St. Lawrence River Environment Natural Resource Damage Assessment: Restoration and Compensation Determination Plan and Environmental Assessment: Appendices November 2012 prepared by: Natural Resource Trustees of the St. Lawrence River Environment: National Oceanic and Atmospheric Administration New York State Department of Environmental Conservation St. Regis Mohawk Tribe Environment Division United States Fish and Wildlife Service with assistance from: Rachel DelVecchio, Robert Unsworth, and Chris Leggett Industrial Economics, Incorporated Draft A-1 LIST OF APPENDICES APPENDIX A: SITE HISTORY AND REMEDIAL DETAIL APPENDIX B: PCBS IN SOIL APPENDIX C: PCBS IN GROUNDWATER APPENDIX D: EVALUATION OF EXPOSURE AND TOXICITY OF ALUMINUM, CADMIUM, CYANIDE, DIOXINS/FURANS, FLUORIDE, LEAD, MERCURY, AND PAHS TO NATURAL RESOURCES WITHIN THE ASSESSMENT AREA APPENDIX E: ST. LAWRENCE ENVIRONMENT NATURAL RESOURCE DAMAGE ASSESSMENT: QUALITATIVE ASSESSMENT OF EFFECTS OF POLYCHLORINATED BIPHENYLS (PCBS) ON REPTILES AND AMPHIBIANS IN THE ST. LAWRENCE ENVIRONMENT APPENDIX F: ST. LAWRENCE ENVIRONMENT NATURAL RESOURCE DAMAGE ASSESSMENT PRELIMINARY ASSESSMENT OF EFFECTS OF POLYCHLORINATED BIPHENYLS (PCBS) ON MAMMALS IN THE ST. LAWRENCE ENVIRONMENT APPENDIX G: DETAILS REGARDING QUANTIFICATION OF PCB-RELATED LOSSES APPENDIX H: ST. LAWRENCE ENVIRONMENT NATURAL RESOURCE DAMAGE ASSESSMENT PRELIMINARY ASSESSMENT OF EFFECTS OF FLUORIDE ON MAMMALS IN THE ST. LAWRENCE ENVIRONMENT APPENDIX I: RANDOM UTILITY MAXIMIZATION (RUM) MODEL FOR THE RECREATIONAL FISHING ASSESSMENT APPENDIX J: ANTHROPOLOGICAL REPORT. THE EFFECTS OF ENVIRONMENTAL CONTAMINATION ON THE MOHAWKS OF AKWESASNE APPENDIX K CULTURAL IMPACT STUDY. ASSESSMENT AND OVERVIEW OF THE EFFECTS OF ENVIRONMENTAL CONTAMINATION ON THE MOHAWKS OF AKWESASNE APPENDIX L CULTURAL ASSESSMENT: INSTITUTIONAL FUNDING EVALUATION TOOL APPENDIX A: SITE HISTORY AND REMEDIAL DETAIL EXHIBIT A-1 ALCOA WEST SITE TIMELINE DATE ACTION 1903 Alcoa’s aluminum manufacturing facility on the Grasse River commenced in 1903 includes a fabricating area, ingot extrusion area, and a smelter. Aluminum is produced from alumina using the pre-baked anode method. 1957 Alcoa begins use of polychlorinated biphenyls (PCBs) in hydraulic fluid and electrical equipment. 1980 SRMT settles with Alcoa for $464,000 after agreeing not to sue for damages to cattle and vegetation for 10 years. January 1985 NYSDEC enters into Consent Order with Alcoa to investigate and remediate industrial waste areas at the facility. 1985 MCA settles with Alcoa and Reynolds for $650,000 for damages to cattle and vegetation from emissions. The suit claimed that emissions from both Alcoa and Reynolds caused damages to the health of the St. Regis Mohawks residing on Cornwall Island and also damaged their cattle and other vegetation crops. The health aspects of the suit were dropped after a fluoride exposure assessment was conducted. The amount of $430,000 was subtracted from the settlement for legal fees. August 1987 Alcoa completes a Remedial Investigation Report (Volumes I and II) for the uplands. February 1989 NYSDEC issues draft SPDES permit modifications to Alcoa requiring non- detectable levels of PCBs using Method 680 with a detection limit of 0.065 ug/l. September 1989 EPA issues Unilateral Administrative Order (UAO) to Alcoa for the investigation and remediation of lower Grasse River sediments. Fall 1989 Alcoa installs a leachate collection system, as an interim measure, at the General Refuse Landfill, to intercept contaminant migration to the East Marsh. Fall 1990 Alcoa excavates contaminated sediment from West Marsh (8000 cy) and the first 400 feet of the Unnamed Tributary (1500 cy) and ships it off- site. October 1990 A revised Consent Order is issued by NYSDEC to guide remaining remedial investigations, design, and remedy implementation. November 1990 Alcoa finalizes Feasibility Study (FS) for nine plant site areas. December 1990 Alcoa stops dumping wastes in the General Refuse Landfill and installs an interim cap. 1991-1994 Alcoa performed Phase I and Phase II of the River and Sediment Investigations (RSI). The Phase I study concluded that PCBs were the major contaminant of concern (COC). February 1991 Alcoa completes FS for remaining plant sites. March 1991 NYSDEC issues ROD to address eight sites on Alcoa property. Remedy includes removal, treatment, and containment of contaminated material. The eight sites comprised the Potliner Disposal Site “A”, Potliner Disposal Site “I”, Dennison Road, Soluble Oil Lagoon, Primary Lagoon and Dredge Spoils Area, Oily Waste Landfill, West Marsh and the Unnamed Tributary. DATE ACTION June 1991 Alcoa installs carbon treatment at one outfall. July 1991 Alcoa pays $7.5 million in criminal fines and civil penalties to