REMEDIAL ACTIONS AT HAZARDOUS WASTE SITES

                    Survey and Case Studies
                               By

          N. Neel-y-r- D- Gi,lLe.s.p,ifi_, F- Schaufj J. Walsh
                         SCS Engineers
                      Covington, Kentucky


This final report EPA-430-9-81-005 describes work  performed  for
      the Municipal Environmental Research  Division  of  the
       U.S. EPA Office of Research and Development under
                    Contract No. 68-01-4885
       and is reproduced as received from the  contractor


           D. Banning and S. James, Project Officers
          Solid and Hazardous Waste Research Division
          Municipal Environmental Research  Laboratory
                   Cincinnati, Ohio    45268


  Published by the Oil and Special Materials Control Division
              U.S. Environmental Protection Agency
                   Washington, D.C.    20460


                         January, 1981

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                          DISCLAIMER
     This report has been reviewed by the Municipal Environmental
Research Laboratory, U.S. Environmental Protection Agency, and
approved for publication.  Approval does not signify that the
contents necessarily reflect the views and policies of the U.S.
Environmental Protection Agency, nor does mention of trade
names or commercial products constitute endorsement or
recommendation for use.
                               ii

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                            FOREWORD
     The U.S.  Environmental  Protection Agency was  created
because of increasing public and government concern  about  the
dangers of pollution to the  health and welfare of  the  American
people.  Noxious air, foul water, and spoiled land are tragic
testimonies to the determioration of our natural  environment.
The complexity of that environment and the  interplay of its
components require a concentrated and integrated  attack on the
problem.

     Research  and development is that necessary first  step in
problem solution; it involves defining the  problem,  measuring
its impact, and searching for solutions.  The Municipal
Environmental  Research Laboratory develops  new and impoved
technology and systems to .prevent, treat, and manage wastewater
and solid and  hazardous waste pollutant discharges from
municipal and  community sources, to preserve and  treat public
drinking water supplies, and to minimize the adverse economic,
social, health, and aesthetic effects of pollution.   This
publication is one of the products of that  research  and provides
a most vital communications  link between the researcher and  the
user community.

     With the  passage of Superfund legislation providing for the
clean-up of environmental hazards at uncontrolled  waste disposal
sites, information is needed on the types of remedial  actions
that have been implemented to date, as well as their effective-
ness and cost.  This report  provides this information  by presenting
the results of a nationwide  survey of 169 such remedial action
sites.  More specific information on nine of these sites is
provided in the form of detailed case studies, also  contained
herein.
                                Francis T. Mayo, Director
                                Municipal  Environmental  Research
                                Laboratory
                               111

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                            ABSTRACT
     During the Summer of 1980, a nationwide survey was conducted
to determine the status of remedial  actions applied at uncontrolled
hazardous waste disposal sites;  Over 130 individuals were
contacted to obtain information on such remedial action projects.
A total of 169 sites were subsequently identified as having
been subject to corrective measures.

     Remedial actions were found to have been implemented at
many kinds of hazardous waste disposal facilities including
drum storage areas, incinerators, and injection wells, but
most frequently landfill/dumps and surface impoundments.   At
the sites receiving such remedial actions, ground water was
found to be the most commonly affected media, followed closely
by surface water.

     Although several types of- reme-d-i-a-1- mea-s-tHpes—we-re—identified,
remedial activities usually consisted of containment and/or
removal of the hazardous wastes.  Sufficient money was often
not available for complete environmental cleanup (e.g.,
extraction and treatment).  The survey determined that a
lack of sufficient funds and/or selection of improper techno-
logies was responsible for remedial actions having been applied
effectively at only a portion of the uncontrolled hazardous
waste disposal sites.  Where they had been applied, remedial
actions were found to be completely effective only 16 percent
of the time.
     Nine
pollution
hazardous
actions we
effective
nine sites
incinerati
water cont
sites were studied in detail  to document typical
problems and remedial actions at uncontrolled
waste disposal sites.  Of these ninesites, remedial
re completely effective at two and only partially
at the other seven.  Technologies employed at these
 included (1) containment, (2) removal  of waste for
on or secure burial, (3) institution of surface
rols, and (4) institution of ground water controls.
     The work upon which this report is based was performed
pursuant to Contract No. 68-01-4885, Directive of Work No. 13,
with the U.S. Environmental Protection Agency.  Work was
performed between April and October L980.

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                             CONTENTS
Foreword. .	 i i 1
Abstract	 _iv
Figures	v i i i
Tables	   x

   1 .   Summary	   1
         Introduction	   1
         Project Description	   2
         Survey Findings	   3
         Case Study Fi ndi ngs	.--	   7
         Concl us ions	   7
         Summary References and Bibliography	  10
         Appendix 1-1,  Remedial Action Hazardous Waste
           Sites by State	  11
   2.   Site A, Olin Corporation, Saltville, Virginia	  21
         Introduction	  21
         Site Description	  21
         Site Operation and History	  26
         Pollution	I	  28
         Remedial Action..,	  33
         Concl us i on	  40
         Site A References and Bibliography	  42
         Appendix 2-1 ,  Site A  Photographs	,.	 ...  43
   3.   Site B, .Firestone Tire  and Rubber Company,                 "
           Pottstown, Pennsylvania	  47"
         Intro duct ion	  47
         Site Description	  47
         Site Operation and History	  48
         Pollution	  53
         Remedial Action	  54
         Concl us ion	  55
         Site B References and Bibliography	  59
         Appendix 3-1,  Site B  Photographys	  60
   4.   Site C, Anonymous Waste-Disposal Company  Dump Site,
           East-Central, New York	,	  65
         Introduction	  65
         Site Description	  65
         Site Operation and History	  70
         Pollution	  74
         Remedial Action	  75
         Concl us ion. . . .. .	"."rr.	  83
         Site C References and Bibliography	  85
         Appendix 4-1,  Waste Disposal  Company Sampling
           (1975-1979)  for Site C	  86
         Appendix 4-2,  Site C  Photographs.	  91

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CONTENTS (Continued)
   5.   Site D, Destructo/Carolawn,  Kernersville
           North Carolina	   95
         Introduction	   95
         Site Description	   96
         Site Operation and History	   99
         Pol 1 uti on	  100
         Remedial  Action	  104
         Conclusion	  109
         Site D References and Bibliography	  Ill
         Appendix 5-1, Site D Newspaper Articles	  112
         Appendix 5-2, Site D Photographs	  116
   6.   Site E, Whitmoyer Laboratories, Myerstown,
           Pennsylvania	  121
         Introduction	  1 21
         Si te Description	 rr~.~........  1 21
         Site Operation and History	  125
         Pollution and Remedial Action	  127
         Con cl us ion	  1 35
         Site E References and Bibliography	  137
         Appendix 6-1, Site E Photographs	  138
   7.   Site F, Western. Sand and Gravel, Burrillville,
           Rhode Island	  141
         Introduction	141
         Site Description	  141
         Site Operation and History	  147
         Pollution	  148
         Remedial  Action	  154
         Concl usi on	  1 54
         Site F References and Bibliography	  157
         Appendix 7-1, Multi-Probe  Well Installation
           Details for Site F	,158
         Appendix 7-2, Site F Photographs	  162
   8.   Site G, Ferguson Property, Rock Hill, South Carolina..  166
         Introduction	  166
         Site Description	  166
         Site Operation and History	  167
         Pollution	  169
         Remedial Action	  171
         Conclusion	  176
         Site G References and Bibliography	  177
         Appendix 8-1, Site G Photography	  178
                                 VI

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CONTENTS (Continued)
   9.   Site H,  3M Company,  Woodbury,  Minnesota.	  182
         Introduction	  182
         Site Description	  182
         Site Operation and History	  186
         Poll ution	  188
         Remedial  Action	  190
         Conclusion	  197
         Site F References  and Bibliography	  198
         Appendix 9-1,  Site F Photographs	  199
  10.   Site I,  Whitehouse/Allied Petroleum,
           Jacksonville, Florida	  202
         Introduction	  202
         Site Description	  202
         Site History and  Pollution	  203
         Remedial  Action	  208
         Monitoring	  215
         Concl usion... .	  222
         Site I References  and Bibliography	'.....	  224
         Appendix 10-1, Well  Log for  Site  I...	  225
         Appendix 10-2, Site  I Photographs	  227
                                vii

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                             FIGURES
Number                                                        Page

 2-1      Aerial  Photograph of Olin Chemical Complex	  22
 2-2      Site Layout of Olin Chemical  Complex	  23
 2-3      Generalized Geologic Cross Section	  25
 2-4      Upper Holston River Watershed	  25
 2-5      Location of Former River Bed  through Waste
           Ponds 5 and 6	-..	  27
 2-6      Process Flow Diagram for Olin Alkali Plant	  29
 2-7      Soda-Alkali Production at Olin Saltville Plant	  30
 2-8      Chlorine-Caustic Production at Olin Saltville Plant..  30
 2-9      Erosion Control Measures at Chlorine Plant Site	  35
 2-10    Construction Details for Sealing North Fork
           River bank	,_. .	  36
 2-11    Mean Mercury Content of the Sediment at the
           Control  and Affected Stations on the Holston
           River July 1978 and July 1979	  38
 2-12    Mean Mercury Content of the Fish at the Control
           and Affected Stations On the Holston River
           July  1978 and July 1979	  39
 3-1      Partial Map of the Firestone  Plant Showing Some
           Wells and Pits Used for Remedial Action	  49
 3-2      Location Map of Firestone Plant with Remedial
           Action Wei Is	 r.. . ,	__5JD_
 3-3      Rough Geologic Cross Section  of the Material
           Underlying the Firestone Plant	  51
 3-4      Location and Partial Geologic Map for Firestone's
           Pottstown, Pennsylvania Plant	  52
 3-5      Sulfate Concentration in the  Ground Water Before
           and After the Use of the Recovery Wells	  56
 3-6      Five Day BOD in the Ground Water Before and After
           Use of the Recovery Wells	  56
 3-7      Chlorine Concentration in the Ground Water Before
           and After Use of the Recovery Wells	  57
 4-1      Site C  Location Map	  66
 4-2      Site Environs (1966 Before Closure)	  67
 4-3      Facility Layout in 1968 Before Closure	  69
 4-4      Generalized Geologic Cross Section of Site C in 1980.  71
 5-1      Site Layout of Destructo/Carolawn, Kernersvi11e,
           South Carolina	  97
 5-2      Drainage Pattern of Destructo/Carolawn Site	  98
 5-3      Tank Location and Flow Direction of 1977 Spill
           at Destructo/Chemway	 102
                               VI 1 1

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FIGURES (Continued)


Number                                                        Page

 6-1      Location of Whitmoyer Laboratories...................  122
 6-2      Detailed Site Location for Whitmoyer Laboratories....  124
 6-3      Ground Water Contour Map of Whitmoyer Laboratories...  124
 6-4      Generalized Geologic Cross Section Drawn
           Perpendicular to the Strike Direction	  126
 6-5      Location of Wells on the Whitmoyer Lab Property	  129
 6-6      Location of Sampling Stations Established by the
           U.S. Army Corps of Engineers	  134
 6-7      Arsenic Content at Station 2 at Whitmoyer Labs	  134
 6-8      Cumulative Graph of Arsenic Removed from the
           Ground Water at the Plant Site.....	  136
 7-1      Location of Western Sand and Gravel Site...	  142
 7-2      Site Environs and Monitoring Well  Locations	  144
 7-3      Well and Pit Location Map	  145
 8-1      Location of Ferguson Site in Rock  Hill,
           South Carolina	  168
 8-2      Location of Drums on Ferguson Property	  172
 8-3      Site Layout After Remedial Action  at the
           Ferguson Property	  1 74
 9-1      Location of 3M Disposal Site in Woodbury, Minnesota..  183
 9-2      Geological Cross Section of Area Beneath
           Woodbury Disposal Site	  185
 9-3     Configuration of Waste Disposal Pits at
           3M Woodbury Site	  187
 9-4     Location of Contaminated Schussler Well
           and Barrier Wells	  189
 9-5     Sum of the Concentration o*f Isopropyl Either,
           Isopropanol, and Dichloromethane for Shall
           Well at Schussler Residence	  191
 9-6     Graphs of Isopropanol Ether Measurements
           for Barrier Well Nos. 1 to 4	  195
10-1      Location of Whitehouse/Al1ied Petroleum Site	  204
10-2     Layout of Whitehouse Oil Pits	  205
10-3     Layout of Whitehouse Oil Pits and  Diversion  Ditches..  206
10-4     Carbon Adsorption Treatment Plant  for PCB's	  212
10-5     Pit Profile After Stabilization	  214
                                 i x

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                               TABLES
 Number

 1-1
 1-2
 1-3
 1-4
 1-5
 1-6
 1-7
 4-1
 5-1

 5-2
 5-3
 6-1
 7-1
 7-2
 7-3
 7-4

 7-5
 7-6
 8-1

 8-2

 9-1
 9-2

10-1
10-2
10-3
10-4
10-5
10-6
10-7
Facility Type at Remedial .Action Sites	   4
Location of Remedial Action Sites..	   5
Affected Media at 169 Remedial Action  Sites..	   6
Funding Sources at 169 Remedial Action Sites...	'. .  6
Pollution and Remedial Action Status at 169 Sites....   7
Case Study Site Identification	   8
Case Study Site Background	  8
Waste Disposal Company Sampling (1966)	  76
Storage of Waste Materials at Destructo
  Chemway Corporation	 101
Carolawn's Inventory as of July 31, 1978	 105
Bioassay Studies	 108
Initial Arsenic Concentrations from Plant Wells	 130
Pit Dimensions and Volumes	 146
Summary of Field Permeability Testing  Results	.150
Analytical Results for ~Ptt' Samp! tug orr 2/27-/-80-T-.—.... 151
Analytical Results for Well  and Stream Sampling
  on February 7, 1980	 152
Analytical Results for Well  Sampling on May 1,  1980.. 153
Estimated Remedial Action Costs	 155
U.S. Environmental Protection Agency Drum
  and Soil Analysis	 170
Cost of Containment Remedial Measures at
  Ferguson Property	 175
Horsepower and Discharge of Barrier Wells	 194
3M Woodbury Wells Priority Pollutant
  Sampling Results	 194
Partial Remedial Action Costs for First Phase	 216
Projected Remedial Action Costs for Second Phase	 216
Depth of Monitoring and Private Wells.......777...... 217
Water Quality in Wells	 218
Initial PCB Analysis of Sludge Samples	 220
Quantitative Analysis of Oil Sludge	 220
Analyses of Treatment System Removal Efficiencies	 221

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                           SECTION 1

                           •SUMMARY
INTRODUCTION

     Proper disposal and transport of hazardous substances is a
major concern of the U.S. Environmental Protection Agency (EPA).
Past management of hazardous residues has generally been inade-
quate and unsound disposal
health and safety impacts.
of all hazardous waste has
Facilities comprising this
(48 percent), landfills  (30 percent), incinerators
and other practices  (2 percent).   [1-1]
practices have created adverse public
 It has been estimated that 90 percent
been disposed of in an unsound manner.
90 percent include surface impoundments
                        (10 percent),
     The  two laws which  provide  federal assistance  for remedial
.actions at  uncontrolled  hazardous waste sites are the Clean
Water Act  (CWA) and the  Resource  Conservation and Recovery Act
(RCRA).   Under  Section 311 of  CWA, a  special contingency  fund
is  available for emergency remedial action at sites where the
release of  oil  or hazardous  materials  threatens  navigable waters.
However,  land spills  that do not  directly threaten  surface
water are  not covered  under  Section 311.

     RCRA dictates the manner  in  which hazardous material may
be  transported, stored,  treated,  and  disposed.   The regulatory
thrust of RCRA  is current!y  being placed on,identification of
abandoned  waste sites  and abatement of pollution at such  sites.
Section 7003 of RCRA  authorizes  EPA to bring suit against
legally responsible parties  to remedy conditions at sites that
present "imminent and  substantial endangerment  to health  or
the environment".

     The  authorities  under  CWA and  RCRA enable  EPA  to  (1) supply
limited assistance for enforcement  related  investigations
 (e.g.,  chemical analysis, site investigation, technical  assis-
tance);  (2) take  emergency  remedial action  where navigable
waters  are threatened;  and  (3) take legal action i.n cases where
sites  pose an  imminent hazard.  However,  remedial actions at
sites  where navigable waters are not  threatened can only be
initiated and  funded.by  states,  local governments,  and
 responsible parties.   Usually  in cases where Section  311  funds
are not  used,  extensive  time is  involved  in  identifying  the
problem,  the -responsible party,  and the  remedial measure which
 is  likely to  be successful.   Even more time  is  often  required
 in  getting the  responsible  party to clean  up such  sites,  either
 voluntarily or  through court action.   The  Comprehensive  Environ-
 mental  Response, Compensation  and Liability  Act  (Superfund) was .
 passed  and signed into law in  December 1980  in order to better
 address  these problems.

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PROJECT DESCRIPTION

     In an effort to determine the type and effectiveness of
past remedial actions at uncontrolled sites, a nationwide
survey of on-going and completed remedial  action projects was
conducted from May to October 1980.  The purpose of the survey
was to provide information and examples of applied remedial
action technologies.  Examples provided in the form of case
histories identify typical problems, effectiveness, and costs
related to implementing remedial action at such facilities.

     During the initial phase of the survey, a list was compiled
of disposal sites where remedial actions had been or were being
implemented.  Remedial action sites were identified based upon
file and literature review and face-to-face discussions with
federal and state personnel.  The intent was to compile a list
of remedial action sites which (1) represented different remedial
action technologies; (2) were located in diverse geographical,
geological, and climatological regions; and (3) were fairly
effective in resolving the environmental hazard.

     In identifying remedial action sites, emphasis was placed
upon landfills, surface impoundments, drum storages, incinerators
and deep well injection facilities.  If federal or state
personnel identified a spill, that site was listed.  However,
spill sites were not usually sought during the survey, since
much of this data is reported yearly in the proceedings from
the National Conference on Control of Hazardous Materials
Spills.

     For the purposes of this survey, a waste burial site was
designated as a "landfill" if it was permitted to receive
such waste.  It was designated a "dump" if it had not been
legally permitted.  Midnight dumping, roadside dumping, etc.,
were cited as "dumps", as well as land disposal sites located
on company property which had not been officially permitted.
Surface impoundments included pits, ponds, and lagoons used
for the storage, treatment, or disposal of wastewater or sludge.
Injection wells included subsurface disposal wells and for
purposes of the survey included such sites as old mine shafts.
Incinerators included facilities which dispose of wastes by
burning.  Spills included events such as liquid disposal into
sewers, pipeline spills, railway spills, and other transpor-
tation associated spills.

     After remedial action sites were identified, the sites
were prioritized to determine candidate sites on which detailed
case history investigations would be conducted.  Factors consi-
dered in prioritizing these sites included consideration of
(1) legal actions which would hamper in-depth investigation;
(2) the extent and nature of the environmental problem associated

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with the site; (3) the nature and effectiveness of the applied
remedial action;  and (4) the availability of background data.
Subsequently, after the top case history candidates were
selected, telephone contacts were made with site owners/operators
to verify information and to request permission to visit the
site.  Permission for a site visit was given for jaine of the
19 sites for which permission was requested.

SURVEY FINDINGS

     Initially 199 sites were identified as having some form of
remedial action.   Thirty of these sites were later deleted from
the list due to (1) lack of sufficient information, (2) insuf-
ficient progress  on planned remedial action, and/or (3) the use
of "low-technology" remedial actions.  "Low-technology" actions
were defined to include measures such as (1) merely filling a
lagoon with native soil without instituting surface or ground
water controls, (2) discontinuing waste receipts at a landfill
without attempting to properly close the facility, or (3) clear-
ing a drum storage facility without regard to existing soil
or water contamination.

     As summarized in Appendix 1-1 to this report, remediaL
measures identified included a variety of technologies such as
containment on-site, chemical treatment (neutralization of
acids and bases,  precipitation, etc.), biological treatment
(land spreading,  oxidation ponds, and underground enhancement
of native microbes using fertilizer), incineration, and
removal and burial in a secure landfill.

     The survey indicated that remedial measures usually
consisted of containment and/or removal of the hazardous waste.
Containment was often approved based upon cost and the concept
that it is better to deal with the problem  in-place rather than
relocate the problem to another locality.   Cost was often the
prime determinant of the type of  technology applied.  As a
result, the primary remedial goal has been  prevention of
further contamination of the environment rather than complete
cleanup.  Gomplete environmental  cleanup can require mil 1 ions
of dollars, sophisticated technologies, and long periods of
time.

     When hazardous material was  contained  in  its original
location, surface water controls  were generally constructed
(e.g.,  grading, diversion ditches, revegetation, surface
sealing, etc.).   In most instances where the ground water was	
contaminated,  a major portion of  the waste  was removed and sent
to a secure  landfill or incinerated  and surface water controls
were constructed  to secure  the remaining contaminants.  Imple-
mentation of  controls for ground  water cleanup is typically
more expensive and time-consuming than implementation of surface

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water controls.  Accordingly, ground water remedial  measures
were implemented at only a few sites..  Ground water  pumping
was the most often applied ground water control  at disposal
sites while a remedial  measure such as a bentonite slurry
trench or steel cutoff wall  was found at some spill  sites.

     Tables 1-1 through 1-5  were compiled based  on information
gathered during the survey.   Over 130 individuals were contacted
to compile the data.  Some of the factors which  should be
considered in reviewing the  data presented in the following
tables include:  (1) data was based solely upon  the  immediate
survey findings, as reported by individuals contacted;
 2) a potential threat was not included in the analysis;  and
 3) probable (but undocumented) contamination was taken as
a positive finding.

     Table 1-1 was compiled  to indicate the types of disposal
facilities which experienced remedial actions.  It should be
noted that the total number  of facilities in Table 1-1 (204)
does not coincide with the number of identified  sites (169).
The higher number is the result of different types of facilities
being located on the same property.  For example, a  landfill,
drum storage, surface impoundment, and/or incinerator could all
be located at one site.  More surface impoundments and landfills
were identified as experiencing remedial action  than other  types
of disposal facilities.  This would be anticipated since
surface impoundments and landfills are the most  used types  of
disposal.


     TABLE 1-rl.  FACILITY TYPE AT REMEDIAL ACTION SITES
Number o^ Facilities
Facility Type '
Landfill
Dump
Drum Storage
Surface Impoundment
Injection Well
Incinerator
Spill
Total
Status
Active
' 16
0
11
18
1
1
0

Inactive
37
27
25
37
3
5
23

Total
Number
53
27
36
55
4
6
23
204
     Table 1-2 was compiled to determine the geographical
location of sites which had undergone remedial  action.   During
conversations with federal  officials, it became apparent that
many factors affect the geographical  distribution.   For example,
industrial waste disposal  sites would typically predominate
in those states which have more industry.   The  possibility of
a larger number of uncontrolled sites needing remedial  measures
would increase with an increase in the number of industrial
disposal sites.  However,  the presence of more  uncontrolled

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sites needing remedial  measures did not necessarily mean
remedial  measures were  being applied.
          TABLE 1-2.   LOCATION OF REMEDIAL ACTION SITES
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin.
Wyoming
Total 50 States
Number of
Sites
2
0
3
2
3
3
4
2
• 7
4
0
0
8
3
1
2
5
3
2
1
5
11
3
0
4
5
0
0
1
10
0
14
7
6
4
0
0
16
4
3
0
10
3
1
0
2
0
1
3
1
169
     institution of remedial measures was dependent upon time
and force exerted by public officials, as well as the
envir )nmental concern of the site's owner/operator.  Public
aware
in ir
state
      less and environmental consciousness were strong factors
      l ementation of remedial measures.  Pressure exerted by
      officials sometimes forced companies and property owners

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to implement corrective actions.  Since remedial action is
generally a time-consuming endeavor, the number of remedial
action sites was also dependent upon how long ago the environ-
mental concerns were emphasized.  Legal action to identify
"responsible" persons for remedial actions generally took four
to nine years.  After this time, the identified responsible
party either instituted remedial actions at the site or declared
bankruptcy (in the process refusing to remedy the situation).

     Table 1-3 was compiled to obtain an indication of the
type of pollution associated with sites which had undergone
remedial action.  Media affected at the 169 sites were found
to include ground water 65 percent of the time, surface water
56 percent, soil 41 percent, air 29 percent, and food chain
12 percent of the time.  Frequently a site affected more than
one media.
    TABLE 1-3.  AFFECTED MEDIA AT 169 REMEDIAL ACTION SITES
                     Affected Media
                                -•- Number'
                                   of
                                Occurrences
Ground Water
Surface Water
Air
Soil
Food Chain
Total
110
95
49
69
20
343
     Table 1-4 was compiled to identify funding sources.
Generally the- state, county, and/or municipality attempted to
persuade the owner/operator of an uncontrolled facility to
voluntarily remedy the environmental hazards.  If this effort
failed, legal proceedings were instituted against the responsible
party.  Depending on the degree of hazard posed by the site,
various government agencies funded the remedial activities
while legal responsibility was determined by the courts.  Federal
financial assistance for remedial measures is largely funded
under Section 311 of QWA.  As previously stated, these funds
are available only for endangerment of navigable waters.  Since
any one site might require millions of dollars, total funding
from state, county, or municipal sources is unlikely.  As a
result of these high costs, more than one party often funded
the remedial activity.

    TABLE  1-4.   FUNDING  SOURCES  AT  169  REMEDIAL ACTION  SITES
Funding
Source
Federal
State
County
Municipal
Private
Total
Number of'
44
62
11
22
103
242
                                 6

-------
     Table 1-5 was compiled to determine the general status of
improvement that occurred at sites which had undergone remedial
actions.  A total  of 180 separate remedial  action efforts were
initiated at the 169 sites.  The pollution status was considered
unimproved when the implemented remedial measure did not
correct the contamination problem.  Usually, lack of improvement
was the result of inadequate funds or the type of action
instituted.  Improved refers to a remedial  measure which may
have partly corrected the problem, but some problems are still
experienced at the site.  A remedied site was one at which the
problem had been corrected; e.g., contaminated surface water
was returned to its natural state.  Based on these definitions,
the last column in Table 1-5 indicates that 46 percent of
corrective actions were not effective, 38 percent improved the
pollution problem, and 16 percent were completely effective.


 TABLE  1-5.  POLLUTION AND  REMEDIAL ACTION STATUS AT 169 SITES
Pollution Status
Unimproved
Improved
Remedied
Total
Number of Remedial Actions
Planned On-Going .Completed
Actions Actions Actions
16 49 17
12 36 21
__0 _3 26
28 88 64

Total
82
69
29
180*
            * A total of 180 remedial activities were Identified at the 169 sites.
 CASE  STUDY  FINDINGS

    "Case study  sites  included  in  the  report  were  selected
 based on a  desire  to  represent  a wide  range of  facility  types,
 pollution type and media,  and remedial  action technology.
 Tables  1-6  and 1-7 present an overview of  the nine case
 histories.   The  nine  sites include two remedied and seven
 improved sites.   Remedial  action applied at the seven  improved
 sites showed varying  degrees of effectiveness.   The combination
 of  all  nine sites  covered  contamination of all  media including
 ground  water,  surface water, soil, air, and the food chain.
 Waste types involved  included mercury, arsenic, solvents,  oil,
 tire  wastes, inorganic and organic waste,  and septic waste.
 The types of facilities examined included  surface  impoundments,
 landfills,  drum  storages,  and  incinerators.   The technology
 employed  consisted mainly  of containment,  removal  of waste  for
 incineration or  secure burial,  and institution  of  surface  water
 and/or ground water  controls.
 CONCLUSION

      Remedial  measures encountered during this
 usually confined to containment and/or removal
survey
of the
were
hazardous

-------
TABLE 1-6.   CASE STUDY  SITE  IDENTIFICATION
to.
A

B
C
0

E

F
G




H
1














Harae
Olin Corporation

Firestone Tire and
Rubber
Anonymous
Destructo/CaroUwn

Hhitsoyer
Laboratories

Western Sand and
Gravel
Ferguson Property




3H Company
Wiltehouse/AlHed
Petroleum



4 	
^
Site 1
Ho. 2
A x
B x
C x

E x
Q
H
I
i
Location
Saltville, PA

Pottstown, PA
East Central, NY
Kernersville, NC

Myerstown, PA

Burrillville, RI
Rock Hill , SC




Woodbury, MN
Jacksonville, FL
TABLE 1-7
Facility Tvpe
c
I a 1 S §
<3 2 S = S
o o   r- CLOJ -PCT3 +J *S
cxo £-a)4->ure .— Sc cu tj
'EJQ. .OJ+JCT-^ CLCDC !- 01
CEs flJ-*-*OUt- OCl-- 3OX
= .-. U-IOOEO. USE. (JZUJ
x X X X X
XX X
x xxx x
XX x X
x XX X
xxx xx x
XX XXX
XX X
xxxx xxx x

-------
wastes with a primary goal  being the prevention of further
contamination of the environment rather than complete cleanup.
Complete environmental  cleanup of ground water or surface water
generally requires sophisticated technology, additional  money,
and additional time.  Therefore, a responsible party with
sufficient funds and expertise must be located for complete
cleanup to occur.  In most cases sufficient funds have not
been available for effective remedial action.  The U.S.  EPA
is able to provide only limited funds under Section 311  of the
CWA.  States and local  governments typically cannot provide
sufficient money for total cleanup, since any one site may
require millions of dollars to correct.
     Based on the case studies and survey, the state-of-the-
practice in remedial action does not look favorable when one
considers that 46 percent of the time the applied remedial
action was ineffective and only a portion
sites have received some form of remedial
                                 of all  uncontrolled
                                 action.   In  addition
remedial
found to
action applied at a site experiencing problems  was
be totally effective only 16 percent of the time.
      It should be emphasized that the numbers presented in
this  section are based on assumptions by the persons performing
the survey and the opinions of those interviewed.  However,
the percentage numbers are a fairly accurate representation
of the state-of-the-practice in  remedial actions.

-------
             SUMMARY REFERENCES AND BIBLIOGRAPHY
1-1   Connery, Jan.  "Draft Report on Review of Uncontrolled
     Site Response, Public Information Document".  Energy
     Resources Company, Inc.   Cambridge, Massachusetts.
     April  4, 1980.
                                 10

-------
                  APPENDIX 1-1



REMEDIAL ACTION HAZARDOUS WASTE SITES-BY STATE
                         11

-------
                                  Facility Type
                                              i—

                                  t  S,  &  S   u

                                  S   2   &   c   S
                              r—       O       O   nj
                              ^-   r—   4->   OJ   -i-   t_
                              *r-   fO   IO   (J   4->   01
Haze and Location
                                                                     Waste Type
                                                                                                         Remedial Action  Technology
 Arsy Redstone Arsenal
 (OHn Chemical Plant)
 Huntsvillo, AL

 Kcvlar Waste Storage Site
 Annlston, AL

 18-Acrc Vacant Lot
 Phoenix, AZ

 TH-C1ty Landfill
 Phoenix, AZ

 Mountain Horae View Estates
 Globe, AZ

 VerUc Chealcal Corporation
 Jacksonville, AR
 GorIcy Refining Company
 Edsondson, AR

 Koppers Company, Inc.
 Butte County, CA

 Stringfellow Industlral
   Waste Disposal Site
 Riverside County, CA

 Holy Corporation
 Mountain Pass Operations
 San Bemadino County, CA

 Rocky Mountain Arsenal
 Denver, CO

 Lovry Landfill
 Denver, CO

 City of Denver,  CO

 Fitzgerald Gasket Company
 Torrington, CT

 Gallup Dusp
 PlatnMcld, CT

 Chemical Waste Removal
 Bridgeport, CT

 Pioneer Products
 East Haddam, CT

 Oiaaond Shaarock Corporation
 Delaware City, OE

Llangollcn (Arey Ck) Landfill
Wilmington, OE

Broward Chcalcol Company
Ft. Laudcrdale, FL

North Miami Beach, FL
                             X   X    X   X
                                                             PCB/D DT
                                                             Sulfuric acid, spent dope
                                                             waste.

