COMMUNITY INVOLVEMENT PLAN

T.H. Agriculture & Nutrition Company, Inc. Superfund Site Montgomery, Montgomery Counts,

April 2018

5 I(5 T

PROf^

U. S. ENVIRONMENTAL PROTECTION AGENCY REGION IV

Date: V- //"■ / ^ Approved by:

096 The S. Environmental Protection Agency's (EPA)

Superfund Community Involvement Progr,-\m is committed

TO PROMOTING COMMUNICATION BETWEEN CITIZENS AND THE AGENCY.

Active public involvement is crucial to the success of any public project.

EP.A'S COMMUNITY INVOLVEMENT ACTIVITIES AT THE

T.H. .Agriculture & Nutrition Company. Inc. Superfund Site

ARE DESIGNED TO

Inform the public of the nature of the environmental issues associated with the site.

Involve the public in the decision-making process that will affect them.

Involve the public in the responses under consideration to remedy these issues, and

Inform the public of the progress being made to implement the remedy. Table of C'ontents

Section Page

1.0 Overview of the Community Involvement Plan...... 4 2.0 Capsule Site Description...... 5 2.1 Site History...... 5 2.2 Site DescriptionLocation ...... 5 2.3 Site Inspections andCleanup .Activities...... 9 3.0 Community Background...... 11 3.1 Community Profile...... 11 3.2 Histoiy of Community Involvement...... 14 3.3 Key Community Concerns...... 14 3.4 Response to Community Concerns...... 15 3.5 Summaiy of Communication Needs...... 15 4.0 EP.A's Community Involvement Program...... 16 4.1 Tlie Plan...... 16 4.2 Time Frame Summaiy for Community Involvement .Activities...... 20

.Appendices: .A EP.A Regional Contacts...... 21 B Local OlTicials...... 22 C State Officials...... 23 D Federal Elected Officials...... 24 E Potentially Responsible PiU'ties...... 25 F Media Contacts...... 26 G Meeting Locations...... 28 H Repositoiy Locations...... 29 I Other Local Resources...... 30 J Glossaiy ...... 31

Figures: 1 Site Map...... 7 2 State Map ...... 8 3 EJ Screen Map...... 13

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 3 March 2018 Section 1.0 Overview of the C'ommunitv Involvement Plan

Tlie EPA developed this Community Involvement Phin (CIP) to tacilitate two-way communication between the community suirounding the T.H. Agriculture & Nutrition Company. Inc. Superfund Site (Site) and the EPA and to encourage community involvement in Site remediation activities. Tlie EP.A will utilize the community involvement activities outlined in this plan to inlbrm iu*ea residents about the Site and provide opportunities for community involvement.

Tills CIP addresses the Site's relationship to the community and the EP.A (Section 2.0). provides a description of the community (Section 3.0). presents the EP.A's community involvement program (Section 4.0). and provides a listing of resources available (.Appendices). Tlie EP.A drew upon several information sources to develop this plan, including community interviews and Site files. Tlie EP.A's Regional OtTice will oversee the implementation of the community involvement activities outlined in this Plan.

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 4 March 2018 Section 2.0 C'apsule Site Description

2.1 Site History

Tlie Site is located in Montgomeiy. Alabama. It includes the iu*ea where operations fomuilated. packaged, iind distributed pesticides, herbicides, and other industrial and water treatment chemicals. Tlie EP.A. the .Alabama Department of Environmental Management (.ADEM). and the Site's potentially responsible parties (PRPs) have investigated Site conditions and taken steps to clean up the Site to protect people and the environment from contamination. Tlie PRPs completed demolition of all on-site buildings in 2010. Site contamination does not cuirently threaten people living and working neiu* the Site. By monitoring groundwater, placing institutional controls on the Site property, and undertiiking five-Year Reviews (EVRs). the EP.A. .ADEM. and the Site's PRPs continue to protect people and the environment from contamination.

In 1990. the EP.A placed the Site on the Superfund programs National Priorities List (NPL) because of contaminated groundwater, sediment, iind soil resulting from operations at the Site.

2.2 Site Description/Location

Tlie Site encompasses an area of 16.4 acres and is comprised principally of two adjacent properties, which are identified as the T.H. .Agriculture & Nutrition property to the north (3405 Binningham Highway) iind the .Ai'kema Inc. (fonnerly .Atofina Chemical Inc.) property to the south (3355 Binningham Highway and IkS. 31 82) in Montgomeiy. Montgomeiy County. .Alabama. Maxwell .Air force Base lies to the east across the highway. The Site is on the west side of Montgomeiy within the city limits iind is about two miles southwest of the .Alabiima River and two miles northeast of Catonia Creek.

Tlie northenimost parcel, the T.H. .Agriculture & Nutrition property, is approximately 11.6 acres with approximately 35 percent of the property along the western and southern boundaries covered with mixed pine forest. .A small pond and low-lying marshy area niiike up the center of the property. .Ai*eas south of the former warehouse iu*ea have been filled to alleviate ponding water and drainage problems. Prior to a demolition project in 2009. the only significant structure on the T.H. .Agriculture & Nutrition property was a warehouse.

Tlie southernmost parcel, the .Ai'kema property, is approximately 4.8 acres. Originally, the center of the property was covered with concrete pavement and a number of buildings iind tanks. Tlie western third of the property is covered with grass iind shrubben and is the fomier site of iin evaporation lagoon and incinerator which Pennvalt Coiporation operated. .Atochem (now Legacy) maintained a 700.000-gallon evaporation lagoon for the storage iind treatment of wastewaters. Tlie lagoon overflowed on various occasions. .Atochem asserts that the lagoon was butyl-reinforced by nylon membrane lines and was closed pursuant to a plan approved by the State of .Alabama in 1978. Liquids, sludges, and adjacent wells were removed and disposed of ofl-site at an authorized waste management tacility. Tlie lagoon was closed in 1979 and is now

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 5 March 2018 covered with grass and shrubben. Tlie eastern quarter of the property is open and covered piU'tially by a paved area.

Commercial and industrial land uses border the Site to the north, east, and south. .Aji undeveloped residential area borders the Site to the west. .A mobile home park is located northwest of the Site. The Site includes the iu*ea where companies fonnulated. packaged, and distributed pesticides, herbicides, iind other industrial and water treatment chemicals. Cuirently. the Site is vacant. Tliere iu*e no plans to redevelop the Site.

Tlie Site is generally flat and slopes gently to the north. Surtace water drains to a marshy area west of the T.H. .Agriculture & Nutrition building. Tlie nuu'sh is drained by a small intennittent stream that, in turn, discharges into the Catoma Creek, intimately, the Catoma Creek discharges into the .Alabama River approximately eight miles west of the Site. Tlie Site is underlain by 5 feet to 15 feet of silt and clay which overlies approximately 25 to 30 feet of sand and gravel.

Tlie nearest residences to the Site are a trailer community about 0.3 miles to the north. .A few other residences are 0.4 miles to the south. Tlie nearest agricultural hinds are about one-half mile away. No schools. piU'ks. or recreational areas are in the immediate vicinity of the Site.

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 6 March 2018 Figure 1: Site Map

THAN PROPERTY

1C PROPERTY

ftUMI

RrKrNiTj.nn ***^thmw

T.H. Agriculture & Nutrition Company Community Involvement Plan Page? March 2018 Figure 2: State Map

Ardmore

Stevemm Id * MuBcJe Shoftls tsv Ue tder. Coi^nd consOoro Odcatur RatnEMiH MouHot). Hartselle Fort Payne Rad Bn akmien> . Pral Campbell 431 Aftieriville tteleyrdle CuHman 4iinCart(B

Detel dsdan • BnBanl: Glencoe iS Carbon Ftil Piedtnemt Bsper JadfflQnvlIel, Kimbarlir < Semen spmfgyile •Oakiran A Fajreito AnniE.1on AdammieC ruseviie Millport BirmingM eeda^*ll Crty ®*™i\Ra(ilMne Fairfeld untsin ^ok Hueytown' elladega .Vild Qeseeme sta^iia W8 Bookwood SSMcwee ■Cam Pelbam Chldersbun odhurt Asbbnd Tuscadoo la boater'CohimbiaftK-Sjiacaijgs Akavtfe liicnenaiki GtMrie Moufldir Jemaon Cetibfiinlle 23 IS Aa Alexander Cty Pbdtford Lafapefla Gaineavdle QfldevNe Gnnnebore S'Ai^ilt' Idea', M«ic* Auburn Liwigston PhNtx Prmdtvil mown TuskegH Linden OnWie Be men fitgomery ' IVeainjlre ^ Union Spreas ■ Bullar .Camden NeetViem Port D^oat Thoramdie PktePiicie ''^edenburtfi*

Grave Hi irrcrne BrsiHey McKenzie Abbevn ■ Chatan Ozark fiiac«Cih Evergre Entarpnae MclnhHdi Ca^le berry ehimlHa \pordon 29 SpnnflB* Cdrwu lie Ftorato Gen»a

auume

Interstate Highways Fairtnpe 'JS highways

uH^res geotogy.oam 50 KM 50 Miled

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 8 March 2018 2.3 Site Inspections and Cleanup Activities

Elf Atochem. hereafter refeired to as Legacy Site Services LLC. a subsidiaiy of Elf Atochem and T.H. Agriculture & Nutrition, the Site's PRPs. led Site investigations iind cleanup activities during the interim groundwater cleanup, while Legacy Site Services LLC (Legacy) implemented the design and cleanup phase of the final groundwater, soil, iind sediment cleanup. Tlie EPA and ADEM have provided oversight of all activities.

.A 1980 study detected low concentrations of the pesticide lindane. Later studies conducted by T.H. .Agriculture & Nutrition detected dichloroethylene. dichloroethane. and trichlorethane. and moderate concentrations of the metals manganese, silver, nickel, and zinc in analyses of sediment on the T.H. .Agriculture & Nutrition property. Surtace-water samples collected later in the study detected quantities of chromium, cadmium, copper, lead, nickel, and selenium.

In 1981. T.H .Agriculture & Nutrition supervised and perfonned a self-initiated Site investigation of its property and initiated the removal of the landfill area.

In 1987. the EP.A conducted a Site inspection and the T.H. .Agriculture & Nutrition property was subsequently ranked under the Hazard Riinking System with a score of 44.46 on the National Priorities List (NPL).

In 1989. T.H. .Agriculture & Nutrition contracted for a study in which monitoring wells were installed on the southern border of the property. That study revealed the presence of hazardous substiinces. including certain organic and inorganic compounds in the groundwater. Based upon groundwater ftow direction. anal\lical results, and the waste disposal practices of the adjacent property, that report concluded that the hazardous substances from the .Atochem or Industrial Chemical property were impacting the T.H. .Agriculture & Nutrition property.

In March 1991. .Atochem. Industrial Chemicals, and .Astro Packaging entered into an .Administrative Order of Consent with the EP.A to conduct the remedial investigation feasibility study on both properties under the EP.A's and .ADEM's oversight.

Tlie Site's long-tenn remedy for Ol^-l (Operable Ihht). selected in 1995. included extracting groundwater to contain contamination within the Site boundiuy and discharging groundwater to the local water treatment plant for treatment.

Erom 1997 to 2002. Legacy and T. H. .Agriculture & Nutrition Co., installed and operated the groundwater exiraction system. In 2002. operation of the groundwater exiraction system stopped so that enhanced techniques could be put in place. Tlie techniques involved injecting compounds such as HRC (Hydrogen Release Compounds) iind EHC (Polysulfide's) into groundwater that optimized the use of living organisms to break down contiiminants.

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 9 March 2018 Tlie Site's long-temi remedy for 01^-2. selected in 1998 included:

• Digging up contaminated soil and sediment • Backlllling the dug-up areas • Treating dug-up soil iind sediment on-site using living organisms to break down contiiminants • Revegetating the backfilled areas • Placing institutional controls, including fencing and deed restrictions, on the Site property to limit Site uses to industrial land uses • Evaluating the Ol^-l cleanup plan and supplementing the use of living organisms to breiik down contaminants in groundwater with other enhanced teclmiques.

In 2002. The 01^-2 treatment cell was constructed by Legacy. About 2.850 cubic yards of contaminated soil and sediment was dug up. consolidated, and placed into the treatment cell.

Construction work on the Ol^-l and 01^-2 remedies was completed in 2002. In 2004. treatment of contiiminated soil sediment was completed, while groundwater monitoring at the Site is ongoing.

Tlie EP.A completed the Eouilh Eive-Veiu* Review for this Site on September 15. 2017.

Tlie remedial investigation portion of the study is intended to identify and assess the extent and nature of contamination at the Site. Tlie EP.A has directed that sufficient sampling be conducted at the Site to determine what, if any. further cleiinup is needed at the Site. Tlie feasibility study evaluated alternatives for cleaning up any contamination detected in the investigation.

Tlie shallow aquifer (the Teirace .Alluvial .Aquifer) underlying the two properties may be hydrologically connected to the underlying aquifers. The l^pper Eutaw iind the Lower Eutaw aquifers iu*e believed to be separated by a confining layer. Residents of the city and county of Montgomeiy rely heavily on these two aquifers for the source of their drinking water. Municipal wells are located in the vicinity of the Sites, with the neiU'est being a little more than one mile south of the Site. This well field supplies approximately 40® o of the water supply for 250.000 people. Municipal wells in the area are about 300 feet deep, iind are not cuirently contaminated from the Site. Monitoring of nearby municipal wells has not detected any pesticides related to this Site. Groundwater fiow in the area is generally to the north.

Tlie EP.A has conducted several Eive-Vear Reviews of the Site's remedy. These reviews ensure that the remedies put in place protect public health iind the environment, and function as intended by Site decision documents. Tlie most recent review in the summer of 2017 concluded that response actions at the Site iu*e in accordiince with the remedy selected by the EP.A iind that the remedy continues to be protective of human health and the environment.

Site investigations and cleanup activities have focused on two areas, which the EP.A refers to as operable units, or Om. Tliese areas include Ol^-l: interim groundwater cleanup: and 01^-2: final groundwater, soil, and sediment cleanup. The EP.A negotiated legal agreements with the Site's PRP to investigate iind clean up the Site.

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 10 March 2018 Section 3.0 C'ommunitj Background

3.1 C'ommunit\ Profile

MontgomeiT County is located in central Alabama and includes the capital city. Montgomeiy. Tlie county has a population of 226.349. and the city's population is 201.332. Tlie area is served by two major interstates (I 85 and I 65) iind 4 major Federal highways (231. 31. 82. and 331). Tlie .Alabama River provides water transportation to the Gulf of Mexico via the Port of Mobile and to the Great Lakes via the Tennessee-Tombigbee watenvay.

Tlie city is a center of retail trade and wholesale distribution for .Alabama and the Southeast. Tlie county supports about 60 public schools and there iu*e about 30 private schools in the county. Five colleges iind universities are represented in the area, as well as two state technical colleges. Two major militaiy bases are located in the city—Gunter .Air Force Base and Max'well .Air Force Base, which houses the .Air Ihiiversity.

Tlie tri-county area includes .Autauga. Elmore, and Montgomeiy counties. Mobility rates in the area are relatively high. The per capita income for residents of the iu*ea is around S26.936.

Tlie county has a five-member county commission which selects a chair and serves for a four-year tenn. Tlie city has a mayor city council type of government also elected for four-year tenns.

Mean annual temperatures range from 35 to 95 degrees with an average rainlall of 50 inches. Tlie CSX Tmnsportation iind Norfolk Southern Railways serve the area. The nearest aiiport is Dannelly Field in Montgomeiy.

Demographics and iiifonnation: Montgonien, .AL (City)

Population: 200.024

Montgoinen median age: 35.5 years

.Alabama median age: 39 years

Montgomeiy estimated median household mcoine m 2015: S41.625

Montgomeiy estimated per capita mcoine m 2015: S26.936

Race/Ethnic Backgromid:

Black: 59.8**o | White: 32.9**o | Hispanic: 3.6**o | .Asian: 2.5**o | Two or more races: 1.8**o |

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 11 March 2018 Education:

High school graduate or higher: 84.9® o

Bachelor's degree or higher: 30.8®o

Graduate degree or higher: 12.6®o

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 12 March 2018 EJ SCREEN Report (Version 2017) 1 mile Ring Centered ALABAMA, EPA Region 4 Approximate Population: 1,068 Input Area (sq. miles): 3.14 T.H. Agriculture & Nutrition Site

Figure 4: EJ Screen Map

J.V ''i'-., •„ •

■A ■ ttpii !• 'I ^ T ^'A- '■ ^■-y.4^ gpiAjSw mi f. m.; ’ m4H,

1.36,112 July 19,2017 /^fn. 1.2 n Buffer Area ^ Digiized Pornt eei 2 km (kipofao I EirMv Gce^^na

EPA State Percentile in Percentile in USA Percentile in Selected Variables Value Region Average State EPA Region Average USA Average Demographic Inc icators Demographic Index 79% 37% 94 38% 94 36% 94 Minority Population 88% 34% 92 37% 91 38% 89 Low Income Population 70% 40% 91 39% 92 34% 92 Linguistically Isolated 18% 1% 99 3% 94 5% 91 Population Population with Less Than 43% 16% 98 14% 98 13% 96 High School Education Population under Age 5 22% 6% 99 6% 99 6% 99 Population over Age 64 7% 15% 10 15% 16 14% 19

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 13 March 2018 3.2 History of C'ommunitj Involvement

Histoiy of community involvement at the T.H. Agriculture & Nutrition Compiiny Site is as follows:

1981: Removal Action on T.H. .Agriculture & Nutrition Site 1990: The Site was listed on the NPL August 1991: The initial CIP was created for the community August 1991: This tact sheet was sent to the community to provide background infonnation about the Site, the study, the Superfund program, iind opportunities for the community near the Site to be involved in EP.A's activities November 1994: .A tact sheet was sent to the community to provide notice of a proposed Interim Remedial .Action for the Site and to provide an opportunity for public to comment on the proposed interim cleanup action 1994: Public Health .Assessment. .Alabiima Department of Public Health Ihider Cooperative .Agreement with the .Agency for Toxic Substiinces and Disease Registiy 1995: 01^-1 ROD (Record of Decision) (Interim Groundwater) 1998: 01^-2 ROD (Soils. Final Groundwater) 1997 to 2002: Legacy and the T. H. .Agriculture & Nutrition Co., installed and operated the groundwater exiraction system May 2000: .A tact sheet was sent to the community which summiu'ized the data that can be found in greater detail in the Remedial Investigation Feasibility Study (RI FS) and other documents that can be found in the .Administrative Record (.AR) 2002: Operation of the groundwater exiraction system stopped so that enluinced techniques could be put in place 2002-2004: Legacy constructed the 01^-2 treatment cell, with about 2.850 cubic yards of contaminated soil and sediment dug up then consolidated into the treatment cell September 2007: The 2"‘' FVR was completed. 2010: Legacy completed demolition of all on-site buildings September 2012: The 3'^^' FVR was completed September 2017: The 4"' FVR was completed

