FIVE YEAR REVIEW - Superfund Records Collections · The remedy selected in ROD-2 for OU3 included placement of a RCRA cap over Pond 5, placement of a soil cover over Pond 6, collection

FIVE YEAR REVIEW REPORT FOR SALTVILLE WASTE DISPOSAL PONDS SUPERFUND SITE

SMYTH AND WASHINGTON COUNTIES, VIRGINIA

United States Environmental Protection Agency Region III

Philadelphia, Pennsylvania

orsellino, Director ardous Sites Cleanup Division

..S. EPA, Region III

Table of Contents

I.Introduction 1 II.Site Chronology ~ 2 III.Background 3

Physical Characteristics 3 Land and Resource Use 3 History of Contamination and Chemical Plant Operations .4 Initial Response Activities 5 Remedial Overview and Basis for Taking Action 6

IV.Remedial Action 7 ROD- 1 (OU1 and OU2) Remedy Selection 7 ROD-1 (OU1 and OU2) Remedy Implementation 7 ROD-2 (OU3) Remedy Selection 8 ROD-2 (OU3) Remedy Implementation 9 Operation and Maintenance (O&M) 10 Long-Term Monitoring 11

V.Previous Five Year Reviews and Progress Since the Last Five-Year Review 12 VI.Five-Year Review Process 13

Administrative Components 13 Community Involvement 13 Document Review 14 Data Review 15 Site Inspection 17 Interviews 18

VII.Technical Assessment 19 Question A: Is the remedy functioning as intended by the decision documents? 19 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial

Question C: Has any other information come to light that could call into question the action objectives ("RAOs") used at the time of the remedy selection still valid? 19

protectiveness of the remedy? 20 Technical Assessment Summary 20

VIII.Issues 21. IX.Issues and Recommendations/ Follow-Up Actions 22. X.Protectiveness Statement 23 XI.Next Review 23

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FIGURES

Figure 1.1-1 Olin Saltville "Site"

Figure 1-1 Historic Monthly Sampling Locations, RM 81.60 - RM 82.93

Figure 1-2 Historic Monthly Sample Locations, RM 80.8 - RM 81.60

TABLES

Table 1 Summary of Surface Water Sample Results for the NFHR and Robertson Branch Creek - March 2011 to June 2012

Table 2.3 Pond 5 Treatment Plant - Treated Water Monitoring Program

Table 2 Issues

Table 3 Recommendations and Followup Actions

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ARAR CD CERCLA CFR DDA EPA FCPS FS HDPE LLPDE LTMP NCP NPL NFHR OUI OU2 OU3 O&M QDR Ilg/L RAO RCRA RI ROD RPM SCLP TMDL USACE VDEQ VPDES

LIST OF ACRONYMS

Applicable or Relevant and Appropriate Requirement Consent Decree Comprehensive Environmental Response, Compensation, and Liability Act Code of Federal Regulations Demolition Debris Area U.S. Environmental Protection Agency Former Chlorine Plant Site Feasibility Study High Density Polyethylene Linear Low Density Polyethylene Long-Term Monitoring Plan National Contingency Plan National Priorities List North Fork Holston River Operable Unit One Operable Unit Two Operable Unit Three Operation and Maintenance Quarterly Data Reports Micrograms per Liter Remedial Action Objectives Resource Conservation and Recovery Act Remedial Investigation Record of Decision Remedial Project Manager Saltville Community Liaison Panel Total Maximum Daily Load U.S. Army Corps of Engineers Virginia Department of Environmental Quality Virginia Pollution Discharge Elimination System

IV

EXECUTIVE SUMMARY

The construction of remedies selected in the first two Records of Decision (RODs) for the Saltville Waste Disposal Ponds Site in Saltville, Virginia (Site) is complete. At least one more ROD is planned to select additional remedies. The contaminants of concern at the Site are mercury and methylmercury. The Site has been addressed in the following four operable units (OUs):

• OUI - Pond 5 surface water diversion; • OU2 - Wastewater treatment plant for Pond 5 leachate; • OU3 - Pond 5 Cap, Pond 6 Cover, and upgrade to the Pond 5 wastewater treatment

plant for Ponds 5 and 6; and • OU4 - Mercury impacts at the Former Chlorine Plant Site and mercury impacts on

the North Fork Holston and Holston Rivers

The remedy selected in the first ROD for the Site (ROD-I) was an interim remedial action for OUI and OU2 and included the collection ofleachate-contaminated groundwater from waste disposal Pond 5, construction and operation of an onsite plant to treat leachate-contaminated groundwater from Pond 5, and engineering controls to divert clean stormwater around Pond 5. ROD-I also required that a Site-wide Remedial Investigation and Feasibility Study (RIfFS) be performed.

The remedy selected in ROD-2 for OU3 included placement of a RCRA cap over Pond 5, placement of a soil cover over Pond 6, collection and treatment of leachate-contaminated groundwater from Pond 6, additional engineering controls for diversion/management of clean stormwater and groundwater, institutional controls and long-term monitoring.

Remedial investigation work addressing the Former Chlorine Plant Site (FCPS), the North Fork Holston River (NFHR) in Virginia and the Holston River in Tennessee is still in progress.

The triggering action for this Five-year Review (FYR) was the signing of the previous FYR on September 27,2007.

The interim remedy selected in ROD-I and the remedy selected in ROD-2 are in place and functioning as intended. However, it is recommended that effluent limitations for the onsite treatment plant and the long-term monitoring plan for the Site should be modified as needed based on EPA's National Recommended Water Quality Criteria for methylmercury, the Virginia Water Quality Standard for methylmercury, the NFHR Mercury Total Maximum Daily Load Report (TMDL) Report and the ongoing remedial investigation of the FCPS and the NFHR.

The remedies for OUI, OU2 and OU3 are in place and protective. There have been no changes in Site conditions that call into question the protectiveness of these remedies.

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Government Performance and Results Act (GPRA) Measure Review

As part ofthis FYR, the GPRA Measures have also been reviewed. The GPRA Measures and their status are provided as follows:

Environmental Indicators Human Health: Current Human Exposure Controlled (HEUC) Ground Water Migration: Contaminated Groundwater Migration Under Control (GMUC)

Sitewide Ready for Anticipated Use (SWRAU) The Site has not achieved Sitewide Ready for Anticipated Use.

VI

Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name: Saltville Waste Disposal Ponds Site

EPA ID: VAD003127578

3 Smyth and Washington Counties

NPL Status: Final

Multiple OUs? Yes

Has the site achieved construction completion? No

~---------------------------------

REVIEW STATUS ,

Lead agency: EPA If "Other Federal Agency" was selected above, enter Agency name:

Author name (Federal or State Project Manager): Darius Ostrauskas, Remedial Project Manager

Author affiliation: EPA Region 3

Review period: June 2012- September 2012

Date of site inspection: August 27 and 28, 2012

Type of review: Statutory

Review number: 4

Triggering action date: September 27,2007

Due date (five years after triggering action date): September 27, 2012

VB

Five-Year Review Summary Form (continued)

Issues/Recommendations

QU(s) without Issues/Recommendatiens Identified in the Fjve-'(eall Review:

OU1

Issues an.d Recommendations Identified in the Five-Year Review:

OU(s): OU3 Issue Category: Monitoring

Issue: Long-term monitoring plan for Pond 5 and/or Pond 6 groundwater may need to be modified depending on results of ongoing RI.

Recommendation: Modify long-term monitoring plan for Pond 5 and/or Pond 6 groundwater as needed based on results of ongoi~g RI.

Affect Current Protectiveness

Affect Future Protectiveness

Implementing Party

Oversight Party

Milestone Date

No Yes PRP EPA 3/31/13

OU(s): OU3 Issue Category: Operations and Maintenance

Issue: Certain wells included in current long-term monitoring plan are damaged and cannot be sampled

Recommendation: Repair or replace damaged wells included in long-term monitoring plan as needed.



Implementing Party

Oversight Party

Milestone Date


Vlll

OU(s): OU2/3 Issue Category: Remedy Performance

Issue: Unclear whether current effluent limitations for mercury for onsite treatment plant are consistent with VA Water Quality Standard for methylmercury and NFHR Mercury TMDL Report. In addition, effluent limitations for onsite treatment plant are not identified in long-term· monitoring plan.

Recommendation: Confirm current effluent limitations for onsite treatment plant are consistent with VA Water Quality Standard for methylmercury and NFHR Mercury TMDL Report (or modify as needed) once the contribution of different sources of mercury to the NFHR are determined by ongoing investigations. Include effluent limitations in long-term monitoring plan.



Implementing Party

Oversight Party

Milestone Date

No Yes PRPNADEQ EPA TBD

OU(s): OU3 Issue Category: Remedy Performance

Issue: Unclear whether dikes for Pond 5 and Pond 6 are in compliance with VA Impoundment Regulations.

Recommendation: Modify O&M plan as needed to ensure that Pond 5 and Pond 6 dikes are in compliance with VA Impoundment Regulations.



Implementing Party

Oversight Party

Milestone Date


OU(s): OU3 Issue Category: Monitoring

Issue: Quarterly sampling results for Pond 6 decant structure are not being provided in reporting of long-term monitoring. Pond 5 decant structure is not being monitored.

Recommendation: Include results of quarterly Pond 6 decant structure sampling in reporting of long-term monitoring. Add quarterly sampling of Pond 5 decant structure to long-term monitoring.

Affect Current Affect Future Implementing Oversight Milestone Date Protectiveness Protectiveness Party Party


IX

OU(s): Issue Category: Operations and Maintenance OU2/0U3

Issue: O&M plans for onsite treatment plant do not reference regulatory requirements to be considered in O&M of the plant or include inspection, monitoring and reporting activities necessary to meet these requirements.

Recommendation: Modify O&M plan(s) for onsite treatment plant as needed to reference regulatory requirements and include the inspection, monitoring and reporting activities necessary to meet these requirements.



Implementing Party

Oversight Party

Milestone Date


Operable Unit: OU 1, OU2, OU3

Protectiveness Determination: Protective

Addendum Due Date (if applicable): NA

Protectiveness Statement: The remedy selected in ROD-I (OUI and (OU2) was an interim remedial action selected to remediate an immediate threat while further studies were conducted to develop a final remedy. The subject interim remedy has been implemented and is functioning as intended by ROD-I. The remedy selected in ROD-2 (OU3) was intended to mitigate a threat posed to human health by dermal contact and incidental ingestion of waste within Pond 5 and Pond 6. In addition, the ROD-2 remedy included treatment of contaminated groundwater collecting at the outfall of Pond 6, groundwater monitoring and institutional controls. The remedy selected in ROD-2 is in place and functioning as intended. Combined with a fish consumption restriction placed on the North Fork Holsten River by the Virginia Department of Health, the remedies selected in ROD-I and ROD-2 are protective ofhuman health.

x

Saltville Waste Disposal Ponds Superfund Site Saltville, Virginia

Third Five-Year Review Report EPA ID No. VAD003127578

I. Introduction

The purpose ofthe five-year review is to determine whether the remedy at a site is protective ofhuman health and the environment. The methods, findings, and conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports identify issues found during the review, if any, and identify recommendations to address them.

The Agency is preparing this Five-Year Review report pursuant to CERCLA §121 and the National Contingency Plan (NCP). CERCLA §121 states:

Ifthe 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 ofsuch remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, ifupon such review it is the judgment ofthe President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. I

The Agency interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states:

Ifa 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 the initiation ofthe selected remedial action.

The U.S. Environmental Protection Agency (EPA), Region 3, conducted this five-year review of the remedy being implemented at the Saltville Waste Disposal Ponds Superfund Site (Saltville or Site) in Saltville, Virginia. This review was conducted by the Remedial Project Manager for the Site between June 2012 and September 2012. This report documents the results of the review.

This is the fourth five-year review for the Saltville Site. The triggering action for this statutory review is the completion of the third five-year review in September 2007. The five-year review is required because the remedy allows mercury and high pH waste material to remain on-Site at levels which do not allow for unlimited use and unrestricted exposure.

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II. Site Chronology

Date Activity

1895-1972 Olin Corporation or its predecessors (Olin Mathieson Chemical Corporation,

Mathieson Chemical Corporation and Mathieson Alkali Works) operated various

chemical manufacturing operations in Saltville.

Olin Corp or its predecessors operated a mercury cell chlor-alkali plant on the bank

of the North Fork Holston River (NFHR). The facility was dismantled in June 1973.

Olin entered into a Consent Special Order with the Virginia State Water Control Board

where Olin agreed to dredge mercury-contaminated sediment from the NFHR,

encapsulate the sediment on the foundation of a former building at the Former

Chlorine Plant Site (FCPS) and cap the FCPS with clay.

1950-1972

November 1982

September 8, 1983 EPA. promulgated the Site in the National Priorities List (NPL)

June 30, 1987 EPA issued first Record of Decision (ROD-l) requiring interim remedial measures

and an additional Remedial Investigation/Feasibility Study (RI/FS).

September 15, 1988 Olin entered into a Consent Decree wherein Olin agreed to implement the ROD-l

selected remedy.

May 17, 1991 Olin completed the Remedial Design for surface water diversion required by ROD-l

(defined as OUI Remedial Action).

Contractors were mobilized to the Site to begin OUI construction.

EPA approved report documenting completion of OU1 Remedial Action.

June 1991

September 22, 1992

April 27, 1993 Olin completes Remedial Design for water treatment plant (defined as OU2

Remedial Action).

Contractors ,mobilize to begin OU2 construction.

Untreated discharge of leachate-contaminated groundwater at Pond 5 ceased and

diverted to equalization basin.

October 11, 1993

July 8, 1994

September 28, 1994 The wastewater treatment plant passed proof-of-performance testing; treatment and

discharge of Pond 5 groundwater initiated.

EPA issued second ROD (ROD-2)

EPA approved RA Report documenting completion of treatment plant construction

required by ROD-l (defined as OU2 Remedial Action)

September 29, 1995

September 3, 1996

July 29, 1997 Olin enters into Consent Decree wherein Olin agrees to implement ROD-2 selected

remedy.

EPA issued initialS-Year Review

Olin completed Remedial Design for the remedy selected in ROD-2

September 1997

March 27, 2001

April 2, 2001 Olin contractors mobilized to bygin OU3 construction.

November 15, 2001 Pond 6 groundwater pump house went on-line and Pond 6 groundwater was

permanently routed to the wastewater treatment plant.

September 20, 2002 EPA issued second 5-Year Review

July 11, 2003 EPA approved RA Report documenting completion of construction of ROD-2 remedy

March 27, 2007 Olin files Environmental Protection Easement and Declaration of Restrictive

Covenants, thereby implementing ICs selected in ROD-2.

February 26, 2010 Draft Supplemental RI Report issued by Olin

April 2011 NFHR Mercury TMDL Report approved by EPA

III. Background

Physical Characteristics

The Saltville Waste Disposal Ponds Superfund Site (Site) includes the Olin Corporation's former facility located along the north bank of the North Fork Holston River (NFHR) between the towns of Saltville and Allison Gap, in western Smyth and eastern Washington Counties, Virginia. The NFHR flows next to the former facility. The Site includes the Former Chlorine Plant Site (FCPS), two waste disposal ponds, Pond 5 and Pond 6, the NFHR and the Holston River in Tennessee, which receives drainage from the NFHR. Pond 5 covers an area of approximately 76 acres while adjacent Pond 6 covers about 45 acres (see Figure 1.1-1). The FCPS is about one-half mile upstream of Pond 5 and has an area of approximately 4 acres. The FCPS, Pond 5 and Pond 6 are located in a mountain valley formed by the NFHR.

Land and Resource Use

From approximately 1895 to 1972, the Saltville facility was owned and used by Olin Corporation (Olin) or its predecessors (Olin Mathieson Chemical Corporation, Mathieson Chemical Corporation and Mathieson Alkali Works) as the location for various chemical manufacturing operations. Mathieson Chemical Corporation constructed a mercury cell chior-alkali plant (also referred to as the chlorine plant) in 1950 and operated that plant until 1972. The former location of the chlorine plant and the immediately surrounding area is the FCPS.

Three residential clusters are located in the immediate vicinity of the Site. Approximately 40 residences are located south of Pond 5 and NFHR on Henrytown Road. Approximately 20 residences are located to the northeast ofPonds 5 and 6. About five residences are located along the northwestern side of Pond 5. All ofthe subject residences are located either upgradient of the FCPS, Pond 5 and Pond 6 or on the south (opposite) side of the NFHR.

Land use adjacent to the FCPS is industrial and includes the Saltville municipal wastewater treatment plant to the north, a dry ice facility to the northwest, a wheel manufacturing plant to the east across the NFHR, and an auto repair/welding shop to the south across the NFHR.

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Poor water quality attributable to the presence of evaporites (e.g., gypsum, potash, bittern and salt (hence the name Saltville)) has rendered certain aquifers in the vicinity ofthe Site unsuitable for potable water supply purposes. However, the poor quality of groundwater underlying and in the area of Pond 5, Pond 6 and the FCPS appears to be primarily attributable to long-term industrial use.

A municipal ordinance requires that residential and industrial developments in the area be connected to a municipal water supply system. This system is the source of water for all residences and industrial operations near the Site. While the dry ice facility to the immediate northwest of the FCPS is connected to this system, this facility also reportedly has a private water supply well. This is the only known private well which may still be in use within areas underlain by groundwater potentially impacted by the Site. This facility does not generate wastewater and/or discharge wastewater to surface water.

History of Contamination and Chemical Plant Operations

Olin manufactured various chemicals at the Site from approximately 1895 to 1972, including chlorine gas from 1950 through 1972. The chlorine plant produced chlorine gas and sodium hydroxide by passing brine, obtained by solution mining salt deposits in the area, between two electrodes. The cathode used in this process was mercury. The electrical current passing through the brine produced chlorine gas at the anode through electrolytic oxidation. A sodium amalgam fomied at the cathode was conveyed to a decomposing tower where the sodium was separated by flushing the water from the sodium hydroxide. Mercury was lost in the production process and solubilized, with the resultant wastewater conveyed to Pond 5 and, to a lesser extent, Pond 6. Mercury was also released to soil, groundwater and surface water at the FCPS via spills and during routine facility washing operations.

Pond 5 was operated from approximately 1925 to 1971 and Pond 6 was put into service in 1964. The ponds were primarily used for the containment of ammonia soda ash wastes. In 1951, Pond 5 began receiving mercury-contaminated wastewater from the chlorine plant. The wastewater was discharged on the surface of Pond 5 near the eastern edge and directed around the northern perimeter by berms on the pond surface. The process and washdown wastewater was conveyed to the eastern end of Pond 5 separately from the ammonia soda ash waste slurry. Pond 6 received mercury-contaminated wastewater but not to the extent of Pond 5. The ponds were designed to percolate wastewater through the pond solids and thus allow mercury in the wastewater to adsorb onto the fine, alkaline particles of the ammonia soda ash waste. At this time, the contents of the ponds can be considered primarily solids which are still settling over time.

The dikes containing the ponds were constructed of rockfill cores (starter dikes) and built up with accumulations ofslaker wastes. The slaker wastes were primarily composed ofspent coke and roasted limestone waste. The Pond 5 dikes are approximately 100 feet high and the depth of settled solids varies from about 35 feet to 70 feet, with an average of about 63 feet. The Pond 6 dikes are approximately 35 feet high and the depth of the solids varies from about 20 feet to 30 feet. Until 1994, surface water runoff and groundwater contaminated by leachate from Pond 5 collected in a decant structure located at the southwest corner of the pond which discharged directly to the NFHR through an outfall.

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Olin ceased chlorine plant operations in 1972 and dismantled the plant in 1972 and 1973. Mercury that could be removed from the equipment and reused was shipped to Olin plants in Georgia and Alabama. The equipment was rinsed at the FCPS and the rinsate was allowed to percolate into the soils at the FCPS. Some of the debris and obsolete equipment from the plant demolition was placed at the eastern edge ofPond 6..Debris was also placed on the lo~er bench of the dike between Pond 5 and Pond 6 (referred to as the Demolition Debris Area). No sampling of the debris was conducted prior to disposal which was completed in June 1973. The debris was covered with locally-obtained soil.

Initial Response Activities

Environmental studies of the Site began in conjunction with heightened concern about mercury discharges nationwide. Investigations by Olin, the Commonwealth of Virginia, and local agencies during the late 1960's revealed mercury contamination at both FCPS and the NFHR. In 1970, as a result of mercury concentrations found in fish, both Virginia and Tennessee placed a ban on fishing in the NFHR and the Holston River. These bans were later modified (Tennessee's in 1972, Virginia's in 1974) to permit fishing on a catch-and-release basis.

In 1978, a Saltville Site Task Force was formed which included the Virginia State Water Control Board, Virginia Attorney General's Office, the Tennessee and Virginia Departments of Health, Tennessee Valley Authority, and EPA. The Task Force required Olin to conduct studies to identify the sources of mercury contamination at the Saltville facility, and negotiated cleanup measures to reduce mercury loading to the river.

Under a special order issued in 1982 by the Virginia State Water Control Board, Olin performed bank stabilization measures to reduce erosion of mercury-contaminated soil from the FCPS to the NFHR and dredged mercury-contaminated sediments from a 1000 foot section of the NFHR next to and downstream of the FCPS. The excavated sediments were placed in a lined cell on the foundation of a former building at the FCPS.· The dredged sediments were segregated by size. The fine fraction was sealed in the lined cell (a 36-millimeter hypalon "envelope") while the larger sediments were power-washed and placed near the lined cell. The sediments were then covered with approximately 2 feet of clay and 6 inches of topsoil. This project was supplemented by the construction of a diversion ditch around the western, upstream side of Pond 5 (referred to as the Western Diversion Ditch) to reduce surface water flow onto the pond. The diversion ditch project captured surface water flowing from four natural swales (i.e., swales numbered 2-5) leading from Little Mountain to the immediate north of the Site and re-routed the clean water to the ditch which conveyed the water to the NFHR by gravity flow. A fifth natural swale ("swale I") leading from Little Mountain to the eastern end of Pond 5 could not be diverted at the time due to subsurface stability in the area of concern.

A fish consumption restriction is still in place for the NFHR at this time. The Virginia Department of Health has issued the fish consumption restriction for the NFHR from Saltville to the Virginia/Tennessee border. Under this restriction, anglers may fish the NFHR for sport but are prohibited from taking fish for human consumption. The NFHR is currently the only body of water in Virginia with a fish consumption restriction.

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Remedial Overview and Basis for Taking Action

EPA proposed the Saltville Waste Disposal Ponds Site for inclusion on the National Priorities List (NPL) in December 1982, and placed the Site on the NPL on September 8, 1983 (48 Fed. Reg. 40658). In 1986, EPA completed an initial Risk Assessment and Feasibility Study (FS) for the Site based on existing data and available information provided by the Saltville Task Force and Olin. EPA did not perform a Remedial Investigation (RI) at the time because of the significant amount of available data and the ongoing investigations being conducted under the 1982 special order between Olin and the Virginia State Water Control Board.

The subject initial Risk Assessment was completed in 1986. While numerous data gaps were identified, the findings of the initial Risk Assessment indicated that certain initial measures should be undertaken to mitigate mercury releases at the Site. The first Record of Decision (ROD-I) for the Site was issued in 1987. ROD-l identified mercury as the contaminant concern at the Site and indicated that mercury can be transformed in the environment to methylmercury, which readily accumulates in biota. ROD-l selected an interim remedy to address an immediate threat while further studies were conducted to develop final cleanup plans. The interim remedy selected in ROD-l included 1) upgrading stormwater controls for Pond 5, 2) treatment ofwater at the Pond 5 outfall in a plant to be constructed onsite, 3) completion of additional groundwater investigations and monitoring and 4) continued sampling and investigation of the NFHR.