NYS for SPDES permit wastewater discharge violations and illegal storage, shipping and disposal of hazardous waste. August 1991 Alcoa enters into Consent Order with NYSDEC to reduce PCB discharges and to settle February 1989 SPDES permit action. December 1991 Alcoa replaces wet air pollution control wet system with dry scrubbers and implements other waste control actions to reduce wastewater discharges from the Alcoa facility from 12 to 6 million gals (mgal) per day. January 1992 NYSDEC issues second ROD to address six sites on Alcoa property. Remedy includes leachate collection, groundwater treatment, and removal and treatment of soils and sediments. The six sites comprise the General Refuse Landfill, Waste Lubricating Oil Lagoon, 60-Acre Lagoon, Sanitary Lagoon, East Marsh, and the Landfill Annex. March 1992 Alcoa installs carbon treatment on second outfall. June 1992 Alcoa pays $2250 fine for violating TSCA when two capacitors are found on-site that were supposed to have been disposed off-site. 1993 EPA produces the Revised Risk Assessment Aluminum Company of America Study Area. An Amendment to the Administrative Order Index No. II-CERCLA-90229 allows for the NTCRA. June – October 1995 Alcoa conducts the Non-Time Critical Removal Action (NTCRA) removing ~2600 cy PCB-contaminated sediment and 400 cy PCB-contaminated debris/boulders from Alcoa’s 001 Outfall. Highest concentrations at outfall were 11,000 ppm. Approximately 85% reduction PCBs achieved from this removal action. 1996 - Ongoing Alcoa initiates Supplemental Remedial Studies (SRS) including annual water and fish sampling in the lower Grasse River. Studies indicate sediments an important source of PCBs in fish. August 1996 NYSDEC issues ROD for the Storage Tank No. 51. December 1996 Alcoa submits a draft Analysis of Alternatives Report (A of A) to EPA. October 1997 The New York State Department of Environmental Conservation (DEC), in a letter dated October 10, 1997, notified Alcoa that its Massena, New York facility allegedly is in violation of certain air pollution control requirements. The allegations included operation of certain emission sources without permits, non-compliance with permitting and control standards for sulfur dioxide, carbon monoxide and carbonyl sulfide and violation of requirements related to the deposition of fluoride on vegetation. 1998 In early March 1998, the Company agreed to an Order on Consent with the DEC. Alcoa pays fine of $57,500 to settle dispute with NYSDEC surrounding Alcoa’s adherence to Consent Order that allowed more fluoride to be released than permitted. March 1998 NYSDEC issues ROD for the HPM Press Area. June 1998 NYSDEC issues ROD for the Unpaved Plant Roads. 1999 Alcoa excavated contaminated sediments from the RCP pipe and the Unnamed Tributary pursuant to March 1991 ROD. August 1999 Alcoa submitted the 1999 Draft Comprehensive Characterization of the Lower Grasse River (CCLGR) Report to EPA. DATE ACTION December 1999 Alcoa submits an Analysis of Alternatives Report to EPA. March 2000 NYSDEC issues a ROD for the West Fill Area. 2001 Alcoa conducted the Capping Pilot Study (CPS) screening a variety of cap material and placement methods in a 750 ft stretch of PCB- contaminated river sediments (7-acres). The primary cap consisted of a foot of 1:1 sand:topsoil (6-12 in). Other cap combinations included Aquablok only (3-4 in), and bentonite only (2 in) or in combination with 1:1 sand:topsoil (12 in). April 2001 Alcoa submitted the amended 2001 CCLGR to EPA. Cleanup of the Soluble Oil Lagoon completed. June 2001 Cleanup of the 60-Acre Lagoon and the West Fill Area completed. October 2001 Cleanup of the Unpaved Plant Roads completed. June –August 2002 Alcoa submitted the Analysis of Alternatives Report dated 6/12/02 and it was subsequently approved by EPA. July 1, 2002 Alcoa submits updated Human Health Risk Assessment. April-May 2002 EPA’s National Remedy Review Board (NRRB) reviews proposed remedial action for the Lower Grasse River and issues its recommendations. April 2003 EPA Region 2 responds to NRRB memorandum recommendations on Alcoa’s Grasse River Study Area. Spring 2003 Ice jam scoured ~ 1 foot of cap and ~3.8 feet of sediment below some parts of the capping pilot study, along with other areas of scouring. 2005 Alcoa performed the Remedial Options Pilot Study (ROPS) to assess remedial effectiveness of potential alternatives for the river. Dredging (~25,000 cy), armored capping (~1 acre) and thin-layered capping (~0.5 acres) were implemented in the lower Grasse River. Dredged material placed in on-site landfill. September-October Alcoa conducted the Activated Carbon Pilot Study (ACPS) in ~0.5 acre 2006 area of the lower Grasse River to assess the effectiveness of granulated activated carbon (GAC) in reducing