3.3 Key C'ommunity C'oncerns

During the 2017 FVR process, interviews were conducted for the T.H. .Agriculture & Nutrition Company Site throughout a six-month timeframe (Winter-Summer of 2017). to document any perceived problems or successes with the remedy that has been implemented to date at the Site. Tlie results of these interviews iu*e summarized below:

1. Ensure that PRPs remain proactive in progressing remediation of the Site. 2. Focus on minor improvements that are needed for the Site, such as rebuilding the fence that has tallen at the Site's perimeter. 3. Maintain effectiveness of the remedy as it appears to be decreasing iind contiiminants of concern (COCs) appear to be rebounding in some areas. 4. Continue to conduct Site visits to check on the upkeep of the Site.

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 14 March 2018 5. Ensure that all institutional controls enforce safety and protection for human health. 6. Continue to keep the Site closed as there are no phins for future use at the Site. 7. Re-evaluate if the remedy in place is capable of achieving the perfonnance standards permanently to prevent Site COCs from migrating otT-site. 8. Ensure that the EP.A shares Site infonnation with residents as some are not aware of any Site remediation activities.

3.4 Response to C'ommunity C'oncerns

Tlie Site is maintained and up to date. Reuse of the Site is yet to be detennined. There iu*e environmental covemints in place. Tlie .ADEM has conducted various Site visits to check on the upkeep of the Site. .Additionally, the .ADEM has reviewed all groundwater monitoring reports from the past five years and one groundwater recoveiy system and well abandonment phin. Groundwater monitoring reports show reduced etTectiveness of the remedy in the treatment area, and the rebounding of Site COCs in some iu*eas. Tlie groundwater recoveiy system and well abandonment plan has been approved by the .ADEM.

3.5 Summary of C'ommunication Needs

Overall, the residents that were interviewed explained that they iu*e slightly tamiliar with the Site. Tlie residents suggest that the EP.A continue to provide them with more infonnation about the Site, preferably by mail, iind continue to ensure that institutional controls are properly used and etTective on-site.

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 15 March 2018 Section 4.0 EPA’s C'ommunitj Involvement Program

Tlie overall goal of the EPA's community involvement program is to promote two-way communication between citizens and the EPA and to provide opportunities for meaningful iind active involvement by the community in the cleanup process. The EPA will implement the community involvement activities described below. The following plan is based on the results of the community interviews described earlier. The plan addresses each issue that was identified as important to the community.

4.1 The Plan

Issue 1: Keeping the public infonned and up to date.

Acti\ity lA: Designate an EPA Conuiiuiiity In\ohenient Coordinator (CIC).

• Objective: To provide a primaiy liaison between the community iind the EP.A. iind to ensure prompt, accurate, and consistent responses and information dissemination about the Site. In those instances, where the EP.A's CIC may be unable to provide adequate infonnation (such as on technical issues), inquiries will be directed to the appropriate EP.A contact.

• Method: The EP.A will designate an EP.A CIC to handle Site inquiries and serve as a point of contact for community members. Tlie CIC is appointed by the Region 4 of the EP.A. .Abena .Ajanaku is the EP.A CIC assigned to the Site. She will work closely with Briiin Earner. EP.A's Remedial Project Miinager for the Site.

• Timing: Tlie cuirent CIC has been designated to provide community support.

.Acti\ity IB: Prepare and distribute Site fact sheets and tecluiical suininaries.

• Objective: To provide citizens with cuirent. accurate, easy-to-read, easy-to-understand infonnation about the T.H. .Agriculture & Nutrition Site when needed.

• Method: Pact sheets will be mailed as needed to all parties on the Site mailing list. In addition, copies will be available at the information repositoiy. the web and in other locations as identified by the community.

• Timing: Tlie EP.A will prepare and distribute fact sheets as needed.

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 16 March 2018 Acti\ ity 1C: Pro\ icle a toll-free ‘‘800 number'’' for the coniniuiiity to contact EPA.

• Objective: To enable citizens to obtain the latest information available whenever they want, rather thiin having to wait for a meeting or a tact sheet, and without incuiring any cost.

• Method: The EPA has activated the 800 number. Timing: Tlie toll-free number is currently operational (1-877-718-3752).

.\cti\ity ID: Maintain a mailing list for the Site.

