Fifth Five Year Review Report

FIFTH FIVE-YEAR REVlEW REPORT FOR SALTVILLE WASTE DISPOSAL PONDS SUPERFUND SITE SMYTH COUNTY, VlRGINIA

SEPTEMBER 2017

Prepared by

U.S. Environmental Protection Agency Region 3 Philadelphia, Pennsylvania

SEP 2 6 2017

Karen Melvin, Director Date Hazardous Site Cleanup Division U.S. EPA, Region III

Table of Contents LIST OF ABBREVIATIONS & ACRONYMS ...... 2 I. INTRODUCTION...... 3 Site Background ...... 3 FIVE-YEAR REVIEW SUMMARY FORM ...... 6 II. RESPONSE ACTION SUMMARY ...... 6 Basis for Taking Action ...... 6 Response Actions ...... 7 Status of Implementation ...... 8 Systems Operations/Operation & Maintenance ...... 12 III. PROGRESS SINCE THE PREVIOUS REVIEW ...... 13 IV. FIVE-YEAR REVIEW PROCESS ...... 15 Community Notification, Involvement & Site Interviews ...... 15 Data Review ...... 16 Site Inspection ...... 19 V. 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 action objectives (RAOs) used at the time of the remedy selection still valid? ...... 20 QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy? ...... 21 VI. ISSUES/RECOMMENDATIONS ...... 21 OTHER FINDINGS ...... 22 VII. PROTECTIVENESS STATEMENT ...... 22 VIII. NEXT REVIEW ...... 23 APPENDIX A – REFERENCE LIST ...... A-1 APPENDIX B – SITE CHRONOLOGY ...... B-1 APPENDIX C – SITE MAPS ...... C-1 APPENDIX D – SITE INSPECTION CHECKLIST ...... D-1 APPENDIX E – PRESS NOTICE ...... E-1 APPENDIX F – SITE INSPECTION PHOTOS ...... F-1 APPENDIX G – SELECTED TABLES AND CHARTS FROM 2015 ANNUAL MONITORING REPORT ... G-1 APPENDIX H – INTERVIEW FORMS ...... H-1 APPENDIX I – SMYTH COUNTY PUBLIC WATER ORDINANCE ...... I-1

LIST OF ABBREVIATIONS & ACRONYMS

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations EPA United States Environmental Protection Agency FCPS Former Chlorine Plant Site FYR Five-Year Review IC Institutional Control LTMP Long-Term Monitoring Plan MCL Maximum Contaminant Level µg/L Micrograms per Liter mg/kg Milligrams per Kilogram ng/L Nanograms per Liter NCP National Contingency Plan NPL National Priorities List Olin Olin Corporation O&M Operation and Maintenance OU Operable Unit PRP Potentially Responsible Party RAO Remedial Action Objective RCRA Resource Conservation and Recovery Act RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision RPM Remedial Project Manager TMDL Total Maximum Daily Load UU/UE Unlimited Use and Unrestricted Exposure VDEQ Virginia Department of Environmental Quality

I. INTRODUCTION

The purpose of a five-year review (FYR) is to evaluate the implementation and performance of a remedy to determine if the remedy is and will continue to be protective of human health and the environment. The methods, findings and conclusions of reviews are documented in FYR Reports such as this one. In addition, FYR Reports identify issues found during the review, if any, and document recommendations to address them.

The U.S. Environmental Protection Agency (EPA) is preparing this FYR pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the National Contingency Plan (NCP) (40 CFR Section 300.430(f)(4)(ii)), and considering EPA policy.

This is the fifth FYR for the Saltville Waste Disposal Ponds Superfund site (the Site). The triggering action for this statutory review is the completion date of the previous FYR. The FYR has been prepared because hazardous substances, pollutants or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure (UU/UE).

The Site consists of four operable units (OUs), three of which will be addressed in this FYR. OU1 addresses Pond 5 surface water diversion. OU2 addresses the wastewater treatment plant for Pond 5 leachate. OU3 addresses the Pond 5 cap, Pond 6 soil cover, 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. OU4 addresses mercury impacts at the Former Chlorine Plant Site (FCPS) and mercury impacts on the North Fork Holston and Holston Rivers. OU4 is not addressed in this FYR because it is still in the remedial investigation phase.

The FYR was led by EPA remedial project manager (RPM) Andrea Bain. Participants included EPA community involvement coordinators Vance Evans and Kimberly Scharl, EPA hydrogeologist Mindi Snoparsky, and William Lindsay from Virginia Department of Environmental Quality (VDEQ). The review began on 9/26/2016.

Appendix A includes a list of documents reviewed for this FYR. Appendix B includes a site chronology.

Site Background

The 125-acre Site is located in Saltville, Virginia, along the north bank of the North Fork Holston River (Figure 1). Olin Corporation (Olin), the Site’s potentially responsible party (PRP), made various chemicals on site from about 1895 to 1972, including chlorine gas from 1950 to 1972. Mercury, lost during the production process of chlorine gas, was mixed with wastewater and conveyed to Pond 5 and, to a lesser extent, Pond 6. The solids settled in the disposal ponds and the remaining wastewater was discharged to the North Fork. During Olin’s operation 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. Mercury was also released to soil, groundwater and surface water at the FCPS via spills and during routine facility washing operations.

The Site includes the FCPS; two waste disposal ponds, Pond 5 and Pond 6; and the North Fork Holston and Holston rivers (Figure C-2). The waste disposal ponds were used primarily to settle alkaline solids from waste slurry generated by the soda ash (sodium carbonate) manufacturing process. The settled solids are referred to as ammonia soda ash waste. Pond 5 and its dike cover about 76 acres. Pond 6 is located immediately west and downstream of Pond 5. Pond 6 and its dike cover about 45 acres.

The dikes containing the ponds were constructed of rockfill cores (starter dikes) and built up with accumulations of spent coke and roasted limestone waste. The Pond 5 dikes are about 100 feet high. The depth of settled solids varies from about 35 feet to 70 feet, with an average depth of about 63 feet. The Pond 6 dikes are about 35 feet high and the depth of the solids varies from about 20 feet to 30 feet. Until 1994, surface water runoff and 3

groundwater contaminated by leachate from Pond 5 collected in a decant structure at the southwest corner of the pond. The structure discharged directly to the North Fork Holston River through an outfall. Overall shallow groundwater flow within the ammonia soda ash waste and the underlying alluvium is toward the south from Little Mountain to the river.

The Town of Saltville gets its water from two different sources. A Smyth County municipal ordinance requires the connection of residential and industrial developments in the area to the municipal water supply system (Appendix I). This system is the source of water for all residences and industrial operations near the Site. A dry ice facility to the immediate northwest of the FCPS, upgradient from the site, is connected to the municipal system, but reportedly also has a private water supply well. This is the only known private well that may still be in use in areas underlain by groundwater potentially impacted by the Site. It is sampled by the PRP. This facility does not generate wastewater and/or discharge wastewater to surface water.

The Site is currently not in use. Three residential areas are located immediately upgradient of Ponds 5 and 6. Land uses adjacent to the FCPS are industrial. They include 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 North Fork Holston River) and an auto repair/welding shop to the south (also across the North Fork Holston River).

Figure 1. Site Vicinity

• Saltville, VA

0 1,000 2,000 4,000 Legend Feet Sources: Esri, DeLorme, AND, Tele Atlas, First American, UNEP-WCMC, USGS, DigitalGlobe, Approximate Pond GeoEye, Earth star Geographies, CNES/Airbus OS, USDA, AEX, Getmapping, Aerogrid, IGN, /GP, 1111 Caps & Covers swisstopo, the GIS User CommunitY, the 2012 FYR and the 2016 Olin Pond 5 OU2 Work Plan. () Saltville Waste Disposal Ponds Superfund Site NORTH Town of Saltville, Smyth and Washington Counties, Virginia

Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only regarding EPA’s response actions at the Site.

FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION Site Name: Saltville Waste Disposal Ponds EPA ID:VAD003127578 Region: 3 State: Virginia City/County: Saltville/Smyth

SITE STATUS NPL Status: Final Multiple OUs? Has the site achieved construction completion? Yes No

REVIEW STATUS Lead agency: EPA Author name: Andrea Bain, EPA Remedial Project Manager, with additional support provided by Skeo

Author affiliation: EPA Region 3 Review period: 9/26/2016 – 9/27/2017 Date of site inspection: 12/6/2016 Type of review: Statutory Review number: 5 Triggering action date: 9/27/2012 Due date (five years after triggering action date): 9/27/2017

II. RESPONSE ACTION SUMMARY

Basis for Taking Action

Environmental studies of the Site began in conjunction with heightened concern about mercury discharges nationwide. An investigation of the plant site and adjacent river by Olin, the Commonwealth of Virginia, and local agencies during the late 1960s revealed mercury contamination at the Site, including in the North Fork Holston River. In 1970, as a result of mercury concentrations found in fish, both Virginia and Tennessee placed fishing in the river under a health advisory.

A Saltville Site Task Force formed in 1978. It included the Virginia State Water Control Board, the Virginia Attorney General’s Office, the Tennessee and Virginia Departments of Health, the Tennessee Valley Authority, and EPA. The Task Force required that Olin conduct studies to identify the sources of mercury contamination at the Saltville facility and negotiated cleanup measures to reduce mercury loading to the river. EPA listed the Site on the Superfund program’s National Priorities List (NPL) on September 8, 1983.

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 ongoing investigations conducted under a 1982 special order between Olin and the Virginia State Water Control Board. EPA conducted a risk assessment based on all available data to determine what data gaps existed. Several data gaps were identified in the 1986 risk assessment, although EPA determined that some initial steps could be taken to address environmental problems at the Site.

Olin entered into a Consent Decree with EPA in 1988, agreeing to implement interim remedial actions and to conduct the RI/FS studies. The final RI and risk assessment reports were accepted by EPA in December 1994, and the final FS for Pond 5 and Pond 6 was accepted by EPA in January 1995. The 1995 risk assessment identified unacceptable noncarcinogenic risks from mercury by hypothetical future residents. EPA determined workers at a hypothetical future industrial facility on Pond 5 could be exposed to a noncarcinogenic risk level equal to the acceptable threshold (Hazard Index of 1.0).

Response Actions

Prior to the Site being listed on the NPL, under a special order issued by the Virginia State Water Control Board in 1982, Olin performed bank stabilization measures to reduce erosion of mercury-contaminated soil to the North Fork Holston River. Olin also dredged mercury-contaminated sediments from a 1,000-foot section of the North Fork Holston River next to and downstream of the FCPS. Excavated sediments were placed in a lined cell on the foundation of a former building at the FCPS. The sediments were then covered with 2 feet of clay and 6 inches of topsoil. A diversion ditch was constructed around the western, upstream side of Pond 5 to reduce surface water flow onto the pond (the western diversion ditch). The western diversion ditch captures surface water flowing from four natural swales then conveys the water to the North Fork Holston River by gravity flow.

In June 1987, EPA issued an interim Record of Decision (ROD) that identified measures to be taken to reduce the migration of mercury to the North Fork Holston River. The 1987 ROD defined three OUs, which were later modified to those outlined in the Introduction of this FYR. OUs and remedial components of the 1987 ROD include:

• Runoff/run-on controls for Pond 5. • Pumping and treatment of Pond 5 outfall/discharge and installation of groundwater monitoring system.

EPA issued a second ROD in 1995 addressing Pond 5 and Pond 6, and upgrading the water treatment plant to meet more stringent discharge standards for mercury abatement in Pond 5 leachate. The 1995 ROD identified the following remedial objectives:

• Reduce infiltration of surface water and migration of contaminants into groundwater at Pond 5. • Prevent human contact with waste material in Pond 6. • Neutralize discharge from Pond 6 decant structure. • Include contingent remedy if groundwater monitoring wells demonstrate that mercury-contaminated groundwater in Pond 6 is migrating toward the North Fork Holston River.

The 1995 ROD selected the following major remedy components:

• Pond 5 • Installation of multi-layered Resource Conservation and Recovery Act (RCRA) cap over Pond 5 to reduce infiltration of surface water and migration of contaminants into the groundwater. • Installation of upgradient groundwater interceptor system to minimize upgradient subsurface flow from coming in contact with contaminated waste in Pond 5.

• Revision of effluent discharge limit for existing Pond 5 treatment facility to achieve current Virginia surface water standard for mercury, and implement any modification of Pond 5 treatment facility necessary to achieve the revised discharge limits.

• Pond 6 • Installation of permeable soil cover over Pond 6, including demolition debris burial area. • Construction of pH adjustment system to neutralize the leachate discharge from the Pond 6 decant structure. • Installation of one or more groundwater monitoring wells downgradient of the Pond 6 buried debris area to detect any mercury that may be migrating toward and ultimately discharged into the North Fork Holston River. Implementation of the following contingent remedy if it is demonstrated that mercury contamination from the buried debris is migrating through the groundwater in Pond 6 toward the North Fork Holston River: • Placing vertical barrier wall around perimeter of FCPS demolition debris buried in eastern end of Pond 6 to contain waste. • Installing a multi-layered RCRA cap over area where the debris is buried.

• Elements Common to Selected Remedies for both Pond 5 and Pond 6 • Institutional controls to prohibit development of Pond 5 and Pond 6 property and prohibit use of groundwater from Pond 5 and Pond 6 as a potable source. • Implement a long-term site maintenance program and operation and maintenance (O&M) program. • Conduct long-term groundwater monitoring to evaluate subsurface flow conditions and water quality in Pond 5 and Pond 6 areas, specifically seepage of contaminated groundwater migrating through the dikes to the North Fork Holston River. • Sample monitoring wells for mercury quarterly for 30 years. • Sample Pond 6 decant structure outfall for mercury and pH quarterly for 30 years.

The 1995 ROD remedy also included upgrading the on-site wastewater treatment plant (OU2) as needed to comply with effluent limits established to meet current Virginia surface water quality standards for mercury.

The RI/FS for OU4 is ongoing. The RI for OU4 includes an assessment of risks posed by site-related mercury to biological receptors in the North Fork Holston River and Holston River watersheds.

The Virginia Department of Health has issued a “Do Not Eat” fish consumption advisory for the North Fork Holston River from Saltville to the Virginia/Tennessee border approximately 80 river miles downstream.

Status of Implementation

In 1991, Olin constructed a water treatment plant to remove mercury from leachate generated at Pond 5, and constructed a network of surface water diversion ditches to intercept clean stormwater flowing toward the waste impoundments and convey this water directly to the North Fork Holston River.

From 1993 to 1994, Olin contractors constructed the water treatment plant (OU2). EPA and the State conducted an inspection on November 28, 1994, and approved the operations.

In 1997, Olin entered into a second Consent Decree wherein it agreed to implement the actions selected in the 1995 ROD. From 2001 to 2003, Olin contractors implemented the OU3 remedy including:

• Installing additional site security fence around Ponds 5 and 6.

• Constructing 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 valuable wildlife habitat as beneficial reuse. • Upgrading Little Mountain swales 1-5 to intercept clean, shallow groundwater and route augmented flow to rehabilitated western and eastern diversion ditches leading to North Fork Holston River. • Closing Pond 6 outfall to eliminate discharge of high pH effluent to North Fork Holston River, retrofitting stilling well (collection station) to accept effluent from Pond 6, installing vertical turbine pumps to pump Pond 6 effluent from stilling well to the existing treatment plant, installing new section of force main tied in to existing Pond 5 force main, pumping Pond 6 effluent to treatment plant for pH adjustment to within range of 6 to 9. • Constructing a multi-layered RCRA-Subtitle C compliant landfill cap on Pond 5 with a profile (from bottom up) of 40-mil Linear Low Density Polyethylene geomembrane, a geosynthetic clay liner (in areas of less than two percent slope and drainage swales), a geocomposite drainage layer, and a 24-inch thick soil layer vegetated with diverse seed mix to provide wildlife habitat as beneficial reuse.

Prior to July 1994, effluent drained by gravity from Pond 5 through the Pond 5 Outfall to the North Fork Holston River. The Pond 5 treatment plant was constructed as part of the OU1 remedial action. The outfall tunnel was sealed and converted to a pumping station. Effluent from the Pond 5 Pumping Station is transferred via a dual- containment force main to an equalization basin and then to the Pond 5 treatment plant.

Prior to November 2001, effluent drained by gravity from Pond 6 through the Pond 6 Outfall to the North Fork Holston River. As part of the remedial action, the Pond 6 Lift Station was constructed and the outfall tunnel was diverted to the lift station. The discharge point to the North Fork Holston River was sealed. Effluent from the Pond 6 Lift Station is transferred via a dual-containment force main to the equalization basin and then to the Pond 5 treatment plant.

At the Pond 5 treatment plant, effluents from Ponds 5 and 6 are collected in the equalization basin and treated at the Pond 5 treatment plant prior to discharge to the North Fork Holston River. Influent to the Pond 5 treatment plant is treated via carbon adsorption. Treated water from the carbon units flows to a clear well with a storage capacity of 12,000 gallons. From the clear well, the treated water passes through a pH and flow monitoring station and then flows via gravity to the river outfall.

Analytical results for near-bank NFHR surface water samples indicated higher mercury concentrations adjacent to the eastern end of Pond 5 in the vicinity of the former NFHR channel. In 2012 and 2013 EPA requested Olin evaluate the feasibility of reducing mercury discharge from groundwater beneath the Pond 5 dike in the former river channel area and achieving measurable reductions in surface water concentrations. Olin developed work plans to investigate subsurface conditions beneath the Pond 5 dike and to conduct a pumping test to provide a design basis for a pilot extraction system. Upon completion of the pumping test, Olin and EPA agreed that additional data would be necessary to properly site and design a pilot groundwater extraction system to reduce near-bank mercury concentrations in the North Fork Holston River in the area of the former river channel.

In 2016, EPA directed Olin to modify the OU2 groundwater pumping and treatment system at Pond 5 to include pumping and treatment of groundwater to reduce the discharge of mercury-contaminated groundwater into the North Fork Holston River between river mile 82.2 and 82.4. Specifically, the letter recommends and directs that Olin initiate continuous pumping of groundwater in monitoring wells MW-119S and PZ-10, and treat the pumped groundwater on site before discharge to the North Fork Holston River. On March 21, 2017, Olin completed the field construction to modify the existing pump and treat system to include MW-119S and Z-10.

Institutional Control Review

Institutional controls were recorded for Ponds 5 and 6 and the FCPS in Smyth and Washington County in March 2007. Olin and the Commonwealth of Virginia signed an Environmental Protection Easement and Declaration of Restrictive Covenants, which includes the following restrictions: 9

• Prohibit development of (Ponds 5 and 6) and prohibits any type of activity that could disturb the surface or the underlying waste, as well as the use of groundwater from that area as a source of potable water, or in any way increase the risk of exposure to contaminants on the property, except for activities performed by Olin, or its representatives, to comply with the 1995 ROD-2 or any order issued by the United States governing activity at or on said property.

• Prohibit residential development of the FCPS and prohibits the use of groundwater found on or under the FCPS as a source of potable water, as well as any type of activity that would require excavation into or through, or any form disturbance of, the clap cap located on the FCPS.

Olin also granted the Commonwealth of Virginia an irrevocable, permanent and continuing right of access, at all reasonable times, to Ponds 5 and 6 for purposes of inspecting site conditions. See Table 1 and Figure 2.

Table 1: Summary of Implemented Institutional Controls (ICs) Media, Engineered ICs Called Controls and Areas Title of IC Instrument ICs for in the Impacted IC that Do Not Support Implemented and Date Needed Decision Parcel(s) Objective UU/UE Based on (or planned) Documents Current Conditions Prohibits development of Ponds 6; prohibits any, activities that would affect the Pond 2007 Environmental Soil and Ponds 5 and 5 cap and Pond 6 Protection Easement and Yes Yes Groundwater 6 cover; and prohibits Declaration of Restrictive use of groundwater Covenants from the Pond 5 and Pond 6 area as a potable water source Prohibits residential development of the FCPS; prohibits the use of groundwater found on or under the FCPS as a potable 2007 Environmental Soil and water source; and Protection Easement and Yes Yes FCPS Groundwater prohibits any type of Declaration of Restrictive activity that would Covenants require excavation into or through, or any form of disturbance of the clay cap located on the FCPS

Figure 2: Institutional Control Map

0 1,000 2,000 4,000 Legend Feet Approximate Pond Areas Under the 2007 Sources.· Esri, Digita/Globe, GeoEye, Earthstar Geographies, CNES/Airbus OS, USDA, USGS, AEX, Getmapping, Aerogrid, JGN, /GP, swisstopo, the GIS User Community, DeLorme, AND, Tele Atlas, First ~ Environmental Protection Easement and American, UNEP-WCMC, the 2012 FYR and the 2016 Olin Pond 5 OU2 Work Plan. Declaration of Restrictive Covenants

Saltville Waste Disposal Ponds Superfund Site 0 Town of Saltville, Smyth and Washington Counties, Virginia NORTH

Systems Operations/Operation & Maintenance

Primary O&M activities for the 1995 ROD remedy include inspection and maintenance of site security fencing, access roads, eastern and western diversion ditches, Pond 5 and Pond 6 dikes, monitoring wells, the swale interceptor system, the Pond 5 cap, the Pond 6 cover and associated surface drainage systems. The five surface water drainage channels are inspected for erosion, standing water, and vegetation, sediments, or other obstructions.

The ROD states that the inspection and maintenance of the Pond 5 and Pond 6 impoundment structures shall be in compliance with Virginia Department of Conservation and Recreation Impounding Structure Regulations VR 625-01-00, which was superseded on July 1, 2002 with 4VAC 50-20 which requires periodic inspections. Olin conducts visual inspections of the dikes for erosion. EPA in consultation with VA is determining if additional dike inspection requirements need to be added to the monitoring plan.

Olin conducts site wide inspections quarterly per the 1995 ROD and performs repairs as needed based on the inspections. Settlement of the Pond 5 cap and grade reversals in drainage channels may cause localized depressions that result in ponding or saturation above the geomembrane. In this case, permanent settlement monuments are surveyed annually to detect any settlement or grade reversals of concern. A mowing plan for Pond 5 prevents colonization of woody plants with tap roots capable of damaging the geomembrane while maintaining wildlife habitat in the area. Pond 6 has less stringent mowing requirements (i.e., there is no geomembrane to maintain) and supports wildlife habitat. Olin inspects the acid storage tank and equalization basin at the treatment plant for leakage. Olin submits an annual O&M Report to EPA documenting inspection results, any identified deficiencies, and associated corrective measures.

Long-term monitoring required by the 1995 ROD consists of monitoring of treatment plant effluent and monitoring of groundwater. These activities are identified in the Site’s Long-Term Monitoring Plan (LTMP) and O&M Plan dated March 27, 2001.

Effluents from Ponds 5 and 6 are collected in the equalization basin and treated at the Pond 5 treatment plant prior to discharge to the North Fork Holston River. The Pond 5 treatment plant operates intermittently as required to treat water collected in the equalization basin. On days when the treatment plant operates and water is discharged to the North Fork Holston River, a daily composite sample of treated water is collected. The sample is tested for total mercury and pH to confirm that the Pond 5 treatment plant is operating as required to meet VDEQ discharge limits for mercury and pH.

III. PROGRESS SINCE THE PREVIOUS REVIEW

This section includes the protectiveness determinations and statements from the previous FYR as well as the recommendations from the previous FYR and the current status of those recommendations.

Table 2: Protectiveness Determinations/Statements from the 2012 FYR Protectiveness OU # Protectiveness Statement Determination 1, 2 and 3 Protective The remedy selected in ROD-1 (OU1 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-1. 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 “Do Not Eat” fish consumption advisory placed on the North Fork Holston River by Virginia Department of Health, the remedies selected in ROD-1 and ROD-2 are protective of human health.

Table 3: Status of Recommendations from the 2012 FYR Completion OU Current Current Implementation Status Issue Recommendation Date (if # Status Description applicable) 3 LTMP for Pond 5 Modify LTMP for Under Olin modified the LTMP to and/or Pond 6 Pond 5 and/or Discussion include the new Pond 5 wells. groundwater may Pond 6 Since then, EPA has conducted need to be modified groundwater as additional investigations and will depending on results needed based on require additional monitoring and of ongoing RI. results of ongoing LTMP modifications. EPA and RI. the PRP will determine the appropriate timeframe to update the O&M for OU3, based on the data being collected as part of the OU4 investigation. 3 Certain wells Repair or replace Completed Olin completed this 6/20/2013 included in current damaged wells recommendation. LTMP are damaged included in LTMP and cannot be as needed. sampled.

Completion OU Current Current Implementation Status Issue Recommendation Date (if # Status Description applicable) 2/3 Unclear whether Confirm current Ongoing In 2014, VDEQ sent letter to Olin current effluent effluent limitations confirming the 2000 discharge limitations for on-site for on-site limits remain valid. This is still mercury treatment treatment plant are consideration by EPA due to the plant are consistent consistent with ongoing remedial investigation. with Virginia water Virginia water quality standard for quality standard for methylmercury and methylmercury and North Fork Holston North Fork River Mercury total Holston River maximum daily load Mercury TMDL (TMDL) Report. In Report (or modify addition, effluent as needed) once the limitations for on-site contribution of treatment plant are different sources of not identified in the mercury to the LTMP. North Fork Holston River are determined by ongoing investigations. Include effluent limitations in the LTMP. 3 Unclear whether Modify O&M Plan Under In 2014, Virginia Department of dikes for Pond 5 and as needed to ensure Discussion Conservation and Recreation Pond 6 are in that Pond 5 and provided a letter to Olin compliance with Pond 6 dikes are in indicating Virginia dam laws are Virginia compliance with not applicable to Ponds 5 and 6. impoundment Virginia However, EPA and VDEQ are regulations. impoundment reviewing state regulations and regulations. historical dike stability studies to determine if Virginia dam regulations are relevant and appropriate. Additional routine inspection components based on standard industry standards may be added to the O&M plan.

Completion OU Current Current Implementation Status Issue Recommendation Date (if # Status Description applicable) 3 Quarterly sampling Include results of Considered EPA and the PRP are results for Pond 6 quarterly Pond 6 But Not determining if a formal decant structure are decant structure Implemented modification to the monitoring not being provided in sampling in requirements is needed. The reporting of long- reporting of long- ROD required sampling of the term monitoring. term monitoring. Pond 6 decant structure due to Pond 5 decant Add quarterly the Pond 6 outfall not being structure is not being sampling of Pond 5 treated. However, the Pond 6 monitored. decant structure to outfall was subsequently plugged long-term and the Pond 6 decant is now monitoring. pumped to the treatment plant. Currently, the PRP is conducting the required sampling of the Pond 6 decant structure, but intends to request that this monitoring be ended since the water is ultimately treated. The Pond 5 decant structure is not being monitored. However, the lack of monitoring or reporting of monitoring data does not affect current protectiveness. 2/3 O&M plans for on- Modify O&M Completed Olin submitted an updated October 18, site treatment plant plan(s) for on-site treatment plant O&M plan in 2013 do not reference treatment plant as October 2013. regulatory needed to reference requirements to be regulatory considered in plant requirements and O&M or include include the inspection, inspection, monitoring and monitoring and reporting activities reporting activities necessary to meet necessary to meet these requirements. these requirements.

IV. FIVE-YEAR REVIEW PROCESS

Community Notification, Involvement & Site Interviews

A public notice was made available by newspaper posting, in the Smyth County News and Messenger on 8/5/2017 (Appendix E). It stated that the FYR was underway and invited the public to submit any comments to EPA. The results of the review and the report will be made available at the Site’s information repository, located at Smyth- Bland Regional Library, located at 111 Palmer Avenue in Saltville.

During the FYR process, interviews were conducted to document any perceived problems or successes with the remedy that has been implemented to date. The results of these interviews are summarized below and included in Appendix H.

Interviewed residents are generally pleased with the site cleanup, but would like fact sheets or other information shared, as appropriate.

The state project manager noted this is a large and complex project requiring a long-term commitment by Olin Corporation, EPA and VADEQ. Cleanup activities and operation and maintenance will continue for the existing remedy in place, and that additional remedial actions will also be required.

Representatives from Olin believe the remedies in place are working as designed and are effectively reducing environmental exposures.

Data Review

Current Site monitoring includes sampling of groundwater, surface water drainage, treatment plant effluent, monument stability, sediments, river water and river biota. Data summarized in this FYR pertain to OU1, OU2 and OU3. Select tables and charts from the most recent annual monitoring report are included in Appendix G.

Surface Water Drainage Surface water in the Pond 5 and Pond 6 diversion ditches and dike cuts is tested annually for mercury concentrations. All samples in 2014 and 2015 were below the detection limit of 0.1 µg/L for mercury (Appendix G).

Monument Survey Settlement monuments were established as a part of the Pond 5 closure. Monuments were installed to monitor the grades along the drainage channels and on the cover surface. The total settlement is calculated and the grades along the drainage channels and cover surface are determined once every five (5) years. Based on inspection of the cap for settlement and approval by the EPA, the requirement to perform an annual monument survey was deferred in 2013, 2014, and 2015. The most recent survey was conducted in 2016 and settlements indicated by those data were within the range predicted in the design report.

