located on Highway 66 between Tell City and Troy. Human Resources Office opens 7:30 a.m. to 4:30 p.m., Monday thru Friday. 

# SUMMER EMPLOYMENT

Equal Opportunity/Affirmative Action Employer 

# RNs and LPNs W ant some extra money for summer?
PRN Positions A

vailable! 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 W ork All Shifts Potential Unlimited Income!
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EOE/AAP/DTR THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Announces a Five-Year Review For the NATIONAL SOUTHWIRE ALUMINUM COMPANY SITE T he US EPA is conducting a Five-Year Review of the Remedial Action at the National Southwire Aluminum Company Site (NSA) located in Hancock County, Kentucky on the south bank of the Ohio River near Hawesville. The purpose of this Five-Year Review is to evaluate theimplementation and performance of the selected action in order to determine if the action is, or will be, protective of human health and the environment. The Five-Year Review is scheduled to be completed bySeptember 14, 2011. The public will be given a 30-day period to comment after review of the report. When completed, a copy of the review report will be placed in the Administrative files located in the US EPA Record Center, 11th Floor, 61 Forsyth Street, SW, Atlanta, GA 30303, and in the Information Repository located at the Hancock County Public Library, Courthouse Square in Hawesville, Kentucky. In 1985, NSA detected cyanide in one of its on-site water wells. Data collected in site investigations subsequent to this discovery, indicated that releases of hazardous substances (including cyanide, fluoride andheavy metals) were migrating in on-site groundwater through the unconsolidated aquifer toward the Ohio River. An Interim Record of Decision issued in February 1993 and a Consent Decree signed in April 1994 required NSA to design, construct and operate a ground water extraction and treatment system to remove the contaminants from the groundwater in the North and South Plumes, and to discharge the treated water to the Ohio River. This portion of the remedy is referred to asOperable Unit No. 1. The system began operation in June 1995. It operated until January 2010 when concentrations of contaminants in the aquifer were consistently below the standards set by the Commonwealth of Kentucky and US EPA.
A US EPA Administrative Order by Consent (AOC) for a Remedial Investigation and Feasibility Study (RI/FS) of the entire Site was completed in 1992. The RI/FS was final in 1999 and supported the completion of a Final Record of Decision in 2000. A Consent Decree was signed in March 2004 and required NSA to design and conduct remedial action activities at five focus areas where releases of hazardous substances (including polychlorinated biphenyls) may have occurred. These focusareas are referred to as Operable Unit No. 2. The objective of the remedial activities was to significantly reduce the short-term and long-term risks of human and ecological exposures to contaminants of concern by reducing contaminant concentrations in soils and by managementand containment of contaminated media. The remedial activities associated with Operable Unit No. 2 were classified as operational and functional in November 2008. US EPA will also conduct a number of telephone interviews with nearby businesses, residents, local offices, state officials and others to obtain their opinion on the clean-up process. If you would like to speak with us about this Site, please call Stephanie Y. Brown, US EPA Public AffairsSpecialist, at 1-877-718-3752 or 404-562-8450. If you have any technical questions, please contact Femi Akindele, US EPA Site Project Manager at 404-562-8809. 

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EFFECT ON THE ENVIRONMENT AND NOTICE T O PUBLIC OF REQUEST FOR RELEASE OF FUNDS May 5, 2011 Hancock County Fiscal Court PO Box 580 Hawesville, Kentucky 42348

To all Interested Agencies, Groups, and Persons: On or about May 23, 2011, the above named county will request the Kentucky Department for Local Government to release Federal Funds under Title I of the Housing and Community Development Act of 1974 (PL 93-383) for the following project: Name of Project: 2008 Hancock County Disaster Recovery Project 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 notconstitute 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 alreadybeen 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 beenmade 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. Suchwritten 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 ortake any administrative action on the project prior to the date specified on the preceding sentence. The Hancock County Fiscal Court will undertake the project describedabove 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 inhis 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 foundto 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. 

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### Appendix C: Site Inspection ChecklistSite 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 envir onmental 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 F YR process, interviews were conducted with the current landowners, local residents, local officials, and regulatory agencies involved in Site activities. T he purpose of the interviews was to document the perceived status of the Site and any perceived problems or successe s 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 con ducted 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 site X 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. Siltation Areal 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 Monitoring Type 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 decliningSite 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: