1 

First Five-Year Review Report 

for 

Redwing Carriers, Inc. 

527 U.S. Highway 43 

Saraland 

Mobile County, Alabama 

List of Acronyms ........................................................................................................................... 3

Executive Summary ...................................................................................................................... 4

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

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

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

3.0 Background ............................................................................................................................. 9

3.1 PHYSICAL CHARACTERISTICS .......................................................................................... 9

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

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

3.4 INITIAL RESPONSE ......................................................................................................... 11

3.5 BASIS FOR TAKING ACTION ........................................................................................... 11

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

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

4.2 REMEDY IMPLEMENTATION ........................................................................................... 15

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

5.0 Progress Since the Last Five-Year Review ......................................................................... 16

6.0 Five-Year Review Process .................................................................................................... 17

6.1 ADMINISTRATIVE COMPONENTS .................................................................................... 17

6.2 COMMUNITY INVOLVEMENT .......................................................................................... 17

6.3 DOCUMENT REVIEW ...................................................................................................... 17

6.4 DATA REVIEW ............................................................................................................... 20

6.5 SITE INSPECTION ............................................................................................................ 22

6.6 INTERVIEWS ................................................................................................................... 22

7.0 Technical Assessment ........................................................................................................... 23

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

DOCUMENTS? ............................................................................................................... 23

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? ............................................................................................................... 23

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

QUESTION THE PROTECTIVENESS OF THE REMEDY? ...................................................... 23

7.4 TECHNICAL ASSESSMENT SUMMARY ............................................................................. 23

8.0 Issues ...................................................................................................................................... 24

9.0 Recommendations and Follow-up Actions ......................................................................... 24

10.0 Protectiveness Statements .................................................................................................. 24
2 

11.0 Next Review ......................................................................................................................... 24

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

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

Appendix C: Interview Form ................................................................................................... C-1

Appendix D. ROD Cleanup Goals ........................................................................................... D-1

Tables 

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

Table 2: Ground water Cleanup Goals.......................................................................................... 14

Table 3: Subsurface soil Cleanup Goals ....................................................................................... 15

Table 4: Surface soil and Sediment Cleanup Goals ...................................................................... 15

Table 5: Previous and Current ARARs for Ground Water COCs ................................................ 19

Figures

Figure 1: Site Location Map ........................................................................................................... 9

Figure 2: Detailed Site Map .......................................................................................................... 10
3 

List of Acronyms 

ADEM Alabama Department of Environmental Management 

ARAR Applicable or Relevant and Appropriate Requirement 

CERCLA Comprehensive Environmental Response, Compensation and Liability Act 

CFR Code of Federal Regulations 

CIC Community Involvement Coordinator 

COC Contaminant of Concern 

EPA United States Environmental Protection Agency 

ESD Explanation of Significant Difference 

FYR Five-Year Review 

HUD United States Department of Housing and Development 

μg/L micrograms per liter 

MCL Maximum Contaminant Level 

NCP National Oil and Hazardous Substances Pollution Contingency Plan 

NPL National Priorities List 

O&M Operation and Maintenance 

OU Operable Unit 

PAH Polycyclic Aromatic Hydrocarbon 

PRP Potentially Responsible Party 

RA Remedial Action 

RAO Remedial Action Objective 

RCRA Resource Conservation and Recovery Act 

ROD Record of Decision 

RPM Remedial Project Manager 

TLM Tar Like Material 

UU/UE Unlimited Use and Unrestricted Exposure 

VOC Volatile Organic Compound 
4 

Executive Summary 

The Redwing Carrier, Inc. Superfund site (the Site) is 5.1 acres in size and is located in the City 

of Saraland, Mobile County, Alabama. The Site is bounded to the east by U.S. Highway 43 and a 

skating rink. On the north it is bounded by a United Gas Pipe Line easement with a residential 

development south of the easement. The Site is bounded on the north by a trailer park, and on the 

west by an undeveloped lot. The Site was the former location of the Saraland Apartment 

Complex (Apartments) that has since been demolished to allow for the complete remediation of 

the site. 

From 1961 to 1971, Redwing Carriers, Inc. (Redwing), a trucking company, owned and operated 

the Site as a terminal for cleaning, repairing, and parking its fleet of trucks. The company 

transported a variety of substances, including asphalt, diesel fuel, chemicals, and pesticides from 

local plants. Redwing discharged untreated hazardous substances to the ground during the 

cleaning of tanker trucks, creating a tar-like sludge and contaminating Site soils. The tar-like 

sludge was composed predominately of polycyclic aromatic hydrocarbon compounds together 

with lesser amounts of pesticides, herbicides and volatile organic compounds. These operations 

resulted in contamination of soils, ground water and sediment. 

The United States Environmental Protection Agency (EPA) placed the Site on the National 

Priorities List (NPL) on February 21, 1990. 

EPA selected the remedy in the 1992 Record of Decision (ROD) and updated the remedy in 

2000. The ROD states that the remedial action objectives (RAOs) include: 

 Prevent migration of contaminated ground water. 

 Prevent human exposure to contaminated soils, sediments and sludge. 

 Permanently reduce the toxicity of the harmful constituents in all media. 

 Prevent migration of site contaminants via drainage pathways. 

The remedy consists of: 

 Removal of the surface soil, subsurface soil and sediments until the remaining soil is 

below the remedial levels established in the ROD. 

 Off-site disposal in a Resource Conservation and Recovery Act (RCRA) Subtitle D 

landfill for soils and sediments that are excavated. 

 Treatment of soils and sediments by incineration at the RCRA Subtitle D landfill. 

 Removal of all buildings, foundations and paving to allow for removal of soils beneath 

the buildings. 

 Reconstitution of the ground water monitoring program at the Site after the backfilling 

and regrading of excavated areas had been completed. The ground water monitoring 

program included sampling to establish baseline conditions at the Site and quarterly 

ground water monitoring for up to three years to determine the effectiveness of the source 

material excavation in reducing surficial ground water contamination. 

The remedy at the Site is protective of human health and the environment because the surface 

soil, subsurface soil, sediment and ground water at the Site met performance standards 

established in the RODs and the Explanation of Significant Difference (ESD). 
5 

Five-Year Review Summary Form 

SITE IDENTIFICATION

Site Name: Redwing Carriers, Inc. (Saraland) 

EPA ID: ALD980844385 

Region: 4 State: AL City/County: Saraland/ Mobile County 

SITE STATUS

NPL Status: NPL 

Multiple OUs? 

No 

Has the site achieved construction completion? 

Yes 

REVIEW STATUS

Lead agency: EPA 

If “Other Federal Agency” selected above, enter Agency name: Click here to enter text.

Author name: Shelby Johnston, EPA 

Author affiliation: Site RPM 

Review period: 8/25/2014 – 9/02/2014 

Date of site inspection: N/A 

Type of review: Policy 

Review number: 1 

Triggering action date: 9/02/2009 

Due date (five years after triggering action date): 9/02/2014 
6 

Five-Year Review Summary Form (continued) 

Protectiveness Statement(s) 

Operable Unit: 

OU1 

Protectiveness Determination:

Protective 

Addendum Due Date 

(if applicable): 

Click here to enter date.

Protectiveness Statement: 

The remedy at the Site is protective of human health and the environment because the 

surface soil, subsurface soil, sediment and ground water at the Site met performance 

standards established in the RODs and the ESD.

Environmental Indicators 

- Current human exposures at the Site are under control. 

- Current ground water migration is under control. 

Are Necessary Institutional Controls in Place? 

 All Some None 

No institutional Controls are necessary. 

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

 Yes No

Has the Site Been Put into Reuse? 

 Yes No
7 

First Five-Year Review Report 

for 

Redwing Carrier, Inc. Superfund Site

1.0 Introduction 

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

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

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

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

address them. 

EPA prepares FYRs pursuant to the Comprehensive Environmental Response, Compensation 

and Liability Act (CERCLA) Section 121 and the National Oil and Hazardous Substances 

Pollution Contingency Plan (NCP). CERCLA Section 121 states: 

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

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

action no less often than each 5 years after the initiation of such remedial action to assure 

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

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

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

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

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

actions taken as a result of such reviews. 

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

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

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

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

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

five years after initiation of the selected remedial action. 

The assigned EPA Region 4 Remedial Project Manager (RPM) conducted the FYR and prepared 

this report regarding the remedy implemented at the Site in Saraland, Mobile County, Alabama. 

The RPM conducted this FYR from August to September 2014. EPA is the lead agency for 

developing and implementing the remedy for the potentially responsible party (PRP)-financed 

cleanup at the Site. The Alabama Department of Environmental Management (ADEM), as the 

support agency representing the State of Alabama, has reviewed all supporting documentation 

and provided input to EPA during the FYR process. 

This is the first FYR for the Site. The triggering action for this policy review was the signing of 

the Preliminary Closeout Report on September 3, 2009. No hazardous substances, pollutants or 

contaminants remain at the Site above levels allowing for unlimited use and unrestricted 
8 

exposure, however it is the policy of EPA to conduct a policy review on all sites which will 

require five or more years to complete. The Site consists of one operable unit (OU). 

2.0 Site Chronology 

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

Table 1: Chronology of Site Events 

Event Date 

Site Operated as a Truck Terminal 1961- 1971 

Property sold to Harrington, Inc. May 1971 

Saraland Apartments Ltd. Purchased the Site and constructed a U.S. 

Housing and Urban Development apartment complex on-site. 

1973 

ADEM investigation of Tar-like material (TLM) 1984 

First Administrative Order on Consent (AOC) with trucking company for 

removal of visible TLM 

July 1985 

EPA listed site on NPL February 21, 1990 

PRPs and EPA signed a second AOC to conduct the remedial 

investigation and feasibility study 

June 1990 

remedial investigation and feasibility study completed July 1992 

EPA signed Record of Decision (ROD) December 1992 

First UAO to trucking company and nine (9) other PRPs August 1993 

First RD field work completed March 1994 

First 90% design completed May 1995 

Second UAO to remove tar seeps July 1995 

START Contractor and TAT Contractor assigned by EPA March 1996 

Initial removal action underway October 1996 

PRP contractor prepares and presents FFS and Second Look Remedy 1997-1999 

ROD amended based on Second Look Remedy June 14, 2000 

SOW agreed upon and approved 2000 

Remedial Design Initiated 2002 

Buildings and Facilities Demolition Spring 2004 

Final RD Work Plan Approved April 2005 

Pre-Design Complete December 2005 

Remedial Design Approved by EPA June 28, 2007 

RA Contractor selected August 2007 

EPA issued an ESD for the Site to revise several ground water cleanup 

levels 

September 25, 2007 

RA Initiated December 2007 

RA Field Work Completed June 2008 

Final RA inspection by EPA and ADEM September 5,2008 

Final Ground water monitoring Program Established March 2009 

EPA Signed the Preliminary Closeout Report September 3, 2009 

Final Ground water Monitoring Event Completed August 2012 

All Remaining Monitoring Wells Abandoned February 2013 

Final Remedial Action Report Submitted April 2013 

First Five Year Review due September 2014 
9 

3.0 Background 

3.1 Physical Characteristics 

The Site is located at 527 U.S. Highway 43, Saraland, Mobile County, Alabama (Figure 