• Objective: To facilitate the distribution of site-specific infonnation to eveiy one who needs or wants to be kept inlbnned about the Site.

• Method: The EP.A will update iind maintain a mailing list that includes all residences adjacent to the Site, in known or suspected paths of migration, or those othenvise atTected by the Site.

• Timing: Tlie EP.A will keep it cuirent.

.\cti\ity IE: Mnmtam Inforniation Repositories.

• Objective: To provide a convenient location for residents to read and copy otTicial documents iind other pertinent infonnation about the Site and EP.A activities.

• Method: The repositoiy is a reference collection of Site infonnation containing the .Administrative Record file, other site-specific inlbnnation. and the Community Involvement Phin. Tlie repositoiy is accessible to the physically challenged, has copier facilities, and is available to residents during nonnal business hours and at least some evening and or weekend hours. .An additional repository is located at EP.A Region 4 otTices at 61 Eors\lh Street S\V in .Atlanta. Georgia.

• Timing: Tlie EP.A established the local repositoiy at the Rufus Lewis Regional Libraiy . 3095 Mobile Highway. Montgomeiy . .Alabama 36108. Tlie EP.A adds new documents as thev become available.

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 17 March 2018 Activity IF: Provide Site information on the Internet.

• Objective: To provide key resources for searching and listing both general and specific information about hazardous waste issues.

• Method: A Site Status Summary for this Site and information about the EPA can be found at: https://www.epa.gov/superfund/th-agriculture ■ EPA Headquarters: http://www.epa.gov ■ EPA Region 4: https://www.epa.gov/aboutepa/about-epa-region-4-southeast ■ EPA Region 4: 61 Forsyth Street Atlanta, GA 30303

• Timing: Site Status summaries are periodically updated.

Activity IG: Maintain the Administrative Record.

• Objective: To provide residents with a paper trail of all documents, resources, etc. used by the Remedial Project Manager and Site Team to make decisions about the Site and its cleanup.

• Method: The EPA will provide at least two sets of the Administrative Record for the Site: one in the EPA Region 4 offices located at 61 Forsyth Street SW Atlanta, GA 30303 and one located in the local Information Repository near the Site.

• Timing: The Administrative Record is opened as soon as Site investigation begins.

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 18 March 2018 Issue 2: Pro\ ide adequate and nieanuigful oppoi*tuiiities for coniinuiiity ui\oh eiiieiit.

Acti\ity 2A: Hold public ineetuigs.

• Objective: To update the community on Site status when needed or requested and address community questions, concerns, ideas, and comments.

• Method: Refer to Appendix G for the suggested meeting location. The EP.A will schedule, prepiu'e for. and attend all announced meetings. Tlie EP.A will provide at least two weeks prior notice of the scheduled meeting. Tlie Regional Project Manager and Community Involvement Coordinator, and other appropriate EP.A statTwill attend.

• Timing: Tlie EP.A will hold public meetings as appropriate.

.\cti\ ity 2B: Re\ ise the Coiiuiiuiiity Iii\ oh eiiieiit Plan (CIP).

• Objective: To identify iind address community needs, issues, or concerns regarding the Site or the cleanup remedy that are not cuirently addressed in this CIP.

• Method: The Revised CIP will update the infonnation presented in the previous version of the CIP.

• Timing: Tlie EP.A will revise the CIP as community concern wiUTiints or at least even three vears until the Site is closed out.

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 19 March 2018 4.2 Time Frame Summary for Community Involvement Activities

ACTIVITY TIME FRAME

Designate an EPA Community Involvement Designated; Abena Ajanaku Coordinator (CIC) Prepare and distribute Site fact sheets and As needed technical summaries Provide a toll-free "800 number" for the Currently in operation community to contact the EPA Maintain a mailing list for the Site Ongoing

Establish and maintain Information Repositories Established, update as needed

Provide Site information on the Internet Currently available, update as needed

Establish and maintain the Administrative Record Established, update as needed

Hold public meetings As needed

Revise the Community Involvement Plan (CIP) As needed, at least every 3 years

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 20 March 2018 Appendix A EPA Regional Contacts

Brian Farrier Abena Ajanaku Remedial Project Manager Community Involvement Coordinator U.S. EPA, Region 4 U.S. EPA, Region 4 61 Forsyth Street SW 61 Forsyth Street SW Atlanta, GA 30303 Atlanta, GA 30303 (404) 562-8952 (404) 562-8834 F arrier.Brian@epa. gov Ajanaku. Abena@epa. gov

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 21 March 2018 Appendix B Local Officials