The second ROD (ROD-2), issued in 1995, selected a remedy with the following major components: 1) installation of a multilayered cap over Pond 5, 2) installation of a permeable soil cover over Pond 6, 3) construction of an interceptor system to minimize flow of upgradient groundwater (e.g, from Little Mountain) into Pond 5,4) treatment of groundwater collecting in a Pond 6 decant structure and 5) institutional controls for Pond 5 and Pond 6. The ROD-2 remedy also included upgrading the onsite wastewater treatment plant as needed to comply with effluent limits established to meet current Virginia surface water quality standards for mercury. Per ROD-2, the remedy selected in ROD-2 was based on the finding that waste materials in Pond 5 and Pond 6 posed an unacceptable risk to human health due to potential incidental ingestion and dermal contact. The RI which supported this finding did not include an assessment of risks posed by Pond 5 and Pond 6 to the ecological receptors or risks posed to human health by consumption of fish . which may bioaccumulate mercury released from Pond 5 and Pond 6. Risks posed to ecological receptors by Pond 5 and Pond 6 are currently being assessed under Operable Unit 4 (see below). The work required by ROD-2 has been identified as Operable Unit 3 (OU3).

Operable Unit 4 (OU4) includes the Former Chlorine Plant Site (FCPS) (including any groundwater impacted by the FCPS), Site-related mercury contamination in the NFHR and the Holsten River, and any other areas/media impacted by Site-related mercury, including the floodplains of the NFHR. The NFHR in this case includes 80 miles to the confluence with the Holston River. Site-related mercury extends an additional 70 miles within the Holston River to sediments of the Cherokee Reservoir in Tennessee, which is managed by the Tennessee Valley Authority. The RI/FS for OU-4 is still in progress at this time. The RI for OU-4 includes an assessment of risks posed by Site-related mercury to biological receptors in the NFHR and Holston River watersheds.

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IV. Remedial Action

ROD- I (OUI and OU2) Remedy Selection

On June 30, 1987, EPA issued a ROD selecting an interim remedy for the Site. The subject ROD identified mercury and methylmercury as contaminants ofconcern at the Site. Per the subject ROD, the interim remedy included the following major components:

• Upgrade run-on controls with ditches/berms/downchutes;

• Treat Waste Pond 5 outfall using either sulfide precipitation techniques or carbon adsorption;

• Additional studies;

• Installation of groundwater monitoring system at conclusion of studies;

• Operation and maintenance of treatment facility and continued sampling and analysis upgradient and downgradient of the NFHR.

ROD-I (OUI and OU2) Remedy Implementation

On September 15, 1988, EPA and Olin entered into a consent decree wherein Olin agreed to 1) perform the remedial design work and remedial action work necessary to implement the ROD-l remedy, 2) perform a Site-Wide Remedial Investigation/Feasibility Study and 3) pay the United States' past response costs associated with the Site. The surface water diversion component and the wastewater treatment plant component of the subject remedy were subsequently managed as separate projects and designated as Operable Unit One (OU-l) and OU-2, respectively.

The remedial design for OU-l was approved by EPA on May 17, 1991. Olin contractors mobilized in June, 1991 to begin OU-l remedial action work. Specific tasks included the capture of surface water runoff flowing through swale #1 ofLittle Mountain area north ofPond 5 and diverting the subject clean water around Pond 5 and Pond 6. The diversion of this runoff was designed to reduce the volume of leachate being generated at Pond 5. The major components of the remedial design and remedial action for OU-l included the following:

• High Density Polyethylene ("HDPE") liner and grout matting in collection basins upgradient of Pond 5;

• HDPE liner and grout matting in an open channel drainage ditch;

• Subsurface 42" HDPE pipe to convey clean water flowing from swale #1 across Pond 5; and

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• Discharge chute and stilling basin to control outfall to NFHR.

In addition to the above, engineered diversion ditches for swales 2,3,4 and 5 were upgraded. These diversion ditches were initially constructed in 1982 to convey clean water stonnwater from these swales to the western diversion ditch which discharges to the NFHR.

Construction and demobilization for OU-1 were completed on November 11, 1991. On September 22, 1992, an OU-1 Remedial Action Report was issued documenting the completion of the upgradient stonnwater run-on controls.

The remedial design for the OU-2 was approved by EPA on April 27, 1993, and remedial action work was initiated on October 11, 1993. Major components of the remedial design and remedial action for OU-2 included the following:

• A sump and pumping station to collect and convey groundwater contaminated with leachate from Pond 5 to a 2,000,000 gallon equalization basin;

• A membrane-lined, 2,000,000 gallon equalization basin; and

• A wastewater treatment plant which provides pH adjustment and carbon filtration for mercury reduction.

Discharge of treated effluent from the wastewater treatment plant to the NFHR was initiated on November 28,1994. On September 3, 1996, EPA approved an OU-2 Remedial Action Report documenting that construction of the remedy per design plans and specifications was complete.

ROD-2 (OU3) Remedy Selection

On September 29, 1995, EPA issued ROD-2 selecting a remedy for the Pond 5 area and for Pond 6. The subject ROD identified mercury and methylmercury as the Site-related contaminants which present an unacceptable risk to human health.

Per'ROD-2, the selected remedy for the Pond 5 area consisted of the following major components:

• Installation of a multi-layered cap over the entire Pond 5 area (approximately 76 acres);

• Groundwater interceptor system;

• Revision of the effluent discharge limit for the existing Pond 5 Treatment Facility to achieve the current Virginia surface water standard for mercury and any modification of the Pond 5 Treatment Facility necessary to achieve the revised discharge limit;

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• Implementation of institutional controls (prohibiting land use that may harm the integrity of the engineered cap and prohibiting installation of drinking water wells);

• Site security and maintenance programs;

• Long-term monitoring.

The selected remedy for Pond 6 consisted of the following components:

• A permeable soil'cover over the entire Pond 6 area ofapproximately 40 to 45 acres, including the demolition debris burial area;

• A pH adjustment system to neutralize the discharge from the Pond 6 decant structure;

• Institutional controls;

• Site security and maintenance programs and;

• Long-term monitoring.

The selected remedy for Pond 6 also included the following contingent remedial action if mercury contamination from the buried debris was demonstrated to be migrating toward the river through the groundwater in Pond 6:

• Isolation ofFormer Chlorine Plant Site demolition debris buried in the eastern end ofPond 6 by vertical barrier wall and multi-layered cap over the two to three acres where the debris is buried.

ROD-2 (OU3) Remedy Implementation

On July 29, 1997, Olin and EPA entered into a consent decree wherein Olin agreed to perform the remedial design work and remedial action work necessary to implement the ROD-2 remedy. The remedial design for the subj ect remedy was approved by EPA on March 27, 2001, and remedial action work was initiated on April 2, 2001. Major components of the remedial action, listed in approximate order of implementation, were as follows:

• Installation of additional Site security fence around Ponds 5 and 6;

• Construction of an 18-inch thick permeable soil cover over Pond 6 with slopes between one and four percent. The surface of the landfill was seeded with a diverse mix of grasses and grains to provide wildlife habitat as beneficial reuse;

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• Upgrades to Little Mountain swales 1-5 to intercept clean, shallow ground water and routing of the subject flow of clean water to rehabilitated western and eastern diversion ditches leading to NFHR;

• Closing of the Pond 6 outfall; modification of the Pond 6 decant structure as need to convey water from the structure to the treatment plant; installation of pumps to convey Pond 6 groundwater to the treatment plant; installation of a new section of force main tied in to existing Pond 5 force main.

• Construction of a multi-layered RCRA-Subtitle C compliant landfill cap over Pond 5 with a profile (from bottom up) of 1) 40-mil Linear Low Density Polyethylene ("LLDPE") geomembrane, 2) a geosynthetic clay liner (in areas of less than two percent slope and drainage swales), 3) a geocomposite drainage layer and 4) a 24-inch thick soil layer vegetated with diverse seed mix to provide wildlife habitat as beneficial reuse, and;

• Deed restrictions on Ponds 5 and 6 to prevent unsuitable development ofthe property and the installation of drinking water wells.

The remedy selected in ROD-2 was constructed per EPA-approved Remedial Design and Remedial Action Work Plans. On July 11,2003, a Remedial Action Report documenting the completion of the remedy selected in ROD-2 was approved by EPA. The treatment plant was designed to meet revised effluent limitations identified by VADEQ to achieve the VA chronic water quality standard of 12 ng/l mercury in the NFHR. These effluent limitations are still in affect at this time.

Institutional controls for Pond 5 and Pond 6 were implemented on March 27, 2007, when Olin filed a signed copy of the Environmental Protection Easement and Declaration of Restrictive Covenants ("Easement") executed between Olin and the Commonwealth of Virginia Department of Environmental Protection. The subject Easement "shall run with the land....prohibit[s] any type of activity that could disturb the surface or the underlying waste, as well as the use ofgroundwater from that area as a source ofpotable water, or in any way increase the risk of exposure to contaminants on the property...".

Operation and Maintenance (O&M)

ROD-I (OUI and OU2) Remedy

Per a Remedial Action Report for OU2 dated September 3, 1996, the Pond 5 treatment facility is to be operated and maintained per an Operation and Maintenance (O&M) Manual included in a Construction Complete As-Built Package dated April 21, 1995. The subject O&M Manual identifies procedures for operating and maintaining the following: 1) Pond 5 Effluent Pumping Station, 2) Equalization Basin, 3) System Feed Pumps, 4) pH Adjustment System, 5) Acid Feed System, 6) Filtration System, 7) Carbon Adsorption Unit, 8) Clearwell/Backwash Pumps, 9) Settling Tank and 1,0) Monitoring Stations.

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ROD-2 (OU3) Remedy

O&M activities for the ROD-2 (OU3) remedy are outlined in an O&M Plan included as Appendix M of a Final Remedial Design Report dated March 27, 2001.

Per the subject O&M Plan, primary O&M activities for the ROD-2 remedy include inspection and maintenance of 1) site security fencing, 2) access roads, 3) eastern and western diversion ditches, 4) Pond 5 and Pond 6 dikes, 5) monitoring wells, 6) swale interceptor system, and 7) the Pond 5 cap, the Pond 6 cover and associated surface drainage systems.

Inspections are to be conducted on a quarterly basis and repairs performed as needed based on the inspections. Settlement of the cap and grade reversals in drainage channels may cause localized depressions which result in ponding or saturation above the geomembrane. In this case, permanent settlement monuments are to surveyed on an annual basis to detect any settlement or grade reversal of concern. A mowing plan for Pond 5 prevents colonization of woody plants with tap roots capable of damaging the geomembrane while maintaining a wildlife habitat. Pond 6 has less stringent mowing requirements (i.e., there is no geomembrane to maintain) and supports a wildlife habitat. The acid storage tank and equalization basin at the treatment plant are to be inspected/monitored for leakage. Anannual O&M report is to be submitted to EPA documenting inspection results, any identified deficiencies and associated corrective measures.

Long-Term Monitoring

Long-term monitoring required by ROD-2 consists of monitoring of treatment plant effluent and monitoring of groundwater. These long-term monitoring activities are identified in a Long-Term Monitoring Plan (LTMP) and O&M Plan dated March 27, 2001 (see Appendix M ofthe OU3 Remedial Design, dated March 27,2001).

The subject LTMP indicates treatment plant effluent will be monitored for compliance with the Virginia State Water Control Law, Code of Virginia §§ 62.1-44.2 et seq., and the VPDES Regulations (VR 680-14-01). The LTMP further indicates that effluent will be monitored daily for total mercury and pH to confirm that these effluent limitations are being met and that effluent samples will be analyzed for total mercury using EPA Method SW-846 7470A. Current effluent limitations for the treatment plant were confirmed by VADEQ on November 22, 2000, and were designed to ensure that NFHR surface water met Virginia's chronic water quality standard of 0.012 ug/l of total mercury which was in effect at that time. However, the specific effluent limitations are not identified in the LTMP. The specific effluent limitations should be identified in the LTMP.

Per ROD-2, the objective ofthe long-term groundwater monitoring program is to evaluate subsurface flow conditions and water quality in the Pond 5 and Pond 6 areas and, more specifically, the seepage of contaminated groundwater migrating through the dikes to the river. In addition to quarterly sampling of wells in place at the time of the issuance ofROD-2, monitoring is to include quarterly sampling of any new wells approved by EPA during the remedial design. The long-term monitoring is to include wells downgradient of the demolition debris burial area within Pond 6 and quarterly sampling/analysis of groundwater collecting at the Pond 6 decant structure outfall for

11

mercury and pH. In 2010, based on review of historic sampling results, EPA subsequently approved semi-annual sampling for certain monitoring wells.