1). The Site was the location of the former Apartment Complex. The residents of the 

Apartments were permanently relocated and the Apartments have since been demolished 

to allow for the complete remediation of the Site and a drainage ditch. The Site is 

bounded to the east by U.S. Highway 43 and a skating rink. On the north it is bounded by 

a United Gas Pipe Line easement with a residential development south of the easement. 

The Site is bounded on the north by a trailer park, and on the west by an undeveloped lot. 

Figure 1: Site Location Map 

 

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for 

informational purposes only regarding EPA’s response actions at the Site. 
10 

Figure 2: Detailed Site Map 

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for 

informational purposes only regarding EPA’s response actions at the Site. 
11 

3.2 Land and Resource Use 

The Site is located in the City of Saraland, Mobile County, Alabama and is bounded to 

the east by U.S. Highway 43 and a skating rink. On the north it is bounded by a United 

Gas Pipe Line easement with a residential development south of the easement. The Site is 

bounded on the north by a trailer park, and on the west by an undeveloped lot. The Site 

was the former location of the Apartments have since been demolished to allow for the 

complete remediation of the Site. 

The Site is underlain by strata that comprise the Alluvial Aquifer of Mobile County. Two 

distinct hydrogeologic units were identified from four strata underlying the Redwing Site. 

The designations assigned to these three units are as follows: (1) a Low Permeability Unit 

and (2) the Alluvial Aquifer (lower sands). The Alluvial Aquifer is considered a Class 

IIA ground water as it is a current source of drinking water. The first aquifer beneath the 

Site is where the ground water protection levels will apply is the Alluvial Aquifer. 

3.3 History of Contamination 

From 1961 to 1971, Redwing Carriers, Inc. (Redwing), a trucking company, owned and 

operated the Site as a terminal for cleaning, repairing, and parking its fleet of trucks. The 

firm transported a variety of substances, including asphalt, diesel fuel, chemicals, and 

pesticides from local plants. During cleaning, untreated hazardous substances were 

released to the ground creating a tar-like sludge and contaminating site soils. The tar-like 

sludge is composed predominately of polycyclic aromatic hydrocarbon compounds 

together with lesser amounts of pesticides, herbicides and volatile organic compounds. 

3.4 Initial Response 

In 1984, ADEM investigated apartment residents' complaints about the tar-like sludge 

seeping to the surface at numerous locations at the Site. In 1985, under Superfund 

removal authority, EPA conducted initial studies in which high concentrations of 1,2,4-

trichlorobenzene and naphthalene were detected in the soil and in leachate coming from 

the sludge. On July 9, 1985, the Agency and Redwing entered into a removal 

Administrative Order on Consent which required Redwing to (among other things) 

conduct a limited sludge and contaminated soil removal. 

The Site was placed on the National Priorities List (NPL) in February 1990. On 

December 15, 1992, EPA issued a Record of Decision for the Site (described in more 

detail below). 

3.5 Basis for Taking Action 

Redwing, under EPA's oversight, began field activities for the first phase of the remedial 

investigation in January 1991. The RI/FS was completed in July of 1992. During the 

investigation, 39 soil borings were collected with a total of 123 separate soil samples 

being analyzed. The substances found most frequently at concentrations above cleanup 
12 

levels fall into three major categories: 1) pesticides and herbicides; 2) Volatile organic 

compounds (VOCs) and Polycyclic Aromatic Hydrocarbons (PAHs). These substances 

were found in soils, ditch sediments and ground water across the Redwing Site. The 

highest levels of contamination were detected in the southern and eastern portions (the 

location of the former containment levee used by Redwing) and across areas of former 

terminal operations. Inorganic substances, which may occur in nature at significant 

levels, were also detected in soils, sludge and ground water. During this investigation 

EPA determined that the contaminants at the Site presented an unacceptable risk to 

human health. Redwing continued periodic removal of surface seeps until 1994, when 

they stopped doing any work at the Site. 

On July 12, 1996, EPA issued a removal Unilateral Administrative Order to Redwing and 

Saraland Apartments, Ltd., directing them to remove the source of the recurring tar seeps. 

When both parties refused to comply with the order, EPA conducted a Removal Action 

which consisted of temporarily relocating 57 families living in the complex and 

excavating and transporting off Site for disposal approximately 20,724 tons of sludge, 

contaminated soil and debris. 

Air monitoring conducted in the Saraland Apartments after the removal was completed 

and detected unacceptable levels of benzene and the pesticide Aldrin in some of the 

Saraland Apartments. Based on this monitoring, EPA determined that the residents could 

not return to live in the Saraland Apartments. Working together, EPA and HUD (United 

States Department of Housing and Development) relocated the residents to comparable 

permanent housing. 