Mayor William Green, District 5 Todd Strange 103 North Perry Street 103 North Perry Street Montgomery, AL 36104 Room 206 (334) 625-4636 Montgomery, AL 36104 [email protected] (334) 241-2000 Mavor@montgomerval. gov Fred Bell, District 6 103 North Perry Street City Council Members Montgomery, AL 36104 Richard Bollinger, District 1 (334) 625-4636 103 North Perry Street Fbell@montgomeryal. gov Montgomery, AL 36104 (334) 625-4636 Arch Lee, District 7 [email protected] 103 North Perry Street Montgomery, AL 36104 Brantley Lyons, District 2 (334) 625-4636 103 North Perry Street Alee@montgomeryal. gov Montgomery, AL 36104 (334) 625-4636 Glen Pruitt, District 8 [email protected] 103 North Perry Street Montgomery, AL 36104 Tracy Larkin, District 3 (334) 625-4636 103 North Perry Street Gpruitt@montgomerval. gov Montgomery, AL 36104 (334) 625-4636 Charles Jinright, District 9 Tlarkin@montgomeryal. gov 103 North Perry Street Montgomery, AL 36104 David Burkette, District 4 (334) 625-4636 103 North Perry Street C i inri ght @mont gomeryal. gov Montgomery, AL 36104 (334) 625-4636 Dburkette@montgomerval. gov

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 22 March 2018 Appendix C State Officials

State Governor Kay Ivey 600 Dexter Avenue Montgomery, AL 36130 (334) 242-7100 http ://govemor.alabama. gov/

President Pro Tempore of the Senate Del Marsh: District 12 11 South Union Street Suite 722 Montgomery, AL 36130 (334) 242-7877 SiteSupport@al-legislature. gov

Speaker of the House of Representatives Mac McCutcheon 11 South Union Street Suite519-A Montgomery, AL 36130 (334) 242-7668 [email protected]

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 23 March 2018 Appendix D Federal Elected Officials

U.S. Senate U.S. House of Representatives Richard Shelby Martha Roby: District 2 Washington D.C. Office Washington D.C. Office 304 Russell Senate Office Building 442 Cannon House Office Building Washington, DC 20510 Washington, DC 20515 (202) 224-5744 (202) 225-2901 https://www.shelbv.senate.gov/public/ https://robv.house.gov/contact

Huntsville Office Montgomery Office 1000 Glenn HeM'n Boulevard #20127 401 Adams Avenue, Suite 160 Huntsville, AL 35824 Montgomery, AL 36104 (256) 772-0460 (334) 262-7718

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 24 March 2018 Appendix E Potentially Responsible Parties

T.H. Agriculture & Nutrition Co. 3017 Binningham Highway Montgomeiy. AL 36108

Elf Atochem North .America Inc

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 25 March 2018 Appendix F Media Contacts

Television Stations; WVAS 90.7 FM: Jazz WSFA 12 South Jaclson Street 12 East Delano Avenue Montgomery, AL 36101 Montgomery, AL 36105 (334) 229-4708 (334) 288-1212 http ://wvasfm.org/ http ://www.wsfa.com/ WACV 93.1 FM: News/Talk Alabama News 4101-A Wall Street 3251 Harrison Road Montgomery, AL 36106 Montgomery, AL 36109 (334) 272-9228 (334) 270-9252 https://www.newstalk931 .com/ http ://www.alabamanews.net/ Y102 FM: Contemporary FOX 20 1 Commerce Street, Suite 300 1 WCOV Avenue Montgomery, AL 36104 Montgomery, AL 36111 (334) 240-9274 (334) 288-7020 http ://www. V102mont gomery. com/ http://www.wcov.com/ Kiss 96.1 FM: Adult Radio Radio Stations; 4101-A Wall Street WAPR 88.3 FM: Public Radio Montgomery, AL 36106 Digital Media Center (334) 396-5477 920 Paul Bryant Drive https://kiss961 .com/ Tuscaloosa, AL 35487 (205) 348 8620 WOOF 560 AM: Sports Talk http://apr.org/ 2518 Columbia Highway Dothmi, AL 36303 WLBF 89.1 FM: Christian (334) 792-1149 381 Mendel Parkway East http://www.woofradio.com/ Montgomery, AL 36117 (334) 271-8900 Newspapers; http ://www.faithradio.org/ Alabama News 1731 Avenue N. WTSU 88.9 FM: Public Radio Birmingham, AL 35203 Wallace Hall (205) 325-4444 Troy, Alabama 36082 http://www.al.com/ (800) 800-6616 http ://trovpublicradio.org/ Montgomery Advertiser 425 Molton Street Montgomery, AL 36104 (334) 262-1611 http://www.montgomervadvertiser.com/

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 26 March 2018 Digital Media; University of Alabama: Student Media http ://www.uab.edu/studentmedia/

Alabama Sports Blog https://www.rollbamaroll.com/

Alabama News & Sports https://bamahammer.com/

Alabama Lifestyle Blog http ://www.ouralabamalife.com/

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 27 March 2018 Appendix G Meeting Locations