V. Previous Five Year Reviews and Progress Since the Last Five-Year Review

The five-year review of 2002 concluded that the interim remedy selected under ROD-l was protective of human health and the environment. The review further found that 1) the remedy selected under ROD-2 was protective in the short-term and 2) institutional controls should be implemented to restrict development of Ponds 5 and 6 and restrict installation of potable wells for the ROD-2 remedy to be protective over the long term.

The third five-year review for the Site was completed in September 2007. This review found that institutional controls had been implemented to prohibit disturbance of the implemented remedy, to prohibit ground water use in the vicinity ofPond 5 and 6 for potable purposes, and to prohibit any land use that would increase the risk of exposure to contaminants on property occupied by Pond 5 lli'1d Pond 6. These institutional controls consisted of an Environmental Protection Easement and Declaration ofRestrictive Covenant filed with Smyth and Washington Counties on March 27,2007. In this case, the remedy selected by ROD-2 was determined to be protective.

In addition to performance of O&M activities and long-term monitoring associated with remedies selected in ROD-l and ROD-2, progress since the last five year review in 2007 has included the completion of substantial additional Remedial Investigation (RI) work for Operable Unit 4, which includes the FCPS, the NFHR and the Holston River, floodplains associated with the NFHR and Holston River and biological receptors in the NFHR and Holston River watersheds.

.Part of this work is summarized in a draft Supplemental RI Report dated February 26, 2010, which provides investigation results for media which include surface water, ground water, sediment, floodplains and a wide range of biological receptors. In addition, the subject report includes an assessment of risks to human health and the ecological receptors based on the subject investigation results. The U.S. Fish and Wildlife Service is assisting in the scoping and review of the subject RI to help assess potential impacts on natural resources.

The third five-year review identified the following single recommendation - the OU4 RIfFS focusing on the FCPS and NFHR should be completed. The subject RIfFS is still in progress due to reasons discussed below. '

Further RI work addressing the FCPS and the NFHS has recently been initiated upon consideration ofa Mercury Total Maximum Daily Load (TMDL) Development Report for the NFHR C"NFHR Mercury TMDL Report ") issued by the Virginia Department of Environmental Quality in March 2011 (and approved by EPA in April 2011). The NFHR Mercury TMDL Report has been issued in accordance with Sections 303(d)(I)(c) and (2) of the Clean Water Act to address impairment of the NFHR due to elevated levels of mercury in fish tissue. This impairment is due to consistent exceedance of EPA's National Recommended Water Quality Criteria and Virginia's Water Quality Standard of 0.3 mg/kg methylmercury in NFHR fish tissue. The impaired river segment of concern extends from Saltville to the Virginia-Tennessee border. Using an NFHR-specific bioaccumulation factor (BAF), the NFHR Mercury TMDL Report found that the target surface water quality concentration or "site-specific endpoint" for restoring NFHR fish tissue

12

to Virginia's Water Quality Standard of 0.3 mg/kg methylmercury in fish tissue is 2 nanograms (ng) /liter of total mercury in NFHR surface water. The findings of the NFHR Mercury TMDL Report and the subject "site-specific endpoint" are being in considered in ongoing remedial investigations and will be considered in the selection of additional remedies at the Site. In addition, the subject findings should be considered in assessing the protectiveness of completed remedies at the Site.

Upon consideration of a preliminary NFHR Mercury TMDL Report, in December 2010, EPA requested that RI work for OU-4 include monthly sampling ofNFHR surface water at multiple locations between the FCPS and the downstream end of Pond 6. EPA further requested that the collected NFHR surface water samples be analyzed using EPA Method 1631E, which has a method quantitation limit of 0.5 ng/l total Hg. The subject sampling was initiated in March 2011. Additional investigations ofthe FCPS and the NFHR have since been initiated based on the results of the subject sampling. The Data Review section includes a discussion of the preliminary results of these investigations as needed to assess the protectiveness of remedies selected in ROD-l and ROD-2.

VI. Five-Year Review Process

Administrative Components

EPA notified the public ofthe initiation of this five year review in a notice appearing in the Bristol Herald Courier on August 31, 2012. The EPA Five-Year Review team included Darius Ostrauskas, Remedial Project Manager; Mindi Snoparsky, Hydrogeologist; Jeff Tuttle, Human Health Risk Assessor; Bruce Pluta, Biological Technical Assistance Group Leader; and David Polish, Community Involvement Coordinator. Tom Modena, Virginia Department of Environmental Quality, also assisted in the review. The five-year was conducted from June 2012 through September 2012.

Community Involvement

A Saltville Community Liaison Panel (SCLP) was established in 1996 and has been actively following the Superfund activities at the Site. The SCLP consists of 10 to 12 local residents representing a cross-section of the community. The SCLP is facilitated by a local community involvement firm retained by Olin. The meetings are attended by Olin and EPA representatives and, at times, topic-specific experts. The SCLP generally meets on a quarterly basis and the meeting agenda features various Site-related topics. SCLP are encouraged to communicate information discussed at SCLP meetings to friends, neighbors, and co-workers. During a recent quarterly meeting, the EPA RPM informed the SCLP that EPA planned to issue a Five-Year Review Report for the Site by September 2012 and explained the purpose of a Five-Year Review. The agenda for a SCLP meeting scheduled for October 25,2012, includes a presentation of the findings of this Five-Year Review by the EPA RPM.

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Document Review

The five-year review has included of a review of available and information relevant to the assessment ofthe protectiveness of selected remedies for the Site. These documents include, but are not limited to, O&M records, long-term monitoring data and the results of remedial investigation work conducted since the last FYR. Applicable or relevant and appropriate requirements ("ARARs") identified in ROD-l and ROD-2 were considered in this review.

The following documents have been considered in this five-year review:

• Interim Record of Decision-l (June 30, 1987)

• ROD-l Remedial Design/Remedial Action Consent Decree (entered September 15, 1988)

• OUI Milestone Report No.6 - Construction Certification and As-Built Drawings for Eastern Diversion Ditch (dated March 4, 1992)

• Operation and Maintenance Manual for Water Treatment Plant (April 21, 1995)

• OU2 Remedial Action Report for Water Treatment (approved September 3, 1996)

• Record of Decision-2 (September 29, 1995)

• ROD-2 Remedial Design/Remedial Action Consent Decree (entered July 29, 1997)

• Saltville Waste Disposal Ponds First Five-Year Review Report (September 1997)

• OU3 Remedial Design Report (approved March 27,2001)

• Focused Remedial Investigation for Former Chlorine Plant Site (March 2004)

• Monthly Progress Reports and Quarterly and Annual Monitoring Reports

• Saltville Waste Disposal Ponds Second Five-Year Review Report (September 2002)

• OU3 Remedial Action Report (approved July 11,2003)

• Environmental Protection Easement and Declaration of Restrictive Covenants (filed March 27,2007)

• OU3 Remedial Action Report (approved July 11,2003)

• Draft Supplemental RI Report dated February 26,2010

• NFHR Mercury TMDL Report (approved Apri1201l) 14

• Quarterly Data Reports (2007-2012)

• Annual Operations, Maintenance and Monitoring Reports (2007-2012)

Data Review

Remedial Investigation Work in Progress

The results of monthly sampling ofNFHR surface water quality requested by EPA in a letter dated December 2,2010, are being reported to EPA by Olin in Quarterly Data Reports (QDRs). The subject sampling includes the collection of composite and discrete surface water samples from a series of river transects from approximately NFHR River Mile (RM) 85 to RM 80. Figures 1-1 and 1-2 indicate the location of the samples and the NFHR RMs. The results for March 2011 through June 2012 are summarized in Table 1. Results for both composite and discrete surface water samples from the NFHR are included in the table as well as analytical results for discrete samples collected from Robertson Branch Creek, which discharges into the NFHR immediately downstream of the FCPS, which is located at approximately RM 82.7. Per Table 1, reported concentrations of total Hg in surface water at RM 85 upstream of the Site were 2 ng/l or less during this period, while concentrations downstream of the FCPS and next to Pond 5 and Pond 6 ranged from 6 ng/l to 36 ng/l total Hg. During the months of June, July and August of2011, concentrations downstream of the FCPS and next to Pond 5 and Pond 6 consistently ranged from 14 ng/l to 18 ng/l total Hg. Results for June 2012 are comparable to those for June 2011.

Based on the subject sampling results, the Virginia Water Quality Standard for methylmercury and the NFHR Mercury TMDL Report, releases of mercury from the FCPS, Pond 5 and/or Pond 6 may contributing to unacceptable levels of methylmercury in NFHR fish tissue. Further remedial investigations are in progress to determine the nature and extent of these releases and their source(s).

Operation and Maintenance

Reporting ofO&M activities between 2007 and 2012 for OU2 and OU3 is contained in Annual Operations, Maintenance and Monitoring Reports submitted during the subject period. The subject reporting indicates that site security fencing, access roads, the eastern and western diversion ditches, the swale interceptor system, the Pond 5 cap, the Pond 6 cover and associated surface drainage systems are all being inspected and repaired per the O&M Plan for OU3 dated March 27, 2001.

While the O&M Plan for OU3 indicates that the acid storage tank and equalization basin at the treatment plant will be inspected/monitored quarterly for leakage, O&M reporting for the subject period does not include the results of any such inspections/monitoring. Also, it is notable that the O&M Manual for OU2 and the O&M Plan for OU3 do not reference regulatory requirements which should be considered in the monitoring /inspection of the acid storage tank, the equalization basin or other components of the treatment plant. The O&M plan/manual for the treatment plant should be modified as needed to identify such regulatory requirements and include the activities necessary to

15

meet these requirements, including reporting activities. O&M reporting should then be consistent with the modified O&M Planes).

ROD-2 indicates that inspection and maintenance of the Pond 5 and Pond 6 dikes shall comply with Virginia Impoundment Structure Regulations (VR 625-01-00). These regulations have since been replaced by 4 VAC 50-20-10. While the current O&M Plan for OU3 indicates the dikes will be inspected quarterly and repaired as needed, there is no reference to ensuring compliance with VR 625-01-00. The O&M Plan for OU3 should be modified as needed to include inspections and repairs as necessary to ensure compliance with 4VAC 50-20-10.

Monitoring wells are being inspected as required. However, reporting ofthe inspection results indicates that certain wells are not being sampled per the frequency identified in the Long-Term Monitoring Plan because the wells are either obstructed/twisted (e.g., MW-11 OS, MW-11 OD, MWI05D, MW-I07, MW-I09S, MW-I04D) or dry (e.g., MW-II0S, MW-lllS, MW-105S, MW-5S,). Obstructed /twisted wells should repaired or replaced. Wells that are frequently dry should be evaluated to determine whether replacements for these wells are warranted.

The Annual Operations, Maintenance and Monitoring Reports continue to provide a summary ofthe days that the treatment plant was in operation and the volume ofwater treated and discharged to the NFHR during each day of operation. For example, Table 2.3 provides the subject data for 2008, 2009 and 2010. Per Table 2.3, the volume and frequency oftreatment/discharge was highly variable during these three years. Monitoring of the treatment plant effluent is discussed under Long-Term Monitoring below.

Long-Term Monitoring

The results of treatment plant effluent monitoring since the last five year review are contained in Quarterly Data Reports (QDRs) submitted by Olin to EPA. Per the QDRs, the effluent apparently is being monitored per the LTMP. However, in certain cases, the QDRs do not appear to report all of the analytical data of interest. For example, while the QDRs report that the treatment system discharged effluent to the NFHR on 61 days during the first quarter of 20 10, reporting oflaboratory QA/QC data is provided for only 14 of these days. Similarly, while QDRs report that the treatment system operated for 28 days during the first quarter of2011, laboratory QA/QC reporting is provided for only 10 of these days. Future QDRs should include all of the subject analytical data.

The LTMP of March 27,2001, indicates that effluent of the Pond 5 treatment plant will be monitored for compliance with Virginia State Water Control Law, Code of Virginia §§ 62.1-44.2 et seq., and the VPDES Regulations (VR 680-14-01). However, the LTMP does not identify the effluent limitations which have been developed pursuant to the subject law and regulations. In this case, it is recommended that the LTMP be updated to indicate the subject effluent limitations.