In July, 1997, EPA collected soil, sediment and water samples from twenty-three 

properties adjacent to the Redwing Site. The purpose of this sampling was to address 

community concerns about possible releases from the Site. Based on a risk evaluation of 

the analytical results of these samples, the Agency determined that there is no 

unacceptable health risk or hazard in the neighborhood adjacent to the Redwing Site. 
13 

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(e)(9)(iii) of the NCP. The nine criteria 

are: 

1. Overall Protection of Human Health and the Environment 

2. Compliance with ARARs 

3. Long-Term Effectiveness and Permanence 

4. Reduction of Toxicity, Mobility or Volume through Treatment 

5. Short-Term Effectiveness 

6. Implementability 

7. Cost 

8. State Acceptance 

9. Community Acceptance 

4.1 Remedy Selection 

 

The Redwing Site ROD was signed on December 15, 1992. The major components of the 

1992 selected remedy include: 

 Excavation of sludge, sediments and contaminated soils. 

 Off-site treatment/disposal of contaminated soils, sediments and sludge. 

 Regrading and backfill of excavations using clean, compacted-fill material. 

 Temporary and possibly permanent relocation of residents with the potential 

demolition of selected apartment units. 

 On-site treatment of contaminated ground water in the surficial aquifer. Monitoring 

and possible withdrawal and treatment of ground water in the alluvial aquifer. 

Treatment of ground water for discharge to a Publicly Owned Treatment Works, or if 

unavailable, to a nearby surface water body. 

The 1992 ROD was subsequently amended on June 14, 2000. The major components of 

the amended remedy were: 

 Development of a phased approach to implement the amended remedy during the 

Remedial Design. 

 Demolition, removal, and off-site disposal of all buildings, foundations, concrete 

walkways, asphalt driveways and parking areas. 
14 

 Excavation, off-site treatment and disposal of the remaining source material (sludge, 

sediments and contaminated soils) to aid in restoring and protecting ground water 

quality. 

 Reconstitution of the ground water monitoring program at the Site after the 

backfilling and regrading of excavated areas had been completed. 

 Postponement of the 1992 ROD requirement for on-site extraction and treatment of 

contaminated ground water and compliance monitoring. Implementation was to be 

contingent upon the results of the baseline ground water sampling and evaluation of 

the quarterly ground water monitoring data. Evaluation of the current remedial 

strategy would be achieved as a result of the removal of the source material. 

On September 25, 2007, EPA issued an ESD for the Redwing Site. In the ESD, EPA 

revised the 1992 ROD subsurface soil cleanup levels for acetone, Aldrin, alpha-BHC, and 

Dieldrin. 

The remedy at the Site is protective of human health and the environment because the 

surface soil, subsurface soil, sediment and ground water at the Site met performance 

standards established in the RODs and the Explanation of Significant Difference (ESD). 

Table 2: Ground Water Cleanup Goals 

Ground Water COCs ROD Cleanup Goal* (micrograms per liter, μg/L) 

4,4-DDT 0.158 

Acetone 1,120 

Aldrin 0.00317 

Alpha-BHC 0.00855 

Beryllium 4.00 

Bis (2-Ethylhexyl) Phthalate 6.00 

Caron Disulfide 47.6 

Chloroform 100 

Chromium 50 

Dieldrin 0.00337 

Gamma- BHC (Lindane) 0.2 

Methylene Chloride 5 

Nickel 100 

Vanadium 78.1 

Vernolate 11.2 

*Based on Risk Assessment 
15 

Table 3: Subsurface Soil Cleanup Goals 

Subsurface soil COCs ROD Cleanup Goal* (micrograms per liter, μg/L) 

4,4’- DDT** 566 

Acetone 453*** 

Aldrin 640,000*** 

Alpha-BHC 2.2*** 

Chloroform 70 

Chromium 47,000 

Dieldrin 81*** 

Gamma- BHC (Lindane) 3.2 

Methylene Chloride 0.6 

Nickel 30,000 

Vanadium** 156,000 

Vernolate 55 

*Cleanup levels are based on risk to ground water protection. 

** Concentrations of these site related contaminants were detected in the ground water during the RI 

but not above cleanup levels in the subsurface soils but contaminants were included post excavation 

confirmation sampling. 

***Cleanup goals updated by revised site specific risk assessment which was detailed in the 2007 

ESD. 

Table 4: Surface Soil and Sediment Cleanup Goals 

Surface soil and Sediment COCs ROD Cleanup Goal* (micrograms per liter, 

μg/L) 

Benzo (A) Pyrene 94.9 

Benzo (B) Fluoranthene 540 

Benzo (A) Anthracene 1,025 

Carbon Tetrachloride 9,590 

Chrysene 362 

*Based on risk from inhalation or ingestion. 

4.2 Remedy Implementation 

EPA approved the Final Remedial Design on June 28, 2007. The Redwing PRP 

conducted the remedial action pursuant to the February 26, 2002 Remedial 

Design/Remedial Action Consent Decree. Site demolition activities started in March 

2004 and were completed in June 2004. During the demolition, 5,700 cubic yards of 
16 

demolition debris were transported off-site for disposal and 3,915 cubic yards of asphalt 

and concrete were transported off-site for recycling. 

The Final Remedial Design Report was approved on June 28, 2007. The Redwing 

Remedial Action (RA) started in mid-December 2007 and was completed in June 2008. 

During the RA, a total of 25,114 cubic yards of soil were excavated. Of this amount, 

approximately 21,375 cubic yards were transported off-site for disposal. The remaining 

soil, together with clean fill brought in from off-site, was used in backfilling and 

regrading excavated areas of the Site. Upon completion of site grading, grass seed was 

broadcast over the site to establish a grass cover. 

After regrading and seeding activities were completed, six (6) monitoring wells were 

installed on-site and ground water samples were collected on September 5, 2008. The 

sampling detected vernolate in one monitoring well (MW-16) at a concentration above 

the ROD ground water cleanup. The monitoring wells were resampled in early December 

2008 and vernolate was again detected in MW-16. It was determined that this well was 

installed near an area where soils containing unexpectedly high concentrations of 

vernolate were removed during the soil excavation phase of the RA. In response to the 

2008 ground water sampling, three monitoring wells were installed on adjacent property 

in early April 2009 to determine if contaminated ground water has migrated of-site. 

Sampling results from these wells did not detect any contamination. 

From September 2009 to August 2012, ground water samples were collected quarterly 

and exclusively from MW-16 and the three (3) off-site monitoring wells. In September 

2012, EPA agreed that the ground water in these monitoring wells was below the ROD 

standard for all constituents and abandonment of the remaining monitoring wells for the 

Site was approved. 

4.3 Operation and Maintenance (O&M) 

 

There are no associated annual O&M costs as the Site meet the Remedial Goal 

Objectives and cleanup goals set forth in the decision documents. 

5.0 Progress Since the Last Five-Year Review 

This is the first FYR for the Site. 
17 

6.0 Five-Year Review Process 

6.1 Administrative Components 

EPA Region 4 initiated the FYR in August 2014 and scheduled its completion for September 

2014. The EPA RPM Shelby Johnston led the EPA site review team, which also included the 

EPA site attorney Marianne Lodin and the EPA community involvement coordinator (CIC) 

Angela Miller. The review schedule established consisted of the following activities: 

 Community notification. 

 Document review. 

 Data collection and review. 

 FYR Report development and review. 

6.2 Community Involvement 

On September 5, 2014, EPA published a public notice in the Mobile Press Register 

newspaper announcing the commencement of the FYR process for the Site, providing 

contact information for Shelby Johnston and inviting community participation. The press 

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

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

FYR, EPA will place copies of the document in the designated site repository. 

6.3 Document Review 

 

ARARs Review 

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

cleanup of hazardous substance, pollutants, and contaminants released into the 

environment and of control of further release at a minimum which assures protection of 

human health and the environment.” The remedial action must achieve a level of cleanup 

that at least attains those requirements that are legally applicable or relevant and 

appropriate. 

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

substantive requirements, criteria, or limitations promulgated under federal 

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

hazardous substance, remedial action, location, or other circumstance found at a 

CERCLA site. 

 Relevant and appropriate requirements are those standards that, while not 

“applicable,” address problems or situations sufficiently similar to those encountered 

at the CERCLA site that their use is well suited to the particular site. Only those state 

standards that are more stringent than federal requirements may be applicable or 

relevant and appropriate. 
18 

 To-be-considered criteria are non-promulgated advisories and guidance that are not 

legally binding, but should be considered in determining the necessary remedial 

action. For example, to-be-considered criteria may be particularly useful in 

determining health-based levels where no ARARs exist or in developing the 

appropriate method for conducting a remedial action. 

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

which, when applied to site-specific conditions, result in the establishment of numerical 

values. These values establish an acceptable amount or concentration of a chemical that 

may remain in, or be discharged to, the ambient environment. Examples of chemicalspecific ARARs include maximum contaminant levels (MCLs) under the federal Safe 

Drinking Water Act and ambient water quality criteria enumerated under the federal 

Clean Water Act. 

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

actions taken with respect to a particular hazardous substance. These requirements are 

triggered by a particular remedial activity, such as discharge of contaminated ground 

water or in-situ remediation. 

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

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

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

Remedial actions are required to comply with the chemical-specific ARARs identified in 

the ROD. In performing the Five-Year Review for compliance with ARARs, only those 

ARARs that address the protectiveness of the remedy are reviewed. 

Ground Water ARARs 

According to the ROD, the ground water ARARs are the National Primary Drinking 

Water Standards. As shown in Table 5, drinking water standards have only changed for 

three site contaminants. Two contaminant standards have become less stringent and the 

chloroform became slightly more stringent. The ground water remediation data at the site 

indicate that the more stringent ARAR for Chloroform has been met and thus the remedy 

is still protective. 
19 

Table 5: Previous and Current ARARs for Ground Water COCs 

COCs 1992 ROD Cleanup 

Goals (μg/L) 

Current (2014) ARAR 

(μg/L) ARAR Changes 

4,4-DDT 0.158 None None 

Acetone 1,120 None None 

Aldrin 0.00317 None None 

Alpha-BHC 0.00855 None None 

Beryllium 4.00* 4.00 None 

Bis (2-Ethylhexyl) Phthalate 6.00* 6.00 None 

Carbon Disulfide 47.6 None None 

Chloroform 100* 80 More stringentb

Chromium 50* 100 Less stringent 

Dieldrin 0.00337 None None 

Gamma- BHC (Lindane) 0.2* 0.2 None 

Methylene Chloride 5* 5 None 

Nickel 100* 300 Less stringent 

Vanadium 78.1 None None 

Vernolate 11.2 None None 

All clean up levels were determined by MCL* or by site specific risk development if no MCL was 

published. The assumptions made for calculation of the site specific clean up levels are still valid. 

b.The ground water remediation data for the site meets the new ARAR for Chloroform.

Table 6: Previous and Current ARARs for Surface Soil and Sediments COCs 

COCs 

1992 ROD 

Cleanup Goals 

(μg/L) 

Current ARAR

(2014) 

 (μg/kg) ARAR Changes 

Benzo (A) Pyrene 94.9 None None 

Benzo (B) Fluoranthene 540 None None 

Benzo (A) Anthracene 1,025 None None 

Carbon Tetrachloride 9,590 None None 

Chrysene 362 None None 

All cleanup goals indicated were developed by site specific risk development. The assumptions made for 

calculation of the site specific clean up levels are still valid. 
20 

Table 7: Previous and Current ARARs for Subsurface Soil COCs 

COCs 

1992 ROD 

Cleanup Goals 

(μg/kg) 

Current ARAR

(2014) 

 (μg/kg) ARAR Changes 

4,4’- DDT 566 None None 

Acetone 453* None None 

Aldrin 640,000* None None 

Alpha-BHC 2.2* None None 

Chloroform 70 None None 

Chromium 47,000 None None 

Dieldrin 81* None None 

Gamma- BHC (Lindane) 3.2 None None 

Methylene Chloride 0.6 None None 

Nickel 30,000 None None 

Vanadium 156,000 None None 

Vernolate 55 None None 

All Cleanup Goals indicated were developed by site specific risk development. 

*Cleanup Goals revised by site specific risk assessment which was detailed in the 2007 ESD. The 

assumptions made for calculation of the site specific clean up levels are still valid. 

6.4 Data Review 

 Soil 

The excavation of TLM contaminated soil was executed from December 2007 to June 

2008. The excavation program was performed by the removal blocks of soil to 

predetermined depths based on analytical results from the pre-design investigation. 

Additional TLM contaminated soil was removed laterally based on visual presence of 

TLM contaminated soils on excavated sidewalls. Additional soil was excavated from the 

bottom of pre-determined excavation block depths based on confirmation analysis. 

Specifically, five-point composite samples were collected at the bottom of each 

excavation block and analyzed for ROD constituents. If the concentration of any 

constituent resulted in an exceedance of the 90% Upper Confidence Limit (UCL) average 

concentration for the Site, then additional soil was excavated and the deeper block bottom 

was again sampled. 

The large majority of the soils excavated from the site contained TLM and were thus 

removed from the site based on that criterion. The removal of the TLM contaminated 

soils resulted in the need to only remove a small amount of additional soils to meet the 

90% UCL average concentration requirement for soil constituent impacts. 

In accordance with the cut lines developed from data obtained during the Geoprobe® 

Investigation, contaminated soil and TLM was removed to the pre-designated cut lines. In 
21 

addition, any additional visible TLM was excavated. These visual determination criteria 

resulted in the excavation of a substantially greater volume of soil than originally 

anticipated form the initial cut lines. TLM and TLM contaminated soil was disposed of at 

a Treatment, Storage, and Disposal Facility. 

Transportation and storage of the excavated soils was governed by the disposition of the 

soil as defined by the ARARs which included RCRA. The ROD indicated that the 

Toxicicity Characteristic Leaching Procedure (TCLP) was to be used for determining 

whether soils are hazardous or non-hazardous. TLM and excavated soil were not 

considered listed wastes. The Site excavation was backfilled with clean soil and 

compacted to simulate natural conditions. Re-vegetation was performed using 

conventional hydroseeding methods to establish a stable stand of vegetation for soil 

erosion control. 

The final excavation volume was greater than the original estimated design volume 

primarily because: 1) confirmation analysis in certain areas required deeper excavation to 

meet 90% UCL requirements, and 2) sidewall TLM contaminated soils were much more 

extensive than previously estimated from pre-design sampling data. 

Excavation proceeded to the limits of visual TLM contaminated soil along the complete 

western, southern and eastern boundaries of the Site property. On a small portion of the 

property on the northern Site boundary, some visual TLM soil staining was permitted to 

be left in place due to the proximity of the excavation to the main pressure natural gas 

line for the City of Saraland. The excavation in this area was terminated approximately 2-

ft. from the gas line. Note that even though a small volume of TLM was left in this area, 

the preponderance of the analytical data from the TLM staging piles indicated low to 

non-detectable concentrations of ROD constituents in the soil. In summary, the original 

design excavation volume was 12,300 CY. The final excavation volume was 25,114 CY. 

Ground Water 

Long-term, post-remediation ground water monitoring was initiated after the completion 

of the RA in 2008 and was ongoing until late 2012. 4,4-DDT, Acetone, Aldrin, AlphaBHC, Beryllium, Bis(2-ethylhexyl)phthalate, Carbon Disulfide, Chloroform, Chromium, 

Dieldrin, Gamma-BHC (Lindane), Methylene Chloride, Nickel, Vanadium and Vernolate 

are the ground water COCs listed in the ROD. This monitoring program began with the 

installation of six (6) new monitoring wells (MW-14, MW-15, MW-16, MW-17, MW-18, 

and MW- 19) on-site. Two (2) monitoring wells that existed prior to the remediation were 

left in place (MW-12U and MW-13U). These eight (8) wells were sampled in September 

2008, December 2008, and March 2009 for the following constituents: Sulfate, Chloride, 

Beryllium (total and dissolved), Total Chromium (total and dissolved), Nickel (total and 

dissolved), Vanadium (total and dissolved), Total Organic Carbon, Methylene Chloride, 

Acetone, Carbon Disulfide, Chloroform, Bis(2-ethylhexyl)phthalate, Vernolate, Lindane, 

Alpha-BHC, 4,4-DDT, Dieldrin and Aldrin. 
22 

Three (3) sampling events were initially performed for the on-site monitoring wells and 

one (1) sampling event for the off-site monitoring wells. Only a few minor exceedances 

of the ROD clean up criteria were observed with the exception of Vernolate in MW-16. 