Hunter Station Community Center 1010 Forest Avenue Montgomery, AL 36106 (334) 625-2300 http://www.funinmontgomerv.com/parks-items/liunter-station

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 28 March 2018 Appendix H Repository Locations

Local Repository: EPA Region 4 Repository:

Rufus Lewis Regional Library U.S. Environmental Protection Agency 3095 Mobile Highway 61 Forsyth Street, SW Montgomery, Alabama 36108 Sam Nunn Atlanta Federal Center, 9* Floor (334) 240-4848 Atlanta, GA 30303 (404) 562-8190 [email protected] 8:00AM-4:30PM Monday-Friday

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 29 March 2018 Appendix I Other Local Resources

Alabama Department of Environmental Management (ADEM) Heather Guerrero 1400 Coliseum Boulevard Montgomery, AL 36110 (334) 271-7700 http://adem.alabama.gov/inside/contact.cnt

The Alabama Department of Public Health (ADPH) 201 Monroe Street Montgomery, AL 36104 (866) 264-4073 http://www.alabamapublichealth.gov/

T.H. Agriculture & Nutrition Company Community Involvement Plan Page 30 March 2018 Appendix J Glossary

T. H. Agriculture (Montgomery) CIP Glossary

1. Aflniiiiistrative Record - All documents which the EPA considered or relied on in selecting the response action at a Superfund Site, culminating in the record of decision (ROD) for remedial action or. an action memorandum for removal actions, usually placed in the inlbnnation repository near the Site.

2. .\quifer - .An aquifer is an underground water supply one found in porous rock. sand. gravel, or the like.

3. Cleanup - .Action taken to respond to a hazardous material release or threat of a release that could atTect humans and or the environment. .Also called remedial action, removal action, response action, or coirective action.

4. Coiiipreheiisi\e Eii\1roiiiiieiital Response, Coinpensation and Liability .Act (CERCL.A) - .Also known as Superfund, is a federal law passed in 1980 and modified in 1986 by the Superfund .Amendment and Reauthorization .Act (S.AR.A): the act created a trust fund, to investigate and cleanup abandoned or uncontrolled hazardous wa.ste sites. Tlie law authorizes the federal government to respond directly to releases of luizardous substiinces that may endanger public health or the environment. Tlie EP.A is responsible for managing the Superfund.

5. Contaniuiation - The act of contaminating, or of making something impure or unsuitable by contact with something unclean, bad. etc.

6. Five Year Review - Pursuant to CERCL.A a five-yeiu* review is required if the remedial action results in haziu'dous substances, pollutants, or contaminants remaining at the Site above levels that allow for unlimited use and unrestricted exposure. Tins review evaluates whether such a remedy is protective of human health and the environment and is required no less often than even five years after the start of the cleanup.

7. Groundwater - Water held underground in the soil or in pores iind crevices in rock.

8. Groundwater Extraction System - S\stems that pump contiiminated groundwater from an aquifer on a long-tenn basis. Groundwater exiraction requires treatment and proper disposal of the pumped groundwater.

9. Institutional Controls (ICs) - Non-engineered instruments, such as administrative iind legal controls, that help minimize the potential for human exposure to contamination and or protect the integrity of the remedy. .Although it is the EP.A's expectation that

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 31 March 2018 treatment or engineering controls will be used to address principal tlu'eat wastes and that groundwater will be returned to its beneficial use whenever practicable. ICs play an important role in Site remedies because they reduce exposure to contamination by limiting land or resource use and guide humiin behavior at a Site.

10. Lagoon - .Aji artificial pool for storage and treatment of polluted or excessively hot sewage, industrial waste, hazardous waste, wastewater, etc.

11. Potentially Responsible Party (PRP) - Piulies that have been found to be potentially legally responsible for contamination and or cleiinup at a Site. Ihider Superfund. PRPs can include persons (including compiinies) that are owners or operators of Superfund designated Sites, persons who airanged for disposal of hazardous substances at a Superfund Site, or certain persons who transported hazardous substances to a Superfund Site.

12. Remedial Investigation/Feasibility Study (RI/FS) - Tlie remedial investigation (RI) serves as the mechanism for collecting data to chiU'acterize Site conditions, detennine the nature of the waste, assess risk to human health iind the environment, and conduct treatability testing to evaluate the potential perfonnance and cost of the treatment technologies that are being considered. Tlie feasibility study (FS) is the mechanism for the development, screening, and detailed evaluation of alternative remedial actions.

13. Seduiient - Soils, sand, orgiinic matter, or minerals that accumulate on the bottom of a water body or at some point in time are submerged.

T.H. Agnculture Nuthtion Company Community Involvement Plan Page 32 March 2018