Long-term groundwater monitoring results for Pond 5 and Pond 6 indicate that oniy several wells have exceeded a concentration of 3 ug/l total mercury since the last five year review. The maximum reported levels of total mercury during this period have been detected in monitoring well MW-I04S (70ug/I), MW-I05S (78ug/l), and MW-I05D (65ug/I). Concentrations oftotal mercury in these wells fluctuated substantially during this period and were generally significantly lower than

16

these reported maximum concentrations. Monitoring wells MW-I04S, MW-I05S and MW-I05D are intended to monitor potential migration of mercury from the debris disposal area in Pond 6. Reported concentrations of total mercury in all other wells being monitored at Pond 5 and Pond 6 since the last five year review were less 3ug/I.

As discussed above, remedial investigation results for NFHR surface water since March 20 II suggest that Pond 5 and/or Pond 6 may still be contributing to elevated levels ofmercury in the NFHR and NFHR fish tissue. Additional investigations are in progress to determine the source of the mercury releases of concern. While elevated mercury has periodically been detected in wells monitoring mercury migration from the debris disposal area in Pond 6, the subject sUrface water data indicates that mercury levels of concern are being initially detected in the NFHR in the vicinity of Pond 5, i.e., upstream of the Pond 6 debris disposal area. Monitoring results for the existing long-term monitoring well network for Pond 5 provide no indication that Pond 5 may be source of mercury levels of concern in the NFHR. If ongoing remedial investigations confirm that leakage of groundwater through or under the dikes of Pond 5 and/or Pond 6 is likely contributing to mercury levels of concern in the NFHR, the long-term groundwater monitoring plan for Pond 5 and Pond 6 should be reassessed and modified as needed. This assessment should consider whether I) the existing Pond 5/Pond 6 well network provides data which is fully representative of the quality of groundwater leaking through or under the Pond 5 and Pond 6 dikes and 2) provides adequate data to estimate the rate of mercury loading from Pond 5 and Pond 6 to the NFHR via groundwater discharge.

While the ROD-2 remedy requires that the contaminated groundwater being collected at the Pond 6 decant structure/outfall be sampled and analyzed for mercury and pH quarterly, based on a review of the quarterly data reports and annual reporting, it is unclear whether this sampling is being performed and/or what the results of this monitoring are. In addition to monitoring groundwater in the Pond 6 decant structure, groundwater in the Pond 5 decant structure should also be sampled on a quarterly basis for mercury and pH.

As previously noted, a private well is reportedly still in place at a dry ice facility to the immediate northwest of the FCPS. This facility is connected to a municipal water system and reportedly uses water from this system for potable purposes. However, the nature and extent of any current use of the groundwater from the private well is unclear. This use should be identified to confirm that such use does not present a concern.

Site Inspection

As part of the subject five-year process, a site visit was conducted by the EPA RPM on August 27 and August 28, 2012. During this visit, the RPM met with Olin and VADEQ representatives to discuss and observe ongoing RI work for OU-4. Due to the extent and complexity of ongoing O&M activities at the Site, inspection of all components of O&M at the Site was not possible during this site visit. However, observations during the site visit were consistent with reporting in the most recent Annual Operations and Maintenance Report (dated July 31, 2012).

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Interviews

As the EPA RPM meets with members of the community on a periodic basis through meetings of the Saltville Community Liaison Panel (SCLP), interviews were not deemed to be a necessary element of this Five Year Review. However, on August 28,2012, the EPA RPM did meet with Mr. Gregg Harris, a current member ofthe SCLP, and discussed Mr. Harris' observations of current fishing use of the NFHR. The EPA RPM also discussed the ongoing five-year review process with Mr. Harris.

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VII. Technical Assessment

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

Yes. The review of site-related documents and available information indicates that the ROD-l and ROD~2 remedies are functioning as intended. The primary components of the interim remedy selected in ROD-l were upgrading controls for stormwater runoff and treating contaminated groundwater collecting in the Pond 5 decant structure/outfall in an onsite treatment plant. These remedy components are in place and functioning as intended by ROD-I. Primary components ofthe ROD-2 remedy were 1) installation of a cap over Pond 5 and a cover over Pond 6 to eliminate potential direct contact with waste materials, 2) collection and treatment of contaminated groundwater collecting in the Pond 6 decant structure/outfall and 3) institutional controls. These remedy components are also in place and functioning as intended by ROD -2. In addition, groundwater monitoring to assess the potential for leakage of groundwater through or under the dikes is generally being conducted per the current long-term monitoring plan. In this case, site remedies are functioning as intended by ROD-l and ROD-2.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives ("RAOs") used at the time of the remedy selection still valid?

Changes in Standards and To Be Considered ("TBCs'~

As noted in Section V., in April of2011, EPA approved a Mercury Total Maximum Daily Load (TMDL) Development Report for the NFHR ("NFHR Mercury TMDL Report") prepared by the Virginia Department of Environmental Quality. The NFHR Mercury TMDL Report was issued in accordance with Sections 303(d)(l)(c) and (2) of the Clean Water Act to address impairment ofthe NFHR due to elevated mercury levels in fish tissue. This impairment is due to consistent exceedance of EPA's National Recommended Water Quality Criteria and Virginia's Water Quality Standard of 0.3 mg/kg methylmercury in fish tissue. Using an NFHR-specific bioaccumulation factor (BAF) which relates NFHR fish tissue concentrations to NFHR surface water quality, the NFHR Mercury TMDL Report has established 2 nanograms/liter (ng/l) total mercury as the "site-specific endpoint" or target surface water quality concentration for restoring NFHR fish tissue to Virginia's Water Quality Standard of 0.3 mg/kg methylmercury. The site-specific endpoint of2 ng/l total mercury in surface water established by the NFHR Mercury TMDL Report should also be considered in assessing the protectiveness of completed remedies at the Site.

The current effluent limitations for the onsite treatment plant for groundwater contaminated by leachate from Pond 5 and Pond 6 were developed in 2000 and designed to be protective of Virginia's Water Quality Standard of 0.012 ug/l or 12 ng/l total mercury which was in place at that time. Since then, Virginia has promulgated a Water Quality Standard of 0.3 methylmercury in fish tissue and issued the NFHR Mercury TMDL Report which has established 2 ng/l total mercury as the site-specific endpoint or target surface water concentration for achieving this standard. In this case, it is recommended that the current effluent limitations for the treatment plant be evaluated to confirm that these limitations are protective of the Virginia Water Quality Standard of 0.3 mg/kg methylmercury in NFHR fish tissue and the established site-specific end-point of2 ng/l total mercury in NFHR surface water.

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Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics

The risk assessment conducted to support ROD-2 found that the exposure pathways of concern consisted of human exposure to contaminated waste in Pond 5 and Pond 6 by dermal contact and incidental ingestion. OU-4 RI work conducted since the last five year review has detected mercury concentrations in the NFHR surface water downstream of the FCPS and next to Pond 5 and Pond 6 which are indicative of an exceedance of the Virginia Water Quality Standard of 0.3 mg/kg methylmercury in fish tissue. Available information suggests that the Hg levels ofconcern in NFHR fish tissue may be at least partly attributable to groundwater contaminated by Pond 5 and/or Pond 6 waste materials which is bypassing the Pond 5 and/or Pond 6 decant structures and discharging into the NFHR without treatment. In the event that additional RI work confirms that Pond 5 or Pond 6 are a substantial source of the recently detected levels ofmercury in surface water, human exposure to contaminated fish should be considered an additional exposure pathway of concern for Pond 5 and Pond 6.

There have been no changes in the toxicity factors for mercury/methylmercury, the contaminants of concern, since the completion of risk assessments supporting ROD-l a.'1d ROD-2.

Remedial Action Objectives

While the current remedial action objectives for selected remedies remain valid, these remedial action objectives may need to be modified based on the recently issued NFHR Mercury TMDL Report.

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 calls into question the protectiveness of the remedy.

Technical Assessment Summary

The remedies selected in ROD-l and ROD-2 are functioning as intended by these decision documents.

The Virginia Department of Health has issued a fish consumption restriction for the NFHR from Saltville to the Virginia/Tennessee border. Under this restriction, anglers may fish the NFHR for sport but are prohibited from taking fish for human consumption. (This is currently the only body of water in Virginia with a fish consumption restriction.) Based on this restriction, conditions at the Site are considered to be protective of human health.

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VIII. Issues

Table 2 summarizes the current site issues.

Table 2: Issues

I.s ue Affects Current Protectiveness?

(Yes Qt:No)

Affects Future Protectiveness?

(Yes or No) Long-term monitoring plan for Pond 5 and/or Pond 6 groundwater may need to be modified depending on results of ongoing RI.

No Yes

Certain wells included in long-term monitoring plan for the ROD-2 remedy are damaged and cannot be sampled per the current plan.

No Yes

Unclear whether current effluent limitations for mercury for onsite treatment plant are consistent with VA Water Quality Standard for methylmercury and NFHR Mercury' TMDL Report. In addition, the treatment plant effluent limitations are not identified in the long-term monitoring plan.

No Yes

Unclear whether the dikes for Pond 5 and Pond 6 are in compliance with VA Impoundment Regulations.

No Yes

Quarterly sampling results for Pond 6 decant structure are not being provided in reporting of long-term monitoring. Pond 5 decant structure is not being monitored.

No Yes

O&M plans for onsite treatment plant do not reference regulatory requirements to be considered in O&M of the plant or include the inspection, monitoring and reporting activities necessary to meet these requirements.

No Yes

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IX. Issues and Recommendations/ Follow-Up Actions

Table 3 provides recommendations to address the current site issues.

Table 3: Recommendations and Follow-up Actions

[ssue Rec'ommendations I Follow-Up Actionos

Party Resp'onsible

o.versjght A~eocy

MiJcstone Date

Affects Protectiveness? (Yes

or No) Current Future

Long-term monitoring plan for Pond 5 and/or Pond 6 groundwater may need to be modified depending on results of ongoing RI.

Modify long-term monitoring plan for Pond 5 and/or Pond 6 groundwater as needed based on results of ongoing RI.

PRP EPA 3/3 I /13 No Yes

Certain wells included in current long-term monitoring plan are damaged and cannot be sampled per the current plan.

Repair or replace damaged wells included in current long-term monitoring plan as needed.

PRP EPA . 9/30/13 No

No

Yes

Yes

Unclear whether current effluent limitations for mercury for onsite treatment plant are consistent with VA Water Quality Standard for methylmercury and NFHR Mercury TMDL Report. In addition, the onsite treatment plant effluent limitations are not identified in the long-term monitoring plan.

Confirm that current effluent limitations are consistent with VA Water Quality Standard for methylmercury and NFHR Mercury TMDL Report (or modify as needed) once the contribution of different sources of mercury in the NFHR are determined by ongoing investigations. Include effluent limitations in long-term monitoring plan.

PRP EPA TBD

Unclear whether the dikes for Pond 5 and Pond 6 are'in compliance with VA Impoundment Regulations.

Modify operation and maintenance plan as needed to ensure that Pond 5 and Pond 6 dikes are in compliance with VA Impoundment Regulations.

PRP EPA 12/30/12 No Yes

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Affects

Issue Recommendations / Follow-Up Action

Party Responsible

Oversigbt Ag.ency

Milestone Date

Protectiveness? (Yes or No)

Current Fu'ture Quarterly sampling Include results of results for Pond 6 quarterly Pond 6 decant decant structure are structure sampling in not being provided in reporting of long-term reporting of monitoring. Add PRP EPA 3/31/13 No Yes long-term quarterly sampling of monitoring. Pond 5 Pond 5 decant structure decant structure is not to long-term being monitored. monitoring. O&M plans for onsite treatment plant do not reference regulatory requirements to be considered in O&M of the plant or include the inspection, monitoring and reporting activities necessary to meet these requirements.

Modify O&M planes) for onsite treatment plant as needed to reference regulatory requirements and include the inspection, monitoring and repOiting activities necessary to meet these requirements.

PRP EPA 6/30/13 No Yes

x. Protectiveness Statement

The remedy selected in ROD-l (OUI and OU2) was an interim remedial action selected to remediate an immediate threat while further studies were conducted to develop a final remedy. The subject interim remedy has been implemented and is functioning as intended by ROD-I.