Three (3) off-site wells (MWOS-01, MWOS-02, and MWOS-03) were installed in April 

2009; however, they were only sampled and analyzed for Vernolate as it was the only 

constituent on-site which still exceeded its cleanup goal. Monitoring continued on these 

three (3) wells and on-site well MW-16 for Vernolate until the ground water cleanup 

standards were achieved in MW-16, consistent with the Ground water Monitoring Plan 

specified in this document. No Vernolate was detected in the off-site monitoring wells. 

During the March 2010 sampling event both Dieldrin and Vanadium ground water 

ARARs were met, each previously detected in one monitoring well each out of sixteen 

total monitoring wells. Following this sampling event, EPA determined that the 

performance standards for all COCs in ground water except Vernolate had been met. All 

monitoring wells except MW-16 and the three (3) off-site monitoring wells were 

abandoned in 2010. 

From September 2009 to August 2012, ground water samples were collected to monitor 

Vernolate concentrations quarterly and exclusively from MW-16 and the three (3) off-site 

monitoring wells. In September 2012, EPA determined that the cleanup goals for all 

COCs in the ground water had been met and that the remedy was protective of human 

health and the environment. With this determination the abandonment of the remaining 

monitoring wells for the site was approved. 

6.5 Site Inspection 

No site inspection occurred in conjunction with this FYR. There was a final RA 

inspection conducted between EPA and ADEM on August 28, 2008. During this final 

inspection, it was determined that the PRP has constructed the remedy in accordance with 

the Redwing Remedial Design plans. 

6.6 Interviews 

No interviews were conducted in conjunction with this FYR. 

 
23 

7.0 Technical Assessment 

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

The remedial actions are functioning as intended. Contaminated soil and sediment have 

been removed preventing any further exposures. Ground water monitoring results 

indicated that the remedial goals established in the ROD have been met. 

 

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? 

Yes, the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time 

of remedy selection are still valid. The ground water standards applied as cleanup goals 

have not changed. Surface soil cleanup goals were based on risk of inhalation and 

ingestion and subsurface soil cleanup goals are based on site specific protection of 

ground water. There have been no changes in the toxicity of the contaminants that would 

affect the cleanup goals. 

 

7.3 Question C: Has any other information come to light that could call into question 

the protectiveness of the remedy? 

No other information has come to light that could call into question the protectiveness of 

the remedy. 

7.4 Technical Assessment Summary 

The remedial actions are functioning as intended. Contaminated soil and sediment have 

been removed preventing any further exposures. Ground water monitoring results 

indicated that the remedial goals established in the ROD have been met. The Site does 

not require any institutional controls since the Site was remediated to residential 

standards to allow for Unlimited Use and Unrestricted Exposure (UU/UE). The exposure 

assumptions, toxicity data, cleanup levels and RAOs used at the time of remedy selection 

are still valid. No other information has come to light that could call into question the 

protectiveness of the remedy. 
24 

8.0 Issues 

There are no current site issues. 

9.0 Recommendations and Follow-up Actions 

There are no recommendations required to address the current site issues. 

10.0 Protectiveness Statements 

The remedy at the Site is protective of human health and the environment because the surface 

soil, subsurface soil, sediment and ground water at the Site met performance standards 

established in the RODs and the Explanation of Significant Difference (ESD). 

 

11.0 Next Review 

The policy requirement for the five-year review has been met and will be discontinued. Per 

EPA’s 2001 Five-Year Review guidance, “Five-year reviews may no longer be needed when no 

hazardous substances, pollutants, or contaminants remain on site above levels that allow for 

unlimited use or unrestricted exposure” (UU/UE). Since the site is UU/UE and has met the 

requirements established by the ROD it is not necessary to conduct another FYR. The site is 

scheduled for deletion from the NPL within the next year. 
A-1 

Appendix A: List of Documents Reviewed 

Amended Record of Decision. Redwing Carriers, Inc. (Saraland) NPL Site. EPA ID: 

ALD980844385. Saraland, AL. Prepared by EPA Region 4. June 14, 2000. 

Explanation of Significant Difference. Redwing Carriers, Inc. (Saraland) NPL Site. EPA ID: 

ALD980844385. Saraland, AL. Prepared by EPA Region 4. September 2007. 

Preliminary Closeout Report. Redwing Carriers, Inc. (Saraland) NPL Site. EPA ID: 

ALD980844385. Saraland, AL. Prepared by EPA Region 4. September 2009. 

Record of Decision. Redwing Carriers, Inc. (Saraland) NPL Site. EPA ID: ALD980844385. 

Saraland, AL. Prepared by EPA Region 4. December 15, 1992. 

Remedial Action Report. Redwing Carriers, Inc. (Saraland) NPL Site. EPA ID: ALD980844385. 