                                                             Arsenic.
                                                             Hazardous waste and heavy
                                                             metals.

                                                             Asbestos dust.
 Pesticides, phenols,       t
 herbicides, dioxin.



 PCB, zinc, heavy oil sludge.



 Creosote, PCP



 Organic and inorganic residues.




 Lead and  zinc.




 Pesticides, herbicides.



 Chemical waste.



 Landfill gas.

 Asbestos.



 Acetate, organics, heavy
metals.

 Chemical wastes.



Hydrocarbons.



Mercury wastes.



Heavy metals and hazardous
wastes.

Calcium hydroxide sludge.



Organosulfate
                                  Plant shut down in 1970, cleaned in 1979




                                  Drums removed, soil removed and treated with lime.
                                  Site limed. Berm constructed to control runoff.

                                  Cleaned soil.



                                  Removed wastes.
Demolished mills, covered asbestos with dirt,
revegetated.

Built interceptor ditch and installed monitoring
wells. Building additional interceptor ditches and
will cap site.

Waste neutralized with lime.   Need to recycle waste
or cap site.

Triple lined lagoons.   Installed recovery wells.
                                                                                              Built dam to contain  waste,  leakage  detected  below
                                                                                              dam.   Waste and contaminated soil  currently being
                                                                                              removed.


                                                                                              Installed a cement cut-off barrier and pumped
                                                                                              contaminated water.
                                                                                             Drainage corrected.  Recycling.  Containment of
                                                                                             ground water, lined impoundment, closure.

                                                                                             Monitor.  Cleanup initiated.
                                                                                             Monitoring.  Placed barriers.

                                                                                             Removed waste.



                                                                                             Cleanup included general containment.



                                                                                             Removed wastes.



                                                                                             Practices corrected.



                                                                                             Monitoring.  Removal of water.   Capped and seeded.



                                                                                             Capped.  Aquifer reclamation, aeration, monitoring.
                                                                                             Higher berms constructed.   Site regrading to  control
                                                                                             sludge planned.

                                                                                             Wells closed, system flushed,  treated  with
                                                                                             activated carbon.
                                                                  12

-------
                                       Facility Type
                                                   S  .5  £
     Name  and  Location
                                  2  —
                                                                          Waste Type
                                             Remedial  Action Technology
Gulf Coast Lead
Tampa, FL
Whitehouse Waste Oil Pits
x Acid, lead.
x x Oil, PCB.
Dumping practice changed. Acid neutralized.
Plan to recovery lead.
Mobile activated carbon unit dewatered pits,
 (Allied  Petroleum  Pits)
 Jacksonville,  FL

 Piper Aircraft Corporation
 Vero Beach, FL

 Gainsville, FL
Taft, FL

Gordon Service Company
Gordon, GA

General Electric
Rome, GA

Vacant Lot
Lake City, GA

Ft. Gill em Old Landfill
Atlanta, GA

Kerr-McGee Disposal Site
West Chicago, 1L

Monsanto Chemical Co. Dump
East St. Louis, IL
U.S. Drum Corporation
Chicago, IL

Banner Landfill
Rockdale, IL

Shamrock Environmental Services
Will County, IL
Texaco Oil Company
Richland County, IL

Johnson Property
Byron, IL
Hyon Waste Management
Chicago, IL

Seymour Recycling
Seymour, IN

Bloomington South Wastewater
  Treatment Plant
Bloomington, IN

Conrail Derailment
Inwood, IN
Tri ch1oroethyl ene


Phenol


Pesticides

Acid, heavy metals, organics,
inorganics.  '

PCB.


Explosive chemicals.


Narcotics, oils.


Hazardous waste, radioactive
waste, Th02 and 1/303.

Phenols, nitrobenzene,
sulfuric acid, fly ash.


Liquid/industrial waste, resin,
paint and pigment waste.

Municipal/industrial waste.


Heavy metals.



Phenol.
Industrial waste, cyanide,
heavy metals.
Mixed chemicals.


Mixed chemicals.


PCB.



Hazardous chemicals
 oil  absorbed  using  solid waste and  Fuller's
 Earth.

 Repaired  tanks.   Ground  water volatilized.
 Lagoons  covered.   Parking  lot on  top.   Since
 phenol problem,  no remedial  action  instituted.

 Barrels  removed,  contaminated area  treated.

 Preliminary  assessment  underway.  Monitoring
 wells  installed.

 Removed  waste.
Drums removed.  Waste  detoxified.
 Cover material  placed on  top.
Chemicals  removed  to  approved  site  and are
negotiating for  cleanup of  radioactive wastes.

Site closed and  covered with 4-6  ft of clay  and
seeded. Monitoring wells  installed.   Chemicals
removed to approved site.

Some drums removed.   Liquid contaminants stored
in water-tight containers.

Leachate collected and recirculated  through
landfill.

Treatment  lagoon,  clay-lined, drainage pattern
changed, area reseeded and  leachate  collected in
tank trucks and  treated on-site.

Contaminated soil  removed.
Drums removed, earthen dams and trenches
constructed to confine runoff which was treated
with calcium hypochlorite to destroy cyanide.
Monitoring program instituted.

Drums removed.
2,700 ft waist high trench constructed to contain
waste.  Sand and charcoal filters to contain waste.

Building new wastewater treatment plant.  Will
replace sewer lines.
                                 Initiated ground water purging and carbon
                                 filtration, soil removed. Ground water monitored.
                                                                       13

-------
                                       Facility Type
                                  ^  r-   S
                                  •*-   «a   m
                                  "O   GJ   E
     Name and Location
                                                  •i-J   U  T-
                                                   J=   C   0.
                                                  »—   t-H  CO
                                                                          Waste Type
                                             Remedial  Action Technology
UBounty Dump
Charles Ctty,  IA

Vulcan Materials Company
Wichita, Kansas
National Zinc Company
Montgomery County, KS

Goodyear Dump
Bores, KY

Rayxlck Chemical Dump Site
(Allan Dump)
Raywlck, KY

Hosslngschlager  Farm
Covtngton, KY

Lees Unc landfill
Louisville, KY

Campground Landfill
Louisville, KY

Southeastern Chemical Corp.
Reserve, LA

Cl eve-Reiser
Sorrento, LA

Vulcan Materials Corporation
Oarrow-Getsnar, LA
Hr. O'Connor's Junk Yard
Augusta, ME

HcKIn Company
Cray, HE

Horrls Fans Landfill
Oundolk, MO

KSH Drua Company Chemical
  Haste Warehouses and
  Disposal Site
Dartoouth, HA

Sllrcsta
Lovell, KA

Harrlwc Chemical Company
Haburn, HA

Bankrupt Waste Hauler
Dorchester, HA

Shad Factory Pond
Rebohoth, HA
 Orthonitroanallne arsenic.


 Chlorinated organlcs.



 Heavy metals and sulfuric
 acid.

 Asbestos,  heavy metals.


 Solvents



 Solvents.


 Combustible gas.


 Combustible gas.
 Chlorosulfonic acid,
 hydrocarbons.

 Corrosive waste and
 volatile:.

 HCB
PCS.


Waste oils.
Sulfides and organic wastes,
hydrogen sulfide.

Chloroform, organlcs, ketone,
toluene, etc.
Solvent waste oils, plating
wastes, toxic metals.

Solvents, tannery wastes.


Chemical wastes.
Toluene, trichloroethylene,
ethyl acetate.
 Ground water monitoring system  installed.
 Future remedial action planned.

 Encapsulated landfill and graded. Purging and
 treating ground water, then  injecting into
 disposal wells.  Surface water  treated.

 Chemical treatment of land with lime and
 precipitation of heavy metals.

 Barrels removed.  Contaminated  soil removed.
 Flammable material sent to incinerators, non-
 hazardous waste disposed in Lebanon Landfill.
 Burial  site reclaimed and revegetated.

 Barrels  removed.
 Extraction system installed.
 Extraction system installed.
 Removed 2 trucks of liquid waste, assessment is
 completed and future closure being planned.

 Runoff controlled with dike - only in preliminary
 stage of assessment.

 Stopped previous practice and are burying waste
 on-site. Emissions of HCB Into the air have been
 reduced. Have covered previously used landfills
 which received HCB wastes with 4-6 ft soil and a
 polyethylene film placed 2 ft below surface.
 Storing HCB wastes underwater in a lagoon and
 subsequently landfilling utilizing above cover.

 Capped.
Wells capped. Water supply extended to homes.
Cleanup completed.

Neutralization.  Covered and graded.


Criminal action.  Removed soil and chemicals.




Contained. Berms constructed.  Monitoring.


Analysis.   Initial stage of cleanup.


Removed waste.


Cleanup initiated.
                                                                      14

-------
                                       Facility Type
                                               g
                                               -I
                                  •r-   tlj   l/l
     Name and Location
                                               <*~   0)   •!-
                                               t.   -o   o
                                               3   C   E
                                               00   >-«   •-•
                                                                          Haste Type
                                             Remedial  Action Technology
Chesapeake & Ohio Railroad
  Derailment
Pearl, HI

Chesapeake & Ohio Railroad
  Derailment
Woodland Park, HI

Anderson Development
Adrian, MI

Oakland County Dump Sites
Oakland County, HI

Bofars Lakeway, Inc.
Huskegon, HI

Cordova Chemical Company
Huskegon, HI
Hooker Chemical Company
Hontaque, HI
Wurtesmith Air Force Base
Oscoda, HI

Hedblom Industries
Oscoda, HI

Central Landfill
Montcalm County,  HI

Chemical Recovery
Wayne County, HI

Pollution Controls
Shakapee,  HN

3H Company
Woodbury Village, HN

Reilly Tar & Chemicals Co./
Republic Creosoting Company
St. Louis  Park, HN

Verona, HO

Albert Harris Property
Dittmer, HO

St. Joseph, HO
Conservation Chemicals Company
Kansas City, HO

Montana Radiation
Butte, HT

Montana Radiation
Anaconda, MT
                                                                  Styrene.
Phenol, ethylene oxide,
vinylidene chloride.
Curene 442.


Numerous chemicals.


Amines, benzene, toluene.
Pharmaceutical intermediates,
herbicides, pesticides,
synthetic musks.

Brine, asbestos, fly ash,
deadly pesticides.
TCE.


TCE.


Metal plating waste C-56.


Mixed chemicals.
Combustible paint sludges,
solvents, and waste oils.

Spent solvents, acid sludge
(isoprophyl ether).

Tars and creosote.
Dioxin.

Oil/PCB waste.


Alcohols, solvents,
chrome sludge.

Pickle liquor, fly ash.


Radioactive phosphate slag.


Radioactive phosphate slag.
                                 Slurry trench, aeration, monitoring wells, and
                                 purging wells initiated.
Carbon filtration, aeration, and ground water
pruging initiated.
Vacuum-swept homes and streets.  Partial cleanup
of site.

Some drums removed or containerized.


Purged ground water.


Drums being removed.  Ground water purged.
Wastes and contaminated soil will be  placed in
a vault being constructed.  Ground water purging
will be continued for 50 years.

Leaky tank repaired. Ground water cleanup planned.
Public water supplied to residents.   Drums moved
to shed.

Excavated tanks and contaminated soil removed.
Approximately 5,000 drums removed. Intercept
trench built - failed - new one being built.

Have removed some drums, will remove all drums
and dispose of contaminated soil.

Barrier wells installed which continuously pump
water to stop continued spreading. Lagoons emptied.

Preliminary assignment of contamination.  Wells
capped and excavated material.
Excavated soil.

Excavated pit, pit sealed. Cleaned debris from
stream bed. Water treated using carbon absorption.

Drums removed and sent to a secure landfill.
Lagoons closed and stabilized, and will be
covered with asphalt.

Gamma monitoring.  Cleanup initiated.


Gamma monitoring.  Cleanup initiated.
                                                                      15

-------
Facility Type
•p
s
•i
C I—
=J r-
Q. OJ O  O. 3 L.
3 « JE O
I— O O (O
i — r- *J 0) •(- L.
•r- « IO U +J OJ
u- en ia o c i—
•o a e iC 
-------
                                       Facility Type
Name and
Location
M-
-o
3
Of
QJ
E
CD
t
,3
to
8'
<(-3
C
c
(J
c
a.
to
Waste
Type
Remedial Action Technology
102nd Street Landfill             x
Niagara Falls, NY

Hudson Valley PCB Sites
1. Caputo ROA                     x

2. Ft. Edward Landfill            x
3. Kinsbury Landfill              x

4. Ft. Miller RDA - operating     x
5. Old Fort Edward RDA            x

Vanderhorst Co., Plant No. 1      x
Olean, NY

Allied Chemical
Onondoga County, NY

Pollution Abatement Services, Inc.
Oswego, NY

Oestructo Chemway Corporation
(Carolawn Co., Inc.)
Kernersville, NC .

"North Carolina Highway Spill"
Raleigh, NC

Koppers Company, Inc.
Morrisville, NC

Renroh Warehouse
Holly Ridge, NC

Summit Avenue
Charlotte, NC

Haywood County                    x
Clinton, NC

Carolina Task Cleaning Company
Greensboro,  NC

Arsenic Disposal                   x
North Dakota

Bel field-North Ashing Site        x
Bel field,  NO

Belfield-South Ashing Site .       x
Belfield,  ND

Husky Industries
Dickenson, ND

Sodium Chromate
Dickenson, ND

North Dakota University at Fargo  x
Mi not, ND

Summit National  Liquid Services
Pontege County,  OH

Chem-Dyne Corporation
Hamilton,  OH
 Pesticides,  phosphorous
 chlorates.
 PCB.

 PCB.
 PCB.

 PCB.
 PCB.

 Chromium.


 Mercury


 PCB, chloroform,  toluene,  etc.
 Fuel oil,  toluene, xylene,
 dichloroethane,  trichlorethenfr.
PCB.


Pentachlorophenol  CPCP).


2-4 dinitrophenol.


Waste chemicals, solvents,
plating wastes.

Petroleum based cleaning
fluid.

Solvent rinses.


Arsenic.


Radioactives and heavy metals.


Radioactives and heavy metals.


Organic residues.


Chromium.


Toxics, radioactives,
flammables.

Chemical waste oils, acetone,


Solvents, organics, inorganics.
Soil cover ussd  in closure.



Runoff  controlled, regraded, capped.   Removed
wastes.
Runoff  leachate  controlled and  treated. Capped.
Regraded, capped, grout-curtain wall,  well  point
system, leachate controls installed.
Capped, reburied wastes.
Removed wastes.

Removed wastes.


Cleaned up lake.


Constructed dike and  trench for leachate control,
removed wastes,  filled.impoundment.

One-third of waste chemicals removed.  32,000 ft
contaminated soil removed.  New drinking water
supply  system constructed.

Sprayed activated carbon and covered the area
with asphalt.

Contaminated soil/waste removed.  Still some
contaminated soil on  site.

Removed drums.


Removed drums.


Surface skimming of water.


EEB cleanup of waterway.  Pit cleaned up.


Collected and recycled waste.


Preliminary study.  Cleanup initiated.


Preliminary study.   Cleanup initiated.


Preliminary study.   Cleanup initiated.


Monitoring.   Cleanup initiated.


Monitoring.   Cleanup initiated.
Containment, drainage instituted, redrummed,
and removed wastes.

Removing wastes and site cleanup.
                                                                     17

-------
                                       Facility Type
                                           s.  a
                                                   e  2
                                                   o  m
     (tee and location
3   5  I
                                                                          Waste Type
                                                                                                              Remedial  Action Technology
Chemicals & Minerals Relcamatlon
Cleveland, OH

Pristine, Inc.
Reading, OH

Ashler Hater Company
(Hew Jersey Zinc)
tobler, PA

KawecM Berylco Industries, Inc.
CKB1)
Hazle Township, PA

National Mood Preservers
Haverford, PA

Hease Chenical Company
State College
College Township, PA

Transformer Sales
Youngsvllle, PA
Revere Chemical Corporation
Hackwixon, PA

Tobyhanna Army Depot
Coolbaugh Township, PA

Firestone T1re & Rubber Company
Pottstown, PA

Kill Service, Yukon Plant
Southington Township, PA

ASH Company - Hade Site
Chester, PA
Elkland Tannery Site
ElMand, PA

Roha-Haas Conpany
(Uhlfanoyer Labs)
fyerstown, PA
Environmental Aids
He* Beaver Burrow, PA

Ohio River Park
Neville  Island
Plttsburg, PA

"1977  Flood"
Johnstown, PA

Footc-Klneral
Exton  Corporation
Uhiteland, PA
                               Solvents, organic and Inorganic. Removed drums.


                               Mixed hazardous chemicals        Some drum removal and site cleanup.



                               Gasoline spill.
                                Beryllium  sludge.
                                PCP,  oil.
Aquifer recycling.  Added phosphate as  fertilizer
to ground to accelerate biodegradation.


Treating collected ground water, site capped.
                                                                 Impoundment filled and graded.
                                Heavy metals,  kepone, mirex.      Initial cleanup created a kepone problem which
                                                                 is ongoing.
                                PCB,  organics.
                                                                  Acids, heavy metals.
                                Electroplating (cyanide
                                hexavalent chromium)


                                Refinery,  S02  scrubber  wastes,
                                organic  waste.

                                Pickle liquor  sludge.
                                Volatile organics  hydro-
                                chloric acid,  PCB,  cyanide,
                                benzene.

                                Sulfuric acid, tannic  acid,
                                lime and sodium hydroxide.

                                Arsenic compounds.
                                Pickle liquor,  organic
                                sludge.

                                Upgrading to landfill  led
                                to release of noxious  fumes.
                                Oil, organics.


                                Lithium.
PCB material placed in new drums. Building has new
roof and concrete floor pad. Berm constructed
around building.  Soil being evacuated.

Waste neutralized, removed, sent to sea. Lagoons
backfilled. Soil at site still contaminated.

Closed, regraded, changed pre-landfilling technique.
Contaminated ground water recirculated and used in
plant processes.

Practice corrected, closure plans being developed.
Determined extent of problem. Materials disposed
above natural grade. Hot spots removed. Runoff
discharge prevented.

Material removed, lagoon backfilled.


Removed arsenic waste from lagoon, treated and
discharged. Waste piles of arsenic placed in
concrete vault. Ground water treated using purging
wells. Some contaminated soil remains.

Removed waste and chemically treated. Limed pond.
Revegetated.

Closed park off. Monitoring gas and ground water.
Material removed.
 Containment. Activated carbon for water treatment.


 Lagoons lined.  Activated carbon for water treatment
                                                                      18

-------
                                       Facility Type
     Name and Location
                                                   "2
                                                                          Waste Type
                                             Remedial  Action Technology
Western Sand and Gravel
North Smithfield &
 Burrilville, RI

Candybox Farm (Piccillo)
Coventry, RI

Bristol Landfill
Bristol, RI

Capuano Landfill
(Sanitary Landfill, Inc.)
Cranston, RI

Ferguson Property
Rock Hill, SC
Chapel Estates
Greer, SC

Fort Lawn, SC
Velsical Residue Hill
Chattanooga, TN
Bumpass Cove Landfill
Jonesboro, TN
Velsicol Chemical  Corporation
Hardeman County, TN
Milan Army Ammunition Plant
Milan, TN

Accidental Spill of Askarel
East TN

Waynesboro  City Dump
Waynesboro, TN

Millington Dump Landfill
Memphis, TN

North Hollywood Site
Memphis, TN
Meryville Pike
Knoxville, TN
Motco, Inc.
LaMarque, TX

DuPont-Ingleside
Corpus Christi, TX
                                      x    x   x
                                                                  Chemical, septic.
                                                                  Ferric chloride, sodium,
                                                                  aluminum, benzene, toluene.

                                                                  Chemical solvents
                                                                  PCB, organics, liquid and
                                                                  industrial wastes.
                                                                  Solvents, paints, inks.
Paints, solvents, dyes,
inks.

Volatile chemical waste,
paints and solvents.

Pesticide wastes.
Industrial waste.



Pesticide wastes.



Explosive residues.


Askarel.


PCB waste.


Pesticides.and herbicides.
Unknown types of industrial
waste.
                                                                  Plastic polymers.
Styrene tars, vinyl
chloride, heavy metals.

Carbon tetrachloride,
Fluoride, arsenic, chloride.
                                 Emptied lagoons. Removed soil.  Use of BarCad
                                 wells.
                                 Drums removed.


                                 Drums removed.


                                 Removed standing water, installed barriers.
Remedial action in two stages:  (1) encapsulated
site  temporarily to prevent runoff into nearby
stream,  (2) since 1 above was ineffective, liquid
was removed and sent to a solvent reclaimer.

Drums removed with some contaminated soil
removed.

Some  drums removed.
Grading, capping, revegetating the area.
Possible backflush planned to minimize impact
on ground water.

Drums removed and incinerator shut down. Landfill
no longer accepting industrial waste.  Plan to
regrade, cap, and revegetate landfill.

Grading, capping, revegetating the area.
Possible backflush planned to minimize impact
on ground water.

Pits covered.
Soil removed. Area covered with top soil, seeded,
and landscaped.

Site fenced, covered, regraded, and planning
future closure.

Site closed in 1976. Clean fill imported.  Since
then land used to grow soybeans.

Visible drums removed and completion of surface
water control. Future efforts to monitor ground
water and surface water.

Surface diversion initiated to prevent rainwater
runoff. Capping, revegetation, and silt control
measures used.

Some styrene tars removed. Vinyl chloride
contamination continues.

Two surface impoundments relined. Purged ground
water treated with sodium hydroxide or disposed
in  injection wells.          *•
                                                                       19

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                                  Facility Type
                                      a  a
                                      2   s
!ii-.t and Location
                                                   =   s
                                                   O   (O
                              _J   »-l   CD
                                          
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                       •   SECTION 2

                            SITE A
                       OLIN CORPORATION
                     SALTVILLE, VIRGINIA
INTRODUCTION

     A chemical  production complex located in Saltville,  Virginia
was established  in 1895 and operated continuously until  its
closure in 1970  by the final  owner/operator,  Olin Corporation.
Major product streams generated by the facility over its
operational  life included soda alkali, chlorine,  hydrazine,  and
dry ice.

     Operation of the now-closed chemical  complex resulted in
total dissolved  solids (TDS)  and mercury pollution in the
nearby North Fork of the Holston River.   The  TDS  pollution has
been traced  to several ponds  on the property  used by plant owners
for disposal of  their manufacturing wastes.   The  mercury
pollution has been traced to  an old chlorine  plant on the
complex (since demolished) and one of the  above-cited ponds.

     Mercury is  the pollution problem of chief concern.   Although
plant officials  and regulatory authorities had been aware of
the mercury  problem for many  years, the  problem was not
seriously addressed until 1976 when it became obvious that
mercury in the North Fork bottom sediments was not decreasing
through natural  dispersive processes.

     Subsequently, environmental engineering  studies indicated
that soil erosion from the chlorine plant  area represented a
major pathway of mercury to the North Fork.   Accordingly,
erosion control  measures at the old plant  site were implemented
by Olin Corporation.  These measures were  apparently effective
in control 1 ing further mercury discharges  from the chlorine
plant site.   However, TDS and mercury discharges  are continuing
from the ponds,  and measures  to control  these discharges  are
now being considered.  Even after all further
discharges from  the chemical  complex site  are
remedial  actions will have to be performed to
mercury in riverbed sediments downstream.
mercury and TDS
control led, some
control settled
SITE DESCRIPTION

     The Olin Chemical  complex is located in the Saltville Valley
in southwestern Virginia.  The plant location is shown in an
aerial photograph included as Figure 2-1; the layout of facilities
at the complex is shown in Figure 2-2.
                              21

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Figure 2-1.   Aerial  photograph of Olin
       Chemical  complex.  [2-1]
                  22

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                                                               HYDRAZINE
                                                                PLANT
                                                                  CONTROL WATER
                                                                  -SAMPLING STATION
          0  5 10 MLES
                                            LEGEND
                                            PRESSURE WELLS-*
                                            MUCK PONDS -i—./
                                            GRAVITY FLOW LINES-	
Figure  2-2.   Site  layout  of  Olin  Chemical  complex.  [2-2]
                                 23

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     The average annual rainfall in the area is 109 cm (43 in.)
and average annual snowfall is 38 cm (15 in.).   The average daily
high temperature is 13°C (55°F) with the highest daily maximum
in July at 29°C (85°F)'and the lowest in January at -4°C (25°F).

     The small town of Saltville lies in the belt of the faulted
and folded Appalacian Mountains.  Saltville and the former Olin
plant site lie in the flood plain of the North  Fork of the Holston
River.  Underlying the site is the MacCrady Formation, a shaley
limestone of Mississippian Age.  The MacCrady Formation contains
evaporite deposits of high quality halite (rock salt) and occupies
a narrow bank less than 300 m (1,000 ft) wide.   This Formation
supplied salt to the brine wells located on the plant property.
     East of the former chlorine plant site, the MacCrady Formation
thickens to about 600 m (2,000 ft) as a result of flowage of the
evaporites during thrust faulting.  The strike of the MacCrady
is 55° NE with a dip ranging from 45° to 60° SE.  The North
flows to the southwest following the bedrock strike and is
underlain by the MacCrady Formation.
                                        Fork
     The Little Valley Formation, resistant limestone of Missis-
sippian Age, overlies the MacCrady Formation.   This limestone
outcrops and forms the cliff and ridge between the former plant
site and the Town of Saltville, southeast of the North Fork.
Northwest of the river valley is Little Mountain formed by the
resistant Price Sandstone of Mississippian Age, which underlies
the MacGrady Formation.  In the river valley,  alluvium overlies
the bedrock and consists mostly of sandstone boulders in silty
and sandy clay.

     Figure 2-3 displays a generalized geological  cross section
of the area in which the plant was located.  The alluvial
material may have been removed from some areas of the plant
grounds during initial site preparation.  Presently, most of
the former chlorine plant site is underlain by loose fine
grained fill consisting of clayey silt and sand and some pieces
of building materials.

     The North Fork is located on the southeast side of the
Olin property and separates the former plant site from Saltville;
it originates from springs and streams near the town of Nebo,
Virginia about 64 km (40 mi) northeast of Saltville.  As shown in
Figure 2-4, it flows southwest for about 209 km (130 mi) to
Kingsport, Tennessee where it joins the South  Fork of the Holston
River to form the Holston River.  The Holston  River flows about
80 km (50 mi) to the Cherokee Reservoir, and thence an additional
160 km (100 mi) to the Tennessee River.
     The North Fork
with an unregulated
of the Holston River is a mountain stream
flow ranging from 0 to 467 m^/sec  (0 to
                               24

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              NW
                LITTLE MOUNTAIN
                                                   SE
                                                SALTVILLE.
           Figure 2-3.  Generalized  geologic cross  section*.

* The cross  section is perpendicular to the strike direction and
  the vertical  exageration  is  approximately 2.5  times the
  horizontal  distance.                   ,
                                                 UPPER HOLSTON RIVER
                                                    WATERSHED
         Figure  2-4.   Upper Holston  River watershed.  [2-2]
                                  25

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16,500 ft3/sec).  Typical stream flow at Saltville is about
80 m3/sec (300 ft3/sec).  Extensive pool and ripple areas are
located in the river, and the riverbed is primarily composed of
boulders and cobbles with submerged rock ledges.   Figure 2-5
shows that the riverbed has been altered in the area which now
houses two ponds used for disposal  of Olin's liquid wastes.
The River now flows to the southeast of Ponds 5 and 6 rather
than through the area in which these waste ponds  are located.

     The two plant site areas causing environmental concern are
the old chlorine plant site and Ponds 5 and 6.   Since corrective
action has only been implemented at the old chlorine plant site,
this area will be .emphasized.

     Hydrogeological studies indicate that most of the ground
water underlying the former chlorine plant area is the result
of infiltration o.f precipitation.   However, the western part of
the chlorine plant area derives some ground water from the
Robertson Branch Creek and some from precipitation falling on
higher surfaces.  Ground water has  been found at  the old
chlorine plant site at depths from  4 to 6.4 m (13 to 21 ft).
Hydraulic connections occur horizontally and vertically between
the rock, alluvium, and fill. [2-4]  The drinking water for the
Town of Saltville is supplied by mountain springs located at
higher elevations north of the plant site.  These springs are
capable of supplying 0.07 m-Vsec (1.5"mgd).

SITE OPERATION AND HISTORY

     In 1748, saline brines were discovered in  the vicinity of
Saltville.  Although salt production began in 1788, production
was sporadic until the Mathieson Alkali Works acquired the
property in Saltville in 1892.  The first alkali  product was
produced in 1895 by Mathieson.

     To capitalize on the raw materials of the  area (e.g., rock
salt and limestone deposits, as well as coal fields), Mathieson
began to broaden their chemical product capability.  A dry ice
plant, the largest of its kind, was constructed in 1931.  In
1951, the electrolytic chlorine and caustic soda  plant was
constructed by the Company, then called Mathieson Chemical
Corporation.  Mathieson merged with Olin Corporation in 1954,
constructed a hydrazine plant, and  began production of rocket
fuel.  The hydrazine plant, operated for the U.S. Air Force,
was the last major addition to the  Olin complex.

     Due to economic and technical  factors, Olin  Corporation
began closing their facility in Saltville in 1970 and completed
the process by 1972.  Olin had owned 3,000 ha (7,300 ac) in
Smyth and Washington Counties and was the only  major industry
in the area.  About 1,400 ha (3,500 ac) was donated to the State
                              26

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                  WASTE POND No.


                   WASTE PONDNo.2


                POND No.5


               HENRYTOWN
Figure  2-5.   Location  of former river  bed through
          Waste  Ponds  5 and 6.  [2-3]
                        27

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of Virginia as a game and timber reserve.   About 1,400 ha
(3,500 ac) within the corporate limits of Saltville were
donated to the Town, including the plant site,  building,  and
surrounding farm lands.  In addition, mineral  rights plus
some money was awarded to the Town.

     From July 4, 1895 until June 20, 1972, Olin Corporation
and its predecessors (Mathieson Chemical Corporation and
Mathieson Alkali Works) operated a chemical complex at
Saltville.  A list of principal products and manufacturing
processes utilized by Olin at the Saltville complex is
displayed in Figure 2-6.  As shown in Figure 2-7, raw materials
were converted to soda-alkali compounds via the Solvay process.
Chlorine and caustic soda were produced by electrolysis
from salt (s.ee Figure 2-8).  The Solvay process  and chlorine-
caustic process produced significant quantities of wastes.
The Solvay process produced sodium chloride, calcium chloride,
calcium carbonate, calcium hydroxide, and other solids as
wastes.  The chlorine-caustic process produced  caustic soda,
salt, and mercury as wastes.  The dry ice, liquid carbon
dioxide, and hydrazine processes did not produce wastewater
with any significant contaminants.
     The Saltville facility produced 0.1 m3/sec
waste containing 910,000 to 1,360,000 kg (1,000
per day of calcium and sodium chlorides (salt),
smaller amounts of caustic agents, mercury, and
contaminants.  The wastewater was discharged to
ponds where the sol
to the North Fork.  During
six such ponds were used.  Ponds 1  and
filled and residences are located atop
4 were only temporary holding lagoons,
                                      (2  mgd)  of
                                      to  1 ,500 tons)
                                      plus  much
                                      other
                                      large disposal
         ids were settled and supernatant discharged
                 the plant's operation,  a total  of
                             2 have since been
                             Pond 1 .   Ponds  3 and
                             and Ponds 5 and 6
exist to this day, although they are now dry.
POLLUTION

     As a
products,
dissolved
result of preparation of alkali  and chlorine
the North Fork has elevated levels of total
solids (TDS)  and mercury.    During the
                              28

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  SODA ASH
 PRODUCTION
(AMMONIA SOOA)
                    100% OF WASTE CHLORIDES
                    FROM SODA ASH (AMMONIA
                    SODA), BRINE PORTION OF
                    CHLORINE PLANT AND
                    HYDRAZINE PLANT
                              TOTAL LIME
                              SODA AND
                              ELECTROLYTIC
                              CAUSTIC SALES
    Figure 2-6.   Process  flow diagram
                 alkali plant.   [2-2]
for Olin
                               29

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     RAW MATERIALS
                                                                  PRODUCTS
     SALT-

     LIME'
     CARBON OIOXIDE-

    •AMMONIA-
                                       »SODA ASH

                                     -•> BICARBONATE  OF SODA

                                     -^•CAUSTIC SODA

                                       •AMMONIA —
                                                              • RECYCLE-«e-
                                     WASTEWATER
                             CALCIUM CHLORIDE
                             SODIUM CHLORIDE

                             CALCIUM CARBONATE
                             LIME
                             OTHER SOLIDS
                       IN  SOLUTION

                                      t,

                       AS  SETTLEABLE SOLIDS
      CALCIUM AND SODIUM CHLORIDE SOLUTION TO RIVER
           Figure  2-7.   Soda-alkali  production  at  Olin
                         Saltville plant.    [2-2]
     SALT - Had
  (SODIUM CHLORIDE)
	+  D.C.	
   VOLTAGE
         Figure  2-8
Chlorine-caustic
Saltville  plant.
production at  01 in
 [2-2]
                                     30

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plant's operation prior to 1969-70,  the State Water Control  Board
          the chloride discharges and gave little attention  to  the
regulated
amount of
500 mg/1
of the ti
IDS loadi
the ri ver
there is
adequate.
          mercury discharged.   Since the pi ant'1 s  closure,  the
         IDS standard for the  North Fork is  exceeded 60 percent
         me.  However, no real  health hazard is  experienced from
         ng and resident fish  appear to have acclimated.   Also,
          water is too brackish for use as  a water supply  and
         no demand for its use  since ground  water supplies are
     Approximately 10 percent of the IDS concentration (as  salt)
in the North Fork is estimated to be the natural  background 1 eve!
Salt leakage from the brinefield is believed to have occurred
for many centuries and could be considered to be  a natural
condition since the present Saltville flat
around which Pleistocene mammals gathered.
that the mining operations of 01 in and its
the situation.   However, saline flows could
                                                           lake
was once a salt
Itisprobable
predecessor aggravated
 probably not be stopped
since the near-surface geological  formations  are fragmented.   The
brinewell field contribution to IDS is not considered to be
easily remedied.   The TDS loading  due to Ponds  5 and 6 is con-
sidered to be at  least partially abateable.

     In 1969, the Swedish scientists Jensen  and Jerneloy published
the first findings on methylation  and subsequent bio-accumulation  of
inorganic mercury in the environment.  Their  discovery focused
attention upon the amount of mercury being discharged as waste.
Virginia State Water Control Board water analysis of the North
Fork indicated that the stream was seriously  contaminated with
mercury.

     Beginning in 1951, 01 in Corporation used mercury in an
electrolytic chlorine process.  The mercury-contaminated waste-
water and process wastewater were  recycled,  disposed in the
ponds, and/or discharged to the river.  In 1970, tighter
restrictions were placed on chlorine plants,  as a result of
Jensen and Jernelov's discovery of mercury methylation.  Before
regulation (1950  to 1970) an estimated 45 kg/day (100 Ib/day)
of mercury discharged to the North Fork via  spills,  runoff,
and other pathways.  After regulations were  developed (1970  to
1972), Olin reduced losses to about 0.1 kg/day (0.25 Ib/day)
by recycling and  tightening plant  operations.

     Olin officials had planned to redesign  the plant and to
further reduce mercury discharge to a minimum.   However, Olin
later decided to  abandon the Saltyille plant  since the cost  of
repair and restoration was prohibitive.  Olin closed the plant
and donated its land to the State  of Virginia and the Town of
Saltville in 1972.
                               31

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      A  0.5  mg/kg  (ppm)  mercury  level  in  fish was  established by
 the  Food  and  Drug  Administration  in  Spring  1970.   Since  September
 1970, the North  Fork  of the  Holston  River has  been closed to
 fishing for eating purposes  as  a  result  of  the mercury content
 in the  fish.   Game fishing is now allowed.  The Virginia State
 Water Control  Board annually monitors  the mercury  content in the
-fish  and  river sediment.

      When it  became evident  that  the natural dispersive  processes
 would not eliminate the mercury problem  and return the River
 to an acceptable  quality, the State  and  Olin began to consider
 clean-up  actions.   A  mass balance study  of  mercury input to the
 river conducted  by Olin from October 1978 until November 1979
 indicated an  average  mercury input of  45 g/day  (0.10 Ib/day).
 State samples  taken during the  same  period  indicated an  input
 of 40 to  60 g/day  (0.10 to 0.13 Ib/day). [2-5]  Mercury's physical
 property  complicates  the contamination process.   Because of its
 weight  mercury has the  tendency to settle out  and  water  does not
 act  as  a  driving  force.  The higher  than water  density of mercury
 resulted  in accumulative deposits of mercury in the riverbed
 from long-term,  historical discharges.   Abatement  of mercury
 contamination  of  the  river   will  thus  require  dredge removal or
 fixation  of the  riverbed mercury.

      Even with a  mercury input  to the  North Fork  of 60 g/day or
 22 kg/year  (0.13  Ib/day or 10 Ib/year),  the concentration of mercury
 in the  flowing river  probably never  exceeds 1  ug/1 (1 ppb) and
 rarely  exceeds 0.2 ug/1  (0.2 ppb).   The  mercury criterion for
 domestic  water supply is 2.0 ppb  and this level would probably
 never be  exceeded. As  further  health  protection,  there  are no
 public  water  supply intakes  in  the North Fork  below Saltville,
 nor  is  there  a need for public  water intakes on the river.  Thus,
 apart from  human  consumption of-fish caught in  the river, the
 mercury level  in  the  water was  not seen  as  presenting a  health
 hazard.

      The  two  site  areas containing residual contamination and
 discharging mercury have been identified as Pond  5 and the old
 chlorine  plant site.   The only  pollution source which has been
 assessed  and  which has  received corrective  actions is the chlorine
 plant site.  Therefore, for  purposes of  clarity,  the mercury
 contamination  as  associated  with  the chlorine  plant will be
 discussed more than the problem associated  with Pbnd 5.

      Pond 5 was  recently assessed by a consultant  for Olin.  The
 report  revealed  that  92 percent of the mercury, approximately
 38,600  kg (85,000  Ibs), in the  pond  was  confined  to the  top 5.3 m
 (17.5 ft) of  the  solids comprising 612,000  m3  (800,000 yd3).  The
 average concentration in the top  5.3 m (17.5 ft)  of soils  was
 about 13  mg/kg (13 ppm). Olin  estimates that  it  will cost
 $25,000,000 to $30,000,000 to remove this material and dispose
 of  it in  a  secure landfill.  A  water balance conducted on Ponds
                                32

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5 and 6 indicated that 60 percent of the total  water results  from
direct rainfall  onto the pond.   Ground-water contributions  are
insignificant.

     Approximately 100,000 kg (220,000 Ib)  of mercury has been
estimated to be  at the surface  and subsurface of the demolished
former chlorine  plant site.   The fill  material  contains the
highest concentration of mercury and the alluvium contains  the
lowest concentration.  Generally, soils in  the western half of
the building site contain the highest concentrations of mercury.
Mercury beads, up to 1.5 mm (0.1  in.) in diameter, have been
visible on the  top surface of concrete structures.   Mercury
                  the soil above and below  the concrete were
                   Most of the  mercury present at the site
entered the subsurface during the years that the chlorine plant
was in operation.
concentrations in
found to be less.
     It appears that mercury percolated downward via gravity
through pore spaces in the fill  and alluvial  materials at the
chlorine plant site and along open bedding planes and joints in
rock.  It-then collected in high concentrations in the subsurface
where relatively tight materials such as concrete and tight
rock formed barriers to further  downward migration.   Because of
gravity and ground water movement, mercury could have spread
laterally for short distances.  However, it is believed that the
lateral movement of elemental mercury at the site in the ground
water is slight.                   •

REMEDIAL ACTION

     When it was determined that the natural  dispersion of
mercury would be slow, with centuries elapsing before the river
ecosystem recovered completely,  01 in Corporation and the State of
Virginia began taking the first  steps to correct the problem.

     A Saltville Task Force was  established to study the level of
mercury, evaluate the problem, and advise Olin on acceptable
measures to remedy the problem.   Members of the Task Force
represent the U.S. Environmental Protection Agency,  State of
Virginia Water Control Board, the State of Tennessee Department
of Public Health, and the Tennessee Valley Authority.

     The former chlorine plant site continued to discharge
mercury into the river after its closure in 1972 through residual
materials and deposits at the plant site.  Olin's consultants
studied the movement of elemental mercury at the chlorine plant
site (1) through the soil and rock, (2) in the ground water, and
(3)  by soil movement through erosion.

     The potential for mercury pollution of the river'through
erosion was deemed to be greater than through ground water
seepage from the area to the river.  The fill material at the
                                33

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former plant site has higher mercury concentrations than the
ground water.  This mercury could be deposited in the river by
sheet flow runoff, especially.from the steep river banks at times
of heavy rainfall.  A flood in April 1977 undercut the river bank
in front of the former chlorine plant site.   The amount of mercury
deposited into the river by erosion and movement of particulate
matter is believed to have been significant.  It is also probable
that stream bank erosion at the site during  high river flows
in the mid-1970's carried more mercury into  the River and
contributed to the noticed increase in mercury contents in fish
and sediment.

     The corrective action completed in 1979 included implementa-
tion of erosion control  measures along the river bank to prevent
further discharge of mercury.   This was the  first corrective
project Olin undertook in conjunction with the Task Force.  Olin
Corporation contracted W-L Construction .of Chilhowie, Virginia
to implement the erosion control project.  The U.S. Army Corps
of Engineers and the Virginia  Water Control  Board reviewed the
plans for the project.  The detailed engineering work was done
by a consulting firm from Chicago, Illinois.

     Approximately $400,000 in costs were incurred by Olin to
prevent erosion of the river bank in the area of the chlorine
plant.  The project (see Figure 2-9) began in October 1978 and
was completed by April 1979.  The corrective measures to reduce
mercury concentrations in the  North Fork included the following:

     1.  Drainage diversion measures.  Revisions to prevent the
         possibility of Robertson Branch Creek overflowing onto
         the chlorine plant site consisted of the following:

         a.  The road across the Branch Creek serving Tri-Cities
             Dry Ice was modified to include a 7.6 m (25 ft) wide
             by 3 m (10 ft) high arch structure to allow higher
             flows to pass.

         b.  An earthen berm was constructed from the above
             mentioned road along the chlorine plant site to-
             the doubl e'-barrel ed culvert.

         c.  An overflow channel was constructed on top of the
             double barreled culvert.  A 2:1 slope was maintained
             in the overflow channel by removing previous railroad
             tracks, and by applying sand, filter material, and
             riprap on the slope.

     2.  Sealing off the plant site from the North Fork (see
         Figure 2-10).  The slope of the chlorine plant site
         facing the river was  regraded to a  2:1 incline.  Soil
         and debris which noticeably contained mercury deposits
         were removed from the slope and placed back away from
         the North Fork on the former chlorine plant site.  Sand
                               34

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                                                                    o>
                                                                    c:
                                                                    03
                                                                    Q-
                                                                   -E
                                                                    O
                                                                    -P
                                                                    CO
                                                                    V)
                                                                    (U
                                                                    s-
                                                                    to
                                                                    to
                                                                    o
                                                                    s-
                                                                    O
                                                                    o
                                                                    o
                                                                    S-,
                                                                    CTl
                                                                     I
                                                                    CM

                                                                    OJ
                                                                    S-
                                                                    3
                                                                    CD
35

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  tTOSr-
  ITOO-
*- I63S
  tesc
(g IfSS
  teao
          r Slope to cfrafn
              Z'-O" riprap

               Filter cloth or 12"coarse filter

               O'-S*'finefilter, minimum
                     - 4" fop soil plus seeding
Soil with high mercury
content to be removed
and replaced with fine
fitter as dirtctfd "
                30 mi/.
               membrane as require
Original ground tins -

      Fill Hith fine filter
      to SH:IV slope-
                                                            5  Teet
               Figure  2-10.   Construction  details  for  sealing
                            North  Fork  riverbank.    [2-6]
                                             36

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         was  applied to  the  slope,  at  a  thickness  of  from
         5 cm to 15 cm (2 to 6  in.).   A  0.8  mm (30 mil)
         polyvinylchloride (PVC)  mesh  filter was  applied
         over the sand to hold  it in  place.   Finally,  riprap
         was  applied on  the  slope.

     3.   Removal and plugging of  drainage  pipes  from  the area.
         Two  drain pipes  and a  rectangular concrete drain
         were located during the  excavation  and  regraded.
         These drain structures were  moved back  a  distance
         from the North  Fork and  plugged.

     4.   Prevention of precipitation  infiltration.  A 10 cm
         (4 in.) layer of topsoil was  used as cover material
         for  the chlorine plant site.   The area  was then
         seeded.

     The above measures  were implemented as  erosion control
measures and  are considered  effective  to that end.  It is  hoped
that these measures will  prevent  the  migration of mercury  from
the chlorine  plant area  during flooding  and  high stream flows.
Entrance of water due to surface  runoff  from the nearby hills
and overflow  of Robertson Branch  Creek,  likewise should be
prevented by  the surface diversion measures  installed.
     It is difficult to accurately determine
mercury contamination at the site and in the
                 the extent of
                 river and fish
Fish data taken since plant
statistically the change in
be equally represented by a
flat slope. [2-5]
closure appear random since
mercury concentration over time can
line with a positive, negative, or
     Figures 2-11 and 2-12 present; mercury concentrations of
fish and sediment before and after the erosion control  activity
was implemented at the chlorine plant site.  The sampling station
identification number increases with distance downstream from
the site.  Sampling Station Bl is located 8 'km'-(5.mi) downstream
from the former Olin plant site.  Sampling Station B6 is 119 km
(74 mi) downstream of the Olin site.  Figure 2-11- illustrates
the mean mercury content of fish in July,1978 (prior to remedial
action) and July 1979 (after remedial action).  Likewise, Figure
2-12 indicates the mean mercury content of the sediment in the
North Fork in July 1978 and July 1979.  From viewing Figures 2-11
and 2-12, it is difficult to determine if further discharge of
mercury .has been prevented.  Because of the behavior of mercury,
lodgement of mercury on the river floor may be creating a random
data appearance.  Time will permit the collect-ion of- a larger
data base for mercury concentrations in fish and sediment.
Perhaps then, a site-specific accurate assessment of mercury
mobility and transport mechanisms can be made, as well as a
determination of whether further mercury discharges from the
chlorine plant site are continuing.
                                 37

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Ul
tu
   5.0-1
    4.0-
    3.0"
    2.0-
    1.0 -
RIVER
MILE
    0.0
 n
  98
CONTROL
                                                              D 1979
                                                              • 1978
  82  77  72
.OLIN  Bl  B2
 59
 B3

STATION
36
B4
22
B5
8
B6
         Figure 2-11.   Mean mercury  content of the  sediment at
           the control  and  affected  stations on the Holston
                 River,  July 1978 and  July 1979.  [2-7]
                                     38

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  3.0-1
  2.0-
8

ce

I
UJ
  1.0
      fl
   0.0
RIVER    98
MILE    CONTROL
                                                        1979


                                                        1978
                 82  77  72        59
                 OLIN Bl  B2       B3
                               STATION
36
B4
B5
                                                                      I
8
B6
     Figure  2-12.  Mean  mercury content  of the fish  at the
      control  and affected stations  on  the Holston  River
                 July 1978  and July 1979.   [2-7]
                                -39

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     Concurrently, Olin's consultants have been collecting data
and investigating methods of corrective action at the disposal
ponds.  The six ponds constructed over the years by the site
operators were operated in accordance with standard operating
practices of the day.  While four of the six have reverted to a
natural state, two of the ponds remain active pollution sources.
Ponds 5 and 6 are sources of total dissolved solids (mainly
calcium and sodium chloride) pollution; Pond 5 is also a source
of mercury pollution.

     Pond 5, which covers 29 ha (72 ac) contains 5 million m3
(7 million yd3) of waste.  No final decision has been made on
abating the mercury problem associated with this pond.  The
soil under the pond consists of sandy, cobbled material, and
thus Containment of  feachate from the bottom of this pond would
be difficult. As an alternative surface sealing has been proposed
to prevent further intrusion of rainwater.  Such sealing would  be
less expensive to install and although it would not prevent any
further leaching, it would minimize the amount of future leachate
discharges.

CONCLUSION

     When the chlorine plant at the Olin complex  ceased operation
and was demolished, it was anticipated that the environmental
problem associated with mercury contamination of the fish in the
North Fork of the Holston River would gradually diminish.  However,
mercury concentrations in fish have fluctuated and actually appear
to have increased in 1977.  This increase correlated with a
reduction in dissolved solids and chlorides in the North Fork.
Likewise, river sediment values fluctuated and a linear decrease
was not noted for some 80 km (50 mi) downstream.  It was
theorized that the increases in mercury content in the fish was
the result of changes in the stream's chemistry after the plant
closure.  This increase has since subsided, but some mercury
discharge has continued and the stream remains contaminated.
No reduction in mercury concentrations has been substantiated in
the eight years since closure.

     In mid-1976, the State of Virginia and Olin Corporation began
studying the problem.  The State -of Tennessee also became involved
with the assessment since the North Fork of the Holston River
empties into the Tennessee River.  There is evidence that the
contamination extends down the river to the TVA Cherokee Reservoir,
161 km (100 mi) from Saltville, Virginia.

     Delay in correcting the mercury contamination problem has
been the result of several factors, one of which would be the
time consuming environmental and engineering studies to
rationally analyze the problem and to formulate cost effective
corrective measures that would have a reasonable chance of success.
                               40

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Presently, only a small  part of the. environmental  problems
associated with the previous operations at the chemical  complex
has been corrected.  The completed corrective action includes
erosion control measures implemented  at the former chlorine
plant site.  These measures appear to be successful  in limiting
further mercury contamination from the chlorine plant site from
entering the North Fork, according to representatives from both
the Virginia State Water Control Board and Olin Corporation.

     01 in believes the largest potential source of mercury dis-
charge to the river has  been corrected.  They maintain that
current discharges of TDS and mercury are between  0 and 20
percent of levels discharged during the years immediately before
and after plant closure.  Thus, Olin  officials believe a large
portion of the overall environmental  problems associated with
the chemical complex were mitigated by the 'plant closure and
subsequent remedial actions. [2-5]  Although a significant
amount of effort and money has been expended, the U.S. EPA and
Virginia State Water Control Board believe that correction of
environmental problems from the site is onVy beginning.
                                41

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              SITE A  REFERENCES AND BIBLIOGRAPHY
2-1   Aerial  photographs, Virginia Department of Transportation,
     Richmond, Virginia.

2-2   Personal  communication and file review with Larry K.  Owens,
     H.V. Arnold, and Dallas Sizemore of Virginia State Water
     Control  Board, Southwest Regional  Office, Abingdon,  Virginia.
     June 6-9, 1980

2-3   Investigation of Ground Water and  Surface Water Conditions
     Related  to Quality of Water in the North Fork of the Holston
     River near Saltville, Virginia. Dames and Moore, Lexington,
     Kentucky.  1976.

2-4   Kleiner,  D.E.  Investigation of Mercury Occurrence,  Former
     Chlorine  Plant Site, Saltville, Virginia.  Harza Engineering
     Company,  Chicago, Illinois.  1976.

2-5   Personal  communication with and memorandum from J.C.  Brown,
     Olin Chemicals Group.  Charleston, Tennessee.  June  6,  1980.

2-6   Topographic Survey for Olin Corporation by Hart and  Bell.
     August  1977.

2-7   Turner,  C.S.  Draft, Mercury in Fish and Sediment of the
     North Fork of the Holston River, 1978 and 1979.  Virginia
     State Water Quality Board, Bureau  of Surveillance and Field
     Studies,  Division of Ecological Studies.  1980.

2-8   Olin Corporation, Saltville Works, Study of Stability at
     Waste Pond No. 6.  Harza Engineering Company, Chicago,  !.'
     Illinois.  1971.

2-9   Olin Corporation, Saltville Works, Stability of Waste Pond. Nos.
     5 and 6.  Harza Engineering Company, Chicago, Illinois.  1976.

2-10 Elimore,  G.R. Investigation of Mercury Occurrance at Waste
     Pond 5,  Saltville, Virginia.  Harza Engineering Company,
     Chicago,  Illinois.  1976.

2-11 Milligan, J.D. and R.J. Ruane.  Analysis of Mercury  Data
     Collected from the North Fork of the Holston River.   Division
     of Environmental Planning, Tennessee Valley Authority,
     Chattanooga, Tennessee.  1978.

2-12 Personal  communication with C.C. Norris, Olin Chemicals Group.
     Saltville, Virginia.  June 6, 1980.

2-13 Personal  communication with Frank  E. Lewis, Mayor of Saltville,
     Saltville, Virginia.  June 6, 1980.
                               42

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   APPENDIX 2-1



SITE A PHOTOGRAPHS
        43

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 View  of  01 in  Corporation  at  Saltville while
 it  was still  oerpational.  Plant  facilities
 are located in  the  upper  right  corner.   Pond
 5 is  in  the center  and  left  portions of  photo.
 The North  Fork  of Holston  River borders  the pond
Overview of Olin Corporation at Saltville.   Town
of Saltville in upper right corner of photo.
Olin plant facilities .with Ponds 5 and 6 are
located in the central portion of the photo.
                    44

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Appearance of river bank bordering  chlorine  plant  site
before and after sloping and sand  application.
     Application  of plastic  liner  and  riprap
     to  resloped,  sanded .embankment  of chlorine
     plant site.
                        45

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Appearance of chlorine plant site after
remedial action.
                     46

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                            SECTION  3

                             SITE B
                 FIRESTONE TIRE AND  RUBBER COMPANY
                      POTTSTOWN,  PENNSYLVANIA
 INTRODUCTION

      In  1942 Jacobs Aircraft and Engine Company operated a
 machine  shop for the production of aircraft engines in Pottstown,
 Pennsylvania.  During this time, they disposed of cutting oils
 and metal filings in lagoons on their site.  Firestone Tire
 and Rubber Company purchased the Jacobs site in Pottstown in
 1945.  Since that time, they have landfilled tires, inert cloth
 and rubber, pigments, zinc oxide, sulfur dioxide scrubber wastes
 rubber flashing, and PVC sludge resins at the site.  Iron,
 manganese, aluminum, sulfates, and chlorides originating from
 the landfill and lagoons on the site have polluted the ground
 and surface water.in the area.

     To  remedy these water quality problems, Firestone has
 established a ground water recovery system of wells which purge
 the ground water near the lagoons and landfill  so that no
 off-site migration of the contaminants occurs.   The amounts of
 contaminants in the ground water and surface water are now
 within health standards as the Company continues to monitor
 the water quality in the area.
SITE DESCRIPTION
     The
located i
northeast
occupies
River whi
a communi
upstream
the groun
Pottstown Plant of Firestone Tire and Rubber
n southeastern Pennsylvania approximately 50
 of Philadelphia in Montgomery County.
106 ha (263 ac) within a meander loop
ch eventually flows to the Delaware
ty of over 20,000 people,  lies  a  few
from the Firestone Plant.   Residents
d water for drinking water.
         Company is
         km (30 mi)
    The site
  of the Schuylkill
River.   Pottstown,
 kilometers  (miles)
 in the area use
     Pottstown receives about 110 cm (43 in.)  of precipitation
and 81  cm (32 in.) of snow per year.  No frost can be  expected
from early April  to late October.  The winds  average 15  km/hr
(9.3 mph) from the west.  The temperature averages about 10°C
(51 F)  year round with a summer average of about 22°C  (72°F)
and a winter average of about -3°C (26°F).

     Firestone's  old landfill  area is  located  45 to  90 m
(150 to 300 ft)  from the Schuylkill  River.   Both the new landfill
                               47

-------
area and the new lagoons lie about 200 m  (600 ft)  from the
Schuylkill  River (see Figures 3-1  and 3-2).   The Schuylkill
River is 0.6 to  1.2 m (2 to 4 ft) deep and 15 to 30 m (50 to
100 ft) wide (depending on seasonal  variations) at  the Firestone
site.  The river is  33 m (110 ft)  above sea level and the
landfill is 9 m (30  ft) deep.  The river's 100 year frequency
flood raises its level 9 m (30 ft) which would flood the bottom
of the landfill.  This has occurred three times in  recent years.
The site is fairly flat with a small valley that will be filled
in with the expansion of the old landfill.  The old landfill
itself is flat across the top with steeply sloped sides.

     The subsurface  consists of two distinct materials.  Alluvium,
6 to 7.5 m (20 to 25 ft) thick, lies at the surface and consists
of thin layers of silt, sand, and gravel.  The water table levels
in this material correlate closely with river stages.  There is
little hydraulic gradient in this, the upper, or shallow flow
system.  The landfill and lagoons lie in this material.  Under-
lying the alluvium are the Lockatong Formation, a mudstone and
shale, and the Brunswick Formation, a shale, siltstone, and
sandstone.  The bedrock is not ^hxir,iz£m±AJ_ku^.cLlps^ap,pjf!iL5dJ]ia.tely
30 degrees to the southeast  (see Figure 3-3 and 3-4).  Ground
water in this, the lower or  deep flow system, occurs along
joints and bedding planes of the Brunswick Formation.  The deep
wells used for process water and potable water extend down into
this system.  There is some  communication or recharge from the
shallow to the deep ground water.  Therefore, the Schuylkill
River, the alluvium aquifer, and the bedrock aquifer are not
independent of one another.

     The area around the Firestone site is hilly and well  drained.
Elevations range from 33 m  (110 ft) to over 90 m (300 ft)  as
seen in Figure 3-4.   The vegetation at the Firestone site  consists
of grasses and some hardwood trees.  The trees grow  along  the
river banks and in the small valley.  Native grasses have  been
planted on the landfill and  other disturbed areas.

SITE OPERATION  AND HISTORY

     In 1942, Jacobs Aircraft  Engine  Company operated a machine
shop and defense plant for  the  production of aircraft engines as
part of the war effort.  Cutting oils, metal filings, and  other
wastes were placed in an open  dump  on the site.  Firestone Tire
and  Rubber  Company bought the  plant in 1945 and  began tire
production  soon afterwards.  They continued the  use  of  the
 open  dump through  the  early  1960's
 accepting vinyl  resins,  factory  trash,
 landfill was  originally  5.3  ha  (13 ac)
 lagoons were  also  used for PVC wastes.
converting it to a landfill
    and rubber tires.   The
    in size.   Six earthen
     Six deep wells were
 used  in  the  early  1960's  to  supply water  for process uses
                              48

-------
                                                  THIS AREA BOTTOM LAND

                                                  SCATTERED TREES B THICK BRUSH
          •am
                                          .owz
                                             OUTS
 • D PLANT WATER SUPFLY
    WELL

Ml • LANDFILL MONITORM6
    WELL (SHALLOW)

OWZ • OBSERVATION WELL
     (DEEP)
Figure  3-1    Partial map  of the  Firestone plant  showing
  some  wells and pits  used  for remedial  action.  [3-1]
                                   49

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  IreSe
  FONSTLVAMA
       .5
              I KM
PLANT WELLS

INVESTIGATION WELLS

LANDFILL

FIRESTONE PLANT
 0   K3OO  200OFT
Figure  3-2.   Location  map  of Firestone plant
            with remedial  action  wells.
                           50

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     NW
                        ALLUVIUM
                     THIN SAND.SILT OR GRAVEL LAYERS
                                                        SE
Om

5m

10m
        BRUNSWICK FM
                                                            20m
                                                             30m
Figure  3-3.   Rough   geologic cross  section of  the material
              underlying the  Firestone plant.
                               51

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    ! PENNSYLVANIA /


    I	J>
                                   LANDFILL
                                   LOCKATONG FORMATION
                                   (MUDSTONE AND SHALE)
               I KM.
Figure  3-4.   Location and  partial  geologic  map  for
  Firestone's  Pottstown, Pennsylvania plant.  L-3-^J
                             52

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 a  ,CVrrently> Firestone operates a tire manufacturing plant,
 a chemical plant, and a sheeting plant which produces plastic
 resins, fi m, and sheeting products.  They have proceeded with
 Pjans to close their tire plant.  However, the chemical plants
 will  remain in operation.  Before the tire plant was closed,
 Firestone employed nearly 2,400 people, and produced 450,000 kg
 (1 million Ibs) of finished tires per day.  Both the number of
 emp oyees and the amount of tires produced declined as closure
 activities continued.  The chemical  plant employs 450 people and
 the film and sheeting plant 250 people.
lanHf
landfill

?L?n
lanSfTl'l
     t*!e t1r? a?o,?he Chem1cal P
       In early  971, an average of 30
         an5fllled per day; the maJ°r
    refuse:  PaP6r'  The followin9
     1s
                                            co n t r i b u ted to the
                                            metric  tons (33 tons)
                                            ty of which was
                                            a "stof typical
t

•

•
9
          Tires
          Paper
          Carbon  black
          Polyethylene
          Wastewater treatment
            sludge
          Metal banding  and
            strappings
          Wooden  pallets
          Coagulated butadiene/
            styrene  latex
            wastes
          Miscel1aneous
            compounding  agents
            or dust  from- clean-
            up  activities
            (including sulfur
            and zinc  oxides)
Inert cloth and rubber
Rubber flashing
Oily rags
Polyvinyl chloride (PVC) film
Clay
Talc
Boiler fly ash
Synthetic polymer fabric
Oil/water emulsions
Sulfur dioxide sludge
Floor and roadway sweepings
Fiber drums
Lagoon wastes  (including
  calcium carbonate,
  calcium hydroxide,  and
  PVC resin)
Two lagoons are now used by the chemical
lined and used only during emergencies
material added to the lagoon.

POLLUTION
      plant.   Both  are  rubber-
      Wastewater is  the only
     Initially, the landfill and lagoon operations were cons
environmentally adequate by the Pennsyl vafiia Department £?nS
anH^HTha\i??i?U^eS- .However> subsequent monitoring of wells
dPtUSpd •  U?lkl11 RlKer 1nd1cated contamination.  Contaminants
detected in the^ground water in 1972 from monitoring wells
placed around the landfill  included iron (185 ppm), manganese
(20 ppm ,  aluminum (10 ppm), and sulfates (140 ppm    Be^ausI
?f.th!V.nterconneCtion of the two aquifers as well as the

theUpoll t-       a11  thrSe Wat6ir b°d1es Were threatened by
                              53

-------
     The landfill  was accepting nearly 27 metric  tons  (30  tons)
of refuse per day  in 1970 when Firestone applied  for  a new
permit to operate  a sanitary landfill.  The permit was approved
in July 1971, but  not actually issued until August 1973 due  to
permit infraction's and revisions.   It was the first industrial
land disposal permit issued by the State's Division of Solid
Waste Management.

     Firestone received a variance for a pilot plant  process to
remove sulfur dioxide and fly ash  from their boiler stacks.
They also received permission to landfill the wastes  from  the
sulfur dioxide scrubber system in  late 1973.  Wastes  from  the
scrubber process included calcium sulfite dihydrate,  lime
residues, fly ash, and sodium sulfate.  The sludge was mixed_
with dirt and landfilled.  Use of the scrubber system began  in
February 1975 as an experimental one-year operation in cooperation
with the State.  A permit for continued operation of the
scrubber processing and disposal facility was granted in
September 1977.

REMEDIAL ACTION
      In early 1974.
Management ordered
Two of the lagoons
installed in their
                  ,  the Pennsylvania Bureau  of Water Quality
                   that use of the six lagoons be discontinued.
                   were excavated and one lined lagoon  was
                   combined locations.  A second lined  lagoon
was installed alongside in virgin ground:.  These new lagoons
were lined with multi-layered rubber liners  developed by
Firestone.  The other four lagoons were filled during
and a solids removal system was constructed  upstream.
four lagoons were then discontinued.  Currently,
are removed upstream go directly to the landfill
lagoons are used only in emergencies.  The new lagoons  lie  in  a
one-hundred year flood area but otherwise there is no discharge
and, therefore, they do not affect the ground water.

     In 1974 Firestone sought permission to  expand their existing
landfill, but were  first required to  install a leachate control
system since lining  the expanded  landfill to isolate it from the
                                                      this time
                                                       The
                                                 solids which
                                                 and the lined
 ground water flow system Was  determined
 than flow manipulation.   Also,  it  would
 attempt to line the existing  landfill.
 began a ground watering  recovery system
 located as shown in Figures  3-1  and 3-2
 water would be used for  processing and
                                        to be more expensive
                                        be impractical to
                                        Therefore, Firestone
                                        consisting of 14 wells
                                          Some of the extracted
                                       potable uses.
      Three wells, used for potable water,  draw a  total  of
 0.01 m3/sec (150 gal/minute)  and are 60 m  to  1.20. m (200 to  ^
 400 ft) deep.   Five wells are used for process water which  is
 deionized previous to use in  the polymerization process.   These
 wells draw 0.006 to 0.01 m3/sec (100 to 200 gal/minute) each.
 The five wells form a large zone of depression beneath  the
                                54

-------
seepage lagoons and the landfill.   Recharge from the  alluvium
aquifer is drawn to this large zone of depression.   Therefore,
the pollutants entering the shallow flow system (alluvium
aquifer) are similarly drawn down  and do not flow to  the
Schuylkill River.   Water from the  Schuylkill River enters the
alluvium aquifer as recharge.  Flow manipulation has  altered
the original flow pattern of the alluvium aquifer which recharges
both the bedrock (deep flow system) and the Schuylkill  River.
Four wells are used for monitoring.  This recovery system has
been effective in controlling off-site migration of pollutants.

     The data presented on the graphs contained in Figures 3-5
through 3-8 illustrates the problems of the pollution to the
ground water as well as the effectiveness of the use  of the
recovery wells.  No graphs illustrating iron, phosphate, or
manganese contamination are included.  Early sampling for iron
was affected by contamination by the iron casings in  the wells.
Phosphate and manganese results are too vague to indicate
consistent contamination or trends.

     Firestone has discontinued their tire manufacturing plant
so less material is now being-1 andfi 11 ed.  Their chemical plant
will continue use of the seepage lagoons and landfill.
Therefore, the recovery system should be adequate to  control the
water flow system and the migration of pollutants.  Monitoring
will continue on a quarterly basis.

     Firestone paid $40,000 for a hydrogeologic study to deter-
mine the best means of leachate control and for the placement
of the recovery and monitoring wells.  Another $210,000 was
used for revisions to the permit application and revisions
necessary to complete the landfill expansion.

CONCLUSION

     Firestone has attempted, through several types of remedial
action, to control leachate migration from  their Pottstown
facility.  There has been a threat of contamination to the
ground water  (a two aquifer system) and to  the surface water
(Schuylkill  River).

     Firestone converted their open dump to a landfill in the
early 1960's.  This helped control surface  conditions  (blowing
litter, etc.).  No data  is available  to determine whether this
influenced  the leachate  entering the  ground water, soil, or
the Schuylkill River.

     In 1974  and 1975,  Firestone closed their earthen  lagoons
and built two  new  lined  lagoons.   They  also initiated  a  ground
water recovery system which manipulated the flow of ground water
                                55

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  200

                               <
                               o
                               iij
                               o:
     ,1972  11973  11974  I 1975  I 1976 ' 1977 11978 M979  ' 1980 I

   Figure 3-5.  Sulfate  concentrations  in the ground water
       before and after  the use of  the  recovery wells.
   30
§  20
   10
                               o
                               Id
      1972  I 1973  I 1974 I  1975 I 1976  I 1977 I 1978  11979  11980 '

   Figure 3-6.   Five day BOD in  the  ground water  before and
               after the use of  recovery wells.
                               56

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   200
Ul
O
o:

3

o
100
1


§
                               o
                               UJ

                               UJ
                               ce
                                         «L2_
       1972  ' 1973 I 1974 '  1975 ' 1976  ' 1977 I 1978 ' 1979  ' 1980  '



      Figure 3-7.   Chloride concentrations in  the ground water

             before and  after  the use of recovery wells.
   1,000
 o.
 ex


I

d
tn
   500
                                I
                                UJ
                                cc
                                                  •  •
        1972  I 1973 I  1974  • 1975  I 1978 ' 1977  ' 1978  ' 1979  ' I9&0  '



    Figure  3-8.   Concentration of total solids in the  ground water

            before and after  the use of the  recovery wells.
                                   57

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to prevent off-site migration of pollutants.   These two actions
occurred close enough in time and location to make it necessary
to assess their effectiveness simultaneously.  Both the supporting
data and persons with the Pennsylvania Department of Environmental
Resources indicate that no off-site migration of pollutants  is
occurring now.  It is predicted that the threat of contamination
to the ground water and to the Schuylkill  River will  lessen  with
the closure of the tire manufacturing plant.   The cost of the
hydrogeologic study and the recovery wells ($250,000) as  a
preventive measure is much less than the cost of
cleanup of migrating pollutants which could have
ground water and in the Schuylkill  River.
extensi ve
appeared in
the
                              58

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            SITE  B  REFERENCES  AND BIBLIOGRAPHY
3-1   Martin and Martin,  Inc.,  and Todd Giddings  and Associates.
     Report to Department of Environmental  Resources on
     Hvdroaeoloqy of the Existing Landfill, Proposed Landfill,
     and Sludge Lagoons:  The Firestone Tire and Rubber Company,
     Pottstown, Pennsylvania.   1975.

3-2  Pennsylvania Geological Survey,  Pennsylvania Geological
     Survey Report W-22.
                                59

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   APPENDIX 3-1



SITE B PHOTOGRAPHS
          60

-------
View of part of the old landfill.  Note access  road
trees (which border the river)  in  the background.
Ponded  water is the result of  a recent rainfall.
and
                          61

-------
View of the edge of the old lagoon.   The final  cover
and vegetation were quickly established.
                         62

-------
View from the old lagoon looking  toward  the  proposed
area for the new lagoon.
                         63

-------
View of the old lagoon's final  cover and vegetation.
Numerous deer tracks were seen.
                         64

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                          SECTION 4

                            SITE C

           ANONYMOUS WASTE DISPOSAL COMPANY DUMP SITE
                      EAST-CENTRAL NEW YORK
INTRODUCTION

     Since 1958,  the discharge of hazardous wastes from a dump site
in east-central  New York has been of concern to local  residents and
to the State and  County Health Departments.  Despite warnings from
the State and County and complaints from local  residents, the Company
continued to accept wastes from local  industries for disposal.  In
1964, the Company tried to contain the pollution by building a dam
across the site outlet, in the process  forming a waste lagoon.
However, the dam  was ineffective and waste continued to escape from
the dump site.
      In  1966,  the  State
 continued,  however,  fish
 General  initiated  court
 Company  to  rfifrain from
 streams,  to cease  dumpin
 the  wastes  already there
 dumping  order.   However,
 Spring  1970,  when  heavy
_sHe j*as  final ly cje^nej
 The  area  was  capped with
 surface  water around the
                        ordered the Company to stop dumping.  Dumping
                         kills occurred, and the State Attorney
                        action.  In 1968, the Courts ordered the
                        further discharges of wastes into nearby
                        g at the site immediately, and to remove
                        .  The Company complied with the cease-
                         area residents complained again in
                        rains sent wastewater over the dam.  The
                         jjpj3y_the_j^^                     1.32.4,..
                         soil and a ditch constructed to divert
                         site.
     Concern. over the effectiveness of remedial action developed
several years later.  Noticeable chemical and oil contamination of
area streams was traced to ground water seeps at the site.  Further,
water, sediment, and fish samples from a downstream lake revealed
the presence of polychlorinated biphenyls (PCB's), and these too
were traced  to the dump site.  Additional remedial action, including
the construction of a slurry wall, is now being considered.

SITE DESCRIPTION
                                                                   *
     The waste disposal site is located in a rural area approximately
24 km  (15 mi) southeast of a large city, 6 km  (4 mi) northeast of
a small community, and 5  km  (3 mi) from a lake in east central New
York.  Area  residents and vacationers use the  Lake for fishing and
other  recreational activities.  The land is partly wooded and partly
pasture land used for grazing.  Several residents live in the
vicinity of  the dump site (see Figures 4-1 and- 4-2).

     When the waste disposal Company  terminated  its dumping
operations  in 1968 as a result of legal action by the State of
                                65

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Figure 4-1.   Site C location  map,
              66

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New York, the operations included two wastewater lagoons, one
oil pit, four above ground storage tanks, a storage shed, and a
drum burial area on the south and eastern perimeter of the dump
site.  The lagoons, referred to as the lower and upper lagoons,
were approximately 0.4 ha (1 ac) and 2 ha (5 ac) in size respec-
tively, and were separated by an earthen dike.  The dimensions
of the earthen dam across the outlet of the lower lagoon were
estimated at 14 m (45 ft) long and 3 m (10 ft) wide.  The oil
pit on the site was approximately 2 m (6 ft) deep and had an
approximate area of 8 m (25 ft) by 46 m (150 ft).  Four large
steel oblong storage tanks, each having a capacity of 114 tin
(30,000 gal), the storage shed, and the drum burial area are
located on the eastern and souther sections of the site.  The
entire dump site was 4 to 6 ha (10 to 15 ac).  Figure 4-3 shows
the waste disposal dump site as it appeared in 1968.

     The climate of New York State is representative of the humid
continental type which prevails in the Northeastern U.S.  The
average annual temperature at the .site is 14°C (58°F) and the average
annual precipitation is 84 cm (33 in.).  There are an average of
155 days between late September and early May with minimum
temperature of 0°C (32°F) or less and 137 days with precipitation
of 0.03 cm (0.01 in.) or more.  The average annual snowfall is
168 cm  (66 in.).
     The dump site is the low point of a
Drainage from the dump site is through a
tributary stream to the upper reaches of
perennial stream is approximately 3.2
into the Lake north of the community,
Currently no surface water enters the
been constructed around the dump site
Originally, the waste disposal dump site was a flat
area about .600 m.^(2,000 ft.)- long and averaging -75 m
   40 ha (100 ac)  watershed.
   small 0.8 km (0.5 mi)
   a perennial  stream.   The
km (2 mi) long  and empties
southwest of the dump site.
site.  Drainage ditches  have
to divert all runoff.
               wet marshy
              (250_ft)  wide.
The terrain sloped upward-into a wooded-area from the marsh

     Glacial deposits left during the Quaternary period
mantle the entire region except for small isolated rock outcrops
and recent alluvium.  These glacial deposits differ considerably
from one another  in lithology and thickness, and may be divided
into till, kames, and outwash.  Till is  a heterogeneous mixture
of largely unsorted material ranging in  size from clay to boulders,
and topographically it  forms the tops of the nearby hills.  Owing
to the lack of  sorting  and the presence  of much fine material, the
till has a low  permeability and yields only small to moderate
quantities of ground water.  Overlying the till in most of the
stream valleys  are kames forming terraces and  knobs of sand,
gravel, and boulders.   Meltwater along the edges of the glacier
stripped the till and kame deposits p>oviding  the source  for the
accumulation of outwash (stratified stream deposits formed by
glacial meltwater) in the deglaciated tributary and perennial
                               68

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OIL PIT'   
                                                      DRUM BURIAL
                                                       AREA
 • MONITORNG WELLS
Figure  4-3.   Facility  layout  in 1968  before  closure.
                           69

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stream valleys to the south.  Ground water yields in the outwash
average about 0.5 m3/min (140.gpm).  Thickness of the outwash
material below the dump site is approximately 9 m (3.0 ft).
Clays and silt alluvium cover the outwash.  The thickest alluvium
lies in the perennial stream near the Lake.  A geologic cross
section through the dump site showing bedrock, glacial  deposits,
alluvium, and the water level at the site is presented in
Figure 4-4.

SITE OPERATION AND HISTORY

     The Company operated as a private scavenger service collecting
and disposing of waste chemicals and oils of various chemical
and industrial plants in east-central New York.  Hazardous waste
materials were collected in 0.2 m3 (55 gal) drums and transported
to the dump site.  The contents of reuseable drums were dumped
into the pit or into the upper lagoon.  Unuseable drums were dumped
either on the perimeter of the upper lagoon or in the drum burial
area.  Drums were later covered with soil using a medium size-
bulldozer.  The pit was used to store and separate recyclable
oily wastes.  The non-recyclable contents were pumped into the
lagoon or onto the ground surface.

     The Company currently has a scavenger waste permit and is
allowed to store oil in the four oil tanks.  The oil tanks operate
as a backup storage 'and transfer station for oily wastes which
are disposed of at a New Jersey site.  There are nd~~l ongeir any
lagoons or pits to dispose wastes, including water from oil
tank trucks.  However, hundreds of drums remain at the  site,
many of them unburied.  Some waste still remains in the drums
and has dried to a tar-like consistency; most of the drums have
leaked onto the ground.

     During the period of active dumpin-g from 1955 to 1968,  large
amounts of oils and chemicals were dumped at the site.   Industrial
wastes dumped in the area included toluene, silicone, benzene,
xylene, phenols, polychlorinated biphenyls (PCB's), isopropanol,
acetone, methanol, butanol, trichloroethylene, methylchloride,
oils, and paints.  Portions of the waste oil were from  cutting
and cooling operations and contained impurities, such as metal
grindings, filings, and silicone.

     During 1965, one industry disposed of 3,340 m3 (883,000 gal)
of silicone-contaminated wastes through contract with the Company.
The industry estimates the total  quantity of waste material  taken
by the Company in the 1960's at approximately 13,617 metric  tons
(15,000 tons), much of it liquid solvents or water solvent mixtures.
A substantial  quantity of filter cake and other solids, often
saturated with solvents, was also  removed.
                               70

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Figure 4-4.   Generalized  geologic  cross  section
               of Site C  in  1980.
                       71

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      Another industry disposed of 3,460  m  (914,000  gal)  and
 17  metric  tons  (19  .tons)  of wastes  from  April  1,  1965  to  April  1
 1966.   For seven  years,  from 38 to. 57  m3 (10,000  to  15,000  gal)
 of  wastes  were  received  from a third company.

      In  August  1953 the  owner of the Company  acquired  the property
 for industrial  waste disposal  activities.   The  property was in
 an  undeveloped  area of east-central New  York  and  at  the time
 seemed to  be an ideal  location for  waste disposal  operations.
 At  the smae  time, area residents  were  informed  what  the property
 was  to be  used  for,  but  there  were  no  objections  to  the purchase.

      During  the summer of  1955,  the Company initiated  their
 scavenger  service for  the  collection and disposal  of wastes,
 chemicals, and  oils  from various  industrial establishments.   In
 late  October 1958 the  County  Health Department  received a complaint
 from  a property owner  adjacent to the  dump site.   The  owner
 reported that the Company's  dumping had  contaminated his pond and
 well.  As  a  result,  the property  owner was forced  to obtain water
 from  another source  for domestic  use.  A County Health Department
 inspection was  the  first indication that a serious water pollution
 probl em exi ste'd.

     A year  la.ter,  in  October  1959, the  County  Health  Department
 received additional   complaints  that waste oil products were
 seeping from the property  and  damaging livestock and private wate
 s.upplies.  The  Company was advised of the continued  complaints
 and was again instructed to confine their waste discharges.   Steps
 were undertaken by  the Company  to regrade the property so that
 drainage of  oil from the dump  site was minimized.  The Company
 stated that  in  the  future, oil  received  would be promptly burned
 and not permitted to accumulate.  However, the complaints
 persisted, and  follow-up -inspections by  the Health Department were
 conducted.   Each inspection reached the  same conclusion:

     1.  Conditions  at the dump site were not improving.

     2.  Freshly dumped oil and chemical  wastes were found at
         the dump at each visit.
     4.
Oil and chemicals were observed in the tributary
and on farm ponds.

Strong chemical  odors pervaded the area and some
discharges were  found in the Lake
     In March 1963, inspections indicated evidence of repeated
oil  and chemical  discharges.  At various points along the
tributary and perennial  stream to the Lake, evidence of No.  2
fuel oil  and silicone odors was evident.
                               72

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     Warned by the State and County  Health Departments  about  further
discharges, the Company constructed  dikes  and diversion ditches
around the disposal  area to contain  the waste chemicals and  oils.
However, the dike and diversion ditches were only  temporarily
effective.  In September 1963,  residents prepared  a  petition
requesting that further dumping and  burning of wastes  at the  dump
site be discontinued.  In May 1964,  the Company constructed  an
earthen dam across the outlet of the swamp to pond the  wastes in
a lagoon.  This measure was largely  ineffective in controllin.g
discharges; sludge still leaked from the dam and entered the
stream as before.

     On July 31, 1964 the County Health Department recommended
that surface disposal of waste be eliminated, and  scum, sludges,
and other deposits collected and enclosed in impervious containers
as soon as possible.  In order to discharge, the Company would
need a permit to comply with the law.  Because voluntary pollution
abatement was not successful, and because open dumping and burning
of wastes continued, causing a serious public health hazard,  legal
action against the Company was initiated in September-1964.   The
Company continued to-act in violation of water standa-rd-s adopted-
by the State and to  discharge .wastes without a permit.

     In April 1965,  drums of contaminated gasoline,  spilled by
a bulldozer, caught  fire and spread to the lagoon.  Complaints
of burning at the dump were received.  Dense smoke and odors were
prevalent  in the area.  Fire spread to the wooded area surrounding
the dump.  Several months later in July 1965, another serious fire
broke out  when chemicals stored at the site ignited spontaneously
while attempts were  made to cover the drums.

      In  1965, amendments to the Public Health Law allowed the
State Health  Department to  take more effective measures against
polluters  of  the State's waters.  An administrative hearing was
convened  by the  State  Commissioner of Health during September 1966,
at which  time an order was  issued directing the Company to stop
dumping  its wastes  by  the end  of October  1966, and to  remove the
remaining  wastes  from  the site by April 1,  1967.

      Despite  the  Commissioner's order,  dumping operations were  not
halted.   Numerous field  inspections  by  the  Health Department
revealed  that  chemical  wastes  were being  dumped into the  lagoon
and the  lagoon  outlet  was  leaching to  the  tributary.   Deposits  of
a yellow-orange  colored  substance covered  the tributary's bottom
soil  and rocks,  and  oil  slicks were  observed  in one location.
 Inspections  in  1967  revealed hundreds  of  drums were still being
dumped  at the  site.   In  October,1967,  a 15  cm  (6  in.)  diameter
valve  outlet  pipe to the tributary was  inserted in the  edge  of
the lagoon providing a  direct  outlet  for  the  waste.  The  outlet
 and additional  construction, including  a  dike  dividing  the lagoon
 into  upper and  lower lagoons,  violated  the  Public Health  Law
                                73

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which required permits for such activities.  These actions were
responsible for fish kills and pollution of the perennial stream.

     To enforce the Commissioner's order and to prevent the
Company from further endangering the public health, the case was
formally referred to the New York State Attorney General's Office
on May 31, 1967.  Court action was initiated on August 8, 1967,
ordering the Company to cease disposal of wastes at the site.
Dumping was finally terminated in 1968.

POLLUTION

     During the period of active dumping between 1955 and 1968,
large amounts of oils and chemicals were dumped into the lagoons
and oil pit.  Hundreds of drums containing chemical wastes were
also scattered along the perimeter of the property, in the lagoon,
and buried in the dump site.   Many drums ruptured or were opened,
their contents spilling onto the ground surface and/or into the
lagoons.  Waste leached into subsurface soils from buried leaking
drums.  With each rainfall, waste washed or leached into the
lagoons.  The lagoons and oil pit were often heavily coated with
oil and sludge floating on the surface.  Strong chemical odors
were emitted from the site.  Spontaneous and intentional fires
were common and heavy clouds of acrid smoke drifted over the
adjoining countryside.

     Some oils and chemicals leached from the drum burial site and
lagoons into a swampy area north of the dump site.  At the outlet
of the lagoon, oils, chemicals, and sludge frequently leaked into
the tributary through holes breeched in the dam  by runoff.

     Numerous documentations were made concerning chemical wastes
and oils entering the tributary, perennial stream, and Lake.  The
tributary flowed through several farm pastures  used as grazing land
for cattle.  Cattle illnesses and deaths were reported.   A pond
in the tributary accumulated a 7.6cm (3 in.) layer of oil, often
killing ducks, herons, and other wildlife or preventing them from
remaining there.  Several fish kills occurred in the perennial
stream.  In 1963 water in the perennial stream  515 m (1,700 ft)
downstream from its confluence with the tributary was contaminated
with trichloroethylene and toluene and was fatal to test fish
within 12 minutes.  In 1966 the water in the tributary about 1.8 m
(6 ft) above its confluence with the perennial  stream diluted with
an equal volume of water was fatal to test brown trout within four
hours.  The fish kill  and absence of aquatic fauna was a result
of high phenol concentrations.  Water samples taken in 1965 and
1966 above and below the confluence of the tributary and perennial
stream and in the tributary showed conclusively that the source
of phenols was the dump site.  The perennial stream above the
tributary contained phenols at 5 ppb.  The tributary varied in
phenols content from 29 ppm to 99 ppm.  The perennial  stream below
the tributary  varied in phenol content from 86 ppb to 774 ppb.
                               74

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     Residential  wells were contaminated during the time of the
fish kills.   In some cases it was felt that the contamination was
not necessarily due to ground water influence,  but due to surface
waters intruding into the wells from the tributary which flows
alongside the wells.  However, it was believed  that contaminated
surface water had slowly percolated to the ground water table and
that neighboring wells located in the direction of ground water
flow had become contaminated.  Table 4-1 presents data from water
samples taken in March and April 1966 in the tributary, perennial,
stream, wells, and springs.

REMEDIAL ACTION

     In the spring of 1970, a large quantity of waste products was
discharged from the lagoon with surface runoff and swept downstream
into the Lake, leaving a film coating on the surface.  State and
County health officials recognized the need for further action.
In a final effort to p-urge the lagoon of its pollutants, health
officials issued a burning permit to the operator.  The object
was to "burn off the top" of the lagoon, destroying as much as
possible of the floating wastes.  Whatever wastes remained were
to be  "skimmed off" by the operator and placed in sealed drums.

     Because of the weather conditions and the seri'ous air pollution
problem and fire hazard that would be created  from the burning,
State  and County officials re-examined the situation and suspended
the burning p_ermit_.  Th.ejie w-erue ma-ny dea_d trees surraunding the
lagoons and it was believed that if the lagoons were set on fire
the dead trees would probably catch fire also.  In addition, any
type of burning was ruled out because of the concern of the
toxicity of the combustible products and the large number of
unknown chemicals  in the  lagoons.

     Other alternatives considered  included skimming the wastes
from the lagoons and  burning  them at another site or applying
straw  or wood  chips on the lagoon to induce "accelerated bacterial
decomposition".  Another  alternative considered was  filling the
lagoons, constructing  a ditch to divert the stream,  and regrading
the site.  A  final  alternative  considered was  pumping  the lagoon
contents  into  open  sand beds  to  filter  out the wastes,  filling
the lagoon, and  removing  remaining  wastes to a sanitary  landfill
or other burial  site.

      Discussions  between  State  and  County  representatives in  a
June  1970 meeting  resulted in  an: agreement that  the  Company  should
undertake  immediate  steps  that  would  serve to  abate  the
problem.   To  guarantee the Company  woul d .take  the  necessary., actions,
a  schedule  for immediate  and  long  term  measures  to cleanup  the
lagoon was  developed,  including the  following  tasks  and  deadlines:
                                75

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TABLE 4-1.   WASTE DISPOSAL COMPANY  SAMPLING (1966)
 Date
               Sampling Location/Source
Phenols (ppb)
PH
3/25/66
3/25/66
3/29/66
3/29/66
3/29/66
3/29/66
3/29/66
3/29/66
3/29/66
4/5/66
4/5/66
4/5/66
4/5/66
Lagoon - 30 ra (100 ft) from discharge
Discharge from lagoon
Lagoon - northwest end
Pond overflow
Tributary
Perennial stream - below tributary
Perennial stream - above tributary
Dug well - Residence A
Spring supply - kitchen tap - Residence B
Dug well - Residence C
Dug well - Residence D
Dug well #1 - Residence E
Dug well 12 - Residence E
148,000
134,000
140,000
14,600
8,600
86
<5
11 .2
<5
293
6.2
<5
10.4

-•
5.0
6.5
7.2
7.3
7.1
6.3
6.8
6.3
6.9
6.5
6.5
1  ra » 3.3 ft
                               76

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     1.


     2.



     3.




     4.



     5.
A competent
be retained
water pollution abatement engineer was to
by the Company by July 15, 1970.
A report addressing the extent of pollution, the nature
of the wastes, and proposals for pollution abatement
was to be completed by October 30, 1970.

A satisfactory and stable dam was to be completed to
contain the polluted waters in the two lagoons at the
site, and the outlet pipe was to be removed by July
31, 1970.

A ditch was to be completed diverting the influent stream,
and necessary grading was to be completed to assure that
no further runoff would enter the lagoons by July 31, 1970,

All floating pollutants were to be removed from the
lagoons and disposed of in an acceptable  manner by
August 31, 1970.
     In complying with the schedule, the Company encountered
problems, particularly because they elected to fill  in the lagoons
rather than building a satisfactory and stable dam.   Described
below for each of the tasks in the schedule is a description of
some of the problems encountered and the effectiveness of each
task in abating the pol1ution:

     1.  Retain a Competent Water Abatement Engineer by July 15,
         1970.  In early July 1970, initial contact  was made with
         a local  professional  engineering and surveying firm
         acceptable to the State and County Health Departments.
         In early August 1970, the Company retained  the engineering
         services of that firm.           \

     2.  Submit an Engineering Report by October 30, 1970.   The
         report was submitted on schedule.   Portions of the
         report have been incorporated in the following section.

     3.  Build a  Satisfactory and Stable Dam and Remove the Outlet
         Pipe from the Dam by July 31, 1970.  In July 1970, the
         outlet pipe in  the dam  was removed.  Instead of building
         a dam, the Company chose to fill the lagoons with
         material from the adjacent hill in an apparent attempt
         to permanently  solve the pollution problem.  State and
         County officials gave informal  approval  to  the proposed
         filling  operations.

         In filling in the lagoons the initial  plan  was to  section
         off the  lagoons  with dikes and then pump out the wastes
         into tanks.  The filling operations began during July
         1970.  The initial earth-moving operation was directed
                               77

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    towards creating a dike 0.6 to 1  m (2 to. 3 ft) in
    height atop the dam for the purpose of preventing any
    further, spills from the lagoons.   A Company bull dozer
    created the"dike and the Company then proceeded to fill
    in the lower lagoon,which was about 0.4 ha. (1  ac) in
    size.  By mid-August 197.0, the lower lagoon had been
    substantially filled.

    In the ensuing months, filling operations in the  upper
    lagoon were slow.  The plan was to section off the upper
    lagoon area into two smaller lagoons with the  construction
    of a new dike.  The lagoon was to continue to  be
    sectioned until filling operations were completed.  The
    major reason for the slow progress was that it was much
    deeper than expected, in addition to having a  much larger
    surface area.  As a result most of the fill was saturated
    below the water level of the lagoon and was unstable,
    making it difficult for the bulldozer to pass  over the
    fill.  In the interests of securing firmer footing, the
    Company decided to a w a11 f reezing weath er be fore  c o n ti n u i n g
    the fill  operations.

    Subsequently, filling operations  were conducted throughout
    the winter.  As with the proceeding months, progress was
    very slow.  By June 1971, only about five percent of the
    upper lagoon area remained to be covered.  Further effort
    to fill and grade the former lagoon diminished by summer's
    end even though ponding of surface water was apparent,
    particularly in substantial depressions in the eastern
    part of the site farthest away from the lagoons.   Limited
    filling and grading was done in.1972, 1973, and 1974.
    In 1973,  the old oil' pit was filled.  The last filling
    and grading at the site was in October 1974.  Additional
    fill material was brought in on the southeastern  end of
    the upper lagoon.  The number of depressions had  been
    minimized and the regrading was essentially adequate.
    However,  considerable ponding of water was noted  in
    other areas near the old lagoons.  No further  effort
    has been made by the Company to complete the filling
    and grading operations since 1974 and the appearance of
    the site  has remained relatively unchanged since  that
    time.  Some areas have been completely or partially
    overgrown by swamp vegetation and weeds. Otherwise, the
    fill material is exposed at the surface.  The  Company
    has made no effort to revegetate  the site.

4.  Construction of Diversion Ditch by July 31, 1970.  Due
    to the Company's decision to completely fill the  lagoons,
    the July 31 deadline could not be met.  Construction
    of the diversion ditch was in conflict with the earth
    moving operations conducted at the site to coverJthe
                          78

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5.
existing lagoons,  since the diversion ditch was
continuously crossed by heavy equipment obtaining
additional  fill  material.   As a resul t, the. Company
requested and received a time extension from the State
and County health departments.

Once the lower lagoon was  filled, work proceeded with
the construction of the diversion ditch on the west side
of the lower lagoon.  The  plan developed by the State
and County Health Departments and the consulting
engineer was to maintain a minimum separation of 9 m
(30 ft) to prevent seepage from the drum burial site
and the former lagoon.  The ditch was to be constructed
in tight clay soil and a transit was to be used to assure
that the diversion ditch had the necessary grade.  Final
sloping of the ditch was expected to be a relatively
simple matter.  When completed, the diversion ditch was
to completely encircle the waste disposal site.

During the filling of the upper lagoon, attempts were
made to— bui Id-temp-opa-ry diversion ditches.  The diversion
ditches were constructed with a sweep by a bulldozer
blade.  In addition, during filling operations, the
ditches were frequently blocked with fill material.  As
a result they were not effective in diverting the surface
water of the influent stream aro.und the lagoons.  Surface
water from the influent stream running through the lagoons
was a constant problem.  However, the diversion ditches
were effective in intercepting runoff from the hill
where fill material was being taken to fill the lagoons.

Another major problem was that leachate was frequently
found in the diversion ditches, mostly because the
ditches were constructed too- close to the lagoons.   As
a result,  some chemicals seeped from the lagoons and
drum burial  site  into the ditches.  One case  occurred
in  June 1971 where  leachate  from the former lower lagoon
area had seeped  into  a ditch constructed adjacent to  the
former  lower lagoon.  The Company was  immediately
instructed to fill  the ditch and construct a  new ditch
further away  from the former lagoon.   This action was
completed  the same  day.

The diversion ditches were  completed in 1973.  They
were excavated with  a rented backhoe and graded  to permit
proper  drainage.  Since their  completion, they  have
been effective  in diverting  considerable amounts of  w.ater
around  the  former dump  site  area.

Removing  All  Floating  Pollutants  from  the Lagoons and
Disposal  in  an  Acceptable Manner  by August  31,  1970.
                          79

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          The Company removed the floating pollutants  at  the
          same time the lagoons  were being filled.   The  liquids
          displaced by the filling operations  had  been pumped
          to a tank truck for salvage use.   The  largest  portion
          of the surface skimmings consisted of  waste  oil,  and this
          was used to spray dirt roads  in  the  nearby towns  in
          which the Company had  contracts.   Most of  the  floating
          pollutants  that were in the lagoons  were removed  by
          December 1970.

          Despite  the skimming operation,  pollutants at the site
          continued to be a major problem.   This was predominantly
          due to surface  water running  into  the  lagoons,  lagoons
          overflowing into the ditches  and  ground water seeping
          from the north  bank  of the upper  lagoon.   Leachate
          accumulated in  the depressions of  the  filled portions
          of the lagoons  where it had not  been graded properly,
          forming  small  shallow  ponds with  floating  chemicals and
          oils.   Runoff or seepage  of leachate into  the diversion
          ditches  was a constant  problem.   In  addition, underground
          leaching from the lagoons  and diversion ditches was also
          observed on the north  side of the  road in  the swampy area
          opposite the dump site  giving it  a red-orange color and
          chemical-oily odor.

          Completion  of the diversion ditch  in 1973  diverted
          considerable amounts of water around the dump site,  thus
          reducing, but not preventing, leaching from the site.
          Ultimately,  however, the  leaching  problem  increased
          with  time.   Ground water  continued to  seep through the
          drum  burial  area  and emerge from the north bank of the
          upper  lagoon  contaminated  with chemicals and oils.  To
          compound  the  problem, chemicals and oils began  to surface
          from  the  drum burial srte  and lagoons,  predominantly
          from  chemicals  and oils stored in  leaking,  deteriorating
          drums.   Many  buried  steel  drums have corroded and are
          now collapsing  causing  sinks in the cover of the site.
          In  addition,  it  is believed that the severe winters  in
          the late  1970's  have had some effect'in loosening the
          fill and  allowing waste to  percolate up through the  soil.
          Heavy  black  oil  and  chemical seeps have been  observed
          from the  north  bank  of  the  old lagoon area.  Ponding of
          pollutants  and  strong odors are becoming  more prevalent
          and the marsh and tributary are becoming  discolored.

     Surface and ground water monitoring of the  site has essentially
been in two phases.   In the first phase,  two monitoring  wells  were
installed approximately 90 m  (300 ft) apart on the Company side
of the road with one well  located about 15 m (50 ft) from the
watercourse, culvert  under the road  (see Figure 4-2).  Each well
was placed about 1.8 m (6 ft) deep with 0.2 m  (0.6 ft) diameter
                                80

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perforated bituminous  fiber pipe as casing.   In addition,  an
existing shallow well about 0.4 km (0.2 mi) downstream from the
Company's property was used as a third monitoring well.   This
well served as a domestic water supply and had been contaminated
earlier by discharges from the dump site.

     Installation of the two monitoring wells on the Company's
property took place in February 1973.  Although analytical
results showed contamination, they were not considered satisfactory.
Wells were not properly sealed and the water in them was believed
to be contaminated with surface runoff or overflow of high  waters
in the stream.  Thus, the results were considered inconclusive.

     Surface water monitoring at the site was very limited  during
cleanup.  Grab sample analysis of lagoon wastewater, the marsh
opposite the dump site, and the tributary by the consulting
engineer using infra-red analysis techniques indicated the
presence of hydrocarbon groups, such as petroleum residues, sul-
fur oxide, organic compounds, and substituted aromatic organic
compounds.

     The second phase of surface and ground water monitoring
began in 1977 after indications of a redeveloping pollution
problem.  Ground water contaminated- with—o-i-l-s- and-ehem4-e-a4-s
continued to seep from the north bank of the former lagoon  and
collect in  pools where the fill had not been properly graded.
Seepage into the marsh opposite the road and probable contamination
of the tributary led to renewed monitoring— of-the--d-ump -site.  T-he
dump site was ordered by State and County officials to be placed
on a regular monitoring and inspection schedule to determine the
degree of contamination of the tributary and perennial stream.

     Results of samples taken in 1977 and 1978 show low levels
of contamination to the surface water although the tributary
contained an orange color during warm periods of the year.
Several ground water samples  likewise showed low levels of
contamination.  Chemicals found in the water samples included
those disposed of at the dump site,  including xylene and benzene.
In addition, polychlorobiphenol  (PCB), a chemical used as an
electrical insulator and a suspected cancer agent, was found
in low concentrations escaping from  the site.

     Following additional sampling in the stream, it was decided
that sediment samples from the Lake  should be collected since
PCB's were more apt to be detected in the sediments rather than
in the water.  Analysis of these samples showed PCB's (Aroclor 1260)
in  the  Lake although not at extremely high levels.  It was also
decided   that fish samples would be  analyzed.

     In the spring of 1979 fish  samples were collected" in the
 Lake.   These  samples
 Large  Mouth Bass and
showed levels of 19.23 mg/kg of PCB's in
63 mg/kg in samples of American Eel.   Samples
                                81

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from a lake 10 km (6 mi) downstream showed the Large Mouth.Bass
to be less than 5 mg/kg.  American Eel  samples showed PCB levels
of 6 mg/kg.  In comparison, the PCB level  guideline set by the
U.S. Food and Drug Administration (FDA) is 5 mg/kg.  As a result
of the PCB levels found in the samples, the State Health Depart-
ment warned residents against consuming fish in the Lake during
November 1979 (a written advisory was not  issued until  May 1980).

     Although the high levels of PCB's  in  the Lake were a good
indication that the dump site was the probable source,  the origin
could not conclusively be determined without further investigation.
Plans developed in November 1979 were to take additional surface
and ground water samples from the tributary and perennial stream
because officials thought the PCB's could  be related to old
leakage rather than new leakage.  In addition, other sources  of
pollution could be involved including waste oil spreading
activities on roads.  Plans also called for the gathering of
contaminated fish samples, as well as additional samples of
sediment and the invertebrates which dwell on the Lake  bottom.
It was felt that sampling should be done in the quiescent areas
of the Lake to determine how widespread the PCB's. were  on the
Lake bottom.

     In November 1979, hundreds of samples were taken from the Lake,
the perennial stream, the tributary pond,  and the swamp next  to
the dump site.  Water samples from the  swamp showed extremely
high levels of PCB's.  However, fish from  the perennial stream
and Lake had lower concentrations than  those taken in April  1979.
Fish taken from the perennial stream, regardless of species,  had
a PCB concentration in excess of 5 mg/kg and most fish  from the
Lake had PCB concentrations between 2 mg/kg and 5 mg/kg.  The
reason may be due to periodic flushing  of  the swamp.  During
periods of low flow such as the Fall, PCB's accumulate  in the  swamp.
Then in the Spring or at other times of high runoff, PCB's are
flushed out of the swamp into the tributary and perennial stream
down to the Lake.  Results of the April and November samplings
are given in Appendix 4-1.

     After the discovery of PCB's in fish, ground water from  15
wells was tested, including wells near  the Lake and in  the higher
elevations near the dump site.  Benzene, toluene, and xylene
were found in a 19.5 m (65 ft) deep drilled well located along
the road 180 m (600 ft) west of the dump site.  Tests indicated
the presence of 15 to 20 ppb benzene, versus the ground water
standard of 5 ppb.  This was the first  indication that  the wastes
at the dump site were entering the ground  water.  The other 14
wells did not show excessive benzene levels.

     To allow additional ground water monitoring in the immediate
vicinity of the site, four monitoring wells were proposed in
December 1979.  The wells were installed in February 1980.
                               82

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Preliminary analysis indicates  that Wells  B-2,  B-3,  and  B-4
down-gradient from the dump site show ground  water  contamination.
Monitoring Well  B-l  up-gradient from the dump site  shows  no
ground water contamination indicating that the  dump  site  is
the probable source of the ground water contamination.

CONCLUSION

     Although problems at first were minimal, conditions  at  the
site are growing steadily worse.  The primary reason is  that
ground water is  seeping through the very permeable  fill  material
and is being contaminated by waste
In addition, the severe winters in
the situation.   It is evident that
effective and should not have been
approach wou.ld have been to remove
buried drums  and contaminated soil
to an approved landfill.
               leaking  from corroded  drums.
               the  late 1970's  have aggravated
               the  remedial  action was  not
               permitted.   A more positive
               all  pollutants,  including
                and water  from  the dump site
     From laboratory analyses and the background history of the
dump site, the following can be concluded about the recent
problem of pollution in the Lake and streams:   (1) the PCB
problem in the Lake has developed over a period of several
years and the most recent data indicates that  a relatively small
periodic discharge of waste is occurring from  the dump site; and
(2) PCB analyses of
the Lake originated
the various samples
from the dump site.
indicate the PCB's in
     Based on the evidence of ground and surface water pollution
and also the deteriorating site conditions, State and County
officials have concluded further investigation will be necessary
to conclusively determine what course of remedial action will  be
necessary to abate the pollution problem.  To further identify
the hydrogeologic condition of the site, field checks including
geophysical studies and a more extensive drilling program have
been suggested to substantiate existing data.  This data will
give additional insight into what types of remedial action
should be undertaken.  Remedial actions considered for the
future have included the following:

     1.  Capping the lagoon with an impervious layer of fill
         and improving the grading of the existing fill to
         prevent seepage.

     2.  Installing impervious cutoff walls around the dump
         site through 6 to 9 m (20 to 30 ft) of gravel to a
         layer of glacial till below to prevent runoff and
         leachate from reaching the watershed.

     3.  Lowering the flow of ground water into the tributary
         by installing a subdrain or French drain.
                                83

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     Concern over the cost of•investigative studies and remedial
actions is a problem.  Possible  recovery of these cost through
enforcement action and assessment of appropriate civil penalties
are among the suggestions.  The  original court order issued to
the Company to close the site can probably be used to order the
necessary corrective action.  In addition, the industries
disposing of their wastes at this site may be requested to pay
for a proportionate share of the site cleanup or face possible
legal action.  If these fail, a  special  remedial
available at the Governor's direction could be
the cleanup.
  action fund
used to finance
                               84

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              SITE C REFERENCES AND BIBLIOGRAPHY
4-1   Personal  communication and file review with David Knowles,
     Department of Conservation, Albany, New York.   June 1980.
                               85

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          APPENDIX 4-1

WASTE DISPOSAL COMPANY SAMPLING
    (1975-1979) FOR SITE C
                  !£

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            WASTE  DISPOSAL  COMPANY  -SAMPLING
 DATE
                TYPE OF SAMPLE
                                              PARAMETER
                                                                  RESULTS
South Side Drainage  from  Dump Site (Reaching Lake)
 11/20/79   Aquatic Organisms
Waste Disposal Company Dump  Site
3/8/79     Water .(Leachate)
           Center" of Fill  Area


Dump Site - Outlet from Site
9/26/75    Water
6/9/77

6/10/77
Water (Leachate)
Water (Leachate)
4/17/78'
           Water
6/29/79    Water


Swamp - North  Side of Road at Dump Site

11/20/79   Aquatic Organisms
                                        Hydroph1l1d bettle (22)
                                        PCB 1016
                                        PCB 1254
                                        PCB 1260

                                        Fingernail clam
                                        (Approximately 100)
                                        PCB 1016
                                        PCB 1254
                                        PCB 1260

                                        Caddisfly larvae (35)
                                        PCB 1016
                                        PCB 1254
                                        PCB 1260
                             Benzene
                             Toluene
                             Xylene
PCB 1016
PCB 1254

Phenols
Toluene
Xylene
Benzene
1,1 ,1-Trichlorqethane
TrlchloroethyTene
Tetrachloroethyl ene
Chloroform
Carbon tetrachloride
Bromodichloromethane
PCB 1254
PCB 1221

1 ,1 ,1-Trichloroethane
Carbon tetrachloride
Bromodichloromethane
Chloroform
Trichloroethylene
Tetrachloroethyl ene
COD
Arsenic
Si-lver
Cadmium
Chromium
Copper
Lead
Mercury
Zinc

PCB 1016
PCB 1254
                                        Dytiscide  bettle  (15)
                                        PCB  1016
                                        PCB  1254
                                        PCB  1260
                                        Giant  water  bug (5)
                                        PCB  1016
                                        PCB  1254
                                        PCB  1260

                                        Caddisfly  larvae
                                        (Approximately 25)
                                        PCB  1016
                                        PCB  1254
                                        PCB  1260
                                                      ND
                                                      ND
                                                      2.43 mcg/g
                                                      ND
                                                      ND
                                                      0.20 mcg/g


                                                      ND
                                                      ND
                                                      0.78 mcg/g
                          >1,000  mcg/1
                          >750 mcg/1
                          >750 mcg/1
 < 0.25 mcg/1
 < 0.25 mcg/1
0.046 mg/1

 < 10 mcg/1
ND
 < 10 mcg/1
 < 5 mcg/1
 *"& mcg/T
 < 2.5 mcg/1
 < 5 mcg/1
 <5 mcg/1
 <5 meg/1
1.5 mcg/1
                                                       <0.02 mcg/1
                                                       <5 mcg/1
                                                       <5 mcg/1
                                                       <5 mcg/1
                                                       <5 mcg/1
                                                       <5 mcg/1
                                                       .<2.5 mcg/1
                                                      7" mg/1
                                                       < 0.02 mg/1
                                                       <0.02 mg/1
                                                       <0.02 mg/1
                                                       .<0.1 mg/1
                                                      0.05 mg/1
                                                       <0.1 mg/1
                                                       <0.0004 mg/1
                                                       <0.05 mg/1

                                                       <0.25 mcg/1
                                                       < 0.25 mcg/1
                                                     ND
                                                     ND
                                                     186.64 mcg/g

                                                     ND
                                                     ND
                                                     10.76 mcg/g
                                                     ND
                                                     ND
                                                     65.64 mcg/g
                                    87

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WASTE  DISPOSAL  COMPANY  SAMPLING  (continued)
DATE
60 m (200
11/7/79

TYPE
ft) West of
Water
OF
SAHPL
.1
Dump Site
PARAMETER
Benzene
Toluene
Xvlene
RESULTS
< 1
< 1
< 1
mcg/1
mcg/1
mcg/1
           Perennial Stream and Tributary Junction

           11/7/79    Fish
           11/20/79
            Pond

            11/21/79   Aquatic  Organisms



            I1/2V/79   Aquatic  organisms
                                                 Gasoline,  kerosene,
                                                  lubricati ng  oil,
                                                  fuel oil
Wite Sucker  (3)
PCB 1260
Blacknose  dace  (4)
PCB 1260
Tesselated darter (1)
PCB 1260
Longnose  dace  (2)
PCB 1260
Creek chub (8)
PCB 1260
Creek chub (1)
PCB 1260
Creek chub (4)
PCB 1260
Fallfish   (2)
PCB 1260
Fallfish  (2)
PCB 1260
White sucker (6)
PCB 1260

White sucker (4)
PCB 1260

White sucker (2)
PCB 1260
White sucker (2)
PCB 1260
Crayfish  (O.limosus  2)
PCB  1016
 PCB  1254
 PCB  1260
 Dragonfly nymph (6)
 PCB  1016
 PCB  1254
 PCB 1260
 Caddisfly larvae (36)
 PCB 1016
 PCB 1254
 PCB 1260
 Isopods  (Apx.100)
 PCB 1016
 PCB 1254
 PCB 1260

 Cranefly larvae  (23)
 PCB 1016
 PCB 1254
 PCB 1260
ND




10.89 mcg/g

23.55 mcg/g

30.26 mcg/g

28.97 mcg/g

5.22 mcg/g

14.1 mcg/g

5.35 mcg/g

9.43 mcg/g

8.92 mcg/g

19.10 mcg/g


15.34 mcg/g


16.67 mcg/g

16.71 mcg/g

ND
ND
2.54  mcg/g

ND
ND
1 .98  mcg/g

 ND
 ND
 0.93  mcg/g
 0.63 mcg/g
 1.23 mcg/g
 ND

 0.34 mcg/g
 0.84 mcg/g
 ND
                                                88

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WASTE DISPOSAL COMPANY SAMPLING (continued)
DATE TYPE OF SAMPLE
Perennial Stream - Between Lake and
11/7/79 Fish















11/20/79 Aquatic Organisms







Perennial Stream
11/19/79 Domestic -Duck
11/20/79 Aquatic Organisms



—







Inlet to Lake
11/20/79 Aquatic Organisms







East Side of Lake
11/14/79 Water
11/14/79 Water
11/16/79 Water


West Side of Lake
11/16/79 Water


	 	 PARAMETER 	
Tributary
Brown Trout (2)
PCB 1260
PCB 1260
White. sucker (4)
PCB 1260
White sucker (7)
PCB 1260
White sucher (3)
PCB 1260
White sucker (1)
PCB 1260
Fall fish (1)
PCB 1260
Fallfish (7)
PCB 1260
Pumkinseed (1)
PCB 1260
Caddlsfly larvae
PCB 1016
PCB 1254
PCB 1260
Cranefly larvae
PCB 1016
PCB 1254
PCB 1260

PCB
Crayfish (0. 1 imosus ) (4)
PCB 1016
PCB 1254
PCB 1260
Cranefly* larvae (13)
PCB 1016
PCB 1254
PCB 1260
Helgrammite larvae (8)
PCB 1016
PCB 1254
PCB 1260

Crayfish (0. 1 imosus ) (1)
PCB 1016
PCB 1254
PCB 1260
Cranefly larvae (10)
PCB 1016
PCB 1254
PCB 1260

Benzene
Toluene
Xylene
Benzene
Toluene
Xylene
PCB
Mi rex


PCB
Mi rex

RESULTS 	 	


10.85 mcg/g
0.31 mcg/g

2.63 mcg/g

2.4 mcg/g

7.01 mcg/g

0.25 mcg/g

3.87 mcg/g

7.39 mcg/g

0.66 mcg/g

ND
ND
ND

ND
ND
1 . 96 mcg/g

Awaiting Results
ND
ND
0.34 mcg/g

ND
ND
0.98 mcg/g

ND
ND
1 . 93 mcg/g


ND
ND
3.72 mcg/g

ND
ND
1 0.69 mcg/g

<1 mcg/1
<1 mcg/1
<1 mcg/1
'
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WASTE  DISPOSAL COMPANY  SAMPLING (continued)
DATE
Lake
2/8/79



4/24/79

TY-PE OF SAMPLE

Sediment
61 m (200 ft) from Inlet
Sediment'
122 m (400 ft) from Inlet)
Sediment
183 m (600 ft) from Inlet
Sediment •
61 m (200 ft) behind Dame
at Outlet
Fish

PARAMETER

PCB 1221
PCB 1016
PCB 1254
PCB 1260
Mirex
PCB 1221
PCB 1016
PCB 1254
PCB 1260
Hi rex
PCB 1221
PCB 1016
PCB 1254
PCB 1260
Mirex
PCB 1221
PCB 1016
PCB 1254
PCB 1260
Mirex
Largemouth bass(2)
PCB
'DDT
American Eel (20
PCB - Average
(Range)
DDT - Average
(Range)
RESULTS

<0.01 mcg/g
0.02 mcg/g
<0.01 mcg/g
0.3 mcg/g
<0.01 mcg/g
<0.01 mcg/g
0.02 mcg/g
<0.01 mcg/g
0.5 mcg/g
<0.01 mcg/g
<0.01 mcg/g
0.01 mcg/g
'<0.01 mcg/g
0.4 mcg/g
"<0.01 mcg/g
<0.001 mcg/g
<0.001 mcg/g
<0.001 mcg/g
0.01 mcg/g
<0.01 mcg/g
19.23 ppm
07TT ppm
45.27 ppm
33.57 to 62.82 ppm
0.29 ppm
0.19 to 0.35 ppm
        ND = not detectable
                                  90

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   APPENDIX 4-2



SITE C PHOTOGRAPHS
        91

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Aerial photograph of the dump site  (1966),
       The waste oil pit  (1966).
                   92

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Overview of the drum burial  area (1966),
      Bank of the lagoon (1966).
                     93

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       Overview of  the site  in June  1980,
 ,y3j3F.
 V,\*e --•• '  -i
 a	•1-|«*»™«;y>*, ,


 tZ^&#•*.- '

 ru*"";	m "y;; • &	
 t'»t*," --tit *₯ "'""LS™"' '•* '
 ^ *w * -Js- ^
       ':^---    ".  •;.;


               - ?~r                         ..
Ground  water  seep from  the bank  of the  former

lagoon  (1980).
                         94

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                           SECTION 5

                             SITE D
                       DESTRUCTO/CAROLAWN
                  KERNERSVILLE, NORTH CAROLINA
INTRODUCTION

     The Destructo Chemway Corporation and Carolawn Company, Inc.
incinerator and drum storage site is located near the Town of
Kernersville in North Carolina.  In June 1977, while the facility-
was managed by Destructo, a chemical spill,from the site contami-
nated Kernersville Lake/Reservoir which had served as the primary
drinking water source for the Town of Kernersvi.il e.
     Ninety to
Reservoir were
evacuate their
99 percent of the fish in the 20.2 ha (50
killed and over 200 people were forced to
homes.  Fuel  oil
dichloroethane, trich1 oroethane,
propane were later identified in
that time, Kernersville Lake has
water supply, although analyses of
that toxic chemicals are no longer
                        ac)
                        temporarily
toluene, ally!  ether, xylene,
and 2-methyl-l, 3-diallyloxy
the Reservoir's water.  Since
not been used as a drinking
  water samples have indicated
  present in the Reservoir.   The
State of North Carolina has refused to approve the use of the water
as long as a chemical disposal facility remains located within the
Reservoir's watershed.

     Carolawn began  using the site after Destructo went bankrupt
in 1978.  Carolawn operated as a waste storage and transfer
facility rather than  a treatment/incinerator facility.  In late
1979, the Town of Kernersville succeeded in forcing Carolawn to
vacate the site.  However, about 273 m3 (72,000 gal) of chemicals
were left behind when Carolawn vacated the facility.

     Emergency cleanup measures initiated after the Destructo
spill included (1) deploying  a boom on a tributary to  the
reservoir, (2) placing sorbent material in the ditch from the
Destructo/Carolawn site to the above tributary, (3) use of an
underdrain spillway,  (4)  excavation of contaminated soil,
 (5)  removal of dead  fish,  (6) placement of contaminated cleanup
matervaj in a line.cLp.it on the property, and (7) . instal 1 ation of
d'ikes around the tanks.   This emergency cleanup activity was
jointly  funded by the U.S. Environmental Protection Agency  (EPA),
the  Town of Kernersville,  and the  State of North  Carolina.

     Subsequent  remedial  activities associated with the Carolawn
operation were funded by-  the  property  owner: Brenner Shredder,
 Inc./United Metal Recyclers.  When  Carolawn abandoned  the leased
 property  in early 1980, Brenner contracted Browning-Ferris,  Inc.
                                95

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 (BFI) to remove the waste and  r'egrade the  s.ite.   Presently, the
 State believes the site has been  improved  to a reasonable degree,
 although some soil contamination  remains on-site.  State approval
 of future use of Ker.nersville Lake as a drinking water source will
 be based upon surface water and ground water monitoring to be
 performed in the future.

 SITE DESCRIPTION

     As shown in Figure 5-1, the  Destructo/Carolawn site is located
 in north-central North Carolina to the west of the Town of
 Kernersville.  The annual precipitation in the area is 118 cm
 (46.6 in.) and the annual snowfall is 148  cm (58  in.).  The
 average wind speed is 12 kph (7.6 mph).  The average daily
 high temperature is 15°C (55°F-) with the highest  daily maximum
 occurring in July at 31°C (88°F), and lowest in January at
 -1.7°C (29°F).

     Little  detail is known about the geology of  the site due to a
 lack of sufficient boring logs.   No rock outcrops appear within
 the general  vic4ni ty.-af~th-e-_si-te-_  Xke, .sJJieL Is. LacjLtM a±Q_£
 granite gneiss and schist bedrock of the Charolette Belt and
 the soils are estimated to be  3.0 to 4.6 m (10 to 15 ft) deep.
 The soil is  a fine sand and loam with a high  permeability of 5
 to 15 cm/hr  (2 to 6 in./hr).   Starting from the ground surface
 the soil stratification is as  follows:  silt, clay, silt, and
 sandy silt.

     The site lies on two terraces.   The upper terrace is to the
 south of the property, next to Highway 66.  The pit excavated by
 the U.S. EPA during the spill  lies in the  southeast corner of
 the propery  in the upper terrace.  This pit area  would tend to
 drain toward the south, _away from the Kernersville Lake.  The
 lower terrace housed the old incinerator,  two storage tanks, and
 0.21  md (55  gal) drums.  The lower terrace to the north of the
 property  and part of the upper terrace drains toward Kernserville
 Lake (see Figure 5-2).

     The seasonal  high water table is estimated to be between
 1.8 to 10.4 m (6 to 34 ft) deep.  Springs appear  at a lower
 elevation northwest of the site, and these and other springs
 feed Kernserville Reservoir.

     Kernersville Reservo.ir has a' 435,275 m3 (115,000,000 gal)
capacity and was used as  the primary drinking water source for
the Town of Kernersville  prior to the spill of 1977.   Drainage
 from the Destructo/Carolawn facility enters an unnamed tributary
about 2.5 km (1.5 mi) above the Reservoir and drains  northward to
the Reservoir.   Kernersville Reservoir is man-made and has an
earthen and concrete dam  with a spillway at the southeastern end.
Two surface streams and three undergound springs  feed the
                               96

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Figure 5-1.   Site layout of Destructo/Carolawn,site.  [5-1]
                           97

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                               KERNERSVILLE LAKE
                                   DESTRUCTO/CAROLAWN
Figure 5-2.
Drainage pattern  of Destructo/Carolawn
      site.   [5-2J
                          98

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Reservoir.   The Town of Kerner.svi ] le requires  about 0.06 m3/sec
(1.3 mgd)  of water.

SITE OPERATION  AND HISTORY

     Destructo Chemway, Inc.  began  operating an industrial  waste
incinerator in 1974 under an  air quality permit issued by
Forsyth County.  Approximately 1.6 "ha (4 ac) belonging to Brenner
Shredder,  Inc./United Metal Recyclers was leased by Destructo
to house their facility.   Brenner operates a metal  recycling
operation  on the property immediately adjacent and  northeast
of the Destructo site (see Figure 5-1).
     During the site's active
incineration were transported
from industrial customers.  A
(1,500 gal) capacity was used
the Destructo site.  Once the
                              years,  liquid wastes suitable for
                              to the  Destructo facility by truck
                              tank truck of approximately 5.7 m3
                              to transport the liquid waste to
                              waste had been transported to the
site, the liquid waste was segregated according to its BTU value
in five large storage tanks.   The waste was then transported
via PVC pipe to two tanks adjacent to the incinerator.  The
storage tanks had capacities  of 11 and 64 rn3 .(3,000 to 17,000
gal).  Small quantities of commercial fuels were used to
staVt up the incineratoV.  There were no cTTkes around tTie
storage tanks, nor was there  any form of secondary containment
to contain spills.  Likewise, the valves on the tanks could be
opened by pulling a lever, since no locks had been installed.

     According to the Destructo Plant Manager, the plant had
originally been set up by Chemwaste Corporation (a division of
Brenner) and had operated since 1974 without incident.  When
Destructo purchased the equipment from Chemwaste, it was agreed
that the equipment would be moved to a more suitable location
(outside the watershed), and  that the new installation would be
properly engineered with containment dikes around all tanks. [5-3]
Neither of these conditions were met during Destructo operations.

     After the spill of June  3, 1977, Destructo went bankrupt
and Carolawn Company, Inc. took over the operation of the site
in early 1978.  Although company officials claimed that Carolawn
was a different company, the  State of North Carolina questioned
the non-association, since Carolawn retained some of Destructo's
officers.   In early 1980, Carolawn vacated the site, leaving behind
chemicals in corroded 0.2  m3 (55 gal) metal drums.  It is now
believed that during Carolawn's active days, the facility was
used more for storage and transfer than treatment, and that wastes
were usually received in 0.2  m3 (55 gal) drums, rather than in
bulk tankers.  Little is known concerning the actual operation of
Carolawn since books (which were reportedly kept) coujd not be
located.  Thus, the type, quantity, and source of the^ wastes is
not  known.  About 91 metric tons  (100 tons) is reported to have
                                99

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 been processed at this site through 1978.   It is  believed the
 Company operated with limited capital  and  that once the State
 prohibited further waste receipts,  the Company had insufficient
 funds with which to perform cleanup activities.

      When Brenner and the Town of Kernersville requested that
 Carolawn discontinue waste receipts and cleanup  the site,  Carolawn
 showed an initial  interest in complying with  the  requests,  but
 later abandoned the site.  During this initial  interest period,
 Carolawn was  constructing a waste disposal  plant  in Fort Lawn,
 South Carolina about 72  km (45 mi)  southwest  of  Charlotte,  North
 Carolina.   Approximately 80 drums had  been  transferred  to  South
 Carolina from the  Kernersville site, when  South  Carolina prohibited
 further transfer of wastes to the Fort Lawn site.   Carolawn  had
 proposed to  establish an incinerator in Fort  Lawn  to  incinerate the
 wastes.  However,  when the State  of  South Carolina  became aware of
 their poorly  managed/supervised  operations  at  Kernersville,  it
 began regulating  their Fort Lawn  operations more  closely.
 Carolawn subsequently abandoned  the Fort Lawn  site,  leaving  behind
 thousands  of  gallons  of  waste.

 POLLUTION

      Problems  associated with the Destructo-Carolawn  site  generally
 have  occurred  in  two  phases.  The  first phase  consisted  of  actual
 pollution  of  the  Reservoir by the chemical  spill  of June  1977.  The
 second  phase  consisted of a threat  of  surface water pollution due
 to the  Carolawn waste storage and transfer operation.

      On  June  3,  1977,  between 9 and 11  p.m., vandals entered the
 facility grounds and  opened the valves  on six storage tanks.  The
 released chemicals  flowed  down a  slope  in a culvert, then through
 a dry  ditch for about 0.4  km  (0.25  mi), thence into an  unnamed
 tributary, before  entering  the Kernersville Reservoir.
     Table 5-1 provides general information on storage
and waste material housed in the tanks associated with
capacity
the spill
Figure_5-3 displays De'structo's layout and the northwest flow
direction of-spilled liquid wastes.  According to the officials
of Destructo, Tanks 33 and 101 contained water contaminated with
small amounts of alcohol, ketone, and toluene from Xylo Graphics
Company.  Tank 34 contained a mixture of ally! ether and water
reportedly from Proctor Chemical Company.  Tank 91 contained allyl
ether (from which most of the water had been removed) reportedly
from Gravely-Roberts Company, Tot Screen II, and Proctor Chemical.

     A_strong chemical odor (possibly ether) was present during
the spill.  Due to the unknown nature of the spill  and the  unusual
odor, approximately 200 people were evacuated from the immediate
area of the spill.  During the excavation of the contaminated
debris and soil  and reservoir cleanup,  23 men were hospitalized
with eye irritations.
                              100

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  TABLE  5-1.
              STORAGE OF WASTE MATERIALS AT DESTRUCTO
               CHEMWAY CORPORATION  [5-4]
Tank
No.
33
34
81
91
101
171
Total
Available
Capacity
(m3)
11
11
30
34
42
64
192
Quantity Discharged
Oily Water
(m3.)
10.1
3.3
18.3
40.7
72.4
Oil
(m3)
18.6
18.6
Ether
(m3)
3.1
,0.3
6.7
12.4
22.5
Total
(m3)
10.1
6.4
0.3
25.0
40.7 .
31.0
113.5
m
i3 = 264.2 gal
                            101

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                                                x-
                        INCINERATOR
                       n
                      I TANK 42
     Tanks that contributed to spill.
Figure  5-3.  Tank location and  flow direction of
      1977 spill  at Destructo Chemway.     [5-5]
                          102

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     Two days after the spill  on June 5,  an extensive fish kill  in
the Reservoir began.   The bottom-feeding  catfish and carp were
the first to be affected .by the spill.   By June 6,  an extensive
number of bottom-feeders died.   On June 7, the fish kill  continued
with all but the bass dying, and by June  8, even the bass had
died.  The State Wildlife Resources Commission reported a 90 to
99 percent fish kill  amounting to several  tons.  Prior to the
spill, the Reservoir was reported to have had a balanced  population
of yellow perch, sun fish, pumpkinseed, bluegills,  and bass.  A
total of 16 different species including shell crackers, warmouths,
yellow perch, and bass died due to the contamination.. The
chemical later identified as likely causing the fish kill was
2-methyl-l, 3-diallyloxy propane; however, not enough data was
taken to show the mechanism of the fish kill.  .
                                                       /
     Samples of the reservoir water analyzed by U.S. EPA
revealed the presence of fuel oil, toluene, ally! ether,  xylene,
dichloroethane, tri ch/1 oroethane, and 2-methyl-l, 3-diallyloxy
propane.  Prior to the fish kill, the U.S. EPA believed that the
chemical spill would not be soluble in water and that 20 percent
of the chemical spill would be adsorbed into -the- grouncUa-S— the.  _
spill ran along the ditch.  O.nce the fish began dying and additional
tests were conducted, it became evident that the material had
become water soluble and that possibly some had later settled
out to contaminate the floor of the Reservoir.  As  a result of
the fish kill and analytical evidence, the Reservoir was declared
by the State Health Department to be unsuitable for use as
drinking water.

     As a result, the Town shifted to alternate water supplies,
obtaining approximately  40 percent of its water demand from the
Winston-Salem/Forsyth system and 60 percent from an old supply
lake.  Water obtained from these two sources met only 67 percent
of Kernersville1s daily  demand.  Therefore, curtailment of water
useage was necessary while connections were made to the adjacent
town to provide the total water flow.  Two textile mills in the
area had to pay for delivery of
modifications to conserve water
two mills was cut by 90  percent
working hours resulted from the
Corporation, one of the  textile
via private wells.  Meanwhile,
a pipeline improvement project
from the Winston-Salem/Forsyth
 water via tankers and for process
   The water consumption at the
 and layoffs and cutbacks in
 water shortages.   Adams-Millis
 mills, now receives its supply
a temporary pumping station and
has increased the  flow of water
system.
      In 1978, Destructo vacated the site, with Carolawn taking
over  operations.  Since that time, the North Carolina Division of
Health Services has continued to test the water at the Reservoir
and has found it to be within drinking water standards.  Within
14 days of the spill, schools of newly hatched fish  (golden
shiners) were seen in the Reservoir and no second fish kill has
                               103

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been observed since.  This evidence pointed toward the volatile
nature of the toxic material.  By October 1977, water samples
showed that the concentration of all chemical  compounds discharged
from the Destructo facility were at less than  detectable levels.
In spite of this data indicating that resumed  use of the Kernersville
Reservoir as a drinking source was acceptable, the North Carolina
Department of Health has refused to approve the use of the water
as long as a chemical disposal plant remains located in the
watershed near the Reservoir.  Therefore, the  problem associated
with the operation of Carolawn at this site has involved the
"threat" of pollution (not pollutfon itself).from the storage
of waste chemicals within the Reservoir's watershed.
     Brenner officials terminated Carolawn's lease
requiring that they vacate the site within 30 days,
departed from the site between August and November
behind their plant, equipment, and chemical  wastes,
                          in July 1979,
                            Carol awn
                          of 1-979,  leaving
                            The wastes
left behind included lubricating oil, waste oil, waste paints.
printing inks, and halogenated and non-halogenated solvents.
Waste generators were reported to have included Monsanto,  Dupont,
Mobil Chemical, Piedmont Publishing Company, and Kingsport Press,
The general characteristics of the abandoned wastes included  the
following categories:  corrosive, toxic,  ignitable, reactive,
highly volatile, and flammable.  Records  reportedly
kept by Carolawn, but were not available  for review.
left behind posed the following pollutant hazards:
                           had been
                             The wastes
     1.  Potential for runoff into the Town Reservoir.

     2.  Potential contamination of the food chain due  to runoff.
     3.  Potential for fire.

     Although earlier reports had indicated
(12,,000 gal) of chemical wastes remained at
                   that only 45 m3
                   the Kernersvilli
Plant, it was later determined that 2,461  drums and 272.1  md
(71,880 gal) of chemicals in tanks (see Table 5-2)  were left at
the site.  It is this waste which must be  removed before the
North Carolina Department of Health will  approve use of the
Reservoir for drinking water purposes.

REMEDIAL ACTION

     As a result of the spill  of 1977, the following corrective
actions were instituted:
     1.   A floati ng boom
         deployed at the
         the Reservoir.
containing sorbent materials was
mouth of the unnamed tributary into
         A large underflow siphon
         stream junction to allow
         dam was installed at the
         the lower zone of water to
                              104

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TABLE 5-2.   CAROLAWN'S INVENTORY AS  OF
            JULY 31,  1978.   [5-6]
Tank
No.
Observed
Vol ume
Actual Volume
(m3)
 33
 34
'41
 42
 81
 91
101
102
171

Total
 Full
 Full
, 1 m-h-igh
 Full
 Full
 Full
 Full
 Full
 Full
12.
12.
 8.4
15.7
29.0
36.9
41.3
48.8
66.6
                272.1
                     105

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      3.
     4.
     5.
     6.
 flow  into the  Reservoir.   Later the siphon dam was
 modified with  the addition of a blanket of peat moss
 to assist in the removal of dissolved organics.  A
 catch basin and siphon dam were also installed at the
 road  culvert as it exits the property.

 Two straw barriers were constructed downstream from
 the source of  the spill.   However, only a small
 quantity of oil had accumulated behind the barriers
 indicating that most of the spilled material  passed prior
 to the barrier construction.
Approximately 906 m3 (32,000 ft3) of contaminated soil
was removed from the drainage swale leaving the site.
Debris was also removed from the dry wash area.
was likewise excavated around the spilled tanks
to 2.4 m (8 ft) deep.
                                                          Soil
                                                         up
A landfill site 30 m x 30 m x 1.5 m (100 ft x 100 ft x
5 ft) was excavated on the upper terrace at the southeast
corner of the facility site.  The excavated pit was
lined with 0.15 mm (6 mil) polyethylene plastic.
Contaminated soil, debris, dead fish,  and sorbent
materials were placed in the pit with  intermittent
layers of agricultural lime.  The filled pit was
subsequently sealed with a, 0.15 mm (6 mil) layer of
plastic and with a layer of clay to prevent infiltration
of precipitation.

The liquid from the two dams and  from  depressions along
the creek bed were removed and stored  in Tanks 81 and 91.
About 150 mj (40,000 gal) of solvents  stored in bulk
tanks at the site  were removed.  Approximately one-third
of the chemicals were removed from the site for
incineration.  Additionally, Industrial  Marine Service
from Norfolk, Virginia was contracted  to remove oil
and sorbent materials from the Reservoir.   A dike and
other safeguards were provided to prevent remaining
chemicals from causing further contamination.
     The principal action instituted during
of attempts to contain the spilled material
migration to the Reservoir.  Initial visual
Reservoir indicated that the measures might
in containing the contaminant which at that
be ally! ether and 75 percent oil  and water.
and the fish kill identified other organic
                                   the spill  consisted
                                   to prevent its
                                   inspection of the
                                   have been  successful
                                   time was  reported  to
                                     Subsequent  analysis
                                  substances  and
2-methyl-l, 3-diallylexy propane which had rapidly dispersed
over the Lake.  Since the spill, the fish population has  been
returning to the Reservoir and no second fish kill has been
observed.  Laboratory analyses likewise reveal  that the
contaminants have decreased to non-detectable levels.
                             106

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     During the spill,  a mobile bioassay laboratory,  analytical
laboratory, and pilot treatment plant were used to  determine  if
the Kernersville Wastewater Treatment Plant could  be  modified
to use activated carbon in its treatment sequence.  The  concen-
trations of the toxicants were significantly reduced  following
carbon filtration.   However, in fish mortality tests  performed
subsequently, some  mortality did occur even though  chemical
analyses had failed to  find the toxicants at detectable  levels
in the carbon-filtered  water (see Table 5-3).

     About $60,000  in U.S. EPA funds, $23,000  in Kernersville
funds, $6,000 in State  funds, and $25,000 in Fish  and Wildlife
Service funds were  spent during the cleanup plus an undetermined
number of man-hours required for cleanup activities.   The water
shortage after the  spill magnified the problem.

     Based upon the conditions at the site since the  spill  of
1977, further action became necessary before the people  of
Kernersville would  be allowed to resume use of the Reservoir for
drinking water.  The State of North Carolina Health Department
has insisted that the Town cannot safely begin using  the Reservoir
as long as a chemical waste disposal plant remains in the
watershed.  Therefore,  Brenner, under pressure from the  Townspeople,
began eviction of Carolawn in April 1979.  Carolawn's activities
were reported to have ceased at the site about August 1979.   In
a proposal contract of January 1980, Carolawn was  to  remove  all
equipment, waste inventory and drums, and Brenner  was to deposit
$32,000 in the North Carolina United Bank to be paid  to  Carolawn
upon completion of their corrective actions.  After removing
approximately 80-0.2  m3  (55 gal) drums, Carolawn  abandoned  the
site.   Five times as much waste was found on the property in
August  1979, as had been  reported earlier.  In August, it was
estimated that approximately 272 m3 (72,000 gal) of chemicals
were stored in large tanks on the property along with about
2,500-0.2 m3  (55 gal) barrels.  Since Carolawn abandoned the
site, the landowner pursued the cleanup activities by contracting
BFI to  remove the barrels, waste equipment, and the upper 15 to
30 cm (6  to 12 in.) of  soil.  BFI was  also to apply imported
soil to the site and grade and seed it.  This corrective activity
was completed during the  Summer of  1980.

     Barrels were segregated according to waste composition
prior to  removal.  The  landowner would not comment on the
remedial  activities of  the  site, but government officials
reported  that the major  portion of  removed waste (aqueous waste/
sludge) was  sent to BFT deepwell•injection and landfill  facilities
in Calcashieu and Livingston,  Louisiana.   Other waste   (aqueous
oil  and chlorinated waste)  was disposed  in a  BFI Baltimore,
Maryland  landfill and  a  small  portion of removed waste was  sent
to an SCA facility  in  Pinewood, South Carolina.  An estimate of
the  total  remedial  cost  funded by  Brenner  ranges from $250,000
to $500,000.
                              107

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       TABLE  5-3.   BIQASSAY  STUDY   [5-4]
Test
1



2



Fish and Water Type
Bluegill
Raw Lake Water
Filtered Lake Water
Control Water
Catfish
Raw Lake Water
Filtered Lake Water
Control Water
BUregill
Raw Lake Water (12 days
after spill)
Catfish
Raw Lake Water (12 days
after spill)
Survivability Count*
0 hr

100
100
100

100
100
TOO

100

100
24 hr

97
100
97

0
100
100

100

91
48 hr

83
97
97

100
100

100

91
72 hr

70
87
97

100
100

—

--
96 hr

63
87
97

80
100

—

—
120 hr

53
63
97

60
100

—

~
* Percent of fish surviving at time intervals shown.
                          108

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     One of the procedures used in removing the waste consisted
of withdrawing liquid waste from the 0.2  m3 (55 gal) drums and
transferring the liquid to a tank truck for transport to the
BFI Louisiana  facilities.  Empty drums were crushed and removed
along with contaminated soil from the site and likewise transported
to an acceptable landfill.  On June 23, 1980, as some of the
remaining drums were being crushed for removal, a 17-year-old
worker was sprayed as he was removing his protective face shield
18 m (20 yd) away.  Although thought to be empty, the drum
actually contained a 30 percent concentration of phenol.  All
efforts to revive the worker failed and the cause of death was
later reported to be dermal toxicity in which all nerve impulses
to the heart stopped.
     According to government officials, cleanup
    reasonably complete.  All  free chemicals (i.e.,
    sludge from a holding pond) have been removed.
    lower terraces have been graded and seeded with
    grass.  Contaminated material  remaining on-site
    top soil  layer and the spill  burial pit.  Soil
                                                activities  are
                                                    drummed waste
                                                    Both  the upper
                                                    wheat straw
                                                    consists of
                                                   samples
now
and
and
and
the
indicate so-il  contamination exists in s-ome area-s-at depths up to
50 cm (20 in.).   The pit containing contaminated spill  debris was
left intact.   The State plans to install  five monitoring wells
(two around the spill  burial  pit with one up-gradient  and one
down-gradient)  and three down-gradient from the entire Destructo/
Carolawn site.   Once surface  water runoff and ground water has
been adequately monitored, the State Solid and Hazardous Waste
Division will  submit a report to the State Water Supply Branch,
which will  make a determination on whether the Kernersville
Reservoir can  again be used for drinking  water.  If the ban on
water use is  removed,  Kernersville will  have the option to return
to their previous water source.
CONCLUSION

     Three years after 110 m3 (30,000 gal)  of chemicals  spilled  into
Kernersvi 1 1 e ' s drinking water supply, the
unused.   The State of North Carolina has
as a source of drinking water as long as
                                          Town's Reservoir remains
                                         banned use of the Reservoir
                                         the existing chemical
waste facility is located in the Reservoir's watershed.   The
equipment and waste were removed from the watershed by the land-
owners, and depending upon results from ground and surface water
sampling, the Town will soon have the option of resuming use of
the Reservoir.

     During the past three years, the residents have been sharply
divided over whether use of the 20.2 ha (50 ac) Lake/Reservoir
should resume (see Appendix 5-1).  The decision to resume use
of the Reservoir has become a heavily debated topic in the Town.
A letter to the editor of the \Kernersvi 1 1 e News of January 1980
exhibits the sensitivity of this volatile issue.
                              109

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     This site provides an example of an entire Town's acute
awareness of an environmental  issue.  The awareness was brought
about initially by the need of a portion of the Town to evacuate
their homes during the spill.   Citizens within the vicinity of
the Destructo site during the  spill  showed health-related effects
including nausea, vomiting, headaches,  and mucous membrane
irritation.  All  of the Townspeople  became aware of improper
management of	          '    --   -
became contaminated,
caused
              industrial wastes when the Town's water supply
                      Loss of the Town's drinking water supply
       inconvenience, loss of income (due to curtailments placed
on local industries), and loss of revenues from expected industrial/
business growth.  The recent death of a worker assisting in the
site's cleanup activities again highlighted the danger associated
with the site.

     Generally, weakness in the laws became evident to the people
of Kernersville with their battle to resume use of the water supply.
The involved governmental officials relayed that they had found
their past State regulations ineffective or inappropriate in
dealing with the management of hazardous materials.  Their laws
had not given them authority to remove a waste until  it became
an imminent hazard.  Under the laws' prior to 1980, the Destructo/
Carolawn site was a storage site, rather than a waste disposal
site.  Therefore, the State's Solid and Hazardous Waste Division
had no jurisdiction over the site.  This site was covered under
an air quality permit issued by the County; however,  the pollution
problem was that of water quality damage and endangerment.   With
each separate agency having its own jurisdictional limits,  it
was difficult for the agencies to respond quickly and effectively
to the problems surrounding the site.

     Some of the government officials  who are involved with the
Destructo/Carolawn incident believe that bureaucratic confusion
could^be overcome by giving authority  to one agency and one
individual  to coordinate environmental  affairs concerning air,
land, and water.  They believe that time delays and duplicated'
efforts could be avoided and the overall environmental  quality
enhanced.
                              110

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               SITE D REFERENCES AND BIBLIOGRAPHY
5-1   Clarification of aerial photo of 4/7/78, provided by North
     Carolina Department of Transportation, Forsyth County,
     North Carolina, City-County Planning Board, Winston-Salem,
     North Carolina.

5-2   Personal communication and file review with Russell Radford,
     Water Quality Section, Department of Natural Resources and
     Community Development, Winston-Sal em, North Carolina.
     June 11, 1980.
5-3  Jackson, Howard.
     Greensboro Daily
 "Another View of the Kernersville Spill
News.   September 7, 1977.
5-4  Stonebreaker, Jack, et al.   "Cleanup of an Oil and Mixed
     Waste Spill at Kernersville, North Carolina, June 1977".
     Proceedings of 1978 National Conference on Control of
     Hazardous Materials."  Miami Beach, Florida.  April 11-13,
     1978.  pp. 182-186.

5-5  Personal  communication and file review with Steve-Phibbs and
     Ernest Cain, Solid and Hazardous Waste Branch, Department
     of Human  Resources, Winston-Sal em, North Carolina.  June 11,
     1980.

5-6  Personal  communication and file review with William Meyer,
     Solid and Hazardous Waste Managemeirtr Br^arnctrr-Etepa-r-t-me-ni-Of
     Human Resources, Raleigh, North Carolina.  June 10, 1980.

5-7  Personal  communi ca-tion and report review with Edward Gavin,
     Enforcement Officer, Department of~Natu"raT~Resources and
     Community Development, Raleigh, North Carolina.  June 10, 1980,

5-8  Personal  communication with Jonathan Hale, Forsyth County
     Environmental Affairs  Department, Winston-Sal em, North
     Carolina.  June 19 and 23,  1980.

5-9  Personal  communication and file review with Joseph~~Yo-ung,
     Residuals Management Branch, U.S. Environmental Protection
     Agency Region IV, Atlanta,  Georgia.   May 1980.
                               Ill

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       APPENDIX 5-1



SITE D NEWSPAPER ARTICLES
            112

-------
f
i   PHETTTGOODIWIMS
                                                   of K«rn«rjvtll« Newi
                                                                                       GREENSBORO  DAILY NEWS
                                                                                          SUNDAY,  JANUARY  27,  1980
 Kernersville  Divided   On  Reservoir   Use
           BY WILLIAM KEESLER
             Daily Mfwi Staff Wrlltr

   KERNERSVILLE - Two and a half years after an
estimated 30.000 gallons o( chemicals  spilled into Ker-
nersville's water system, the town's main reservoir re-
mains out of commission.
   Residents are  sharply divided over when, if ever,
use of the approximately 50-acre lake should resume.
   Debate  on  the question has become entangled in
the town's politics and in the continuing struggle over
an issue that has faced the town for years: Should Ker-
nersville be a suburb — a bedroom community for sur-
rounding municipal giants Greensboro, Winston-Salem
and High Point? Or should it he a self-sufficient com-
mercial and  industrial community with an identity all
its own?
   The reservoir  was contaminated  on June 2. 1977,"
when thousands of gallons of chemicals flowed  out ol
tanks at the Dc'struclo Chcmway Corp. waste disposal
plant, down a hilf and into a creek feeding into the lake.
Vandals were blamed for  turning (he valves on the
tanks.
   The chemicals  polluted the lake,  killed thousands
of fish and forced  the temporary evacuation of 1,000
area residents. The town was forced to close the reser-
            r
voir and begin buying water  from the Winston-Sa-
lem/Forsyth County water system.
   According to officials with the water supply branch
of the N.C. Division of Health Services, the water in the
reservoir has been tested periodically since and is now
free of contamination. Carolawn Co., which took over
operation of the site from Desu-ucto, moved out of Ker-
nersville in November and is now constructing a waste
disposal plant in Fort Lawn, S.C., about 45 miles south-
west of Charlotte.
   When Carolawn moved, it left behind an estimated
50.000 gallons of  chemicals in rusting 55-gallon metal
drums. According to Charles Rundgrcn, head of the
state water supply branch, the potential for further con-
tamination exists.
   State officials have recommended but say they do
not have the power to require that the town keep the
reservoir closed until the  chemicals are removed. If the
town begins using the lake sootier, it will have  to bear
the liability for any resulting contamination, Rundgren
said.
   Despite this warning, some Kernersville citizens
want to use the reservoir immediately.  On Dec. 4, re-
versing an earlier decision, the town Board of Aldermen
voted 3-2 to disconnect from the Forsylh water system
and hook back onto the lake.
   This change of mind sent shivers of horror through
other town residents. Morgan Culliton and his wife,
Kay. filed a class-action suit seeking a permanent in-
junction against reopening the reservoir, charging that
doing so would be "the first step in a perilous course to .
eventual catastrophe for both the city and its citizens."
   Early this month, the board reversed itself again,
voting 3-2 to postpone resuming use of the reservoir un-
til after the chemicals are removed. But the class-action
suit is  pending.
   At this time, the Cullitons and their attorney, John
Stone, a leader in the opposition to the December board
decision, want the reservoir closed for good, even if the
chemicals are removed. While the water could be used
for industrial purposes, they say, it  should not be al-
lowed for human consumption.
   Stone believes Kernersville could become another
Love Canal — the New York catastrophe of the mid-
1970s  In which people began having miscarriages and
other health problems after building homes on top of
an old chemical waste dump. He contends the Kerners-
ville reservoir still may contain undetected chemicals
that could be stored in the body fat and reappear in
10-20 years in the form of canr«" and other  serious
illnesses.
          (See Residents: B-4. Col. 1
                                                          113

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    Residents   Sharply   Divided
                  From  II-1
    Chemicals still could be in the floor of the reser-
voir, he said, and they have seeped into the soil of the
disposal site, creating a potential runoff problem. Stone
said he has been told some of the fish killed in the 1977
spill are buried in the watershed, raising another possi-
.bllity of contamination. He and Culliton also fear that a
creekside landfill at the metal recycling plant beside the
'.Waste disposal plant site could cause further problems.
' •  "This scares the  hell out of  me," said Culliton. "I
don't see  how they can say it's safe. They just don't
know."
 *  "We don't know exactly what chemicals went in
th'ere,"  said Stone, 31. a  Kernersville resident' with a
wife and a child. "When chemicals get together, they
form  compounds. The reactions  can vary.  Nobody
knows what compounds were  formed.
 ;  "If  there's one chance in a million  that there's
something harmful out there, then I don't  think we
should take that chance of hurting our families and our
friends,"
 y
 ••  Officials of the state water supply branch said tests
of the reservoir bottom have shown no contamination
problem. According  to Roy Rettinger, a state environ-
mental engineer based in  Winston-Salem, preliminary
results from a recent test just downstream from the re-
cycling plant landfill  showed no  runoff problem there.
    The state's solid  and hazardous waste branch  and
the U.S. Environmental Protection Agency are now in-
specting the waste disposal site to identify the remain-
ing chemicals and determine how  to dispose of them.
Once the chemicals are identified, more water tests will
be performed, said M.O. Caton of Winston-Salem, the
water supply branch  regional engineer.
    The three aldermen who voted  to reopen the reser-
voir in December say the water is safe to drink now.
One of them, Larry  Brown, went so far as to dip raw
water out of the lake in late 1978 and drink it, passing it
through a coffee filter only once for protection.
    Brown, 36, who  operates a local clothing outlet,
swears he and his dog drank about 25  gallons of the
stuff during a period of several  months, with no noticea-
ble, ill effects.
 . | "We feel like we have one of the best-quality water
supplies in the Southeast  or the nation," Brown said.
"Even despite the chemical spill, we have a good-quali-
ty! water."
   ' rie said that since the spill a dike and other safe-
guards  have been provided at the waste disposal  site
that will prevent the remaining chemicals from causing
further contamination.
 f" Brown helped lead the campaign against a town
proposal in 1978 to issue $1.2 million in bonds to finance
a permanent hook-up to the Winston-Salem/Forsyth
County system. The referendum was viewed as a battle
between  those wanting to control the growth' of the
town (Brown's group), and those wanting an  increased
supply of water to recruit new industry (a group unoffi-
cially headed by Mayor Roger  Swjsher).  Inextricably
bound up in the fight was the stricken  reservoir. The
bond proposal failed by a  substantial margin.
 '. t "There are some people in the city who want a no-
growth  policy,"  said Swisher, 49,  a local car dealer.
"They figure that if you don't have any water, the city
will stagnate. It can't grow.

    "If Kernersville is going to stay a strong and inde-
pendent community, we're going to have to grow. We
can't stand still. We'll be swallowed up by the commun-
ities around us."

    Brown's group, however,  maintains it opposes only
uncontrolled growth. They say Kernersville should seek
clean  industries, like product 'distribution centers, in-
stead of heavy manufacturing  operations that would use
large amounts  of water.
    The group also strongly resists the  idea of ceding
to the county the responsibility of supplying water. Ac-
cording to Alderman Larry Cain, another who voted for
reopening the reservoir in December,  the town already
has given  up too much.
    "If they've got our sewage, they've got our water,
they've got our schools, they've got our library, they've
got our YMCA, what else does the town have other than
garbage collection?" said Cain, 37, a local funeral home
director. "And  we could have a private garbage service
take that.  If we give everything we've got away, then I
think we've lost our identity  as a town."   ..
    Alderman  Inez Davis cast the deciding'ballot  in.
both the December and January board votes. Davis, 49,
a substitute schoolteacher, voted for reopening the res-
ervoir in December, she said,  because among other rea-
sons, after two and a half years nobody —  the  town,
the state, Carolawn or C;irolawn's landlord, Brenner In-
dustries of Winston-Salem  — had done much about the
problem.  She voted against in January, she said, be-
cause  finally it appeared  action had started.
    The state solid and hazardous waste branch and the
EPA have entered the controversy since the first of the
year. O.W. Strickland, solid and hazardous branch head,
said identifying and disposing  of the chemicals probably
would be a "rather slow process." There is no disposal
site available in North  Carolina.
    Officials for Brenner, Carolawn  and the town held"a
negotiating session  last week. Swisher said afterwards
that Brenner is negotiating a contract with Carolawn to
remove the remaining chemicals. He said he is hopeful
that the chemicals  can be removed by the  first week
in March and that the state can then  come in for final
testing..
    Telephone calls to Carolawn and to Brenner, which
also is the operator of the metal recycling plant next
door to the waste disposal site, were not returned.
    Besides the matter of the chemicals, there still is
considerable litigalion.to resolve. Kernersville has a $1.5
million suit pending against  Carolawn  and  Destructo
Chemway, and the state recently  filed a $24,500 suit
against Destructo and its president, David M.  Neill  of
Charlotte.
    "Law, there were times I thought we would never
get anywhere," Davis said. "Now it looks like we're  fi-
nally getting somewhere.  But I won't believe it until I
see it."
                                                     114

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             A     Little  Watergate!
 tetter to the Editor:
  Do  we  have  a   little
Watergate going on in Ker-
nersville?    Why all  the
secrecy  about, our  water
situation?
  When was it  decided that'
our water plant was really in
need     for    substantial •
.renovation ,pr_ replacement? t.
•How long bas this been in the"
making?  It's  been  in  the
making for a long time, or it
would seem so.
  A group of engineers set up
office in Kernersville and a
temporary  water  line was
laid prior to the  chemical
spill at Destructo in June of
1977.     Who hired  these
engineers to whom we owe a
substantial debt of $120,000?
Was it the town manager or
the aldermen?
  If our system was in such a
rundown condition, why  did
our officials spend $100,000 on
a parking lot? Would you call
mis good planning for  the
future of the citizens?
 . I suggested to some of our
aldermen a long  time ago
that I and others would rather
pay a substantial increase in
our water rates if we could
use our own "clean, spring-
fed lake" rather  than  the
Yadkin River for our water
supply.
  But this wouldn't' be good
for a big industry boom or
Isrgs developments,  would
it?
  Since  we are  required to
operate our utilities on a self-
sustaining,   enterprise
system, why can't we, with
the population  we have  of
over 7,000?  We've had this
large    population   ' for
sometime now and if s just
come to light that this utility
must pay for itself and that it
 has not done so for the past
 four years. Very interesting!
   Yet we keep on annexing,
 overloading our water, sewer
 lines and streets.    Good
 planning!
   This  was  one  way  of
 phasing out our present water
 plant, of which we do have
r sufficisnt.watgr^for.lthe next
'"10-15 years.       •
   If  we  go  to  city-county
 water,' and  that's  exactly
 where we're going, then  we
 can expect to be the first  cut
 off if any malfunctions  or
 water shortages occur in  the
 future.  This  is exactly what
 happened last summer.
   Going  to  county water
 would  really  help  Ker-
 nersville to have a big  in-
 dustry  boom and  develop-
 ment would really blossom,
 and that's what if s all about.
   Come  on,  citizens,  wake
 up!
   Because of poor planning,
 "power," and "what I want"
 rather than what's best  for.
 the citizens,  we  have  a
 clearer picture of why  we
 have insufficient sewer lines
 and streets.
;   When  our  clean lake  is
 closed for our water supply, I
 wonder who  stands to gain
 from this move?  Who will
 profit?   Who is really  in-.
 terested in our lake? A  great
 recreation center, you might
 say.   If  the  water  isn't
 suitable for us to drink, then
 would we be allowed to eat
 fish that are caught from  it?
   Since the mention of fish
 comes to mind, I wonder why
 the fish did  not  die down-'
 stream from  the lake during
 the oil spill that  supposedly
 killed the fish in the lake?  Oh
 yes, why did the fish die first
 at the opposite end of the lake
 after the oil spillage?
   A   meeting  has  been
 scheduled for Monday, Feb.
 13, at 6:30 p.m. in the Pad-
 dison Library to hear from
 citizens who depend on  the
 town for their water supply,
 to find out whether or not they
 want to again use the clean
 lake .for our water supply cr
 gcf to countylwater.:"'    "T;~*
   Call your aldermen and let
 them  know how  you  feel
• about this situation. They are
 Larry Brown, Max Coltrane,
 David  Holt, Aubrey Morris
 and Ivey Redmon.
   Our mayor said at the last
 Board meeting that Mr; M. O,
 Caton, of the North Carolina
 Department   of    Human
 Resources, would be present
 at this meeting.  Will he? If
. so, come and  bring  your
. questions to the man who has
 declared our lake  safe  for
 drinking, and to the engineers
 who have been the town's
 advisors in this situation and
 have  given  our  aldermen
 several alternatives to take.
   I have said several times
 and I will say  again that I
 would like to use. our lake
 again as a water supply and
 use the county  water as a
 backup source.
   We  have  asked  that  a
 clipping be run in this week's
 KernersyMe^flfiwa^ asking
 whether  the  citizens  of
 Kernersville would like to use
 our lake again as our primary
 water supply or go to county
 water.
   If it is run, please sign your
 name  and state the. reason
 why you would or would not
 be in favor of this move and
 return  it to  the newspaper
.feefore Feb. 13.
                                    115

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   APPENDIX 5-2



SITE D PHOTOGRAPHS
       116

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As a result of the spill  in 1977, more than 90 percent
of the fish in Kernersville Lake" died  (top photo).
The fish were  gathered, removed from the Lake, and
placed in barrels (bottom photq).