Treatment Plant Effluent

Effluent data for 2015 and 2016 are included in Appendix G. The Pond 5 treatment plant operates intermittently as required to treat water collected in the equalization basin. The number of Pond 5 treatment plant effluent samples collected is dictated by the number of days the treatment plant operates. A daily composite sample is collected on each day of operation.

The samples are tested for total mercury and pH to confirm that the Pond 5 treatment plant is operating as required to meet the VDEQ discharge limits for mercury (3.6 µg/L) and pH (between 6 and 9 standard units). Results indicate compliance with applicable discharge standards. The maximum 2016 concentration of total mercury in the treated discharge was 0.39 µg/L.

Groundwater

Sampling of groundwater monitoring wells at Pond 5 and Pond 6 began in 2003. Olin collects groundwater samples quarterly or semi-annually from monitoring wells in the Pond 5 and 6 areas (Figure C-3 and C-4). Monitoring wells include:

• Background monitoring wells – MW-16 and CP-13, located northeast of Ponds 5 and 6 near the FCPS to monitor background/upgradient groundwater quality. • Trigger wells – MW-104D and MW-105D, to monitor the demolition debris burial area in northeast corner of Pond 6. • Pond 5 Dike Wells – to monitor groundwater quality conditions along the Pond 5 Dike. • Pond 6 Dike Wells – to monitor groundwater quality conditions along the Pond 6 Dike.

The objective of the 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 of 1995 ROD, monitoring includes quarterly sampling of any new wells approved by EPA during the remedial design. Although specific cleanup goals are not defined in the existing RODs, the mercury maximum contaminant level (MCL) of 2 µg/L is applied for assessing groundwater, as well as overall contaminant trends.

Long-term groundwater monitoring results for Pond 5 and Pond 6 are included in Appendix G. During 2015, the maximum total mercury detections in Pond 5 wells was 8.9 µg/L. 2015 data include exceedances of the mercury MCL in wells MW-5S, MW-5I, MW-5D, MW-7I and MW-7D. Pond 6 dike wells included two exceedances of the MCL in 2014 (MW-104S and MW-105S, September 2014) and one exceedance in 2015 (MW-105S, June 2015).

Monitoring wells MW-104D and MW-105D are intended to monitor potential migration of mercury from the debris disposal area in Pond 6. The maximum detection in MW-104D in 2014-2015 was 2.0 µg/L. Concentrations in MW-105D vary quarterly, with high exceedances in June 2014 (162 µg/L) and June 2015 (127 µg/L).

EPA had determined that Pond 5 may still be contributing to elevated levels of mercury in the North Fork Holston River. Following discussions in 2012 and 2013, EPA directed Olin to develop a pilot extraction system to evaluate the feasibility of reducing mercury discharge from groundwater beneath the Pond 5 dike in the former river channel area (Figure C-5). A dye tracer study conducted in 2015 provided additional information about the groundwater flow paths to the river to support the design of this pilot. A pumping system was designed to reduce the concentration of mercury as well as elevated pH attributable to dike seepage in the area of the former river channel at the upstream end of Pond 5. Groundwater is extracted from MW-119S and PZ-10 (Figure C-6). The groundwater flow path is likely to move from these wells and seep into the river through the riverbank. To measure the performance of the pumping system, monitoring of adjacent monitoring wells and near-bank surface water in the river will be conducted as outlined in a performance monitoring plan.

In March of 2016, EPA, VDEQ and Olin personnel conducted a site tour to examine seep locations and collect pH measurements of surface water seeps, drainage channels, and the receiving stream, NFHR. Several locations of seeps had pH results that could potentially expose recreational users of the NFHR to high pH water exceeding 12.5. On August 16, 2017 Olin and EPA entered into an Administrative Order on Consent (AOC) to mitigate the human health risks associated with coming into contact with elevated pH. The objectives of the AOC are to prevent physical contact with high pH discharging from Pond 5 and Pond 6 and perform an initial comprehensive Site assessment along the entire right descending bank of the NFHR adjacent to Pond 5 and 6, to identify any additional seep areas with a pH level that poses a human health risk.

OU4 Remedial Investigation

Ongoing OU4 investigations include regular sampling of river water, sediments and river biota and will be the subject of future decision documents and therefore are not considered in this five-year review.

Figure 3: Detailed Site Map

0 1,000 2,000 4,000 Legend Feet Sources.· Esri, Digita/Globe, GeoEye, Earthstar Geographies, CNES/Airbus OS, USDA, USGS, AEX, c:::J Approximate Pond Caps & Covers Getmapping, Aerogrid, JGN, /GP, swisstopo, the G/S User Community, DeLorme, AND, Tele Atlas, First American, UNEP-WCMC, the 2012 FYR and the 2016 Olin Pond 5 OU2 Work Plan.

Saltville Waste Disposal Ponds Superfund Site 0 Town of Saltville, Smyth and Washington Counties, Virginia NORTH

Site Inspection The site inspection took place on 12/6/2016 – 12/7/2016. In attendance were EPA remedial project manager Andrea Bain; EPA community involvement coordinators Vance Evans and Kimberly Scharl; EPA hydrogeologist Mindi Snoparsky; Sandip Chattopadhyay from EPA’s Office of Research and Development; Dan Sirkis from the U.S. Army Corps of Engineers; William Lindsay from VDEQ; Keith Roberts, Stanley Haynes and Julie Irwin from PRP Olin; Pete Ingraham from PRP contractor Golder Associates; and Melissa Oakley and Kelly MacDonald from EPA contractor Skeo. The purpose of the inspection was to assess the protectiveness of the remedies in the 1987 interim ROD and 1995 ROD. See Appendix D for the site inspection checklist and Appendix F for site photos.

The site inspection team met at the Olin trailer on site and discussed relevant site activities, such as the upcoming connection of MW-119S and PZ-10 to the leachate treatment plant, issues and recommendations from the previous FYR, and daily facility operations. Participants then inspected the Pond 5 cap, the Pond 6 cover, the treatment plant, the equalization basin, three dike cuts, the eastern and western diversion ditches, surface drainage features, swales, the treatment plant/diversion ditch outfall, Pond 5 and 6 decant structures, the Pond 6 pumping station, monitoring wells, fencing along the site, and the North Fork Holston River and fish consumption warning signs near the river. All monitoring wells observed were secured with locks and clearly labeled. Vegetation on Pond 5 and Pond 6 appeared healthy and well-established. Pond 5 was vegetated with grass. Pond 6 had a variety of larger vegetation to attract wildlife, including trees and shrubs; deer were spotted on site. Site inspection participants observed minimal vegetation growing in the western diversion ditch; it did not impede water flow. A locking gate restricts access to the Olin trailer, Ponds 5 and 6, and the leachate treatment plant. Participants noted several areas of damaged fencing. In addition, participants noted pink, tan, and white discoloration and foaming on the Pond 6 dike cuts, and foaming and discoloration of surface water in the North Fork Holston River where the dike cuts discharge into the river.

Skeo visited the site repository, Smyth-Bland Regional Library, located at 111 Palmer Avenue in Saltville. Many administrative records were on file for OUs 1, 2 and 3. The 1986 Risk Assessment Report, the 1995 FS Report, the OU2 RI Report and the 2002 FYR Report were also available. Recent documents were not present.

V. TECHNICAL ASSESSMENT

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

Question A Summary:

Yes, the OU1, OU2, and OU3 remedies called for in the 1987 interim ROD and 1995 ROD are generally functioning as intended. OU4 remedial investigation activities will determine the site wide extent of contamination and future decision documents will address remaining areas of contamination resulting in unacceptable risks, if any, including contaminated media associated with the FCPS, sediments, surface water, soils and biota.

The primary component of the OU1 remedy is Pond 5 surface water diversions. These remedy components are in place and functioning as intended. The western and eastern diversion ditches and the surface drainage channels are inspected and maintained as needed. However, the site inspection during this FYR review process and previous inspections noted surface water seeps along Pond 5 descending bank and foaming on the Pond 6 dike cuts, and seeps of surface water in the North Fork Holston River where the dike cuts discharge into the river. In August 2017, EPA and Olin entered into an AOC to mitigate human health risk associated with coming into contact with elevated pH. These areas are sampled for mercury based on the 1987 ROD and for pH based on the AOC entered into by EPA and Olin in August 2017.

The primary component of the current OU2 remedy is the water treatment plant.

Primary components of the OU3 remedy are the Pond 5 cap, the Pond 6 cover, and the upgrade to the water treatment plant for Ponds 5 and 6. The cap over Pond 5 and a cover over Pond 6 are functioning as intended to eliminate potential direct contact with waste materials. The covers are inspected regularly to assess vegetative conditions. However, it is unclear if the Pond 5 and Pond 6 dikes are being maintained in accordance with Virginia dam regulations. EPA and VDEQ are reviewing state regulations and historical dike stability studies to determine if Virginia dam regulations are relevant and appropriate. Additional studies or more refined inspections may be added to the O&M.

OU4 ongoing remedial investigations have detected elevated mercury concentrations in the North Fork Holston River surface water downstream of the FCPS and next to Pond 5 and Pond 6. Investigations are ongoing and will identify the sources of contamination. The final OU4 remedy will address all remaining site contamination.

Groundwater monitoring to assess the potential for leakage of groundwater through or under the dikes is ongoing, per the current LTMP. In 2016, EPA directed Olin to modify the groundwater pumping and treatment system at Pond 5 to include pumping and treatment of groundwater to reduce the discharge of mercury-contaminated groundwater into the North Fork Holston River between river mile 82.2 and 82.4. Specifically, the letter recommends and directs that Olin initiate continuous pumping of groundwater in monitoring well MW-119S and PZ-10, and treat the pumped groundwater on site before discharge to the North Fork Holston River. In March 2017 Olin completed the construction to modify the groundwater pumping and treatment system. The performance of this additional pumping system will be monitored with a performance monitoring plan.

Institutional controls are in place to prohibit development of Ponds 5 and 6, as well as any type of activity that could disturb the surface or the underlying waste, use of groundwater from that area as a source of potable water, or in any way increase the risk of exposure to contaminants. A municipal ordinance requires the connection of residential and industrial developments in the area to the municipal water supply system. The North Fork Holston River will be addressed under OU4. In the interim, a fish consumption advisory is in place for affected areas.

Ongoing OU4 investigations include regular sampling of river water, sediments and river biota and will be the subject of future decision documents and therefore are not considered in this FYR.

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?

Question B Summary:

The 1995 ROD remedy 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 cover and cap and institutional controls have eliminated this pathway of concern. The RI that 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 that may bioaccumulate mercury released from Pond 5 and Pond 6. Virginia Department of Health has placed a “Do Not Eat” fish consumption advisory for any fish species caught from Saltville, VA to the Virginia-Tennessee state line. The Virginia Department of Inland Game and Fisheries notes downstream of Saltville is an exceptional smallmouth bass fishery. Risks posed to ecological receptors from releases to the river by Pond 5 and Pond 6 are currently being assessed under OU4.

Current effluent limitations for the on-site treatment plant for groundwater contaminated by leachate from Pond 5 and Pond 6 were developed in 2000. They were designed to be protective of Virginia’s water quality standard of 0.012 µg/L or 12 nanograms per liter (ng/L) total mercury that was in place at that time. Since then, VDEQ has promulgated a water quality standard of 0.3 milligrams per kilogram (mg/kg) methylmercury in fish tissue and issued the North Fork Holston River Mercury Total Maximum Daily Load (TDML) Report, which established 2 ng/L total mercury as the site-specific endpoint or target surface water concentration for achieving this standard. EPA is evaluating the effects of these standards on the effluent limitations and the ongoing remedial investigation.

QUESTION C: Has any other information come to light that could call into question the protectiveness of the remedy?

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

VI. ISSUES/RECOMMENDATIONS

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the FYR: OU1 Issues and Recommendations Identified in the FYR:

OU(s): 3 Issue Category: Monitoring Issue: LTMP for Pond 5 and/or Pond 6 groundwater to be modified based on results of ongoing RI.

Recommendation: Modify LTMP for Pond 5 and/or Pond 6 groundwater as needed based on results of ongoing RI. Affect Current Affect Future Party Responsible Oversight Party Milestone Date Protectiveness Protectiveness No Yes PRP EPA/State 9/30/2018

OU(s): 2 Issue Category: Operations and Maintenance 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 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). Affect Current Affect Future Party Responsible Oversight Party Milestone Date Protectiveness Protectiveness No Yes PRP EPA/State 9/30/2018

OU(s): 3 Issue Category: Remedy Performance Issue: Routine Dike inspections for Pond 5 and Pond 6 must adequately determine their long-term stability. It is unclear whether the dikes for Pond 5 and 6 are in compliance with VA impoundment regulations per the 1995 ROD. Recommendation: Implement necessary modifications to the routine Pond 5 and Pond 6 dike inspections based on current industry standards and appropriate and relevant Virginia Impoundment regulations.

Affect Current Affect Future Party Responsible Oversight Party Milestone Date Protectiveness Protectiveness No Yes EPA/State EPA/State 9/30/2018

OTHER FINDINGS

Several additional recommendations were identified during the FYR. These recommendations do not affect current and/or future protectiveness.

• Update Site Repository with Administrative Records • Repair damaged fencing. • Confirm the cause of the discoloration and foaming on the Pond 6 dike cuts, and foaming and discoloration of surface water in the North Fork Holston River where the dike cuts discharge into the river. • Performance monitoring of the pumping and treatment of groundwater from MW-119S and PZ-10.

VII. PROTECTIVENESS STATEMENT

Protectiveness Statement(s) Operable Unit:1 Protectiveness Determination: Planned Addendum Protective Completion Date: Click here to enter a date Protectiveness Statement: The remedy at OU1 is protective of human health and the environment.

Protectiveness Statement(s) Operable Unit:2 Protectiveness Determination: Planned Addendum Short-term Protective Completion Date: Click here to enter a date Protectiveness Statement: The remedy at OU2 is protective in the short term because the treatment plant is reducing mercury discharge to the North Fork Holston River. However, in order to determine if the remedy is protective in the long-term, the effluent discharge standards and monitoring requirements need to be updated in the O&M manual.

Protectiveness Statement(s) Operable Unit:3 Protectiveness Determination: Planned Addendum Short-term Protective Completion Date: Click here to enter a date Protectiveness Statement: The remedy at OU3 is protective of human health and the environment in the short term because the Pond covers and caps have eliminated direct exposures and the infiltration of precipitation into waste material. However, for the remedy to be protective in the long-term, the relevant dike regulations and associated inspection procedures need to be updated and the groundwater monitoring program needs to be updated following the completion of the OU4 remedial investigation.