Saraland, AL. Prepared by NewFields. July 2014. 
B-1 

Appendix B: Press Notice 

The U.S. Environmental Protection Agency, Region 4 

Announces the first Five-Year Review of 

the Redwing Carrier Superfund Site, 

Saraland, Mobile County, Alabama 

Purpose/Objective: The U.S. Environmental Protection Agency (EPA) is conducting a FiveYear Review of the remedy for the Redwing Carrier Superfund site (the Site) in Saraland, 

Alabama. The purpose of the Five-Year Review is to ensure that the selected cleanup actions 

effectively protect human health and the environment. 

Site Background: The 5.1-acre site is located in Saraland, a suburb of Mobile County, 

Alabama. Site surroundings include residential and commercial land uses. Residential areas 

border the site to the north, south and west. Commercial businesses border the site to the east. 

From 1961 until 1971, Redwing Carriers, Inc. owned and operated a terminal for cleaning, 

repairing and parking trucks at the site. Cleaning operations released hazardous substances onto 

the ground. 

In 1973, Saraland Apartments purchased the site property and built an apartment complex 

subsidized by the U.S. Department of Housing and Urban Development (HUD). Construction 

activities covered the sludge and contaminated soils with approximately five feet of clean soil. In 

1984, ADEM investigated apartment residents' complaints about the tar-like sludge seeping to 

the surface at numerous locations. In 1990, EPA listed the site on the NPL. The apartment 

complex was demolished in 2004. The vacant site is fenced and secured. Primary contaminants 

of concern at the Site include benzo(a)pyrene, benzo(b)fluoranthene, benzo(a)anthracene, carbon 

tetrachloride and chrysene in the soil and acetone, arsenic and carbon disulfide in the ground 

water. 

Cleanup Actions: EPA designated one operable unit (OU) to address the Site’s soil and ground 

water contamination. EPA signed the Site’s Record of Decision (ROD) December 15, 1992, 

selecting a remedy to dig and haul the Site’s soil contamination. The major components of the 

remedy included temporary relocation of residents, onsite treatment of ground water and 

monitored natural attenuation of ground water contaminants. The ROD was amended June 14, 

2000. The amended plan allowed for demolition, removal and disposal of all buildings, 

foundations, concrete walkways, and asphalt driveways and parking areas offsite, digging up and 

treating remaining contamination and offsite disposal, and delaying the ROD requirement for 

ground water treatment until it was determined to be needed. In 2007, EPA issued an 

Explanation of Significant Differences to update the soil remediation goals based on new 

findings during the 1996- 1997 removal actions which indicated that the depth to actual ground 

water was much greater than previously determined. 

Between 1985 and 1994, Redwing Carriers, Inc. conducted periodic cleanups at the site. 

Beginning in 1996, EPA took over cleanup activities. EPA relocated 57 residents temporarily in 

1996 and then permanently in 1997. EPA also dug up and disposed of approximately 20,724 tons 

of sludge, contaminated soil and debris off site. In 2004, the site’s PRPs removed the Saraland 
B-2 

apartment buildings, foundations, concrete walkways, asphalt driveways and parking areas. The 

PRPs completed soil contamination cleanup activities in 2007 and 2008. PRPs removed a total of 

25,114 cubic yards of soil. The PRPs backfilled and graded the dug-up areas and installed six 

monitoring wells on site. PRPs conducted ground water sampling in 2008. In 2009, the PRPs 

installed three additional monitoring wells on a property next to the site which concluded the 

onsite construction for the site. After monitoring until 2011, a review of the sampling results 

determined that the site remediation had been completed and the ROD requirements full filled. 

 

Five-Year Review Schedule: The National Contingency Plan requires that remedial actions that 

result in any hazardous substances, pollutants or contaminants remaining at the Site above levels 

that allow for unlimited use and unrestricted exposure be reviewed every five years to ensure the 

protection of human health and the environment. While no waste has been left in place on this 

site it is a policy of Region 4 to complete at least one policy Five Year Review before a site is 

delisted. The first and only anticipated Five-Year Review for the Site will be completed by 

September 2014. 

EPA Invites Community Participation in the Five-Year Review Process: EPA is conducting 

this Five-Year Review to evaluate the effectiveness of the Site’s remedy and to ensure that the 

remedy remains protective of human health and the environment. As part of the Five-Year 

Review process, EPA staff members are available to answer any questions about the Site. 

Community members who have questions about the Site or the Five-Year Review process are 

asked to contact: 

Shelby Johnston, EPA Remedial Project Manager Angela Miller, EPA Community 

Involvement Coordinator 

Phone: (404) 404-562-8287 Phone: (404) 562-8561 / 

(800) 435-9233 (toll-free) 

E-mail: johnston.shelby@epa.gov E-mail: miller.angela@epa.gov

Mailing Address: U.S. EPA Region 4, 61 Forsyth Street, S.W., 11th Floor, Atlanta, GA 30303-

8960 

Additional site information is available at the Site’s local document repository, located at 

Saraland Public Library, 111 Saraland Loop, Saraland, AL 36571 and online at:

http://www.epa.gov/region4/waste/npl/index.htm - AL. 
C-1 

Appendix C: Interview Form 

REDWING CARRIERS, INC. FIVE-YEAR REVIEW 

SUPERFUND SITE INTERVIEW FORM 

 
D-1 

Appendix D. Site Cleanup Goals 

1992 ROD 

 

 
D-2 
D-3 

2007 ESD Revised Subsurface Clean-up Levels