                       117

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Berms (.top photo) were placed around the tanks
following the 1977 spill.  By March 1980 pools of
wa.ter had collected in the bermed area around the
tanks (bottom photo).
                      118

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 Dead  fish  and  contaminated  soil  and  debris  were
 placed  in  a  limed,  lined  pit  at  the  Destructo/
 Carula-wn  site  in  1977.
This incinerator was used by Destructo prior to
the spill  of June 1977.   Carolawn reportedly
only used the site as a  storage and  transfer station,
and did not use the incinerator.
                      119

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 As  evidenced  by  the  photo  of March  1980,  the site
 was poorly  managed by Cajr_olawn,  the successors  to
 Destructo.

After Carolawn vacated the site, initial cleanup
activities were implemented by the landowner,
Brenner.  One of the first steps was to
segregate the waste according to characteristics.
                      120

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                          SECTION 6

                            SITE E
                    WHITMOYER LABORATORIES
                    MYERSTOWN, PENNSYLVANIA
INTRODUCTION

     Whitmoyer Laboratories, Inc.  has operated an animal  pharma-
ceutical  manufacturing facility in Myerstown, Pennsylvania
since 1934.  In July 1964, they became a subsidiary of the
Rohm and Haas Company of Philadelphia.  Rohm and Haas sold
Whitmoyer Laboratories in early 1978 to Beecham, Inc., but
Whitmoyer Labs has retained its identify as a separate company.

     When Rohm and Haas purchased  Whitmoyer Labs in 1964,
extensive arsenic contamination of the,soils, ground water,
and a nearby stream became apparent to Company officials.
Emergency remedial actions were taken to stop further contamin-
ation and to remove the contamination that existed.  Ground  and
surface water studies were conducted and a ground water monitor-
ing, extraction, and treatment program initiated which consisted
of three parts:  clean-up and recovery; development of cones
of depression; and stream and well monitoring.

     Actions to remove arsenic from the ground and surface
waters have been fairly successful.  However, insoluble arsenic
remains in the soils and ground water of the facility and  the
sediment of the creek.  These levels are expected to slowly
decline.

SITE DESCRIPTION

     Whitmoyer Labs is located on  North Railroad Street in
Myerstown, Pennsylvania.  Myerstown is located between Harrisburg
and Reading, Pennyslvania, approximately 95 km (60 mi) northwest
of Philadelphia.

     The normal annual precipitation for the area is 110  cm
(44 in.) and is distributed fairly evenly year round.  Snow  fall
averages 90 cm (35 in.).  The average wind is 12 km/hr (7.7  mi/hr)
The average temperature is 11°C (53°F) with the highest daily
maximum of 24°C (76°F) occurring in July and the lowest of
-1°C (30°F) occurring in January.

     The facility lies adjacent to Tulpehocken Creek 60 km
(37 mi) upstream from its confluence with the Schuylkill  River
and about 25 km (16 mi) upstream from the upper end of the
Blue Marsh Dam Project (see Figure 6-1).  Myerstown is situated
                             121

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                                            BLUE MARSH DAM
•WHITMOYER PLANT
     Figure 6-1.  Location of Whitmoyer Labs [6-1]
                           122

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a few miles upstream of Whitmoyer Labs.   Womelsdorff is  the
first town downstream at approximately 6 km (4 mi).   There are
some farms, which use the local  ground water,  located nearby
on both sides of Tulpehocken Creek.   A 45 m (150 ft) deep
calcite quarry lies 2.4 km (1.5  mi)  west of Whitmoyer Labs.
     There are
administration
and there is a
               several  buildings
               (see Figure  6-2).
               temporary storage
and a Buckeye pipeline pumping
of the lagoons.  There is also
by 3.6 m (12 ft) high concrete
filled with arsenic wastes.   A
property beginning and ending
                            on-site used  for production  and
                             The old lagoons are  covered
                            building situated on  one  part
                               station  located  on  another  part
                               a  25  m (83  ft)  by  37  m (123 ft)
                               vault on site which "is compl etely
                               cooling  canal flows  through the
                              in  the Tulpehocken  Creek.
     The drainage basin of the Tulpehocken Creek covers 550 km2
(211 mi^) and is 54 km (33.5 mi) long.   The average and minimum
flows at the confluence of the Tulpehocken Creek with the
Schuylkill River during Septemberand October T964" were" T~r6~ cms
(58 cfs) and 1.5 cms (56 cfs), respectively.  The average annual
flow for the creek is approximately 5.7 cms (200 cfs) and the
maximum flood, flow was 200 cms (9,890 cfs) on December 7, 1953.
The general direction of the stream follows the east northeast
strike of the carbonate bedrock.  The ground water found under
Whitmoyer Labs is potable and used by local residents and farmers
There are some artesian wells found nearby but the static water
level in most wells lies near the ground water table.

     Whitmoyer lies close to a ground water divide in a system
of limestone aquifers underlying the Lebanon Valley.  Prior to
the industrialization of the Lebanon Valley area, the natural
ground water divide was probably conformable to the present
topographic divide which lies between the headwaters of
Tulpehocken Creek and Quittaphalla Creek, about 5 km (3 mi) west
of the plant.  A calcite quarry, located 2.4 km (1.5 mi) to the
west of Whitmoyer, has pumped ground water from the bedrock
aquifers while continuing quarry operations.  This has shifted
the ground water divide east so that it is now located just
to the west of Whitmoyer as seen in Figure 6-3.

     The position of the ground water -divide determines the
flow direction of wastewater produced by Whitmoyer.  This
wastewater has been a source of recharge to the local ground
water aquifer for several years.  The majority of the flow
moves east but some pollutants which originated from the plant
have been found to the west.  Figure 6-3 shows the ground water
level contours at the plant on July 23, 1973.  Ground water
                               ground water trough coinciding
                               is another ground water divide
                               6-1) which interrupts the
                              no arsenic wastes reach Blue
flow
with
east
f 1 ow
was to the northeast- to a
Tulpehocken Creek.  There
of Womelsorff (see Figure
down valley.  Therefore,
Marsh Lake via the ground water,
                             123

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  Figure 6-2.  Detailed site location for Whitmoyer Labs. [6-2]
Figure 6-3:  Ground water contour map for Whitmoyer Labs.  [6-2]
                             124

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     The Bedrock under the plant consists of limestones and
dolomites which strike east-northeast and exhibit a dip of
30 degrees to the southeast.   Whitmoyer lies directly over the
Ontelaunee Formation (dolomite)  which is-approximately 275 m
(900 ft) thick (see Figure 6-4).  Underlying the Ontelaunee,
and surfacing about 460 m (1,500 ft)  north of the plant,  is
the Annville Formation (high  calcium  limestone).  The Epler
Formation (a dolomite not present at  the plant)  overlies  the
Ontelaunee surfacing about 130 m (425 ft) south  of the plant.
The Hershey Formation (a tight shaley, silty limestone) under-
lies the above formations and, together with the Epler Formation
contains the ground water in  the Ontelaunee and  Annville  Forma-
tions.   Any cones of depression  formed by purging wells will
not be conical, but ellipsoidal  in shape following fractures
and solution channels in the  rock.

     The soil mantel averages 1.5 m to 2 m (5 to 7 ft) thick
and is made up of alluvial sand, silt, and gravels.  It is
fairly permeable and allows for  rapid recharge to the bedrock
aquifers.  The area has a gently rolling topogrpahy resulting
from erosion by the Tulpehocken  Creek and its tributaries.
The valley walls to the north slope upward from  the creek's
elevation of T4TO m (T50 ft) at the svfce, to T5D-m fBOO ftj in
1  km (0.6 mi).  To the south  it  is steeper, reaching 150  m
(500 ft) in 0.5 km (0.3 mi).

     The area near the Whitmoyer site is predominantly farmland.
It is used for grazing and crops.  Deciduous trees are found
along water courses and on hillsides.  The Whitmoyer site is
vegetated with short grasses  and a few outlying  trees.

SITE OPERATION AND HISTORY

     Whitmoyer  Labs employs  approximately 100 people and
manufactures a diverse line of pharmaceutical and nutritional
products for the poultry, livestock,  and feed industries.
These products include sulfur compounds, vitamins, antibiotics,
feed additives, and supplements  based on arsenic chemicals.
In 1963, Whitmoyer's consolidated sales totaled  nearly
$9,000,000.  Their products are  sold  over the counter, not
distributed through veteVinarians.  Some of their major
products include:

     1,   Arsanilic Acid - used to prevent dysentery and
         promote growth in swine.

     2.   Biodin and Ethylenediamine Dihydroiodide (EDDI)  -
         used to prevent foot rot in  cattle and  used as
         a source of iodine.
         Piperazine -
         turkeys, and
used as
swine.
a low cost dewormer for chickens
                             125

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WNW
                             ESE
                              WHITMOYER PLANT
ONTELAUNEE FM.
  HERSHEY FM.
                                 SCALE I  1=9600
   Figure 6-4.   Generalized geologic cross section drawn
           perpendicular to the strike direction.
                            126

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     4.   Carb-0-Gain and Carb-0-Sep - used to
         head and promote growth in turkeys.
prevent black
Whitmoyer also packages and labels their products for shipment.

     Whitmoyer Labs was founded in September 1934 when Mr.  C.  W.
Whitmoyer's firm merged with a similar pharmaceutical company.
Whitmoyer began production of arsenic compounds at Myerstown
in 1959.

     The wastewater generated by their manufacturing plant  was
treated with lime and handled as a slurry for disposal in an
unlined lagoon.  The arsenic wastes were primarily organically
bound arsenic compounds (arsenical compounds), calcium arsenate,
and calcium arsenite.  A total of about 450,000 kg (1 million
Ibs) of waste was lagooned.  The plant's sanitary sewage and
other non-arsenic bearing wastes are discharged to the Myerstown
Sewage Authority Treatment Plant.

     In July 1964, the Rohm and Haas Company, a Philadelphia
based chemical company, bought Whitmoyer Labs.  Although Whitmoyer
became a wholly-owned subsidiary, it retained its former
managerial staff.

POLLUTION AND REMEDIAL ACTION

     The arsenic pollution problem was first identified by
Thomas  lezzi of Rohm and Haas in September 1964.  Ground and
surface water in the vicinity of Whitmoyer Labs was  found to
have been affected by the arsenic wastewater production.
Therefore, on-site treatment and disposal practices were dis-
continued in December 1964.  The ensuing recovery and rehabili-
tation  program consisted of three phases:  (1) clean-up and
.recovery, (2) development of cones of depression, and (3) stream
and well monitoring.

     At this time, four wells began purging ground water
containing the arsenic compounds.  Subsequently, the Rohm and  Haas
Research Department  perfected a treatment process to remove
the arsenic from the purged water in the form of insoluble
precipitates.  They  added ferric sulfate at the ratio of
approximately two  parts ferric  sulfate to one part arsenic, and
adjusted the pH to neutral- conditions by adding lime.  This
process reduced the  arsenic content from more than 2,000 ppm
to  1 ppm.  All the recovered water was handled in alternating
batch mixing tanks on a continuous feed treatment schedule
and sent to the lagoons to dissipate via slow percolation to
the subsoil.

     Yields of extracted arsenic  peaked at 5,000 kg  (11,000 Ibs)
per week, later leveling off at about 2,000 kg to 2,300  kg  (4,500
to  5,000 Ibs) per  week by April 1965.  The water from the
                              127

-------
 contaminated  aquifer  initially  contained  10,000 ppm arsenic.
 After  400 m3  (100,000  gal) of ground water was pumped, the
 arsenic  level  dropped  first  to  6,500 ppm, and then to 100 ppm.

     Early  in  1965  sludge was removed from the lagoons as well
 a's the contaminated soils underlying the  lagoons.  These
 materials were  deposited in  an  impervious concrete bin 43 m
 (123 ft) long,  25 m (83 ft)  wide, and 3.5 m  (12 ft) deep.
 The bin  was filled  to  capacity  and covered.  Three additional
 purging  wells  began operations  in early 1965.  Approximately
 450 md (120,000 gal) per day of wastewater was treated, and
 about  200,000  kg (400,000 Ibs)  of arsenic compounds were
 purged and  treated.  The plant  was reopened  rn the spring of
 1965 on  a no-discharge basis.   They began trucking treated
 wastes to a holding area in  New Jersey to await ocean dumping.

     The second phase  (entailing development of cones of
 depression  via  counterpumping)  began as the  arsenic recovery
 rates  from  the  seven wells continued to decline.   By the end
 of 1966, 23 new wells  had been  drilled.  These original
 seven wells and seven  of the new" wells were  then  used as
 production wells to form cones of depression east of the plant.
 Ten of the  remaining wells were used for observation, five were
 abandoned,  and one later used to replace one of the original
 seven purging wells.  Arsenic concentrations in water from
 the new  extraction wells ranged from 33 ppm  to 440 ppm.   The
 increased rate of arsenic removal  is seen with the addition of
 seven wells:

     •   Initial 7 wells  - 28 kg/day (62 Ibs/day) arsenic

     •   Initial 14 wells - 44 kg/day (97 Ibs/day) arsenic.
The well locations
indicates the well
initially, and the
of completion.
may be seen in Figure 6-5".   Table 6-1
number, well  depth, amount  of water pumped
arsenic concentration present at the time
     Whitmoyer Lab's production rate was partially dependent
on its purging rate and the development of the cones of depres-
sion.  Nearly all of the liquid extracted from the ground was
returned.  Natural precipitation also contributed to the recharge
adding to the aquifer's volume.  The cones of depression were
developed to stop the migration of the ground water.  Therefore,
as the volume of the aquifer contained by the cones  of depression
grew, it became more and more difficult to maintain  the
existing cones of depression.  With the addition  of  the seven
new purging wells, the cones of depression were initially
increased and Whitmoyer Labs could increase their production
rates.
                              128

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                                                                               o.

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                                                                               JD
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                                                                               o
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                                                                               +•>
                                                                                O)
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                                129

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TABLE 6-1.
INITIAL ARSENIC CONCENTRATIONS
 FROM PLANT WELLS

Well
No.
5-A
9
9-A
10-A
11
16-B
17
*
Depth
(m)
48
29
30
30
30
37
21
Extraction
Rate
(m3/min)
• 0.036
0.150
0.190
0.098
0.045
0.038
0.303
Arsenic
Concentrati on
(ppm)
326
155
102
440
349
146
297
 1  m = 3.28 ft
 1  m3/min = 264 gpm
                   130

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      The  treatment  of  the  ground  water  continued  until  late  1968
 when  Whitmoyer  Labs  began  to  discharge  the  purged water  directly
 to  Tulpehocken  Creek.   Permission to  do so  was  granted  by  the
 Delaware  River  Basin Commission.   By  December  1968,  direct
 discharge of  the  total  amount of  purged water  to  the Creek had
 been  attained.  The  discharge rate of all  14 wells  increased
 to  950  m3/day (250,000 gpd) and then  dropped as  the  cones  of
 depression began  to  expand.   Direct discharge  to  the Creek
 ceased  in April 1969 but  resumed  in September  of  the same  year.

      Early in 1971  there  was  a public outcry against the dumping
 of  arsenic in both  the Atlantic Ocean and  local . surface  waters.
 Rohm  and  Haas ceased operation of their purging  wells  and  of
 their discharge to  Tulpehocken Creek.  The  cones  of  depression
 never developed to  their  full potential , but they did  contribute
 to  an improvement in conditions.   Approximately  22,000  kg
 (50,000 Ibs)  of arsenic was recovered and  disposed  of  during the
 second  phase.  But  there  probably was a considerable amount of
 arsenic waste carried  ultimately  to the Atlantic  Ocean.   Runoff
 and ground waters which contained arsenic  flowed  to  Tulpehocken
 Creek which flowed  to  the Schuylkill  River  to  the Delaware Bay.
involved
                                                   Whitmoyer
                                                   n t o£_
      There  were  two  forms  of arsenic wastes
-La-b-s- o&ean -dumping-; - so44-ds— a-n4-l-tq u td-
 the arsenic found in the liquid. waste was  trivalent (which is
 considered  toxic).   The balance, including solids,  was pentavalent,
 In  March  1971,  Whitmoyer Labs produced approximately 1.4 million
 kg  (3 million Ibs)  of 1 iqu-id— wa-stes per- month.   Th-i s included
 mother liquids  from  the Arsanilic Acid and Carb-0-Sep crystal-
 lization  process.  The components were as  follows:
                   Component
                                      Value
Organic arsenic (Arsanilic
Inorganic arsenic (
Arsenite (toxic)
NaCl
Water
PH
Specific gravity
                                 Acid)
2,
5
   43%
   82%
 0.59%
13.20%
77.96%
 5.90
 1 .166
      Whitmoyer sent- nearly 18,144 kg (40,000 Ibs) of waste per
 day to a 3,700 m3 (1  million gal) holding tank in New Jersey to
 await ocean dumping.   Approximately 1,900 to 3,400 m6
 (500,000 to 900,000 gal) of wastes were dumped by ship on one
 trip.

      Solid wastes produced and ocean dumped included tar-like
 aniline still  bottoms, and carbon filter cake produced from
 the Arsanilic  Acid clarification filters.  The content ,of the
 aniline still  bottoms was as follows:
                              -131

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                    Component
                         Content
         Arsenic
         Aniline
         TTAA
(free  and combined)
12-13%
30-40%
25-35%
The arsenic is in a tightly bound molecular form.  Aniline
degrades rapidly but should not have migrated rapidly into the
sea water while present in the still bottoms. [6-3]

     In March 1971, Representative Charles W. Sandman (New
Jersey) filed a civil action in U.S. District Court against:

     •   Pennsylvania Department of Environmental Resources,
         Industrial Waste Division.

     •   Pennsylvania Department of Health.

     •   Whitmoyer Laboratories.

     •   Rohm and Haas Company.

     •   Norton Lilly and Company (a shipping agent).

A temporary restraining order prohibited further ocean dumping.

     The third phase of the recovery and rehabilitation program
(stream and well  monitoring) began after the di scontfnuatibrf
of the counterpumping.  Quarterly monitoring of existing wells
and of Tulpehocken Creek helps to identify the arsenic levels.
Since 1972, the wastewater has been reduced in volume via
evaporation (boiling), centrifuged, and drummed.  The waste is
then shipped to a secure landfill in New York State.   Totals of
the drummed wastes and by-products of the arsenic process for
1978 and 1979 are as follows:
          Drum Contents

          Arsenic salt
          Arsenic carbon
          Arsenic Tar
          Total

     The U.S. Army
waters which would
Number of
1978
1,778
681
84
2,543
Drums
1979
1,573
734
85
2,392
  Corps of  Engineers  began
  feed their proposed Blue
 sampling  surface
 Marsh  Lake  early
the 1970's.  Figure 6-6 shows the location of sampling stations
that the Corps established along Tulpehocken Creek.   They found
the following arsenic concentrations in samples taken from
September 1971 to August 1972:
                             132

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     •   Tulpehocken Creek Water

            Near Blue Marsh Dam

            Total  arsenic = 0.03 ppm
              (range * 0.01 to 0.062 ppm)

            Inorganic arsenic = 0.01 ppm

            Near Whitmoyer Labs

            Total  arsenic = 0.088 ppm
              (range = 0.03 to 0.18 ppm)

            Inorganic arsenic =0.04 ppm

     •   Tulpehocken Creek Mud

            Near Blue Marsh Dam

            Total  arsenic = 43 ppm

         -^  Near Whitmoyer Labs

            Total  arsenic = 152 ppm

     The following gives the arsenic content found in several
wells drawing ground water at the Whitmoyer site:
Date .
5/72
7/72
7/72
7/72
Well
No.
7
5
7
9
Total
Arsenic
(ppm)
370
124
412
66
I norgani c
Arsenic
(ppm)
224
126
280
49
Tri val ent
. Arsenic
(ppm)
115
—
150
*•• «
Organic
Arsenic
(ppm)
146
—
132
w ™
     Figure 6-7 shows the seasonal changes in arsenic concentra-
tion found in Tulpehocken Creek waters.  Higher contents of
total arsenic occur generally with higher stream flows.  The
organic arsenic decreased in the winter-,months.  In October
1975, wastewater containing about 2 kg (4 Ibs) or less of
arsenic was discharged accidentally into Tulpehocken Creek.
Preventative measures to protect the creek from a similar
accident were taken.

     A plot of residual arsenic release in the vicinity of
Whitmoyer Labs is asymptotic in a declining rate.  The waters
of Tulpehocken Creek contain  less than 0.05 ppm arsenic and
the arsenic contents in some private wells have dropped.
Although arsenic compounds still remain in the ground water,
                             133

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                                          BLUE MARSH DAM'
            -WH1TMOYER PLANT
  Figure  6-6.  Location of  sampling stations established  by
           the U.S.  Army Corps  of Engineers.  [6-1]
         JO
         .06
         J02
            SEPT.
            1971
                  NOV.
JAN.
1972
                               MAR.
                                      MAY
                                             JULY
SEPT
1972
Figure  6-7.   Arsenic content at Station  2 at Whitmoyer Labs.  [6-2]
                                134

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soil, and subsoil, a large amount has been removed or re-
covered.

CONCLUSION

     Rohm and Haas has attempted, since their ownership of
the Whitmoyer facility, to control  the flow and reduce the
amount of arsenic on and around their plant site (see Figure
6-8).  The first phase of remedial  action cleanup and recovery
halted the production of arsenic wastes and removed quantities
of sludge and contaminated soils.  The plant was shut down
until a process could be developed to remove arsenic from the
wastewater.  This phase eliminated the possibility of new
arsenic compounds being added to the soils and subsequently
to the ground and surface water.

     The next phase (removal of arsenic from the ground water)
was also largely successful.  The recycling and treatment of
the purged water did reduce the level of arsenic in the ground,
and succeeded in controlling its movement.  Little work was
done to remove the arsenic from the mud and waters of Tulpehocken
Creek since it w^u-Vd~ h^-ve-4nvol ved the-dred-gi ng~chf mi les- of
creek bottoms and banks.  Arsenic levels in the creek water
have been brought under the limits set by the U.S. Department
of Health and they continue to decline.  Whitmoyer continues
to supply bottled water to some area residents whose wells
remain affected.

     The third phase, monitoring, 'tracks arsenic levels to
ensure that they do not increase, either through release of
arsenic from bottom muds, or via spills from the plant.
Remedial actions taken  seem to have  been the logical and
effective response to  limit and reduce arsenic contamination.
                              135

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I  1965    11966
                     1 1967     11968
11969
11970
M971
Figure 6-8.  Cumulative  graph  of  arsenic  removed from
       thp ground water  at  the  plant site.  [6-2]
                           136

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             SITE E REFERENCES AND BIBLIOGRAPHY
6-1   File Review at State Water Quality Division,  Department of
     Environmental  Resources, Harrisburg,  Pennsylvania.

6-2   Wood, C.R., Evaluation of Arsenic Concentrations in
     Tulpehocken Creek Basin, Pennsylvania,  U.S.  Geological
     Survey.

6-3   Whitmoyer Laboratories.  Description  of Whitmoyer Labora-
     tories,  Myerstown, Pennsylvania.  March 23, 1971.
                               137

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   APPENDIX 6-1



SITE E PHOTOGRAPHS
       138

-------
 •tfelfflttfl'

 jjp >*'""
 **%^
 '*. •*"

View of an  old  lagoon with final  cover and vegetation.

The grass has  had adequate time  to  become well established,
                           139

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View of the Buckeye Pumping Station  located  atop
an old lagoon.
                         140

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                           SECTION 7

                             SITE F
                    WESTERN SAND AND GRAVEL
                   BURRILLVILLE, RHODE ISLAND
INTRODUCTION

     Western Sand and Gravel  is a hazardous waste disposal  site
located in northwestern Rhode Island.  Waste disposal  operations
were initiated in 1975.  Liquid septic and industrial  wastes
were transported to the site  by municipalities and industries
for disposal in pits where they were allowed to either evaporate
into the air or percolate into the ground.

     Since the start of operations, numerous complaints have been
registered with the Rhode Island Department of Health (RIDOH).
RIDOH attempted to close the  site in 1977 but were unable to do
so until 1979 when the Superior Court declared the existing
guidelines, laws, and regulations governing disposal sites
sufficien-t 1 e-g-a-1 support.

     In February 1980, the U.S. Environmental Protection Agency
(EPA) assumed jurisdiction over the site.  Remedial work
sponsored by EPA consisted of pumping liquid and solid wastes
from four of the disposal pits and transporting them off-site.
Solid residues from the cleanup are currently being stored at the
disposal site in 0.2 m3 (55 gal) drums and in a mound mixed with
sawdust and covered -with a polyethylene cover.  The removal of
septic wastes from other on-site disposal pits will commence in
thenearfuture.

     A hydrogeologic study is currently underway to determine the
extent of any ground water contamination.  Work to date has
shown that  unless immediate action is undertaken the water supply
down-gradient from the site will be permanently damaged forcing
residents to find alternate water supplies.  The total cost for
such cleanup activities has been estimated at $1,000,000.

SITE DESCRIPTION

     Western Sand and  Gravel,  Inc. (WS&G) is located  in a  sparsely
populated section of northwestern Rhode  Island, approximately
24  km  (15 mi) northwest of Providence and 8  km  (5 mi) southwest
of  Woonsocket.   It  is  on the  north side of Douglas Pike  (Route  7),
2  km (1.3 mi) southeast of Nasonville in  Burrillville, straddling
the  Burrillville-North Smithfield township line.  The location
of  the  site  is  shown in  Figure  7-1.

     The  waste  disposal  area  of  the  site  is  adjacent  to  the
Company's sand  and  gravel operations.   It consists of 12 in-ground
                               141

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                                          ^> Minnivc —\




                                              \


                                NORTH SMITHFIELD   '•>
 NOTE: All  elevations in ft above mean sea level.