VIII. NEXT REVIEW

The next FYR Report for the Saltville Waste Disposal Ponds Superfund site is required five years from the completion date of this review.

APPENDIX A – REFERENCE LIST

Olin Corporation, Quarterly Data Report No. 95-110, Saltville Waste Disposal Site, Saltville, Virginia, April 2013 - January 2017.

Olin Corporation, Annual Operation, Maintenance, and Monitoring Report OM&M Year 12 – 2014, Saltville Waste Disposal Ponds Superfund Site Operable Unit 2 (Ponds 5 And 6), Saltville, Virginia. December 28, 2015.

Olin Corporation, Phase IX Hydrogeologic Investigations Pond 2/Pond 5 Area, Saltville Waste Disposal Ponds Site, Pond 5 Operable Unit 2 (OU-2) Remedial Investigation, Saltville, Virginia. February 29, 2016.

Olin Corporation, Performance Monitoring Plan for Pumping and Treatment of Groundwater in MW-119S, Saltville Waste Disposal Ponds Superfund Site, Saltville, Virginia. February 29, 2016.

Olin Corporation, Annual Operation, Maintenance, and Monitoring Report OM&M Year 13 – 2015, Saltville Waste Disposal Ponds Superfund Site Operable Unit 2 (Ponds 5 And 6), Saltville, Virginia. July 29, 2016.

USEPA, Record of Decision, Saltville Waste Disposal Ponds Superfund Site, Saltville, Virginia, Operable Unit 1, June 30, 1987.

USEPA, Record of Decision, Saltville Waste Disposal Ponds Superfund Site, Saltville, Virginia, Operable Unit 2 (Pond 5 And Pond 6), September 29, 1995.

USEPA, Five-Year Review Report for Saltville Waste Disposal Ponds Superfund Site, Smyth and Washington Counties, Virginia. September 30, 1997.

USEPA, Second Five-Year Review Report for Saltville Waste Disposal Ponds Superfund Site, Smyth and Washington Counties, Virginia. September 30, 2002.

USEPA, Third Five-Year Review Report for Saltville Waste Disposal Ponds Superfund Site, Smyth and Washington Counties, Virginia. September 27, 2007.

USEPA, Fourth Five-Year Review Report for Saltville Waste Disposal Ponds Superfund Site, Smyth and Washington Counties, Virginia. September 27, 2012.

A-1

APPENDIX B – SITE CHRONOLOGY

Table B-1: Site Chronology

Event Date Olin or its predecessors (Olin Mathieson Chemical Corporation, 1895-1972 Mathieson Chemical Corporation and Mathieson Alkali Works) operated chemical manufacturing operations in Saltville Olin or its predecessors operated a mercury cell chlor-alkali plant on the 1950-1972 banks of the North Fork Holston River Olin dismantled its facility June 1973 Olin entered into a special order with the Virginia State Water Control November 1982 Board where Olin agreed to dredge mercury-contaminated sediment from the North Fork Holston River, encapsulate sediment on the foundation of a former building at the FCPS and cap the FCPS with clay EPA listed the Site on the NPL September 8, 1983 EPA signed first ROD requiring interim measures and additional June 30, 1987 investigations PRP Olin entered into Consent Decree to implement 1987 ROD remedy September 15, 1988 PRP began OU4 RI PRP completed OU1 remedial action September 30, 1991 EPA signed second ROD September 29, 1995 PRP completed OU2 remedial action September 3, 1996 EPA signed Site’s first FYR Report July 29, 1997 EPA signed Site’s second FYR Report September 20, 2002 PRP completed OU3 remedial action July 11, 2003 PRP filed Environmental Protection Easement and Declaration of March 27, 2007 Restrictive Covenants EPA signed Site’s third FYR Report September 27, 2007 EPA signed Site’s fourth FYR Report September 27, 2012 EPA directed Olin to modify the existing groundwater pumping and January 28, 2016 treatment system at Pond 5 to include pumping and treatment of groundwater to reduce the discharge of mercury-contaminated groundwater between river mile 82.2 and 82.4 Olin submitted Phase IX Hydrogeologic Investigations Pond 2/ Pond 5 February 29, 2016 Area Report EPA and Olin entered into an Administrative Settlement Agreement and August 16, 2017 Order on Consent for Removal Action under which Olin agreed to address high pH seeps discharging from Ponds 5 and 6.

B-1

APPENDIX C – SITE MAPS

Figure C-1. Historical Site Layout

ROBERTSON' BRANCH

LEGEND VIRGINIA PRESSURE WELLS -# MAP MUCK PONDS -~ - GRAVITY FLOW LINES- ...... O 5 10 MLES

C-1

Figure C-2. Site Features

Legend: - DNERSIONDITCHLOCATION SUPPLEMENTAL REMEDIAL INVESTIGATION REPORT ...£.. APPROXIMATE LOCATION OF SALTVILLE TRUST FAULT, NORTH FORK HOLSTON RIVER - OPERABLE UNIT 4 TEETH ON UPPER PLATE (AFTER COOPER, 1966) References: 1. USGS T OPOGRAPHIC MAP, 7.5 MINUTE SERIES. SALTVILLE, OLIN SALTVILLE "SITE" BRANDFORD, CHILHOWIE AND GLADE SPRINGS, VIRGINIA, PHOTOREVISEDIPHOTO INSPECTED, 1976-78 2. GOLDER, 2004. SITE LOCATION MAP, FIGURE 1-1 FlGURE ll-1

C-2

Figure C-3. Pond 5 Monitoring Points

...... ,,..., ...... ,,..., ... t.N.12 ..... ---...... --,... .. -,.... -...... - -... -.... -,...... -... - .... -.... l,Jall) ,,_,. ,_,. ,_ -- .., .,...,...... ,,...... ,,..... uo .,.... -.. , .., ,,...., ..., .. 11"1'.0 ,,.,.,. ,..,., 17oi1.1l .., 1,141M ...... , ... 17<1U:t ,,.,...... ""·" ...... , .... 1"'1.U .... • ,.. ,. . ,,.,..., ,,... ,...... ,,... .., ... .,,.,, ...... ua.11 ...... ,,.,...... 1,7-02 ,.,. .,,.,. .,, ,,.. ,,,.., ,,,.., ,.,. ,...,. .,. ,,..,. . ... ,,,.,, ...... ,,,.,...... 1,7aflt ,.,.,7:l .,,...... , ...... •• .,,...... 1,131l. mm --.,,.,, ,,..... mu, .,,.. .., =• --, ...... ,,,._,...... 1,7a.17 ...... '""H~U·"I ,,... ,",.,.,"" .,...... ,',,.,,""" .., ... .., ... 1,731M ,m'""",. ,,,,., ,,.,.., ,m.,. '""" .,,,,, 17t1.1• .,, 1Jl"""l.10' .,. • ,,. , ... .,, ...... ,,..,...... 1,na.02 .,., .. .,.,. 1m.11 "'"'.. ,,,,.. '""' •• ... m u n ...... 11'J1.JI> ...... 1111.75 .,,,., .., 1,7:lt.10 .,., .. .,., .. .,,, ... ,m.- ...... 1n1.a ... .., ...... " ,...... ,.,.,w .,,.,. .,... ,m .n ·-,..,.'"'"' •• ... ,,..., ...... ,m,...... -~ ...... ,...... ,.nu1 ,,.,., ,...,, ""mu,·" ,,,,. .,.. .,. ,.,..., , .,. , .,. .. """',,,...... ,....,,. .. ,,,...... 1.no.• l.13o.t1 .,,.,, ,,.,... muo ...... ,. ",. t.m.11 .,.,... ,,., ',m"'"'.M 11'\,,0 "" """ '·" ,.,,,_ ,,.,.. ,,,.,. """' ,,.,.... ,,...,""·" ...... ,,..., ...... •• ...... ,. 1,l'al1 ...... •• ... "'"' ...... ,,..., ...... ,, 1,nz.u .,... ,,,... ,,,,,., .,,, .. ,,.,...... ,,..,...... 1131,7) .., ... .,,,.,, ...... ,. 1,ncur _.,.., n.a ,,.... .,.,. ,.... ,'""..... " ...... ,, ...... , ...... 1,111.0I Ulltt ....,. ,...,. .,,. ,,...., ,,.... .,, ,,,.... ,,,.,., .. ,,.,,...... ,,,..,, ...... 1,no,_17 ,...... ,,,... 11'Z.M ,...... ,'.....""'' ...... , , 1,1"6,11 ,,.. .,...., , ,..... ,., ,...., .,...... , .... .,.,..,...... --,,.,,, ... ,m,.. ... ,,,,., ...... 1,131.tt v,,., ,,.,.. ,,,,...... ,, ... .,, ... .,. 1-,NM'I .., .,, ,...... ""·"...... fN t.lZ '"'"'fK\.rJ' ...... '7~1.1'J •• ... .. "'"' "'"' -·.. - .. , ..... ,,...... _ PC·--,~ 5 - - ...... ame

C-3

Figure C-4. Pond 6 Monitoring Points

e ~r,,-2 Lt.Dll

·- ·- OUn ,,.,. ... , ... · ~WI :"u C~I' I I O ....

C-4

Figure C-5. Pond 2 and Pond 5 Features

] ! I "

No ..: Loc.1tions of all features art appruirNttd l\,r J. - ~a Locat:10nol Fonne, AMI o.nn., Kn:MnfClfN, Ctllmdr.•d ~ Duh ! based on gt oreferenud historic Ima gee. ~ Ponds 2 and 5 Site Features of ( ..,_.,. RCRA Cap + ._ - (Rlf; 0 ~ ~-:-m:~;•,:-.,:::;::.rom\&lion dn~:::~ :=;-~ } Figure - -~.,...... ,-'°"'(A.SAW) on Porct l o-....e,.-ow J,_ EB....,,..,_,_...,...,. ,._._-... amec roster whee Ier .,~.,~ (at r... olCoWt Pllc9m.ntJ HIJltGYZ.-:.OtS 1 O - Robeftaon 8'Wl:h CrHII =~~- ! ------~~=----~------~--~ .....------

C-5

Figure C-6. Surface Water Sampling Results, MW-119S Area

NFHR Surface Water

-,-- I 200 I 0

100

0 0 50

20 -r- I

-r- 10 0 I

BI 5 I g I ---'--- I - ·- ---'---

I i :• !, t= l... I, :: ~ i"' .:I I 5 :E.. I i ~ ~

Legend j Performance Monitoring Plan ~' -$- Monitoring Well E2L'.} Areal Extent of pH > 9.00 - , I--- River Channel Segments Summary of Surface Water :iii, -q, Piezomeler - Segment 4: RM82.12-82.22 Sampling Results: MW-119S Area

:, + Sub River Mile Segment 3: RM 82.22 - 82.28 Proc•••O By-Date1 ; , Observed Former River Channel Segment 2: RM 82.28 _ 82.38 CLS 2/29/20 6 • s., ChockQd8y-Dot• fo h l {.. Figure ~ --North Fork Holston River Channel - Segment 1: RM 82.38-82.46 Notes: ng/L: nanograms per liter, RM: river mile EFC2129/20l6 amec ster W ee er ...~ . 3 ~ .______...J ______J [!P~n>ie:t· ci~N~um~~·::,'·_...l______: 6107160017 _JL ___J

C-6

Figure C-7. River Miles

.,, i .~ Ir 8 E ~ ,,I C ~ aC Ii • ,! ..; i North Fork Holston River RM 80 · RM 83 !,:, + River Mile Marker (Tenth) River Mlle Marker Locations ; , - Robertson Branch '"'"'"J Oy.0~ !IP 0~/1~:? Existing River Channel 500 1,000 2,000 Figure: i - IO I Ct,r11~11,o.,1e, E:fC OX!Zm 1 -" .______"'""' Former River Channel . Feet. _J,!! "!!u~,~~·:::•:::...1. ______amecO L __J ~ --

C-7

APPENDIX D – SITE INSPECTION CHECKLIST

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

I. SITE INFORMATION

Site Name: Saltville Waste Disposal Ponds Date of Inspection: 12/6/2016 Location and Region: Saltville, Virginia 3 EPA ID: VAD003127578 Agency, Office or Company Leading the Five-Year Weather/Temperature: rain and 45 degrees F Review: EPA Region 3 Remedy Includes: (Check all that apply) ~ Landfill cover/containment D Monitored natural attenuation ~ Access controls D Groundwater containment ~ Institutional controls D Vertical barrier walls D Groundwater pump and treatment D Surface water collection and treatment ~ Other: leachate treatment plant Attachments: ~ Inspection team roster attached D Site map attached II. INTERVIEWS (check all that apply) 1. O&M Site Manager - - - Name Title Date Interviewed D at site D at office D by phone Phone: - Problems, suggestions D Report attached: 2. O&M Staff - - - Name Title Date Interviewed D at site D at office D by phone Phone: - Problems/suggestions D Report attached: 3. Local Regulatory Authorities and Response Agencies (i.e., state and tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices). Fill in all that apply.

Agency - Contact - - - - Name Title Date Phone No. Problems/suggestions D Report attached: -

Agency - Contact - Name - - - Title Date Phone No. Problems/suggestions D Report attached:-

Agency - Contact - - - - Name Title Date Phone No. Problems/suggestions D Report attached:-

Agency - Contact - - - - Name Title Date Phone No. Problems/suggestions D Report attached: -

Agency - Contact

D-1 Name Title Date Phone No.

Problems/suggestions D Report attached: 4. Other Interviews (optional) D Report attached: -

III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply) 1. O&M Documents ~ O&M manual D Readily available ~ Up to date D N/A ~ As-built drawings ~ Readily available ~ Up to date D N/A ~ Maintenance logs ~ Readily available ~ Up to date D N/A Remarks:

- 2. Site-Specific Health and Safety Plan ~ Readily available ~ Up to date D N/A ~ Contingency plan/emergency response ~ Readily available ~ Up to date D N/A plan Remarks: Emergency Plan 2016 for Ponds 5 and 6 Treatment Plant – hard copies on site in control room - 3. O&M and OSHA Training Records ~ Readily available ~ Up to date D N/A Remarks: Training certificates and records on site in control room

4. Permits and Service Agreements D Air discharge permit D Readily available D Up to date ~ N/A D Effluent discharge D Readily available D Up to date ~ N/A D Waste disposal, POTW D Readily available D Up to date ~ N/A

D Other permits: - D Readily available D Up to date ~ N/A Remarks: No permit for effluent because it meets standards

5. Gas Generation Records D Readily available D Up to date ~ N/A Remarks:

- 6. Settlement Monument Records ~ Readily available ~ Up to date D N/A Remarks: Surveyed in November 2016

7. Groundwater Monitoring Records ~ Readily available ~ Up to date D N/A Remarks:

- 8. Leachate Extraction Records D Readily available D Up to date ~ N/A Remarks:

- 9. Discharge Compliance Records D Air D Readily available D Up to date ~ N/A ~ Water (effluent) D Readily available D Up to date D N/A Remarks: Records submitted for effluent analysis

10. Daily Access/Security Logs ~ Readily available ~ Up to date D N/A

D-2 Remarks: Access restricted by locking gate

IV. O&M COSTS 1. O&M Organization D State in-house D Contractor for state ~ PRP in-house D Contractor for PRP D Federal facility in-house D Contractor for Federal facility D Olin operates the treatment plant and performs monitoring.