The remedy selected in ROD-2 (OU3) was intended to mitigate a threat posed to human health by dermal contact and incidental ingestion of waste within Pond 5 and Pond 6. In addition, the ROD-2 remedy included treatment of contaminated groundwater collecting at the outfall of Pond 6, groundwater monitoring and institutional controls. The remedy selected in ROD-2 is in place and functioning as intended.

Combined with a fish consumption restriction placed on the NFHR by the Virginia Department of Health, the remedies selected in ROD-l and ROD-2 are protective of human health.

XI. Next Review

The next five-year review for the Saltville Waste Disposal Ponds Superfund Site will be September 2017, five years from the date of this review.

23

.- •t-=.

''~

'

f Legend:

- DIVERSION DITCH LOCATION ..... APPROX1l.'.ATE LOCATI '

SUPPLEMENTAL REMEDNORTH FORK HOLSTO:ii~TlGATION REPORT- OPERABLE UNll' 4

OLIN SALTVILLE ·SITE'

es AGUR211-1

North Fork Holston River

RM 81.60 - RM 82.93

Historic Monthly Sampling Locations

Figure: 1-1ame&

RM 80.08 ·RM 81.60

Historic Monthly Sampling Locations

Figure: 1-2

TABLE 1 Summary of Surface Water Sample Results for the NFHR and

Robertson Branch Creek - March 2011 to June 2012

Analyte Name: Mercury Units: (ng/L)

Flow Location 10 Sample 10 (cfs) Sample Type

May 7.2012 NFHR - RM 80.08 NFHR - RM 80.82 NFHR - RM 81.45 NFHR - RM 81.62 NFHR- RM 81.74 NFHR - RM 82,67 NFHR - RM 82.68

. NFHR - RM 82.71 NFHR - RM 82,84 NFHR - RM 84.88 RBC-1 RBC-2 RBC-2.5 WWTP1 WWTP2

June 11, 2012 NFHR - RM 80.08 NFHR - RM 80.82 NFHR - RM 81.45 NFHR - RM 81,62 NFHR - RM 81.74 NFHR - RM 82.67 NFHR - RM 82.68 NFHR - RM 82,71 NFHR - RM 82.84 NFHR - RM 84.88 RBC-1 RBC-2 RBC-2.5 WWTP1 WWTP2

WS 80.00-0512 A&B WS 80.80-0512 A&B WS 81.50-0512 A&B WS 81.70-0512 A&B WS 81.80-0512 A&B WS 82.40-0512 A&B WS 82.50-0512 A&B WS 82.75-0512 A&B WS 82.85-0512 A&B WS 85.00-0512 A&B

WS RB1-0512 WS RB2-0512

WS RB2.5-0512 WWPT1-0512 WWPT2-0512

WS 80.00-0612 A&B WS 80.80-0612 A&B WS 81.50-0612 A&B WS 81.70-0612 A&B WS 81.80-0612 A&B WS 82.40-0612 A&B WS 82.50-0612 A&B WS 82.75-0612 A&B WS 82.85-0612 A&B WS 85,00-0612 A&B

WS RB1-0612 WS RB2-0612

WS RB2.5-0612 WWTP 1-0612 WWTP 2-0612

218

87

Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample

Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample

7.4 7.9 8.7

11.0 JH 7.6 2.0 2.3 1.7 1.6 1.3 9.1 7.3 2.3 5.5 7.1

15.7 J 11.7 13,2 14.2 16.1 3,3 4.0 3.0 2.7 1.8

17.7 17.2 1.2 8.8 7.0

Notes: cfs =cubic feet per second Ptepared by: RMB 07/13/12

nglL = nanograms per liter Checked by: CLC 07/16/12

Data Flag Definitions: J = Detected, estimated based on QC criteria JH :: Detected, estimated biased high based on QC criteria JQ =Detected, reported between the Method Detection

Limit (MOL) and the Reporting Limit (RL) < = Less than the Reporting Limit

Page 6 of 6




Flow location 10 Sample 10 (cfs) Sample Type

NFHR - RM 82.68 NFHR-SW-RM 82.50 A&B Sample 5.0 NFHR - RM 82.71 NFHR-SW-RM 82.75 A&B Sample 1.3 NFHR - RM 82.84 NFHR-SW-RM 82.85 A&B Sample 1.2 NFHR - RM 84.88 NFHR-SW-RM 85.00 A&B Sample 1.0 RBC-1 RB1-SW-0.10 Sample 3.9 RBC-2 R82-SW-0.20 Sample 3.8 RBC-2.5 RB3-SW-0.25 Sample 1.2

January 10, 2012 175 NFHR - RM 80.08 WS 80.00-0112 A&8 Sample 3.8 NFHR - RM 80.82 WS 80.80-0112 A&8 Sample 3.7 NFHR - RM 81.45 WS 81.50-0112 A&B Sample 3.6 NFHR - RM 81.62 WS 81.70-0112 A&B Sample 3.9 NFHR - RM 81.74 WS 81.80-0112A&B Sample 3.7 NFHR - RM 82.67 WS 82.40-0112 A&B Samp'le 1.2 NFHR - RM 82.68 WS 82.50-0112 A&B Sample 1.4 NFHR - RM 82.71 WS 82.75-0112 A&B Sample 1.1 NFHR - RM 82.84 WS 82.85-0112 A&B Sample 0.963 JQ NFHR - RM 84.88 WS 85.00-0112 A&B Sample 0.851 JQ RBC-1 WS RB1-0112 Sample 3.1 RBC-2 WS RB2-0112 Sample 3.3 RBC-2.5 WS RB2.5-0112 Sample 0.894 JQ WWTP1 WWPT1-0112 Sample 4.9 WWTP2 WWPT2-0112 Sample 6.1

April 2. 2012 463 NFHR - RM 80.08 WS 80.00-0412 A&B Sample 13.6 NFHR - RM 80.82 WS 80.80-0412 A&B Sample 8,9 NFHR - RM 81.45 WS 81.50-0412 A&B Sample 8.2 NFHR - RM 81.62 WS 81.70-0412 A&B Sample 9.5 NFHR - RM 81.74 WS 81.80-0412 A&B Sample 7.6 NFHR - RM 82.67 WS 82.40-0412 A&B Sample 3.1 NFHR - RM 82.68 WS 82.50-0412 A&B Sample 2.9 NFHR - RM 82.71 WS 82.75-0412 A&B Sample 2.4 NFHR - RM 82.84 WS 82.85-0412 A&B Sample 2.0 NFHR - RM 84.88 WS 85.00-0412 A&B Sample 1.7 RBC-1 WS RB1-0412 Sample 7.4 RBC-2 WS RB2-0412 Sample 8.1 RBC-2.5 WS RB2.5-0412 Sample 4.1 WWTP1 WWTP1-0412 Sample 3.7 WWTP2 WWTP2-0412 Sample 5.5

Page 5 of 6

TABLE 1 Summary of Surface Water Sample Results tor the NFHR and



Flow Location ID Sample ID (cts) Sample Type

November 8, 2011 77 NFHR - RM 80.08 NFHR-SW-RM 80.08-1111 A&B Sample 4.1 J NFHR - RM 80.08 NFHR-SW-DUP-1111 Duplicate 4.2 J NFHR - RM 80.82 NFHR-SW-RM 80.82-1111 A&B Sample 4.7 J NFHR - RM 81.45 NFHR-SW-RM 81.45-1111 A&B Sample 6.0 J NFHR - RM 81.62C NFHR-SW-RM 81.62 C-1111 Sample 3.8 J NFHR - RM 81.62RC NFHR-SW-RM 81.62 RC-l111 Sample 3.6 J NFHR - RM 81.70 NFHR-SW-RM 81.70-1111 Sample 3.8 J NFHR - RM 81.74C NFHR-SW-RM 81.74 C-1111 Sample 3.9 J NFHR - RM 81.74RC NFHR-SW-RM 81.74 RC-1111 Sample 4.1 J NFHR - RM 81.80 NFHR-SW-RM 81.80-1111 Sample 3.8 J NFHR - RM 81.88A NFHR-SW-RM 81.88-1111 Sample 4.0 J NFHR - RM 81.95 NFHR-SW-RM 81.95-1111 Sample 3.9 J NFHR - RM 82.10A NFHR-SW-RM 82.10-1111 Sample 4.8 J NFHR - RM 82.21 NFHR-SW-RM 82.21-1111 Sample 10.7 J NFHR - RM 82.26A NFHR-SP-RM 82.26-1111 Sample 47.6

NFHR - RM 82.26A NFHR-SW-RM 82.26-1111 Sample 4.3 J NFHR - RM 82.30A NFHR-SW-RM 82.30-1111 Sample 4.3 J NFHR - RM 82.42A NFHR-SW-RM 82.42-1111 Sample 3.6 J NFHR - RM 82.58 NFHR-SW-RM 82.58-1111 Sample 1.9 J NFHR - RM 82.67RC NFHR-SW-RM 82.67 RC-1111 Sample 2.3 J NFHR - RM 82.67SE NFHR-SW-RM 82.67 SE-1111 Sample 1.5 J NFHR - RM 82,69RC NFHR-SW-RM 82.69 RC-1111 Sample 1.7 J NFHR - RM 82.69SE NFHR-SW-RM 82.69 SE-1111 Sample 1.6 J NFHR - RM 82.71 RC NFHR-SW-RM 82.71 RC-1111 Sample 1.7 J NFHR - RM 82.71SE NFHR-SW-RM 82.71 SE-1111 Sample 1,1 J NFHR - RM 82.75 NFHR-SW-RM 82.75-1111 Sample 2.8 J NFHR - RM 82.78 NFHR-SW-RM 82.78-1111 Sample 1.7 J NFHR - RM 82,84A NFHR-SW-RM 82.84 A-1111 Sample 0.807 JQ

NFHR - RM 82.84B NFHR-SW-RM 82.84 B-1111 Sample 0.660 JQ

NFHR - RM 84.88A NFHR-SW-RM 84.88-1111 A&B Sample 0.790 JQ NFHR - WWTP NFHR-SW-WWTP-1111 Sample 15.7

RBC-1 NFHR-SW-RB 1-1111 Sample 7.0 J RBC-2 NFHR-SW-RB 2-1111 Sample 5.4 J RBC-2.5 NFHR-SW-RB 2.5-1111 Sample 1.1 J RBC-2.5 NFHR-SW-RB DUP-1111 Duplicate 0.869 JQ

December 13, 2011 293 NFHR - RM 80.08 NFHR-SW-RM 80.00 A&B Sample 3.1

NFHR - RM 80.82 NFHR-SW-RM 80.80 A&B Sample 2,8

NFHR - RM 81.45 NFHR-SW-RM 81.50 A&B Sample 4.4




Pa,ge 4 of 6


Robertson Branch Creek· March 2011 to June 2012

Analyte Name: Mercury Units: (ng/LI

Flow Location 10 Sample 10 (cfs) Sample Type

NFHR - RM 82.30 WS 82.2-0811 A&B Sample 8.5 NFHR - RM 82.42 WS 82.3-0811 A&B Sample 4.5 NFHR - RM 82.67 WS 82.4-0811 A&B Sample 5.6 NFHR - RM 82.71 WS 82.75-0811 A&B Sample 23.3 NFHR - RM 82.84 WS 82.85-0811 A&B Sample 5.0 NFHR - RM 84.88 WS 85.0-0811 A&B Sample 1.3 NFHR - RM 82.69 WS 82.65-0811 A&B Sample 5.5 RBC-1 WS RB1-0811 A&B Sample 13.9 RBC-2 WS RB2-0811 A&B Sample 11.2 RBC-2.5 WS RB2.5-0811 A&B Sample 2.7 RBC-3 WS RB3-0811 A&B Sample 5.3