2. O&M Cost Records D Readily available D Up to date D Funding mechanism/agreement in place D Unavailable Original O&M cost estimate: _D Breakdown attached Total annual cost by year for review period if available

From: - To: - - D Breakdown attached Date Date Total cost

3. Unanticipated or Unusually High O&M Costs during Review Period Describe costs and reasons: - V. ACCESS AND INSTITUTIONAL CONTROLS ~ Applicable D N/A A. Fencing 1. Fencing Damaged D Location shown on site map D Gates secured D N/A Remarks: Fencing generally in good condition, gates typically secured with locks. Small section of fence down near Pond 6 western dike cut. B. Other Access Restrictions 1. Signs and Other Security Measures D Location shown on site map D N/A Remarks: Signage posted on fencing. C. Institutional Controls (ICs)

D-3 1. Implementation and Enforcement Site conditions imply ICs not properly implemented D Yes ~ No D N/A Site conditions imply ICs not being fully enforced D Yes ~ No D N/A Type of monitoring (e.g., self-reporting, drive by): - Frequency: - Responsible party/agency: - Contact - - - - Name Title Date Phone no. Reporting is up to date D Yes D No ~ N/A Reports are verified by the lead agency D Yes D No ~ N/A Specific requirements in deed or decision documents have been met ~ Yes D No D N/A Violations have been reported D Yes ~ No D N/A Other problems or suggestions: D Report attached

2. Adequacy ~ ICs are adequate D ICs are inadequate D N/A Remarks: Based on available information, institutional controls appear to be adequate. D. General

1. Vandalism/Trespassing D Location shown on site map ~ No vandalism evident Remarks: Cars have hit the site fence near Pond 6 three times in the last five years. Olin repairs fencing as needed.

2. Land Use Changes On Site ~ N/A Remarks: -None. 3. Land Use Changes Off Site ~ N/A Remarks: -None. VI. GENERAL SITE CONDITIONS

A. Roads ~ Applicable D N/A 1. Roads Damaged D Location shown on site map ~ Roads adequate D N/A Remarks: Roads in good condition B. Other Site Conditions Remarks: Construction to connect two wells to the treatment plant will begin soon.

VII. LANDFILL COVERS ~ Applicable D N/A A. Landfill Surface

1. Settlement (low spots) D Location shown on site map ~ Settlement not evident

Aerial extent: - Depth: - Remarks:

- 2. Cracks D Location shown on site map ~ Cracking not evident

Lengths: - Widths: - Depths: - Remarks:

D-4 3. Erosion D Location shown on site map ~ Erosion not evident

Aerial extent: - Depth: - Remarks:

- 4. Holes D Location shown on site map ~ Holes not evident Aerial extent: - Depth: - Remarks: Some groundhogs. No active plan to manage them. They stop burrowing when they hit the cap cover.

5. Vegetative Cover ~ Grass ~ Cover properly established ~ No signs of stress ~ Trees/shrubs (indicate size and locations on a diagram) Remarks: Grass cover, well-established on Pond 5 cap. Grass and 11,000 trees on Pond 6 cover.

6. Alternative Cover (e.g., armored rock, concrete) ~ N/A Remarks:

- 7. Bulges D Location shown on site map ~ Bulges not evident

Aerial extent: - Height: - Remarks:

- 8. Wet Areas/Water ~ Wet areas/water damage not evident Damage

D Wet areas D Location shown on site map Aerial extent: - D Ponding D Location shown on site map Aerial extent: - D Seeps D Location shown on site map Aerial extent: - D Soft subgrade D Location shown on site map Aerial extent: - Remarks: N/A

- 9. Slope Instability D Slides D Location shown on site map ~ No evidence of slope instability

Aerial extent: - Remarks:

- B. Benches D Applicable ~ N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.) 1. Flows Bypass Bench D Location shown on site map D N/A or okay Remarks:

2. Bench Breached D Location shown on site map D N/A or okay Remarks:

- 3. Bench Overtopped D Location shown on site map D N/A or okay Remarks:

- C. Letdown Channels ~ Applicable D N/A (Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill

D-5 cover without creating erosion gullies.)

1. Settlement (Low spots) D Location shown on site map ~ No evidence of settlement Aerial extent: - Depth: - Remarks: - 2. Material Degradation D Location shown on site map ~ No evidence of degradation

Material type:- Aerial extent: - Remarks:

- 3. Erosion D Location shown on site map ~ No evidence of erosion

Aerial extent: - Depth: - Remarks:

- 4. Undercutting D Location shown on site map ~ No evidence of undercutting

Aerial extent: - Depth: - Remarks:

- 5. Obstructions Type: - ~ No obstructions D Location shown on site map Aerial extent: -

Size: - Remarks:

6. Excessive Vegetative Growth Type: - ~ No evidence of excessive growth

D Vegetation in channels does not obstruct flow D Location shown on site map Aerial extent: - Remarks:

- D. Cover Penetrations ~ Applicable D N/A 1. Gas Vents D Active D Passive D Properly secured/locked D Functioning D Routinely sampled D Good condition D Evidence of leakage at penetration D Needs maintenance ~ N/A Remarks:

- 2. Gas Monitoring Probes D Properly secured/locked D Functioning D Routinely sampled D Good condition D Evidence of leakage at penetration D Needs maintenance ~ N/A Remarks:

- 3. Monitoring Wells (within surface area of landfill) ~ Properly secured/locked ~ Functioning D Routinely sampled ~ Good condition D Evidence of leakage at penetration D Needs maintenance D N/A Remarks: Four wells on Pond 6; no wells on Pond 5.

4. Extraction Wells Leachate D Properly secured/locked D Functioning D Routinely sampled D Good condition D-6 D Evidence of leakage at penetration D Needs maintenance ~ N/A Remarks:

- 5. Settlement Monuments ~ Located ~ Routinely surveyed D N/A Remarks: There are 24 monuments on Pond 5. Surveyed in November 2016 Not in cap cover itself; they sit 6 inches above the cap’s liner.

E. Gas Collection and Treatment D Applicable ~ N/A 1. Gas Treatment Facilities D Flaring D Thermal destruction D Collection for reuse D Good condition D Needs maintenance Remarks:

- 2. Gas Collection Wells, Manifolds and Piping D Good condition D Needs maintenance Remarks: - 3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) D Good condition D Needs maintenance D N/A Remarks:

- F. Cover Drainage Layer ~ Applicable D N/A 1. Outlet Pipes Inspected ~ Functioning D N/A Remarks: - 2. Outlet Rock Inspected ~ Functioning D N/A Remarks: Rocks at Pond 6 west dike cut covered in pink discoloration.

G. Detention/Sedimentation Ponds D Applicable ~ N/A 1. Siltation Area extent: - Depth: - D N/A D Siltation not evident Remarks:

2. Erosion Area extent: - Depth: - D Erosion not evident Remarks:

- 3. Outlet Works D Functioning D N/A Remarks:

- 4. Dam D Functioning D N/A Remarks:

- H. Retaining Walls D Applicable ~ N/A 1. Deformations D Location shown on site map D Deformation not evident

Horizontal displacement: - Vertical displacement: - Rotational displacement: - Remarks:

D-7 2. Degradation D Location shown on site map D Degradation not evident Remarks:

- I. Perimeter Ditches/Off-Site Discharge ~ Applicable D N/A 1. Siltation D Location shown on site map ~ Siltation not evident

Area extent: - Depth: - Remarks:

- 2. Vegetative Growth D Location shown on site map ~ N/A D Vegetation does not impede flow

Area extent: - Type: - Remarks:

- 3. Erosion D Location shown on site map ~ Erosion not evident Area extent: - Depth: - Remarks: - 4. Discharge Structure ~ Functioning D N/A Remarks:

- VIII. VERTICAL BARRIER WALLS D Applicable ~ N/A 1. Settlement D Location shown on site map D Settlement not evident

Area extent: - Depth: - Remarks:

2. Performance Monitoring Type of monitoring: - D Performance not monitored

Frequency: - D Evidence of breaching Head differential: - Remarks:

IX. GROUNDWATER/SURFACE WATER REMEDIES ~ Applicable D N/A A. Groundwater Extraction Wells, Pumps and Pipelines D Applicable ~ N/A 1. Pumps, Wellhead Plumbing and Electrical D Good condition D All required wells properly operating D Needs maintenance D N/A Remarks: - 2. Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances D Good condition D Needs maintenance Remarks:

- 3. Spare Parts and Equipment D Readily available D Good condition D Requires upgrade D Needs to be provided Remarks:

- B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable D N/A

D-8 1. Collection Structures, Pumps and Electrical ~ Good condition D Needs maintenance Remarks:

- 2. Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances ~ Good condition D Needs maintenance Remarks:

- 3. Spare Parts and Equipment D Readily available D Good condition D Requires upgrade D Needs to be provided Remarks: N/A

- C. Treatment System ~ Applicable D N/A 1. Treatment Train (check components that apply) D Metals removal D Oil/water separation D Bioremediation D Air stripping D Carbon adsorbers ~ Filters: carbon filtration (2 tanks)

D Additive (e.g., chelation agent, flocculent): - ~ Others: sulfuric acid to address pH ~ Good condition D Needs maintenance ~ Sampling ports properly marked and functional D Sampling/maintenance log displayed and up to date ~ Equipment properly identified ~ Quantity of groundwater treated annually: 1,300,000 gallons

D Quantity of surface water treated annually: -N/A Remarks:

- 2. Electrical Enclosures and Panels (properly rated and functional) D N/A ~ Good condition D Needs maintenance Remarks:

- 3. Tanks, Vaults, Storage Vessels D N/A ~ Good condition ~ Proper secondary containment D Needs maintenance Remarks: All tanks clearly marked and labeled. Treatment plant has secondary containment.

4. Discharge Structure and Appurtenances ~ N/A D Good condition D Needs maintenance Remarks:

- 5. Treatment Building(s)

D N/A ~ Good condition (esp. roof and doorways) D Needs repair ~ Chemicals and equipment properly stored Remarks:

- 6. Monitoring Wells (pump and treatment remedy)

D-9 ~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition D All required wells located D Needs maintenance D N/A Remarks:

- D. Monitoring Data 1. Monitoring Data ~ Is routinely submitted on time ~ Is of acceptable quality

2. Monitoring Data Suggests: D Groundwater plume is effectively contained D Contaminant concentrations are declining

E. Monitored Natural Attenuation 1. Monitoring Wells (natural attenuation remedy) D Properly secured/locked D Functioning D Routinely sampled D Good condition D All required wells located D Needs maintenance ~ N/A Remarks:

- X. OTHER REMEDIES If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction. XI. OVERALL OBSERVATIONS A. Implementation of the Remedy Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant plume, minimize infiltration and gas emissions). The remedies have been implemented as designed. EPA and Olin will modify the monitoring and O&M requirements as needed. B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. The specific monitoring requirements and discharge criteria need to be updated. C. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised in the future. Potential migration of contaminated groundwater beneath Pond 5 into the river. Olin is initiating groundwater pumping. D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. Olin has been looking for opportunities to cut back on monitoring events in areas they think are justified.

Site Inspection Roster:

Andrea Bain, EPA remedial project manager Mindi Snoparsky, EPA hydrogeologist Dan Sirkis, U.S. Army Corps of Engineers Sandip Chattopadhyay, EPA Office of Research and Development Kimberly Scharl, EPA community involvement coordinator Vance Evans, EPA community involvement coordinator William Lindsay, VDEQ Keith Roberts, Olin Stanley Haynes, Olin D-10 Julie Irwin, Olin Pete Ingraham, Golder Associates Melissa Oakley, Skeo Kelly MacDonald, Skeo

D-11

APPENDIX E – PRESS NOTICE

EPA REVIEWS ClEANUP Saltville Ponds Superfund Site

The U.S. Environmental Agency is reviewing the cleanup conducted at the Saltville Waste Disposal Ponds in Saltville. EPA inspects sites regularly to ensure that cleanups conducted remain protective of public health and the environment. EPA's previous review of the site in 2012 determined that the remedy is protective and that more investigation is needed to determine protectiveness in the long term. Findings from the current review being conducted will be available September 2017.

To access the review, or to provide site-related information: Contact: Vance Evans, Community Involvement Coordinator Phone: 215-814-5526 Email: [email protected]

To access detailed site information, including Review Report: https://www.epa.gov/superfund/saltville Protecting human health and the environment

E-1

APPENDIX F – SITE INSPECTION PHOTOS

Entrance to the Site off Perryville Road with security fence and gate

Downed barbed wire on fence on Pond 5 border near entrance

F-1

Equalization basin and piping near treatment plant

Treatment plant and equalization basin

F-2

Pond 5 and Little Mountain (facing northwest)

Pond 5 cap and Little Mountain (facing southwest)

F-3

Pond 5 decant structure

Underdrain discharge in Pond 5 dike cut (facing northeast)

F-4

Surface water drainage features on Pond 5

Settlement monuments and markers on Pond 5 cap

F-5

Western diversion ditch

Pond 6 cover and decant structure

F-6

Pond 6 pumping station

Pond 6 eastern dike cut with discoloration

F-7

Pond 6 eastern dike cut with discoloration

North Fork Holston River

F-8

Access road and wells south of ponds

Eastern diversion ditch outfall (with water flowing, left) and treatment plant outfall (dry, right)

F-9

Eastern diversion ditch and treatment plant outfall to North Fork Holston River

Wildlife on Pond 6 cover

F-10

Pink, tan and white discoloration on western dike cut on Pond 6 (facing North Fork Holston River)

Pond 6 cover and western dike cut

F-11

Damaged fence at western dike cut in Pond 6

Fence and private property sign around Pond 5

F-12

Fence along Route 611

Slush-grouted swale 3

F-13

Swale 3 outfall into western diversion ditch

No trespassing and fish health advisory signs near North Fork Holston River

F-14

·WARNING I Iealth adYisory on eating fish

Eating fish from this location may be harmful to your health. These fish may cpntain mercury and chemicals called Pelis. Eating fish tlult contain North Yoft Holllton Rh.·e, r~inS.lt,iJJe about 84 PCBs may increase your risk for can• inik,s to lhe \lirglnia•Tm~ •••te Une ccr. Eating fish contaminated with Afftttfll locality1 Smyth, Wuhington and S

Women who are pregnant or may become pregnant, nursing mothers and young children should not cat the fish listed in the table. Others should follow the dirootions in the table on the type and amount of fish to eat. For more infonna.tioo: Virginia Oea>artmeot of Health 8<>4·864·8182 www.vdh.virginia.gov f> 0

Fish health advisory signs near North Fork Holston River

F-15

APPENDIX G – SELECTED TABLES AND CHARTS FROM 2015 ANNUAL MONITORING REPORT

TABLE 2.6 GROUNDWATER ANALYTICAL DATA PONDS 5 AND 6 MONITORING WELLS SALTVILLE WASTE DISPOSAL SITE, SALTVlLLE, VIRGI.NlA 2014 LONG-TERM MONITORING PROGRAM

Total Ilg Filtered Hg Well No. Datl' fnnb) (oob) Di ke Cuts, Di version Ditch,-s and Channl'ls Pond 5 fastem Diversion Ditch 3!6i2014 0. 1 lJ na Pond 5 Dike Cut 3/6/2014 0. 1 U na Pond 5 Western Diversion Ditch :1/6/2014 0. 1 l.l na Pond 6 E;ist Dike Cut 3/6/2014 0. 1 LI na Pond 6 West Dike C'ut 3!6/2014 0.1 U na

Notes : na: Not Analyzed ns: Not Samp~ U: The compow,d was analy.ed for, but was not dete

G-1

TABLE 2.6 GROUNDWATER ANALYTICA .L DATA PONDS S AND 6 MONITORING WELLS SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA 2015 LONG -TERM MONITORING PROGRAM

Total Hg Filtered H g Well ~o. Date Conb) fonb) Dike Cuts, Diversion Ditches, and Ch annels Pond 5 Eastern Channel 3/2/2015 0.1 U na Pond 5 Easlt:m Divt:rsion Ditch 3/2/2015 0.1 l: na Pond 5 Dike Cut 3/2/2015 0.1 C na Pond 5 Western Diversion D itch 3/2/2015 0.1 U na Pond 6 Ea!ll Dike Cul 3/2/2015 0.1 t; na Pond 6 West Dike Cut 3/2/2015 0.1 t; na

Notes: na: Not Analyzed ns: Not Sampled U: The compound Wl!'IS analyzed for, but was not detected at°' above the MRL/MDL. J: The result is an estimated concentration that is less than the MRL but greater than or equal to the MDL

G-2

Table2.3 POND S TREATMENT PLANT DISCHARGE TREATED WATER MONITORING PROGRAM SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA

Vohune Total Dissolved Chlmidcs Mermry Date Sampled Treated pH Solids (mg/L) (mg/L) (ppb) (gal) 1/5/2015 260,985 6.6 3,800 J 1,260 0.033 J 1/6/2015 268,154 6.6 3,840 J 1,250 0.02 J 117/2015 222,898 6.6 3,790 J 1,250 0.024 J 1/8/2015 256,340 6.5 3,890 J 1,260 0.033 J 1/9/2015 249,404 6.5 3,900 J 1,250 0.035 J 1/10/2015 240,519 6.7 3,970 J 1,260 0.036 J 1/1 1/2015 244,972 6.6 4,020 J 1,280 0.027 J 1/12/2015 221 ,173 6.5 4,080 J 1,270 0.05 J 1/13/2015 243,01 3 6.5 3,940 J 1,220 0.073 J 1/14/2015 237,347 6.5 3,980 J 1,240 0.054 J 1/1 5/2015 237,121 6.8 4,110 J 1,260 0.078 J 1/19/2015 107,066 6.8 4,010 1,230 O.D40J 1/20/2015 256,073 6.6 4,210 1,250 0.071 J 1/21/2015 259,478 6.7 4,310 1,270 0.058 J

2/2/2015 230,139 6.5 3,860 J 1,220 J 0.03 J 2/3/2015 252,919 7.0 3,970 J 1,240 J 0.07 J 2/4/2015 248,144 6.6 5,030 J 1,230 J 0.0 J 2/10/2015 234,915 6.6 5,010 J 1,230 0.04 J 2/1 1/2015 267,917 6.6 3,880 J 1,250 0.04 J 2/12/2015 217,897 6.7 5,050 J 1,260 0.09 J 2/23/2015 236,106 6.9 4,470 J 1,380 J 0.10 U 2/24/2015 253038 6.9 4,240 J 1,280 0.02 J 2/25/2015 45 298 6.8 4 400 J 1,320 0.02 J 2/27/2015 213 495 6.8 4 360 J 1,280 0.02 J 2/28/2015 253 185 6.7 4 450 J 1,270 0.02 J

3/1/2015 254,926 6.8 4,450 J 1,250 0.02 J 3/5/2015 184,774 6.6 4,020 J 1,100 0.02 J 3/6/2015 249,996 6.6 4,030 J 1,100 0.038 J 317/2015 202,812 6.7 4,040 J 1,130 0.10 U 3/8/2015 268,116 6.8 4,100 J 1,120 J 0.02 J 3/9/2015 269.575 6.7 4 270 J 1,1 10 0.02 J 3/10/2015 270 271 6.9 4 380 1,150 0.03 J 3/11/2015 270207 7.3 4370 1,110 0.01 J 3/12/2015 260,151 6.9 4,260 1,160 0.06 J 3/13/2015 268,752 6.6 4,310 1,120 0.04 J 3/14/2015 266,222 7.0 4,510 1,1 10 0.05 J 3/15/2015 258,153 6.7 4,500 1,090 0.04 J 3/16/2015 241 .470 6.9 4,190 J 1,100 0.13 3/17/2015 241.860 6.7 4 400 J 1,1 10 J 0.09 J 3/18/2015 250 859 7.0 4 450 J 1,1 40 0.08 J 3/19/2015 234,412 7.2 4 390 J 1,120 0.14 3/20/2015 197,327 7.5 4,570 J 1,100 0.09 J 3/21/2015 179,236 7.0 4,720 J 1,120 0.08 J

U = Analyte was not detected. Value is reporting limit. J = TI1e result is an estimate concentration that is less than the MRL but greater than or equal to the MDL na = Not Analyzed

G-3

Table2.3 POND S TREATMENT PLANT DISCHARGE TREATED WATER MONITORING PROGRAM SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA

Vohune Total Dissolved Chlmidcs Mermry Date Sampled Treated pH Solids (mg/L) (mg/L) (ppb) (gal) 3/22/2015 139.024 7.0 4,560 J 1,070 0.08 J 3/23/2015 174,687 7.0 4,240 J 1,120 0.07 J 3/24/2015 203,003 7.0 4,240 J 1,180 J 0.07 J 3/30/2015 258.984 7.1 4,160 1,120 0.036 J 3/31/2015 241,550 6.9 4,140 1,110 0.062 J

4/1/2015 256,871 6.9 4,260 1,170 0.06 J 4/2/2015 248,218 6.9 4,120 J 1,170 J 0.140 4/3/2015 254.136 6.8 4,280 J 1,160 0.11 4/6/2015 244,804 6.7 4,270 J 1,190 0.066 J 4/7/2015 256,910 6.7 4,280 J 1,210 0.086 J 4/8/2015 248,895 6.6 4,140 J 1,130 0.06 J 4/9/2015 259,070 6.7 4,240 J 1,190 0.09 J 4/10/2015 247,306 6.7 4,260 J 1,190 0.19 4/11/2015 258,970 6.6 4,230 J 1,200 O.D? J 4/12/2015 241,125 6.9 4,390 J 1,100 0.08 J 4/13/2015 241.}83 6.9 4,320 J 1,090 0.091 J 4/14/2015 227,657 6.9 4,120 1,130 0.20 4/15/2015 237,266 7.0 3,950 1,120 0.10 J 4/16/2015 187,195 6.8 4,020 1,090 0.07 J 4/17/2015 171,780 6.7 4,240 1,120 0.08 J 4/18/2015 188,590 6.7 4,270 1,080 0.071 J 4/19/2015 219,274 6.8 4,010 1,1 40 0.09 J 4/24/2015 215 066 6.9 4,080 J 1,040 0. 11 4/25/2015 243 180 6.9 4,280 J 1,050 0.08 J 4/26/2015 246,768 6.7 4,290 J 1,020 0.10 J 4/27/201 5 242,993 6.8 4,220 J 980 0.082 J 4/28/2015 231 ,379 6.9 4,290 J 1,030 0.1 20 4/29/2015 243,084 6.9 3,990 J 982 0.10 J 4/30/2015 243,795 6.8 4,430 J 1,000 0.079 J

5/4/2015 220,540 6.8 4,180 J 1,040 0.083 J 515/2015 245,856 6.6 4,590 J 1,030 0.100 5/6/2015 245,970 6.9 4,240 1,060 J 0.100 5/1 1/2015 229,566 6.8 3,960 J 1,080 0.110 5/12/2015 248,004 6.6 4,010 J 1,150 J 0.082 J 5/13/2015 247,338 6.8 4,120 J 1,1 40 0 .1 10 5/14/2015 245,880 6.9 4,050 J 997 0.091 J 5/15/2015 225,912 6.8 4,150 J 1,040 0.210 5/16/2015 240,064 6.9 4,370 J 1,1 10 0.099 J 5/17/2015 235.774 6.9 4,300 J 993 0.210 5/18/2015 241,592 6.8 4,410 J 1,070 0.10 5/19/2015 231,532 6.9 4,370 J 1,090 0.140 5/20/2015 198,708 7.0 3,900 J 989 0.086 J

U = Analyte was not detected. Value is reporting limit. J = TI1e result is an estimate concentration that is less than the MRL but greater than or equal to the MDL na = Not Analyzed

G-4

Table2.3 POND S TREATMENT PLANT DISCHARGE TREATED WATER MONITORING PROGRAM SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA

Vohune Total Dissolved Chlmidcs Mermry Date Sampled Treated pH Solids (mg/L) (mg/L) (ppb) (gal) 6/1/2015 172,134 7.5 4,070 J 1,260 0.220 J 6/2/2015 241 ,356 7.0 4,110 J 1,350 O.D78J 6/3/2015 229,354 6.8 4,090 J 1,370 0.095 J 6/4/2015 249,624 6.9 4,040 J 1,310 J 0.094 J

7/6/2015 219,396 6.6 3,620 J 1,410 J 0.08 J 717/2015 233,084 6.7 3,560 J 1,380 0.045 J 7/8/2015 222,612 6.7 3,770 J 1,420 0.096 J 7/9/2015 233,160 6.7 3,460 J 1,420 0.077 J

8/17/2015 221 ,034 6.6 3,570 J 1,450 0.046 J 8/18/2015 237,326 6.9 3,570 J 1,470 0.043 J 8/19/2015 235,454 6.8 3,670 J 1,490 0.04 J 8/20/2015 225,148 6.6 3,640 J 1,460 0.070 J 8/21/2015 236,288 6.7 3,460 J 1,410 0.052 J 8/22/2015 237,516 6.8 3,600 J 1,450 0.047 J 8/23/2015 243,266 6.7 3,760 J 1,470 0.051 J

10/15/2015 136,574 6.7 4,150 1,930 0.01 U 10/16/2015 218,428 6.6 4,280 1,950 0.012 U 10/17/2015 211,720 6.7 4,110 1,920 0.012 U 10/18/2015 145,328 6.9 3,950 1,880 0.01 U 10/19/2015 210,768 6.8 4,420 1,930 0.015 J

11/30/2015 195 470 6.8 4,030 J 1,790 0.069 J

12/1/2015 210.518 6.8 3,880 J 1,710 0.063 J 12/2/2015 193,784 6.8 3,630 J 1,630 0.074 J 12/3/201 5 182,070 6.8 3,720 J 1,610 0.039 J 12/4/2015 205,544 6.9 3,810 J 1,590 0.051 J 12/5/2015 150,298 6.8 3,860 J 1,570 0.057 J 12/6/2015 114 722 6.8 4,010 J 1,620 0.06 J 12/7/2015 112.898 6.9 4,160 J 1,520 0.059 J 12/8/2015 105 632 6.9 4,240 1,530 0.041 J 12/9/2015 94328 6.9 4,250 1,540 0.059 J 12/10/2015 86,534 6.8 4,440 1,570 0.072 J 12/15/2015 142,986 7.1 3,780 J 1,380 0.025 J 12/16/201 5 90,886 6.8 3,810 J 1,400 0.012 U 12/17/2015 79,394 6.8 3,700 J 1,380 0.012 U 12/21/2015 92 016 6.8 3,700 J 1,320 0.012 U 12/22/2015 59182 7.8 3,780 J 1,350 0.041 J 12/28/2015 93 956 6.7 3,730 1,310 0.045 J 12/29/2015 75 232 6.7 3,640 1,340 0.022 J 12/30/2015 145,210 6.7 3,6/0 1,290 0.062 J 12/31/2015 122,364 6.6 3,720 1,280 0.02 J

U = Analyte was not detected. Value is reporting limit. J = TI1e result is an estimate concentration that is less than the MRL but greater than or equal to the MDL na = Not Analyzed

G-5

Table2.3 POND S TREATMENT PLANT DISCHARGE TREATED WATER MONITORING PROGRAM SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA

Vohune Total Dissolved Chlmidcs Mermry Date Sampled Treated pH Solids (mg/L) (mg/L) (ppb) (gal)

2/13/2015 #5PPT (EO) na 4,580 J 1,260 6.5 2/13/2015 #6PPT (EO) na 1,950 J 211 0.15 4/20/2015 #5 PPT (EQ) na 4,360 J 1, 170 24 4/20/2015 #6PPT (EQ) na 1,980 J 188 0.14 10/20/2015 #5PPT (EQ) na 4,170 1,370 2.6 10/20/2015 #6 PPT (EQ) na 1,970 283 0.044 J

10 15 11 ,143,963 2015 9,605,319 3015 2,544,284 4015 3,475,842

Total 26,769,408

U = Analyte was not detected. Value is reporting limit J = TI1e result is an estimate concentration that is less than the MRL but greater than or equal to the MDL na = Not Analyzed

G-6

POND 5 TREATMENT PLANT TREATED WATER MONITORING PROGRAM SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA POND 5 TREATMENT PLANT DISCHARGE

Total Volume Tn>.ated Chlo1idcs Mcrcmy Date Sampled pH Dissolved (gal) (mg/L) (ppb) Solids (mg/L) 1/1/2016 65,163 6.73 3,600 1,410 0.012 U 1/2/2016 134,413 6.84 3,650 1,400 0.071 J 1/3/2016 161 ,375 6.88 3,760 1,400 0.012 U 1/4/2016 166,309 6.85 3,650 J 1,200 0.031 J 1/5/2016 136,160 6.65 3,620 J 1,200 0.013 J 1/6/2016 170,180 6.72 3,670 J 1,200 0.019 J 117/2016 153,646 6.85 3,660 J 1,180 0.012 U 1/8/2016 136,922 6.80 3,830 J 1,180 0.020 J 1/9/2016 156,962 6.75 3,780 J 1,180 0.061 J 1/10/2016 148,868 6.72 3,720 J 1,150 0.063 J 1/11/2016 153,191 6.70 3,860 1,180 0.036 J 1/14/2016 198,428 6.62 3,940 1,200 0.038 J 1/20/2016 74,544 6.68 3,500 J 1,220 0.110 1/21/2016 256,967 6.64 4,190 J 1,100 0.150 1/26/2016 263,176 6.70 4,380 J 1,100 0.180 1/27/2016 261 ,302 6.54 3,710 J 1,250 0.190 1/28/2016 223,945 6.74 4,480 J 1,230 0.200

2/1/2016 59,217 6.88 4,450 J 1,190 0.170 2/2/2016 217,730 6.70 4,480 J 1,200 0.150 2/3/2016 227,978 6.88 4,410 1,190 0.180 2/4/2016 223,335 6.88 4,310 1,170 0.230 2/5/2016 227,329 6.74 3,880 1,160 0.210 2/8/2016 146,919 6.60 3,820 J 1,080 0.120 2/9/2016 220,284 7.10 3,860 J 1,080 0.150 2/10/2016 186,005 6.55 4,090 J 1,160 0.210 2/11/2016 191 ,681 6.58 3,770 J 1,080 0.210 2/12/2016 206,199 6.82 3,820 J 1,080 0.230 2/13/2016 183,345 6.64 4,060 J 1,090 0.390 2/14/2016 172,115 6.68 4,060 J 1,090 0.360 2/15/2016 150,190 6.30 3,880 J 1,080 0.310 2/16/2016 106,714 6.33 3,640 J 1,100 0.290 2/17/2016 204,306 6.38 4,000 J 1,120 0.310 2/18/2016 236,948 6.68 3,980 1,060 0.300 2/19/2016 228,750 6.60 3,980 1,060 0.310 2/20/2016 233,552 6.56 4,130 1,030 0.320 2/21/2016 232,803 6.57 3,860 1,050 0.320 2/22/2016 222,351 6.58 4,090 1,060 0.330 2/23/2016 214,588 6.68 3,640 J 1,060 0.320 2/24/2016 203,877 6.78 3,460 J 1,040 0.340 2/25/2016 214,677 6.80 3,760 J 1,320 0.280 2/29/2016 220,408 6.87 3,800 J 1,300 0.270

G-7

POND 5 TREATMENT PLANT TREATED WATER MONITORING PROGRAM SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA POND 5 TREATMENT PLANT DISCHARGE

Total Volume Tn>.ated Chlo1idcs Mcrcmy Date Sampled pH Dissolved (gal) (mg/L) (ppb) Solids (mg/L) 3/1/2016 239,002 6.87 3,840 J 1,070 0.220 3/2/2016 176,686 6.89 3,420 J 1,070 0.210 3/3/2016 76,234 6.90 3,680 J 1,070 0.220 3/9/2016 127,136 6.80 3,630 1,070 0.200 3/10/2016 222,389 6.83 3,620 1,060 0.210 3/11/2016 235,139 6.78 3,630 1,060 0.200 3/12/2016 228,641 6.94 3,450 1,090 0.190 3/13/2016 223,153 6.81 3,460 1,080 0.180 3/14/2016 247,745 6.81 3,800 J 1,070 0.190 3/15/2016 239,550 6.77 3,990 J 1,040 0.220 3/16/2016 233,858 6.84 3,240 J 1,040 0.170 3/17/2016 226,506 6.78 3,870 J 1,070 0.160 3/21/2016 187,384 6.88 3,760 J 1,090 0.130 3/22/2016 222,152 6.78 3,810 J 1,080 0.120 3/28/2016 202,143 6.87 4,070 1,100 0.140 3/29/2016 211,687 6.91 3,910 1,090 0.140 3/30/2016 240,688 6.88 3,900 1,150 0.130

4/6/2016 202,610 7.02 1,140 J 1,140 J 0.200 J 4/19/2016 187,817 6.81 1,180 J 1,180 0.110 4/20/2016 217,422 6.76 1,190 J 1,190 0.100 4/21/2016 222,735 6.88 1,650 J 1,650 0.110 4/22/2016 221 ,397 6.80 1,310 J 1,310 0.097 J

5/2/2016 195,855 6.68 3,680 J 1,390 0.088 J 5/3/2016 229,385 6.78 3,310 J 1,730 0.091 J 5/4/2016 203,852 6.83 3,480 J 1,820 0.086 J 5/5/2016 192,759 6.75 3,550 J 1,470 0.075 J 5/16/2016 166,564 6.74 968 1,720 J 0.077 J 5/17/2016 212,784 6.68 3,400 1,440 0.075 J 5/18/2016 218,126 6.64 3,730 1,460 0.067 J 5/19/2016 252,648 6.80 3,750 1,150 0.061 J 5/23/2016 236,099 6.68 3,840 J 1,160 J 0.066 J 5/24/2016 235,003 6.60 3,800 J 1,160 J 0.062 J 5/25/2016 202,048 6.58 4,070 J 1,150 J 0.070 J

6/14/2016 190,133 6.52 4,000 J 1,170 0.049 J 6/15/2016 263,772 6.80 3,490 1,250 0.055 J 6/16/2016 218,419 7.25 3,450 1,180 0.068 J 6/18/2016 248,965 7.22 3,880 J 1,200 0.080 J 6/19/2016 175,199 6.88 3,510 1,210 0.084 J 6/20/2016 160,397 6.78 4,190 1,210 0.078 J

G-8

POND 5 TREATMENT PLANT TREATED WATER MONITORING PROGRAM SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA POND 5 TREATMENT PLANT DISCHARGE

Total Volume Tn>.ated Chlo1idcs Mcrcmy Date Sampled pH Dissolved (gal) (mg/L) (ppb) Solids (mg/L) 7/11/2016 184,032 6.94 3,630 J 1,330 0.10 7/12/2016 203,281 6.84 3,630 J 1,350 0.054 J 7/13/2016 168,583 6.88 3,800 J 1,390 0.060 J

8/24/2016 240,483 6.74 4,010 J 1,720 J 0.04 J 8/25/2016 271 ,309 6.74 3,610 J 1,720 J 0.06 J 8/26/2016 230,670 6.77 3,840 J 1,710 J 0.05 J

12/9/2016 231 ,114 6.77 4,680 J 2,220 0.012 U 12/10/2016 131 ,030 6.87 4,440 J 2,220 0.012 U 12/11 /2016 104,770 6.84 4,760 J 2,220 0.012 U 12/13/2016 201 ,706 7.10 4,140J 2,290 0.012 U 12/14/2016 201 ,342 6.77 4,980 J 2,240 0.012 U 12/15/2016 184,310 6.87 4,970 J 2,240 0.012 U

3/14/2016 #5 PPT (EQ) na 3,370 1,210 13 3/14/2016 #6 PPT (EQ) na 1,550 190 0.23 7/20/2016 #5 PPT (EQ) na 5,040 2,010 15 7/20/2016 #6 PPT (EQ) na 4,040 219 0.012 U 12/21/2016 #5 PPT (EQ) na 7,460 3,590 2.5 12/21/2016 #6 PPT (EQ) na 1,900 278 0.027 J

1Q16 11,132,945 2Q16 4,653,989 3016 1,298,358 4Q16 1,054,272

Total 18,139,564 U = Analyte was not detected. Value is reporting limit. J = The result is an estimate concentration that is less than the MRL but greater than or equal to the MDL NA = Not Analyzed * = Analytical report currently not available. Data will be reported in a subsequent report.

G-9

POND 5 TREATMENT PLANT TREATED WATER MONITORING PROGRAM SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA POND 5 TREATMENT PLANT DISCHARGE

Total Volume Tn>.ated Chlo1idcs Mcrcmy Date Sampled pH Dissolved (gal) (mg/L) (ppb) Solids (mg/L) 2/6/2017 180,490 6.84 4,340 J 1,620 0.055 J 2/7/2017 240,755 6.81 3,790 J 1,450 0.012 U 2/8/2017 243,764 6.84 3,750 J 1,480 0.012 U 2/14/2017 202,549 7.03 3,380 J 1,450 0.028 J 2/15/2017 205,731 7.01 3,660 1,410 0.016 J 2/16/2017 185,519 6.93 3,840 1,410 0.028 J

3/6/2017 215,302 6.72 * * * 317/2017 242,232 6.68 * * . 3/8/2017 228,967 6.72 • * * 3/9/2017 217,733 6.88 * * * 3/13/2017 228,268 6.77 * * * 3/14/2017 210,484 6.85 . * . 3/15/2017 204,451 6.68 * * * 3/27/2017 221 ,573 6.99 * * * 3/28/2017 252,771 6.74 * * * 3/29/2017 236,229 6.95 . * . 3/30/2017 242,717 6.84 * • *

2/20/2017 #5 PPT (EQ) na 5,100 1,860 17 2/20/2017 #6 PPT (EQ) na 2,230 238 0.11

10 17 3,759,535

Total 3,759,535 U = Analyte was not detected. Value 1s reporting l1m1t. J = The result is an estimate concentration that is less than the MRL but greater than or equal to the MDL NA = Not Analyzed * = Analytical report currently not available. Data will be reported in a subsequent report.

G-10

TABLE 2.6 GROUNDWATER ANALYTICAL DATA PONDS 5 AND 6 MONITORING WELLS SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA 2014 LONG -TERM MONITORING PROGRAM

Total H g Filtered Hg Well No. Date

Notes: na: Not Analyzed ns: Not Sampled U: The compound was analyzed for, but was not detected at or above the M Rl/MDL. J: The result is an estimated concentration that is less than the M RL but greater than or equal to the MDL.

G-11

TABLE 2.6 GROUNDWATER ANALYTICAL DATA PONDS 5 AND 6 MONITORING WELLS SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA 2014 LONG-TERM MONITORING PROGRAM

Total Hg Filtered Hg Well No. Date

G-12

TABLE 2.6 GROUNDWATER ANALYTICAL DATA PONDS 5 AND 6 MONITORING WELLS SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA 2015 LONG-TERM MONITORING PROGRAM

Total Hg Filtered H g Well No. Date

G-13

TABLE 2.6 GROUNDWATER ANALYTICAL DATA PONDS 5 AND 6 MONITORING WELLS SALTVILLE WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA 2015 LONG-TERM MONITORING PROGRAM

Total Hg Filtered Hg Well No. Date

G-14

Graph A.1

Total Mercury Concentrations in Pond 5 Dike Wells (Shallow)

- MW-5S --MW-6S .....MW-75 ~ MW-109S ...,_MW-110S - MW-111S

MCL = 7 pg/I

2003 2004 2005 2006 2007 2008 2009 20IO 2011 2012 2013 2014 2015 2016 Dato(You)

G-15

Graph A.2

Total Mercury Concentrations in Pond 5 Dike Wells (Intermediate)

-+-MW-51 - MW-71

0 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Dato(Yoar)

G-16

Graph A.3

Total Mercury Concentrations in Pond 5 Dike Wells (Deep) 10

8 ..~ 'i 3 ~ :,e (!) .5 6 ...::; --MW-SD .:- --MW-6D i: .g .....MW-7D !! ,: --MW-109D .. 4 l! ..._MW-110D 0 1.,1 - MW-111D i::' :, ..I:! ::E

2 M CL= 2 µg/l

0 2003 2004 2005 2006 2007 2008 2009 20:0 2011 2012 2013 2014 2015 2016 Dato (Yoar)

G-17

GraphA.4

Total Mercury Concentrations in Pond 6 Dike Wells (Shallow)

- MW-8S - MW-95 - MW-106S - MW-107S - MW-108S

MCl= 2 µg/L

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Data (Year)

G-18

Graph A.5

Total Mercury Concentrations in Pond 6 Wells (Shallow)

160

140

.....MW-104S - MW-105S

MCL= 2 µg/L 0 -=- 2003 2004 2005 2006 2007 2008 2009 2C10 2011 2012 2013 2014 2015 2016 Dato (Yoar)

G-19

GraphA.6

Total Mercury Concentrations in Pond 6 Dike Wells (Deep)

- MW-8D - MW-9D ...... MW -106D - MW-1070 - MW-1080

0 2003 2004 2005 2006 2007 2008 2009 20:0 2011 2012 2013 2014 2015 2016

G-20

APPENDIX H – INTERVIEW FORMS

H-1

Saltville Waste Disposal Ponds Five-Year Review Interview Form Superfund Site Site Name: Saltville Waste Disposal Ponds EPA ID No.: VAD003127578

I Subject Name: I William Lindsay Affiliation: RPM – VADEQ Time: I 9:00 a.m. Date: I 5/05/2017

Interview Format (circle one): I In Person Phone I E-Mail I Other:

Interview Category: State Agency

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)? This is a large and complex project requiring a long-term commitment by Olin Corporation, EPA and VADEQ. Cleanup activities and operation and maintenance will continue for the existing remedy in place. Additional remedial actions will also be required. Re-use of the site will remain limited as stipulated in the restrictive covenants on the property.

2. What is your assessment of the current performance of the remedy in place at the Site? The remedy components in place appear to be working according to design and according to the information known at the time of their design. Per the RODs, additional work is ongoing and additional remedial actions are expected.

3. Are you aware of any complaints or inquiries regarding site-related environmental issues or remedial activities from residents in the past five years? No.

4. Has your office conducted any site-related activities or communications in the past five years? If so, please describe the purpose and results of these activities. Yes, VADEQ has conducted site-related activities and communications continually during the past five years. VADEQ is the support agency to EPA for this site and provides meaningful and substantial involvement in the project, including assisting and collaborating with EPA in review of technical data and reports and in long-term planning.

5. Are you aware of any changes to state laws that might affect the protectiveness of the Site’s remedy? In 2013, the Virginia Department of Health (VDH) repealed regulations that prohibited the taking of fish for human consumption from the North Fork Holston River. However, VDH continues to maintain a “Do Not Eat” Fish Consumption Advisory (Advisory). Olin maintains Advisory signs at public access points. If the Advisory is followed, then repeal of the regulation should not affect the protectiveness of the Site’s remedy.

6. Are you comfortable with the status of the institutional controls at the Site? If not, what are the associated outstanding issues? Yes.

7. Are you aware of any changes in projected land use(s) at the Site? In 2016, a company proposed using the site for a solar project. However, the viability of such a project has not been evaluated because no substantial details were provided regarding the proposal. At this time there does not appear to be any changes to the projected land use at the site.

8. Do you have any comments, suggestions or recommendations regarding the management or operation of the Site’s remedy? VADEQ will remain engaged with EPA and Olin Corporation regarding management and operation of the Site’s remedy.

H-2

Saltville Waste Disposal Ponds Five-Year Review Interview Superfund Site Form Site Name: I Saltville Waste Disposal Ponds I EPA ID No.: I VAD003127578 Subject Name: I Keith D. Roberts I Affiliation: I Olin Corporation Subject Contact Information: I 3855 North Ocoee St, Suite 200, Cleveland, TN 37312_ Time: I __3:30 pm______I Date: I _5/25/17______

Interview Format (circle one): I In Person I Phone I E-Mail I Other:

Interview Category: Potentially Responsible Parties (PRPs)

1. What is your overall impression of the remedial activities at the Site? The remedial actions implemented for Operable Units 1 and 2 that include the treatment plant, diversion ditches, soil covers, and impermeable cap have been effective in reducing the environmental exposures. The addition of the two pumping wells should further reduce mercury in the North Fork Holston River.

2. What have been the effects of this Site on the surrounding community, if any? I am not aware of any effects of the site on the surrounding community. Olin supports a community liaison panel to facilitate communications of issues between the town and Olin.

3. What is your assessment of the current performance of the remedy in place at the Site? The remedies have performed as designed with low maintenance and operating costs.

4. Are you aware of any complaints or inquiries regarding environmental issues or the remedial action from residents since implementation of the cleanup? Olin has not received any complaints or inquires.

5. Do you have any comments, suggestions or recommendations regarding the management or operation of the Site’s remedy? Over the last several years, we have identified several reductions for operations that would reduce costs with no impacts on effectiveness of the operations. The recommendations are presented in the annual O&M report.

H-3

Saltville Waste Disposal Ponds Superfund Five-Year Review Interview Site Form Site Name: Saltville Waste Disposal Ponds EPA ID No.: VAD003127578 Subject Name: Stanley Haynes______Affiliation: Olin Saltville Site Manager Subject Contact Information: P O Box 1105 (186 Perryville Rd) Saltville, VA 24370-1105 Time: ____1:14 pm______Date: __5/23/17__

Interview Format (circle one): In Person Phone E-Mail Other:

Interview O&M Project Manager Category:

1. What is your overall impression of the project, including cleanup, maintenance and reuse activities (as appropriate)? The river is looking better and better every year. The reuse at this time is hay production on Pond 5 cap and wildlife habitat on Pond 6 cover.

2. What is your assessment of the current performance of the remedy in place at the Site? It is working as designed.

3. What are the findings from the monitoring data? What are the key trends in contaminant levels that are being documented over time at the Site? The treatment plant consistently meets it treatment objectives. NFHR (river) mercury levels continue trending down.

4. Is there a continuous on-site O&M presence? If so, please describe staff responsibilities and activities. Alternatively, please describe staff responsibilities and the frequency of site inspections and activities if there is not a continuous on-site O&M presence. The site is manned daily during normal business hours. The Treatment Plant operation system notifies me (the site supervisor) of any upset conditions on a 24 hour/7 day basis. I provide daily oversight of site operations for the pumping and treating of the groundwater systems.

5. Have there been any significant changes in site O&M requirements, maintenance schedules or sampling routines since start-up or in the last five years? If so, do they affect the protectiveness or effectiveness of the remedy? Please describe changes and impacts. The installation of the pump and treat system for PZ-10 and MW119s began in April 2017. The system is designed to improve the NFHR conditions.

6. Have there been unexpected O&M difficulties or costs at the Site since start-up or in the last five years? If so, please provide details. There has been no unexpected O&M difficulties or costs at the site in the last five years.

7. Have there been opportunities to optimize O&M activities or sampling efforts? Please describe changes and any resulting or desired cost savings or improved efficiencies. There has been no changes at this time. The 2014 and 2015 annual reports recommendation reductions in several O&M activities but agency approval has not been received.

8. Do you have any comments, suggestions or recommendations regarding O&M activities and schedules at the Site? The 2015 annual report (dated July 29, 2016) makes several recommendations for reductions to the site monitoring program based on thirteen years of monitoring data. The recommendations are as follows: H-4

• Reduce frequency of Pond 5 and Pond 6 groundwater monitoring and reporting • Reduction of the quarterly data report to annually • Reduced sampling frequency for the Pond 5 Treatment Plant to weekly composite samples • Combine the Saltville Site progress report and the OU-2 progress report into one monthly report

H-5

Saltville Waste Disposal Ponds Five-Year Review Interview Form Superfund Site Site Name: Saltville Waste Disposal Ponds EPA ID No.: VAD003127578

Interviewer Name: Vance Evans Affiliation: EPA Subject Name: Redacted Affiliation: Resident Time: 5:00 p.m. Date: 4/26/2017 Interview Location: Public Library

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Resident 1

1. What is your overall impression of the project and the effectiveness of the cleanup? N/A.

2. Were you involved with or had an opinion concerning how the cleanup was decided and implemented? No.

3. What effects have the current site operations had on the surrounding community, if any? None.

4. Are you aware of any community concerns regarding the site or its operation and administration? If so, please give details. No.

5. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or emergency responses from local authorities? If so, please give details. No.

6. Current sampling results are showing that the remedy now in place is working. Do you have an opinion as to anything that we should currently be doing? No.

7. Do you feel well informed about EPA’s activities and progress? No.

8. How do you want to be informed about upcoming work at the site? Fact Sheets.

9. Do you have any comments, suggestions, or recommendations regarding EPA’s current management or operation of the site? No.

10. What extent of community involvement do you wish to have during the future work at the site? Resident stated that the library is a great resource for the community and would be happy to be a mediator between EPA and the government in helping to disseminate information.

H-6

Saltville Waste Disposal Ponds Five-Year Review Interview Form Superfund Site Site Name: Saltville Waste Disposal Ponds EPA ID No.: VAD003127578

Interviewer Name: Vance Evans Affiliation: EPA Subject Name: Redacted Affiliation: Resident Time: 4:00 p.m. Date: 4/26/2017 Interview Location: Residence

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Resident 2

1. What is your overall impression of the project and the effectiveness of the cleanup? Everything has gone “pretty good”. Resident stated the Site is in much better condition than the “muck” that was there previously.

2. Were you involved with or had an opinion concerning how the cleanup was decided and implemented? No. Resident did not live here at the time.

3. What effects have the current site operations had on the surrounding community, if any? None.

4. Are you aware of any community concerns regarding the site or its operation and administration? If so, please give details. No.

5. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or emergency responses from local authorities? If so, please give details. No.

6. Current sampling results are showing that the remedy now in place is working. Do you have an opinion as to anything that we should currently be doing? No.

7. Do you feel well informed about EPA’s activities and progress? Yes.

8. How do you want to be informed about upcoming work at the site? Fact Sheets.

9. Do you have any comments, suggestions, or recommendations regarding EPA’s current management or operation of the site? No.

10. What extent of community involvement do you wish to have during the future work at the site? None.

H-7

Saltville Waste Disposal Ponds Five-Year Review Interview Form Superfund Site Site Name: Saltville Waste Disposal Ponds EPA ID No.: VAD003127578

Interviewer Name: Vance Evans Affiliation: EPA Subject Name: Redacted Affiliation: Resident Time: 2:00 p.m. Date: 4/26/2017 Interview Location: Residence

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Resident 3

1. What is your overall impression of the project and the effectiveness of the cleanup? If it’s doing what it’s supposed to do, resident is pleased. Resident stated it’s a smart idea because he understands the science of what is going on. Resident suggested that EPA thoroughly discuss the remedy and why it is important in the next public meeting.

2. Were you involved with or had an opinion concerning how the cleanup was decided and implemented? No.

3. What effects have the current site operations had on the surrounding community, if any? It angered local motorcycle riders, though that is now a “dead issue.” Resident is pleased his children are no longer playing on the property now.

4. Are you aware of any community concerns regarding the site or its operation and administration? If so, please give details. No.

5. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or emergency responses from local authorities? If so, please give details. No.

6. Current sampling results are showing that the remedy now in place is working. Do you have an opinion as to anything that we should currently be doing? No.

7. Do you feel well informed about EPA’s activities and progress? No.

8. How do you want to be informed about upcoming work at the site? Education for future generations is very important. Public meetings and a quarterly or annual report would be very helpful in keeping new generations of residents informed of an event that happened in the past.

9. Do you have any comments, suggestions, or recommendations regarding EPA’s current management or operation of the site? No.

10. What extent of community involvement do you wish to have during the future work at the site? Updates on an as needed basis.

H-8

Saltville Waste Disposal Ponds Five-Year Review Interview Form Superfund Site Site Name: Saltville Waste Disposal Ponds EPA ID No.: VAD003127578

Interviewer Name: Vance Evans Affiliation: EPA Subject Name: Redacted Affiliation: Resident Time: 12:00 p.m. Date: 4/26/2017 Interview Location: Museum of the Middle Appalachians

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Resident 4

1. What is your overall impression of the project and the effectiveness of the cleanup? Resident stated that Olin, with EPA oversight, has done a fabulous job with the cleanup and is very pleased with the efforts to clean the water. Resident was pleased with the decision to cap the contamination, as opposed to removal and remediation.

2. Were you involved with or had an opinion concerning how the cleanup was decided and implemented? No.

3. What effects have the current site operations had on the surrounding community, if any? None.

4. Are you aware of any community concerns regarding the site or its operation and administration? If so, please give details. No.

5. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or emergency responses from local authorities? If so, please give details. No.

6. Current sampling results are showing that the remedy now in place is working. Do you have an opinion as to anything that we should currently be doing? No.

7. Do you feel well informed about EPA’s activities and progress? Yes.

8. How do you want to be informed about upcoming work at the site? An information booklet placed in places such as the Museum of the Appalachians and the local Library.

9. Do you have any comments, suggestions, or recommendations regarding EPA’s current management or operation of the site? No.

10. What extent of community involvement do you wish to have during the future work at the site? Resident stated they would be happy to help in any way that results in the public being more informed about their community.

H-9

Saltville Waste Disposal Ponds Five-Year Review Interview Form Superfund Site Site Name: Saltville Waste Disposal Ponds EPA ID No.: VAD003127578

Interviewer Name: Vance Evans Affiliation: EPA Subject Name: Redacted Affiliation: Resident Time: 5:00 p.m. Date: 4/26/2017 Interview Location: Residence

Interview Format (circle one): In Person Phone Mail Other:

Interview Category: Resident 5

1. What is your overall impression of the project and the effectiveness of the cleanup? Good. Nobody in the town speaks about the Site.

2. Were you involved with or had an opinion concerning how the cleanup was decided and implemented? I attended one or two meetings.

3. What effects have the current site operations had on the surrounding community, if any? None.

4. Are you aware of any community concerns regarding the site or its operation and administration? If so, please give details. No.

5. Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or emergency responses from local authorities? If so, please give details. No.

6. Current sampling results are showing that the remedy now in place is working. Do you have an opinion as to anything that we should currently be doing? No.

7. Do you feel well informed about EPA’s activities and progress? Yes.

8. How do you want to be informed about upcoming work at the site? Facts sheets and door-to-door community engagement.

9. Do you have any comments, suggestions, or recommendations regarding EPA’s current management or operation of the site? They need to clean this place up down here.

10. What extent of community involvement do you wish to have during the future work at the site? None.

H-10

APPENDIX I – SMYTH COUNTY PUBLIC WATER ORDINANCE

Accessed 8/21/2017 at https://library.municode.com/va/smyth_county/codes/code_of_ordinances?nodeId=CH53UT_ARTIIIWA

Sec. 53-76. - Connection to public water system. (a) Service connection required. The owner, tenant, or occupant of all commercial buildings, industrial plants, institutional establishments, structures and properties used for human occupancy, business, employment, recreation, and industrial or other purposes, and which abut upon any street, alley, public right-of-way, or public easement containing a public water line hereafter made available by the county, and such building or dwelling is not greater than 200 feet from a public water line, shall connect such building or dwelling with such water line within 180 days after such line becomes available, and shall cease to use any other source of water supply for domestic use except for hereafter provided. (b) Installation of water lines. The county may only install water lines in a predominately residential area after a majority of at least 60 percent of the property owners with a residence in the service area, as defined hereafter, file a sworn affidavit with the county administrator's office in favor of the proposed water line project. The requirement of a 60 percent majority shall not apply where the proposed water line will serve commercial or industrial facilities. A residence shall be considered to be located in the service area if the residence is 200 feet or less from the proposed line, or if the property owner has signed a service agreement and the residence is located more than 200 feet from the proposed line. (c) Fees and deposits. The owner shall pay a connection fee and an application fee set by the county to connect to the water system. Tenants who have obtained a signed landlord authorization form shall pay an application fee and a security deposit as set by the county. (d) Exceptions to required connection. The county administrator shall be allowed to grant exceptions to this requirement where it is not physically feasible to make the connection. (e) Domestic supply. Notwithstanding any other provision of this section, those persons having a domestic supply or source of potable water shall not be required to discontinue the use of same. However, persons not served by a water supply system as defined in Code of Virginia, § 15.1-341, producing potable water meeting the standards established by the Virginia Department of Health, shall be required to pay a monthly service availability charge, which charge shall not be more than that proportion of the minimum monthly user charge, imposed by the county, as debt service bears to the total operating and debt service costs. (f) Exemptions. (1) Annually, beginning March 1 and not later than May 31 of each taxable year, the person claiming the exemption must notify the county administrator in writing that the person is claiming the exemption. (2) The county administrator shall contact the treasurer to see that the proper certification has been filed with the treasurer's office to ensure that the person is entitled to said exemption or deferral, and upon confirmation, shall notify the billing department of the amount of said exemption or deferral.

( Ord. of 6-26-2014 )

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