September 20. 2011 34 NFHR • RM 80.08 WS 80.00-0911 A&B Sample 8.1 NFHR - RM 80.82 WS 80.80-0911 MB Sample 8.5 NFHR - RM 81.45 WS 81.50-0911 A&B Sample 7.9 NFHR - RM 81.62 WS 81.70-0911 A&B Sample 9.5 NFHR - RM 8'1.74 WS 81.80-0911 A&B Sample 11.2 NFHR - RM 82.67 WS 82.40-0911 A&B Sample < 1.0 NFHR - RM 82.68 WS 82.50-0911 A&B Sample < 1.0 NFHR - RM 82.71 WS 82.75-0911 A&B Sample < 1.0 NFHR - RM 82.84 WS 82.85-0911 A&B Sample < 1.0 NFHR - RM 84.88 WS 85.00-0911 A&B Sample < 1.0 RBC-1 WS RB1-0911 A&B Sample 11.6 RBC-2 WS RB2-0911 A&B Sample 10.5 RBC-2.5 WS RB2.5-0911 A&B Sample < 1.0 Town Discharge WS-TO 82.80-0911 A&B Sample < 1.0

·October 17. 2011 63 NFHR - RM 80.08 WS 80.00 - 1011 MB Sample 5.5 J NFHR - RM 80.82 WS 80.80 - 1011 A&B Sample 3.6 J NFHR - RM 81.45 WS 81.50 - 1011 A&B Sample 3.1 J NFHR - RM 81.62 WS 81.70-1011 A&B Sample 3.1 J NFHR - RM 81.74 WS 81.80 -1011 A&B Sample 4.5 J NFHR - RM 81.88 WS 81.95 - 1011 A&B Sample 6.6 J NFHR - RM 82.25 WS 82.25 - 1011 Sample 35.4 J NFHR - RM 82.26 WS 82.26 - 1011 Sample 5.8 J NFHR - RM 82.67 WS 82.40-1011 A&B Sample 1.7 J NFHR - RM 82.68 WS 82.50 - 1011 A&B Sample 1.1 J NFHR - RM 82.71 WS 82.75 - 1011 A&B Sample 0.868 JQ NFHR - RM 82.84 WS 82.85 - 1011 A&B Sample 0.801 JQ NFHR - RM 84.88 WS 85.00 - 1011 A&B Sample < 1.0 UJ RBC-1 WS RB1 -1011 A&B Sample 6.7 J RBC-2 WS RB2 - 1011 A&B Sample 5.5 J RBC-2.5 WS RB2.5 - 1011 A&B Sample 0.946 JQ

Page 3 of 6

TABLE 1 Summary ot Surface Water Sample Results tor the NFHR and


Analyte Name: Mercury Units: (ng/l)

Flow location 10 Sample 10 (cts) Sample Type

June 14. 2011 100 NFHR - RM 80.08 WS 80.0-0611 A&B Sample 14.3 NFHR - RM 80.82 WS 80.8-0611 A&B Sample 12.1 NFHR - RM 81.45 WS 81.5-0611 A&B Sample 15.4 NFHR - RM 81.62 WS 81.7-0611 A&B Sample 13.7 NFHR - RM 81.74 WS 81.8-0611 A&B Sample 13.7 NFHR - RM 82.67 WS 82.4-0611 A&B Sample 4.6 NFHR - RM 82.68 WS 82.5-0611 A&B Sample 3.9 NFHR - RM 82.68 WS 82.5-0611 DUP Duplicate 3.8 NFHR - RM 82.71 WS 82.75-0611 A&B Sample 3.6 NFHR - RM 82.84 WS 82.85-0611 A&B Sample 3.7 NFHR - RM 84.88 WS 85.0-0611 A&B Sample 1.6 NFHR - RM 80.08 WS 80.0-0711 A&B Sample 15.7 RBC-1 WS RB1-0611 A&B Sample 15.4 RBC-2 WS RB2-0611 A&B Sample 11.5 RBC-3 WS RB3-0611 A&8 Sample 2.3

July 26. 2011 108 NFHR - RM 80.82 WS 80.8-0711 A&B Sample 18.0 NFHR - RM 81.45 WS 81.5-0711 A&8 Sample 14.4 NFHR - RM 81.62 WS 81.7-0711 A&B Sample 19.7

NFHR - RM 81.74 WS 81.8-0711 A&8 Sample 17.0 NFHR - RM 82.67 WS 82.4-0711 A&B Sample 5.6

NFHR - RM 82.69 WS 82.65-0711 A&B Sample 5.9 NFHR - RM 82.71 WS 82.75-0711 A&B Sample 9.9

NFHR - RM 82.84 WS 82.85-0711 A&B Sample 5.7

NFHR - RM 82.84 WS 82.85-0711 A&B DUP Duplicate 5.0 NFHR - RM 84,88 WS 85.0-0711 A&B Sample 1,7

NFHR - RM 82.1 WS 82.1-0711 A&B Sample 14.7 RBC-1 WS RB1-0711 A&B Sample 5.7 RBC-2 WS RB2-0711 A&B Sample 7.3

RBC-2.5 WS RB2.5-0711 A&B Sample 2.5

RBC-3 WS RR3-0711 A&B Sample 1.8

August 11. 2011 45 NFHR - RM 80.08 WS 80,0-0811 A&B Sample 18.3 NFHR - RM 80.82 WS 80.8-0811 A&B Sample 17.4



NFHR - RM 81.62 WS 81,7-0811 A&B Sample 17.3



Page 2 of6

TABLE 1 Summary of Surface Water Sample Results for the IIlFHR and

Robertson Branch Creek· March 2011 to June 2012


Flow Location Ie Sample 10 (cfs) Sample Type

March 29, 2011 452 NFHR - RM 80.08 WS 80.0-0311 Sample 5.0 NFHR - RM 80.82 WS 80.8-0311 Sample 5.2 NFHR - RM 81.45 WS 81.5-0311 Sample 5.5 NFHR - RM 81.62 WS 81.7-0311 Sample 5.6 NFHR - RM 81.74 WS 81.8-0311 Sample 5.2 NFHR - RM 82.68 WS 82.5-0311 Sample 2.8 NFHR - RM 82.71 WS 82.75-0311 Sample 2.0 NFHR - RM 82.84 WS 82.85-0311 Sample 2.0 NFHR - RM 84.88 WS 85.0-0311 Sample 1.5 RBC-1 ROBERTSON BRANCH #1-0311 Sample 1.2 RBC-2 ROBERTSON BRANCH #2-0311 Sample 3.4 RBC-3 ROBERTSON BRANCH #3-0311 Sample 1.4

April 26, 2011 224 NFHR - RM 80.08 WS 80.0-0411 Sample 5.9 NFHR - RM 80.82 WS 80.8-0411 Sample 5.3 NFHR - RM 81.45 WS 81.5-0411 Sample 6.6 NFHR - RM 81.62 WS 81.7-0411 Sample 7.7 NFHR- RM 81.74 WS81.8-0411 Sample 6.7 NFHR - RM 82.67 WS 82.4-0411 Sample 2.0 NFHR - RM 82.68 WS 82,5-0411 Sample 2.2 NFHR - RM 82.71 WS 82.75-0411 Sample 1.7 NFHR - RM 82.84 WS 82.85-0411 Sample 1.3 NFHR - RM 84.88 WS 85.0-0411 Sample 0.890 JQ RBC-1 WS RB1-0411 Sample 3.6 RBC-2 WS RB2-0411 Sample 3.8 RBC-3 WS RB3-0411 Sample 1.0

May 31, 2011 129 NFHR - RM 80.08 WS 80.0-0511 Sample 10.2 NFHR - RM 80.82 WS 80.8-0511 Sample 10.0 NFHR - RM 81.45 WS 81.5-0511 Sample 10.9 NFHR - RM 81.62 WS 81.7-0511 Sample 9.3 NFHR - RM 81.74 WS 81.8-0511 Sample 12.5 NFHR - RM 82.67 WS 82.4-0511 Sample 4.1 NFHR - RM 82.68 WS 82.5-0511 Sample 3.4 NFHR - RM 82.71 WS 82.75-0511 Sample 3.4 NFHR - RM 82.84 WS 82,85-0511 Sample 2.1 NFHR - RM 84.88 WS 85.0-0511 Sample 1.2 RBC-1 WS RB1-0511 Sample 9.3 RBC-2 WS RB2-0511 Sample 9.0 RBC-3 WS RB3-0511 Sample 2.2

Page 1 of6

Table 2.3 POND 5 TREATMENT PLANT

TREATED WATER MONITORING PROGRAM SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA

Pond 5 Treatment Plant Discharge

Date Sampled Volume Treated

(gal) pH

Total Dissolved Solids (mglL)

Chlorides (mglL)

Mercury (ppb)

1/5/2010 130,771 7.0 5.000 1.990 0.20 U 1/6/2010 168,671 6,3 5.100 2,000 0.20 U 1/7/2010 69379 6.8 4.800 2,030 0.20 U 1/8/2010 111.279 7,0 4,900 1,960 0,20 U 1/9/2010 147,201 6.9 5,100 1,920 0,20 U

1/10/2010 98.245 7.0 5,100 1.970 0.20 U 1/11/2010 161.925 7.1 5.100 1,980 0.20 U 1/12/2010 83,525 6,7 5,000 1,990 0.20 U 1/13/2010 169,373 6.9 5,100 1,920 0,20 U 1/14/2010 176,124 6.9 5,100 1,940 0.20 U 1/15/2010 151,155 7.0 4,700 1,920 0.20 U 1116/2010 166,667 7.1 4,900 1,920 0,20 U 1/17/2010 164,207 7,1 5,200 1,910 0,26 1/18/2010 165,100 7.1 5,000 1.920 0.25 1/19/2010 217,798 7.1 4,800 1,830 0,24 1/20/2010 243,679 7,0 4,700 1,670 0,20 U 112112010 247,680 7,0 4,600 1.820 0.24

2/3/2010 216,343 6.9 6,500 1.600 0,14 J 2/4/2010 250.341 7.0 4,800 1.500 0.14 J 2/5/2010 248,312 7.0 4,600 1.600 0.16 J 2/6/2010 240.345 6.9 4.500 1.600 0.21 21712010 234,970 6,8 4.600 1.600 0.26 2/8/2010 216,446 6.7 4,800 1.600 0.30 2/9/2010 230764 6.7 4,900 1.600 0.35 2/10/2010 251,488 6,7 4,600 1,600 0.36 2/11/2010 265.043 6.7 4,800 1,500 0.45 2112/2010 248,199 6.7 4,800 1,500 0.46 2/13/2010 249,380 6.8 4,800 1,500 0,52 2/14/2010 221.994 6.8 4,800 1.500 0.50 2/15/2010 194,414 6.5 4,800 1.500 0.59 2/16/2010 84,842 7.3 4,800 1,500 0.53 2/1712010 187,755 7.0 5.400 1,500 0.46 2/18/2010 231,101 6.7 5,600 1,500 0.45 2/19/2010 168,532 6.7 5,800 1,500 DAD 2/20/2010 201,681 6.7 5.500 1,500 0.38 2/21/2010 212,935 7.1 5,500 1,500 0.39 212~/2010 217,036 6.7 5,600 1,600 0.64 2/23/2010 210.400 6.8 5,000 1.500 0.45 2/24/2010 214,158 6.8 5,000 1,500 0,39 2/25/2010 196.232 6.7 5.000 1,500 0.35

Tables.xls 10f3 )2/20/2011

Table 2~3

POND 5 TREATMENT PLANT TREATED WATER MONITORING PROGRAM

SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA


2126/2010 193,602 6.8 5,200 1,600 0.37 2/27/2010 205,990 6.8 5,500 1,500 0.34 212812010 166.850 6.7 5,300 1.600 0.45

3/1/2010 205,299 6.7 5,300 1.600 0.45 3/2/2010 118,695 6.7 5,400 1,500 0.35 3/3/2010 247,138 6.6 5.200 1,500 0.32 3/4/2010 205.023 6.9 5,400 1.500 0.26 3/5/2010 189,055 7.0 5,000 1.600 0.48 3/6/2010 139,007 7.0 5,200 1.500 0.45 3/8/2010 185,039 69 5.100 1.600 0.51 3/9/2010 204,402 6.6 5.200 1.600 0.41

3/1012010 189,631 6.8 5,400 1.600 0.39 3/11/2010 203,623 6.9 5,400 1.600 0.33 3/12/2010 203,926 6.8 5,400 1.600 0.32 3/13/2010 145,794 6.9 5,500 1.600 0.33 3/26/2010 113,989 6.6 4,900 1,400 0.15 U 3/27/2010 251,571 6.8 4,800 1,400 0.15 U 3/2812010 250,560 6.8 5.100 1,400 0.17 J 3/29/2010 200.569 6.8 4,800 1,400 0.16 J 3/30/2010 282,739 6.7 4,800 1,400 0.08 U 3/31/2010 168,084 6.7 4,900 1,400 0.18 J

4/1/2010 259,608 6.7 5.100 1,400 0.08 U 4/2/2010 263.694 6.6 5.100 1,400 0.20 4/3/2010 95,921 6.8 5.200 1,400 0.20

4/13/2010 193,853 6.8 4,800 1.500 0.15 J 4/14/2010 263,566 6.8 4.800 1,500 0.20 J 4/15/2010 233,269 6.7 4,900 1,400 0.17 J 4/16/2010 248,549 6.8 4,900 1.500 0.19 J 4/17/2010 266,614 6.7 4,800 1,400 0.19 J 4/18/2010 270,623 6.6 4.900 1,500 0.16 J

5/4/2010 210,341 6.6 4.800 1,400 0.08 U 5/5/2010 271.233 6.6 5.100 1,400 0.09 U 5/6/2010 268,919 6.6 4,800 1,400 0.08 J 5/7/2010 256,716 6.9 5000 1,400 0.13 J 5/8/2010 271.725 6.6 4,940 1,400 0.13 J

5/24/2010 199,108 6.5 4,320 1,420 0.08 U 5/25/2010 271.807 6.7 4,380 1,450 0.08 U 5/26/2010 270,826 6.7 4.350 1440 0.09 J 5/27/2010 260,462 6.8 4,440 1,450 0.08 U 5/28/2010 85,035 6.9 4,410 1,430 0.08 U

6128/2010 198,677 7.0 4,000 1,500 0.08 U

Tables.xls 2of3 12120/2011

Table 2.3 , POND5TREATMffiNTPLANT



6/29/2010 215.779 6.7 4,040 1.550 0.08 U 6/30/2010 205.625 6.9 4,270 1,560 0.08 U

7/1/2010 215.418 6.8 4,130 1,600 0.08 U 7/2/2010 213,180 6.6 4,220 1,620 0.08 U 7/3/2010 207,598 6.8 4,250 1.550 0.08 U 714/2010 218,590 6.8 4.670 1,710 0.08 U 7/5/2010 216.514 7.1 4,470 1.660 0.08 U

91712010 222.032 6.9 4,730 2.040 0.08 U 918/2010 257,798 6.9 4,850 2,020 0.08 U 9/9/2010 256,536 7.0 4,860 2,010 0.08 U

9/10/2010 244.860 7.8 4,850 2.010 0.08 U 9/11/2010 258,288 7.2 4,750 1,960 0.08 U 9/12/2010 258,054 7.7 5,480 1,990 0.08 U 9/13/2010 161.900 6.9 5,280 1.990 0.08 U

12115/2010 36.870 6.4 4,720 2.520 0.13 U 12/1612010 214,984 6.8 4,780 2,590 0.13 U 12117/2010 187.406 7.8 4.840 2,580 0.13 U 12/18/2010 202,542 6.8 4,920 2,570 0.13 U 12/19/2010 138,112 7.2 4,710 2,450 0.13 U 12/2012010 203,318 7.2 4,610 2.390 0.13 U

1Q10 11,738,076 2010 5,082,150 3010 2.730,768 4010 983232

Total 16.820.226

U = Analyte was not detected. Value is reporting limit.

Tables.xls 30f3 1212012011

Table 2-3 POND 5 TREATMENT PLANT



Date Sampled Volume Treated

(gal) pH

Total Dissolved Solids (mg/L)

Chlorides (mglL)

Mercury (ppb)

2/12/2009 152,282 6.9 4.510 2,760 0.20 U 2/13/2009 231,360 7.1 4,960 2,760 0.20 U 2/14/2009 217.343 7.2 4,870 2.670 0.20 U 2/15/2009 232,348 7.3 4,820 2.770 0.20 U 2/16/2009 232,944 7.2 4,960 2.750 0.20 U 2/17/2009 224,510 7.3 4,930 2,750 0.20 U 2/1812009 230.677 7.2 4.900 2,740 0.20 U 2/19/2009 231,402 7.3 4,840 2.730 0.20 U 2120/2009 232,632 7.1 4,790 2,650 0.20 U 2/21/2009 206.445 7.1 4.740 2,610 0.20 U

3/2912009 176,985 6.6 4,900 2,200 0.20 U 3/30/2009 257,873 6.8 5,200 2,180 0.29

4/1/2009 265.437 7.3 5.500 2.140 0.20 U 4/2/2009 250,468 7.3 5.200 2.130 0.31 4/3/2009 223,262 7.0 5,000 2,120 0.37 4/412009 236,999 7.2 5,300 2.100 0.41 4/5/2009 237,593 7.4 4,400 2.120 0.46 4/6/2009 236.158 7.7 5,300 2.080 0.38 4/7/2009 217,557 7.5 4.600 2,130 0.28 4/8/2009 218,146 7.2 5,000 2.110 0,31 4/9/2009 228,227 7.5 5.100 2.090 0,29

4/10/2009 210.720 7.5 5,100 2.080 0.35 4/11/2009 276.733 7.6 5,000 2.090 0.32 4/12/2009 253,243 7.4 5.300 2.040 0.35 4/13/2009 249,741 7.5 5,800 2,030 0.34 4/14/2009 238,161 7.0 5,100 1,960 0.36 4/23/2009 248,683 7.1 4,800 2,070 0,20 U 4/24/2009 239.772 6.9 4.800 2.090 0.20 U 4/25/2009 227,801 7.1 4.800 2,100 0.23 4/26/2009 241.960 7.0 5.700 2.100 0.20 U 4/27/2009 246.330 6.9 5,300 2.090 0.20 U 4/28/2009 237,762 6.9 5,400 2,230 0.21 4/29/2009 226.162 6.9 5.200 2.080 0.20 U 4/30/2009 241.225 6.9 5,200 3,480 0.20 U

5/1/2009 239,649 6.9 5.400 2,180 0.20 U 5/7/2009 227.149 6.7 4.400 1.870 0.20 U 5/8/2009 234,741 6.7 4,700 1.780 0.20 U

Tubles.xls I of3 12121/2010


TREATED WATER MONITORING PROGRAM SALTVILLE WASTE DISPOSAL SITE, SAI,TVILLE, VIRGINIA


5/9/2009 236.559 6.8 4.700 1,850 0.20 U 5/10/2009 225,021 6.9 4,700 1.950 0.20 U 5/11/2009 234.315 6.7 4.800 2.060 0.20 U 5/12/2009 234,408 6.7 5,200 1,890 0.20 U 5/13/2009 221,147 6,6 5,900 1,880 0.29 5/18/2009 172.739 6,6 4.800 1.800 0.20 U 5/19/2009 234.263 6.6 4,800 1,610 0.20 U 5/20/2009 236,749 6.6 5,000 1,810 0.20 U 5/21/2009 233,377 6.6 5.300 1.810 0.20 U 5/27/2009 46.267 6.3 5,100 1,860 0.20 U 5/28/2009 252,709 6.5 5.500 1,840 0.20 U 5/29/2009 241,711 6.5 5.000 1,800 0.20 U 5/30/2009 228.423 6.6 5.200 1,920 0.20 U 5/31/2009 250,599 6,6 5,000 1,910 0.20 U

6/1/2009 243,022 6.6 5.600 1,880 0.20 U 6/2/2009 265,163 6.7 5.600 1.800 0.20 U

6/23/2009 249,511 6.7 4,800 1.850 0.20 U 6/24/2009 245,455 6.5 4,900 1,880 0.20 U 6/25/2009 233,819 6.6 4.600 1.960 0.20 U 6/26/2009 244,883 6.6 5,200 1..960 0.20 U 6/27/2009 243,274 6.7 5,500 1.970 0.20 U 6/28/2009 243,366 6.7 5,400 1.920 0.20 U 6/29/2009 237.018 6.8 5,500 1,850 0.20 U

8/7/2009 206.040 6.6 3,600 2,020 0.28 8/8/2009 259.558 6.5 4,200 1,930 0.20 U 8/9/2009 165.531 7.2 4,200 2,050 0.20 U

8/10/2009 260.169 7.2 4.500 2,070 0.20 U 8/11/2009 256.718 6.8 4,900 2,070 0.20 U 8/12/2009 247.290 6.7 5,400 2,050 0.20 U 8/13/2009 255.552 6.7 5.100 2,140 0.20 U 8/14/2009 255.886 7.0 4,900 2,120 0.20 U 8/15/2009 240.203 6.7 5,200 2,130 0.20 U

9/9/2009 246,161 6.8 4.600 2.080 0.20 U 9/10/2009 54.574 6.9 4,700 2,120 0.20 U 9/11/2009 235.183 6.9 5,500 2,080 0.20 U 9/12/2009 229,979 6.8 4,300 2,360 0.20 U 9/13/2009 221.452 6.8 4.300 2.220 0.20 U 9/14/2009 210.202 6.9 4,900 2,290 0.20 U 9/15/2009 199,632 6.9 4,800 2.280 0.20 U

12/9/2009 235,600 7.3 3,800 2.790 0.20 U

Tables.xls 2 on 1212112010




12/10/2009 228,600 6.8 4,500 0.20 U2.760 12/11/2009 227,748 4,900 2,8207.1 0.20 U

4,60012112/2009 201,966 2,8106.9 0.20 U 12/13/2009 216,474 4,400 2,860 0.20 U6.8 12/14/2009 217,160 4,900 2,810 0.20 U7.2 12/15/2009 214,648 4.500 2,630 0.20 U6.9

5,10012/16/2009 216.726 2,290 0.20 U7.0 12/17/2009 180,628 4,000 2,2506.9 0.20 U

1009 2,626,801 2009 11.209,517 3009 3.544.130

1,939,5504009

Total 19.319,998 ..

U ::: Analyte was not detected. Value IS reporting limit. •=Analytical report currently not available. Data will be reported next quarter.

Tables.xls 30f3 12/21/2010

Table 2-3 POND 5 TREATMENT PLANT ANALYTICAL DATA


2008 LONG-TERM MONITOIUNG PROGRAM

Date Sampled

Volume Treated (gal) pH

Total Dissolved Solids (mglL)

Chlorides (mglL)

Mercury (Ppb)

1/15/2008 208,032 6,B 5120 3320 0.2 U 1/16/2008 220,239 6.7 5210 3310 0.2 U 1117/2008 286,733 7.1 4770 3220 0,2 U

2/29/2008 200,168 7,0 3720 2840 0.2 U

311/200B 217.226 7.0 4260 2790 0.2 U 3/2/2008 232,088 7.0 4480 2780 0.2 U 3/3/2008 221,662 7.0 4120 2780 0.2 U 3/4/2008 213,483 7.0 4420 2800 0.2 U 3/5/2008 223,524 7.0 4130 2470 0.2 U

4/23f2008 286.340 6.7 4450 2090 0.2 U 4/24/2008 282,098 6.9· 4430 2000 0.2 U 4/25/2008 283.139 6.8 4630 2040 0.2 U 4/26/2008 270.167 6.8 4800 2010 0.2 U 4/27/2008 280.726 6.8 . 4650 2060 0.2 U 4/26/2008 284,104 6.8 3900 1650 0.2 U

6/3/2008 265.855 a.7 5950 1920 0.2 U 6J4f2008 285,255 6,8 5610 1910 0.2 U 6/5/2008 287,256 6.8 5500 1940 0.2 U 6/6/2008 276,767 6.8 5900 1870 0.2 U 6/7/2008 281,211 6.7 5730 1850 0.2 U 6/8/2008 279,529 6,8 6000 1940 0,2 U 6/9/2008 211,431 6.8 5910 1960 0.2 U

1007 2,023,155 2Q07 3,573.878 3Q07 0 4Q07 ° Total 5.597.033

U -- Analyle was not delecled. Value Is reporllng Ilml!. * = Analytical report currently not available. Data will be reported next quarter.

SVTPSUM.XLS Page 1 1212/2009

Documents

FIVE YEAR REVIEW - Superfund Records Collections · The remedy selected in ROD-2 for OU3 included placement of a RCRA cap over Pond 5, placement of a soil cover over Pond 6, collection