 1 ft - 0.3  m
Figure 7-1.   Location of Western  Sand  and
                  Gravel site.
                       142

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pits or trenches on 2.8 ha (7 ac) of land.  The largest pit is
45 m (150 ft) by 15 m (5.0 ft) and the deepest pit is about 2.4 m
(8 ft)  deep.  A sketch of the site and- pit locations are shown
in Figures 7-2 and 7-3.  The pits are identified as Nos. 1 through
12.  The respective dimensions, volumes, and uses of each-pit are
presented in Table 7-1.
     The climate
heavy precipitati
temperature.  In
temperatures of s
Based on 30 years
the area is 15°C
108.6 cm (42.75 i
October and April
1 ess.
of Rhode Island is characterized by moderately
on, high evaporation, and a wide range of
general, the winters are cold, having extreme
hort duration, and the summers are cool  but humid,
 of record, the average annual temperature in
(59°F) arid the average annual precipitation is
n.).  There are an average of 123 days between
 wTth minimum temperatures of 0°C (32°F) or
     The site lies in a hilly northwestern upland of Rhode Island,
a continuation of the New England Upland of eastern Connecticut
and southeastern Worchester County in Massachusetts.  The ground
surface of the waste disposal site slopes gently to the northwest.
Immediately to the west, th.e ground surface drops steeply to
Tarklin Brook wfricfrnrrtiTrrately" eTTters STaTers"vTTTe KeservoTr.  The
Slatersville Reservoir, approximately 300 m (1,000 ft) north of
the site, currently supplies the City of Woonsocket with 13.2
m^/sec (58.3 gal/sec) of water.   The reservoirs are papular
recreational areas; aird"~were""oFfgiiraTly constructed for supply
water for power generation, processing, and waste disposal for
textile mills.  There are also a number of lakes, ponds, and
swamps in the area.  The land is mostly wooded and has some open
pastures for grazing.  The general topography of the site has
been radically altered from its  natural state by the sand and
gravel mining operations.
     Although the ground water in the
undeveloped, the WS&G site is located
principal recharge area of the
quality of this aquifer is
for its use as a municipal
of layers of sorted gravel,
deposited in valleys from glacial meltwater.  Ground water
beneath the site is to the north in the direction of the
Slatersville Reservoir with velocities on the order of 0.3
m (1 to 3 :ft) per day.
                     general  area is
                     above the major
              Slatersville Reservoir.
          such that little treatment
          water supply.  The aquifer
           sand, silt, and clay drift
relati vely
aquifer and
 [7-1].  The
is required
consists
 that were
     flow

     to 0.9
     Till and bedrock aquifers, hydraulically interconnected with
the stratified drift aquifer, have much lower ground water
yields.  The till is a poorly sorted, non-stratified, dominantly
sandy deposit composed of varying proportions of clay, silt,
sand, gravel, and boulders.  The till covers the bedrock surface
in uplands and lies beneath the stratified drift at most places
                              143

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                              - c
                            //  A'2  V
                           / /         N
                      D    , /0E-2
                          '  /
                          I /^DISPOSAL

                          \ I    AREA
         1 I
         I 1
                              \  \
                                     \ \        CONVENTIONAL

                                     /  j      A MONITORING WELL


                             \       / /      • MULTI-PROBE

                             V \   ..   /  '         MONITORING WELL
                             » »   F  /  /

                             \\  A//



                              \\ ' '
                               VNN-/ / (ALL WELL LOCATIONS AREAPPROX.)
                                                          UJl
                                     »F-3
                        J  l_
                                ROUTE 7
               O




               0
                            ICOm
Figure 7-2.   Site  environs  and monitoring  well   locations
                                 144

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                                   A

                                  A
\.    A


 K..-.:
  I  -   x-'
 /    /

'-^  \  •"

     \v
DISPOSAL AREA
                E-2
                                  \  I


                                  \ I


                                  / I

                                  /  \

                                S  V
                                                                        *»«.
                                                              CONVENTIONAL

                                                              WELL


                                                              MULTI-PROBE MONITORING
                                                              WELL
                                                            200ft
                                                         ,50m
             Figure 7-3.   Well and pit  location  map.
                                 145

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            TABLE  7-1.   PIT DIMENSIONS AND VOLUMES
Pit Depth
No. (m)
1
2
3
4
5
6
7
8
9
10
11
12
Subtotal
Subtotal
Total -
27.
5.
3.
27.
45.
18.
18.
18.
30.
9.
18.
—

4
2
4
4
7
2
2
2
5
1
2

Oil
Width Diameter
(m) (m)
9.
3.
1.
9.
15.
4.
4.
4.
6.
4.
4.
--
and
1
7
5
1
2
6
6
6
1
6
6
30.5
chemicals
Depth
(m)
1
1
0
1
1
1
1
1
1
1
1
1

.8
.5
.6
.8
.8-
.8
.8
.8
.8
.8
.8
.8

- Septage
All
Uses
Vol ume
450
29
3
450
1,250
150
150
150
335
75
150
1,315
632
3,875
4,507
Pit Use
Septage
Oil and
Chemical
Chemical
Septage
Septage
Septage
Septage
Septage
Septage
Oil and
Septage
.




chemicals
s
s






chemicals




1  m » 3.28 ft
1  m3 = 264 gal
                               146

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in the lowlands.   The bedrock aquifer consists  of igneous  and
metamorphic bedrock (granite beneath the site)  and water occurs
almost exclusively in a network of irregularly  spaced fractures.
Subsurface  flow from bedrock to stratified drift is a source of
recharge to the stratified aquifer.   Three well  logs from  the
site are presented in Appendix 7-1.

SITE OPERATION AND HISTORY

     During the period of active dumping from 1975 to 1979,
large amounts of hazardous and septic wastes  were dumped at  the
site.  Records of the types of chemicals and  the dates and
locations of the discharges are not  available because the
operator failed to keep complete detailed records listing  such
information.  Known wastes dumped include septage, oils, acid and
alkaline cleaning agents, heavy metals,  cutting  coolants,  paint
residues, perch!oroethylene, and aromatic and halogenated  solvents
Most of the wastes consist of several phases  of  liquid,  suspended
solids, settleable solids, and sludges and slurries.
        estimated total  of 1,586 m3 (419,000 gal)  of septage
     An
has been dumped TrTto TH"e~p"its~6~ver the operational  life of the
site.  In addition, up to 125 'm3 (33,000 gal)  of hazardous wastes
were disposed monthly, representing about 14 percent of the
hazardous wastes land  disposed in Rhode Island at the time.  About
80 percent of the wastes disposed into the pits were believed to
be aqueous acid or alkaline waste.   About 10 percent were a
mixture of oil, solvent, and acid and alkaline cleaning agents.
The remaining was predominantly catch basin cleanout generated
by various companies.   The estimated volumes of sludge material
contained in the pits  is presented in Table 7-1.

     In July 1975 WS&G asked and received permission from the
Rhode Island Department of Health (RIDOH)  to dispose of septage
into two pits.   In late 1976 and early 1977 chemicals were
dumped into the pits without approval from RIDOH.  The ensuing
citizen concern over the health and safety of the dump site
resulted in numerous complaints.  In the spring of  1977, a
substantial number of  complaints were made to  RIDOH because of
the severe off-site odors originating from WS&G.  WS&G was
notified by the Town of Burrillville and the North  Smithfie%d Fire
Department to remove the chemicals.  Several days later the
chemicals were buried.

     Inspection of the site by RIDOH revealed  WS&G  to be
in violation of the guidelines for facilities  receiving septic
tank and cesspool pumpings.  Specifically, pit length was found
to exceed 15.2 m (50 ft) and the depth exceeded 2.1 m (7 ft).-
There were no stakes or signs on the finished  trenches and there
was no fencing around  the pits.  Finally, five pits were found
to exist exceeding the two pit limit established in 1975.  The
site was ordered closed by the RIDOH.
                             147

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     At a hearing on May 2, 1977, the site was ordered to remain
closed.  This order was stayed by the Superior Court on May 5,
1977 and the guidelines used to regulate disposal  facilities
were declared null and void, allowing WS&G to continue their
waste disposal practices.  New laws and regulations governing
the disposal of septic waste were drafted in July  1977.  In the
spring of 1978, "The Rhode Island Hazardous Waste  Management
Act" was passed by the Rhode Island legislature.   The law
created procedures for communities to sue for better enforcement
of existing regulations, to challenge regulations  if considered
inadequate, and even to stop environmentally harmful actions not
covered by the regulations.

     On November 30, 1978, the Towns of North Smithfield and
Burrillville, acting jointly, petitioned the Attorney General's
office to initiate legal action against WS&G as a  hazard to
public health.  On February 2, 1979, the special  assistant to
the Attorney General stated that the evidence did  not justify
closure of the site and would not support the initiation of
legal action against WS&G under any statutory or common-law
principle.  However, legal action was considered if evidence of
pollution should develop in the future.

     Inspection of the disposal site in the spring of 1979
revealed violation of the "Hazardous Waste Disposal Facility
Rules and Regulations", which became effective December 21,.1978.
WS&G was found in non-compliance for not preparing complete and
accurate manifests which describe the chemical make-up of wastes
disposed at the site.  Also, inspections were made since
residents living near WS&G complained of noxious odors from the
dump.  State inspectors confirmed the complaints by determining
that objectionable odors could be detected beyond  the facility's
property line in clear violcation of the new State regulations.

     On April 24, 1979 the RIDOH issued an order directing WS&G
to immediately cease accepting or disposing of any hazardous
wastes.  The order also required WS&G to prepare and submit
plans to the RIDOH no later than May 7, 1979 for permanent closure
of their disposal facility.  In accordance with the RIDOH order,
the permanent closure had to take place no later than June 1,
1979.

POLLUTION

     For several years residents living near the disposal site
and local officials have been concerned that toxic and hazardous
wastes dumped at the WS&G would pollute surface and ground water
supplies.in the area.  Water samples taken in December 1978
from a stream bordering the WS&G site revealed no  bacterial or
chemical pollution.  Water samples taken from drinking water
wells located in the vicinity of WS&G also showed  no trace of
pollution attributable to the dumping site.
                             148

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     In a June 1979 meeting, RIDOH officials approved the
installation of six monitoring wells.   This was part of a
consent order for the permanent closure of the facility.  The
six monitoring wells were installed in November 1979 throughout
the disposal area and all were perforated through the entire
depth of the water table.  Well B was  installed to drill auger
refusal; the remaining were installed  to refusal or 21 m (70 ft).
Wells D and E were located in the Tarklin Brook flood plain
adjacent to the disposal site (see Figures 7-2 and 7-3).

     Information obtained from the monitoring wells, residential
wells, and Tarklin Brook indicated the presence of a contamination
plume which was stratified with depth.  Contaminants appeared
to be concentrated at the top and bottom of the stratified drift
aquifer.  Visual observation and studies of the quality of water
in Tarklin Brook shewed that it was intercepting a portion of
the plume.  Leachate seeps -in Tarklin  Brook were noted.  However,
the monitoring wells could not fully determine the location or
extent of the plume.

     Because the six monitoring wells  failed to clearly answer
questions regarding the ultimate destination of contaminants,
additional monitoring wells were required.  Ground water sampling
weTTs each with probes alTTnuTTTpTe revels were ctrosen to prwide
ground water quality information-wi th depth and to ultimately
assess the conditions of the aquifer in the vicinity of the
disposal site.  Ijni February 1980, a consulting firm under
contract to~ R-IDOU fnsTaTreeF- tfiese-muTTi -"probe wells;  The.
installation details for each sampling location are presented
in Appendix 7-1.  A summary of the field permeability tests is
included in Table 7-2.
     On February 26, 1980 representatives of the
Water Resources and the consultant met for the purpose of
and measuring the various disposal pits located at WS&6.
EPA conducted a sampling program of their own at the same
The primary purpose of  the sampling was to obtain sludge
sediment samples for PCB analysis, and to obtain samples
Division of
         samp!ing
         The "
        .time.
         and
        from
the chemical pits  for complete organic analyses.
of the pit  sampling are provided  in Table  7-3.
 The results
      Samples  from the multi-probe wells,  conventional wells,
 private wells,  and surface water were taken on February 6 arid
 7 and again on  May 1, 1980 through State, federal, and private
 testing.  Severe ground water contamination has been detected
 on the site and points downs.tream-f rom the disposal area, some
 as far as 305 m (1,000 ft) downstream .where Tarkl.in 6'fook
 enters the Slatersville Reservoir.  Chem.ical contaminants have
 also  been found in five private wells in  the vicinity of WS&G.
 Results of the  testing are presented in Tables 7-4 and 7.-5.
                              149

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           TABLE  7-2.
                          SUMMARY  OF  FIELD  PERMEABILITY
                            TESTING  RESULTS
Exploration
Number
A-2
A-2
A-2
A-2
A-2
A-2
E-2
E-2
F-2
LFRR-A
LFRR-A
LFRR-B
LFRR-B
LFRR-B
Depth
(m)
11.2
n.2
19.2
29.1
33.2
49
19
49
25-27
14.3
39.2
14.1
39.1
54.1
K- Range1
(cm/sec x 10"3)
2.3 - 2.6
0.7 - 0.8*
1.0 - 1.1
1.5 - 2.0
4.3 - 8.0*
0.4 - 0.5
0.35 - 0.37
0.41 - 0.43
—
0.4
0.15 - 0.24
0.10 - 0.14
0.5 - 0.8
1.3 - 1.9
Average K'
(cm/sec)
2.5 x 10'3
8.1 x 10-*
1.1 x 10-3
1.7 x TO'3
6 x 10-3
4.4 x 10"4
3.7 x 10-4
4.2 x 10-4
3.0 x ID"5*
4.0 x 10-4
2.0 x TO'4
1.2 x TO"4
7.0 x ID'4
1.6 x TO'3
Test Type
Flush Bottom
W1ck Test
Flush Bottom
Flush Bottom
Wick Test2
Flush Bottom
Flush Bottom
Flush Bottom
Wick Test
Flush Bottom
Flush Bottom
Flush Bottom
Flush Bottom
flush Bottom
Soil Strata
Description
Stratified Sand
Stratified Sand
Stratified Sand
Stratified Sand
Stratified Sand
Silty Sand
Fine to Medium Sand
Stratified Sand
Glacial Till
Silt
Silt
Silty Sand
Silty Sand
Fine to Coarse Sand
NOTES:
1.

2.
3.
K represents average mean coefficient of permeability for flush bottom tests and average horizontal permeability for
wick tests (denoted *).
Constant head test.  (All others falling head.)
                                   v (1
   Calculations based on equations from Hvorslev (1949).
1 OH

1 IK
  0.4 In.
  3.28 ft
                                          150

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TABLE 7-3.  ANALYTICAL RESULTS FOR PIT
          SAMPLING ON 2/27/80
	 RTF-
Parameter Sludge
Arsenic (mg/kg) 0.8
Lead (mg/kg) 7.0
Mercury (mg/kg) <0.3
Toluene (ppb)
Xylene {ppb)
Tetrach loroethylene
(ppb)
Trichloroethylene (ppb) —
1 ,1 ,1-Trichloroethane
(ppb)
Methylene Chloride (ppb)—
Chloroform (ppb)
PCB (ppm) <50.0
Top
0.5
32.0
<0.3
20,000
390,000
2,900
1,600
6,800
2,800
"
Pit 2
Liquid
360
630
2
5
—
— ~
Sludge
0.6
8.0
<0.5
—
—
-~
pit
0.4
38.0
0.5
31 ,000
410,000
250,000
220,000
300,000
—
3
u
71 h^ O U3
3 •••II
3 O (-» O 1 1
; *
—
—
—

270,000
1,40Q,000
210,000
72,000
56,000
75,000
5 600

Pit 4
6,300
9,700
19,000
25,000
21,000
66,000
--

SI udge
0.6
82.0
<0.3
	
—
—
' Pit 5
Parameter Sludge
Arsenic (mg/kg) <0.2
Lead (mg/kg) 20.0
Mercury (mg/kg) 0.4
Toluene (ppb)
Xylene (ppb)
Tetrachl oroethyl ene
(ppb)
Trichloroethylene (ppb) —
1 ,1 ,1-Trichloroethane
(ppb)
Methylene Chloride (ppb) —
Chloroform (ppb)
PCB (ppm) <50
Pit 6
Sludge
0.3
98.0
1.0

	

-
	
__
__
<50
Pit )
Sludge
0.5
38.0
<0.5

__

—
-_
—
	
<50
Pit 8
Sludge
0.3
58.0
<0.5

	

—
^_
_._
	
<50
Pit 9
Sludge
8.0
538.0
0.3

	

« ' -
	
__
	
<50-
Pit 10
SI udge
0.4
42.0
<0.5

	

~
	
	
	
<50

Top
0.5
26.0
<0.5
23,000
120,000

420,000
7,100
1,200

—
Pit 11
Liquid

	
	
680
730

3
650
510

	

SI udge
2.0
32.0
<0.2
	
	

—



	
                  151

-------
TABLE  7-4.    ANALYTICAL  RESULTS  FOR  WELL  AND
              STREAM  SAMPLING  ON  2/7/80

Parameter 	
Benzene (ug/1)
Toluene (ug/1)
Xylcnc (ug/l)
Carbon Tetrachloride (ug/1)
Trichloroethylene (ug/1)
1,1.1-Trichloroethane (ug/1)
Browodlchlorocnethane (ug/1)
Chloroform (ug/1)
Dibronochloromo thane (ug/1)
PCS (ug/1)
Tetrachloroethene (ug/1)
Arsenic (sag/1 )
Barium (ng/1)
CadniuR (nig/1)
Chromium (mg/1)
Copper (iag/1)
Lead (iwj/1)
ItltHU V***;!/ ' /
Kercury (»g/l)
Nickel (wg/l)
Selenium (mg/1)
Silver (ng/1)
Zinc (rag/1)
F3-1
<200
164
533
<1
12
56
<1
7
<1
2
	
—
—
:;
—
"
F3-2
<20
<20
<20
<1
<]
<1
<1
<1
<0.005
< 0.033
< 0.002
<0.02
<0.02
< 0.005
<0.0018
<0.02
<0.005
<0.02
OO1
F.2-1
11,077
21 ,560
18,880
<1
2,033
<1
9,020
<1
<20
368
0.115
1.12
0.13
0.26
no
0.12
0.0018
3.9
<0.005
<0.02
120
£2-2 £2-3 F.2-4 A2-1 A2-2
<20
66
28
<1
4
18
<1
14
<1
5
< 0.005
0.21
< 0.002
<0.02
<0.02
<0.005
<0.001
<0.02
<0.005
<0.02
-2
2,091
6,070
9,710
<1
1,176
2,525
<1
1,085
<1
<20
280
0.062
0.70
0.09
0.23
20.5
0.021
0.0012
3.7
<0.005
<0.02
60
3,098
12,314
16,152
<1
1,343
2,678
< 1
779
<1
<40
222
0.32
0.60
0.10
1.2
92.0
0.10
0.0022
4.0
< 0.005
<0.02
128-
<20
<20
<20
<1
<]
<1
*!
<1
0.031
0.31
0.004
0.06
0.33
0.46
0.0012
0.17
< 0.005
<0.02
3^
<20
<20
<20
*1
^1
^1
<1
**1
<0.005
0.032
< 0.002
<0.02
0.06
0.11
<0.001
0.02
<0.005
0.02
0.11
— AJPT"
<20
<20
<20
<>
<1
^1
*1
"^ 1
<20
0.012
0.20
0.005
0.05
0.31
0.13
0.0012
0.16
0.005
0.02
5.0
              Parameter
                                          Stream Location
                                       SI
                                                 52
                                                         S3
         1,1,1 Trichloroethane (ppb)        <1          1        18
         Benzene (ppb)                  <20        <20       <20
         Toluene (ppb)                  <20        <20       <20
         Xylene (ppb)                   <20        <20       <20
         Chloroform (ppb)                <1         <1        <1
         Carbon Tetrachloride (ppb)        <1         <1        <1
         Trichloroethylene  (ppb)           <1         <1        3
         Tetrachloroethylene (ppb)         <1         <1     '<1
         Bromodichlororaethane (ppb)        <1         <1        <1
         Dlbromochloromethane (ppb)        <1         <1        <1
         Turbidity                       0.5        1.2      9.3
         Dissolved 0*ygen                12.7       12.5      2.8
         BOO                            111
         pH                             7.0        6.2      6.0
         Amnonia                         0.04       0.04     0.06
         Alkalinity                      4          5        11
         Chloride                        6          9        22
         Suspended Solids                 052
                                   152

-------
TABLE 7-5.
 ANALYTICAL RESULTS FOR WELL
SAMPLING ON 5/1/80
Parameter
Benzene (ppb)
Hylene (ppb).
Toluene (ppb)
Chloroform (ppb)
Bromodichloromethane
Bromoform (ppb)
Dibromochloromethane



(ppb)

(ppb)
F3'-l
<20
I'?
<1
<1
<1
	 F3-2 ' '
<20
<10
<]
<]

-------
REMEDIAL ACTION

     Because of the immediate health threat to citizen's living
in the surrounding area, RIDOH has been under pressure to clean-
up the site.  RIDOH issued an order against WS&G in December
1979 requiring WS&G to remove al.l  waste materials contained in
the pits within a specified timeframe.   WS&G did not comply with
this order.  As a result, RIDOH obtained legal authorization to
undertake closure of the site.

     Because wastes continued to seep into the subsurface from
the pits, the EPA assumed jurisdiction  under the 311 provisions
of the Clean Water Act in February 1980 and ordered the removal
of the contents from four pits containing hazardous wastes.  Work
began on March 4, 1980 and 144 m3 (38,000 gal) of liquid were
pumped and transported to Stoughton, Massachusetts for storage.
In addition, 296-0.2m3 (55 gal) drums of sludge were removed
from the pits and are now stored at the site.  An additional amount
of sludge and contaminated sand has been mixed with sawdust and
covered with polyethylene and stored at the east end of the pits.

     On February 20, 1980, RIDOH was given authority to hire a
private firm for the removal  and disposal of the liquid and
sludge septic wastes not removed under  311 work.  Three alterna-
tives were proposed:  (1) sludge waste  removal for on-site
storage; (2) sludge waste removal  for off-site disposal, and
(3) sludge waste disposal on-site.  An  agreement has been reached
with the Blackstone Valley District Commission for the disposal
of the liquid septage at their facility in Lincoln, Massachusetts.
An estimated 317 m3 (415 yd3) of septage will be removed at the
direction and expense of RIDOH.

     An interim hydrogeologic report prepared by a consultant in
June  1980 concluded that "the major water quality threat is to
private wells down-gradient of the disposal site, primarily in
an area to the west of Tarkiln Brook and south of the Slatersville
Reservoir.  Therefore, if a do nothing  policy is adopted, a
permanent alternate water supply will have to be provided for
homes served by domestic wells located  in the plume." [7-1]

     The cost to the State of Rhode Island for the removal of
wastes at WS&G is estimated to be over  $1,000,000.  The
pumping of the septage and chemical wastes and its removal and
disposal is estimated to be $483,724.  If a leachate collection
and treatment system is installed it will cost approximately
$362,000.  Contingencies could cost another $250,000.  The
breakdown of total estimated costs is given in Table 7-6.

CONCLUSION

     Considering the poor records and disposal methods encountered
at this site, the identification of the precise limits of
                             154

-------
          TABLE 7-6.  ESTIMATED REMEDIAL ACTION COSTS
Pumping out septage pits (963,000 gal @
     $0.04/gal)
     Tipping charge (@ $8.00/1,000 gal)
Pumping out chemical pits (250,000 gal @
     $1.25/gal)
Sludge removal and disposal  (100,000 gal @
     $1.25/gal)
Well  points
Leachate collection and treatment (2 years)
Site  preparation
Impermeable membrane
Subtotal
Contingencies (@ 30 percent)
Total
$   38,520
     7,704

   312,500

   125,000
    12,000
   270,000
    40,000
$  835,724
   250,717
$1 ,086,441
                              155

-------
contaminated ground and surface water has  been  a  costly under-
taking.  Since the mere identification of  the problem was  not
considered a solution, RIDOH proposed to establish  a  means  of
dealing with the situation before it had an  opportunity to  spread
to adjacent land and water supplies.

     The remedial  action taken by EPA under  311  funds to remove
the hazardous wastes and the proposed work under  the  authority
of RIDOH to remove septic wastes is a starting  point  for the
complete clean-up  of the site.  However, remedial  action should
have been initiated long before the 311  work.  WS&G is hydro-
geologically a poor location for a hazardous waste  site.  WS&G
should never have  been permited to accept  waste and immediate
action should have been taken when it first  became  evident  in
1976 that WS&G was causing problems.

     Of the remedial actions available to  abate or  control  the
contamination plume, the leachate collection and  treatment
system appears to  be the most cost-effective.  A  well point
dewatering system  could be implemented.   Since  the  contamination
plume has migrated beyond the boundaries of  WS&G,  it  would  be
necessary to install a number of wells further  down-gradient
from the main cluster of wells.

     If remedial actions are not initiated,  the ground water
and the Slatersville Reservoir will likely become  extensively
contaminated.  Alternate water supplies, including  new reservoirs
and a public water supply system to local  residents,  would  be
needed in the near future.  In addition, it  will  jeopardize the
economic, industrial, and domestic development  of the region as
well as endangering the health, safety,  and  welfare of the
citizens.  These costs far outweigh the  costs of  cleanup.
                               156

-------
          SITE F REFERENCES AND BIBLIOGRAPHY
7-1,




7-2,



7-3


7-4
Johnston, H.E. and D.C. Dickerman.   "Availability of Ground
Water in the Branch River Basin, Providence County, Rhode
Island".  U.S. Geological Survey Water Resources Investi-
gation 18-74.  December 1974.
Barvenik, Matthew
Sampling Systems"
80-3.
and Richard
  Landfills
                              Cadwgan.    "BarCad Groundwater
                              and Lagoons,  Technical  Bulletin
Preliminary Hydrogeologic Report by Goldberg, Zonio, and
Associates, Inc.  Newton Upper Falls, Massachusetts, 1980.

Personal communication and file review with Frank B.
Stevenson, Principal Engineer, Division of Air and Hazardous
Materials, Department of Environmental Management.
Providence, Rhode Island.  June 1980.
                         157

-------
             APPENDIX 7-1

MULTI-PROBE WELL INSTALLATION DETAILS
              FOR SITE F
                 158

-------

-SOIL DESCRIPTION- r
E
DEPTH
_ .
"
-I-
FINE SAND. 3-0nrr~
LITTLE TO
SOME SILT
| —

6.1m— [Z -

1 —
t —
1 —
i —
1—
g | m 	 t=r-
FINE TO COARSE
SAND, LITTLE TO 77

TRACE SILT l^-^m prr-

t

(=
15.2m— 1=-
« —

— r i
*\
\
1 '
_L1_
	
. -^ —
	
— —
_ —
	
_ — .
\
•3
fej
SLOTTED 11/2" l.D.STEEL PIPE

—1
" — 1
— -j
- -1

— -4
— I
^ — i
	 1
— / — ~i
_ j- — i
Y/I////\
fi
WELL POINT A-2-2
I
^/ / //A
— 	 .

	 _i
rzr i^l
— — -^^1
	 1

1 	 -1


SOMt SILI ////V S / yl
STRATIHtU WIIH
FINE SAND AND
SILT 18.3m—
	 FINF Tft r-rtACWF SAKJB I-T-
Q 1 WELL POINT A-2-3
, , , , , r\
H=^=_-^--=-4
BEDROCK -GRANITE
= 3.28ft
                       159

-------
                      INSTALLATION DETAIL E-2
-SOIL DESCRIPTION- IT
Z
L_j?
3.0m _
V

6.1m— Kx/
t= ' =
FINE TO COARSE 1= :
SAND, TRACE GRAVEL, ^- -
TRACE SILT WITH & :
LAYERS OF FINE SAND fc= -5
Cruuip OH T- R MPIt Q*l m S S ^
TOCOARSE SAND, |
TRACE SILT |

E E
12.2m— |=t
K/>
J
h

I5.2m_ ^x^
£^
FINE TO COARSE I8'3rn~fe:_r7
SAND,SC*£ GRAVEL, ^~r:
SOME SILT Y7"7
\
21 3m 1
r-i

uimmmni
F
1
/ /

S~S

'/
''A
' / j
b

•^C
1-JZ~Z
w

-------
                         INSTALLATION DETAIL F-3
-SOIL DESCRIPTION-



FINE TO MEDIUM
SAND






E-~
E~
[|=1
3.0m- ZZZ
I
1
1
1
\tl , , j
FINE TO COARSE SAND (' "1
6 FINE TO COARSE 1 p
9.1m 1 *-

Er^3
• - H
--=1

'77J
•


SLOTTED 11/2" I.D STEEL PIPE

WELL POINT F-3-2
VVW
 BEDROCK
    3.28ft
                       161

-------
   APPENDIX 7-2



SITE F PHOTOGRAPHS
       162

-------
Two waste disposal pits at Western Sand and Gravel
Note the excavated sand characteristic of the
disposal site.
                    1,63

-------
Location of leachate seep into Tarklin Brook
emanating from the disposal pits.
View of the sludge contaminated sand  and sawdust
mixture stored at Western Sand and Gravel.   Note
the polyethylene cover.
                    164

-------
Collecting samples from multi-probe well  used
provide ground water quality data at Western
Sand and Gravel  site.
to
                    165

-------
                          SECTION 8

                            SITE G
                       FERGUSON  PROPERTY
                    ROCK  HILL, SOUTH  CAROLINA
 INTRODUCTION

     Approximately 2 ha  (5 ac) of land in north-central South
 Carolina was leased from the  Ferguson Family by  Industrial
 Chemical Company, Inc.  (ICC)  in the mid-1960ls.  The land was
 used to store solvents  prior  to their reclamation.  In 1966 ICC
 vacated the site, leaving behind approximately 2,500 to 5,000
 drums of waste.  Subsequently, the situation came to the attention
 of the South Carolina Department of Health and Environmental
 Control (SCDHEC) in 1976.  A  site investigation  found many of the
 drums to be corroded and leaking.  Sample analyses of the drummed
 material revealed highly flammable and toxic material.  It was
 suspected that some of  the leakage had seeped into a nearby
 stream.

     SCHDEC attempted to persuade ICC and the landowner to
 come to a mutual agreeement for cleaning up the  site.   Since
 neither party would accept responsibility and since the site
 represented a fire and  pollution hazard, the U.S. Environmental
 Protection Agency (EPA) Region IV, Environmental  Emergency
 Branch (EEB) initiated  cleanup activities.  After their first
 containment attempt was ineffective, EEB returned to remove
 drummed wastes and contaminated rainwater.   The contaminated
 rainwater was removed and hauled to a wastewater treatment plant
 for processing.  A substantial amount of the drummed waste was
 removed from the site and reclaimed, with deteriorated drums and
 some contaminated soil  buried on-site.

     Currently some liquids and sludges  in drums  and tanks remain
 at the site, even after the second remedial  activity described
 above.   It is expected that some additional  actions will  be
 necessary to remove the long term threat to  the environment.  To
 this end,  the SCDHEC is pursuing legal  action to  assign
 responsibility for future cleanup costs.

 SITE DESCRIPTION

     As shown in Figure 8-1,  the site is  located  in north-central
 South Carolina about 3  km (2  mi)  west of the City of Rock  Hill.
The site occupies 1.2 to 2.0  ha (3 to 5  ac)  of  42.3 ha  (104.5  ac)
owned by the Ferguson Family.   The site  is bordered by  a  tributary
to Fishing Creek, which is  a  tributary  to the Catawba  River.

     The area's normal  precipitation is  approximately  107  cm/year
 (42 in./year);  average  snowfall  is  approximately  13 cm/year (5 in^./
                              166

-------
year).  The annual average wind speed is 12 kph  (7.5 mph).  The
average daily high temperature is 16°C  (61°F), with the highest
daily maximum in July at 31.3 C (88.3°F) and lowest in January
at 0.1°C  (32.1°F).

     The  topography of the area is characteristically rolling
hills.  The slope range is 0 to 30 percent and the total  relief
is about  15 m (50 ft).  Vegetation is extensive, covering nearly
all of the land.  The site itself was covered with tree growth
and kudzu  (a leguminous vine) prior to  implementation of  remedial
measures.

     Deep  ancient soils (saprolite) developed in the general area
on Precambrian,and Paleozoic metamorphic and igneous bedrock.
.Little site specific  information exists about the stratification
and depth  of soil to  bedrock underlying the site.  It is  known
that a minimum  2 m (8 ft) thick layer of red clay soil covers the
former drum storage area.  The depth to ground water is likewise
unknown;  however, ground water movement occurs through a  network
of irregularily spaced fractures.  Small springs or diffuse
seepage issuing from  fault zones or joints are sources of
recharge  for area streams.

     The  site is located in the Piedmont Province approximately
24 km  (15  mi) west of the Fall Line, a  sharply defined boundary
marked by  a line of rapids and falls separating  the sljghtly
elevated  rocks  of the Piedmont Pro vini:e^froflr~the~ToweT" format ions
of the Atlantic Coastal Plain.  The crystalline  metamorphic and
igneous rocks of the  Piedmont Province  are grouped in five north-
east trending lithologic belts which are interpreted to be
zones  of  different grades of regional metamorphism.  Underlying
the site  is the Charlotte Belt, which is composed of feldspathic
gneiss and migmatite  of the albite-epidote amphibolite facies.
Cross-cutting granite fills fractures.  Granite"piutons shaped
like  inverted tear drops occupy folds in localized regions to
the east.

SITE OPERATION  .AND HISTORY

      Industrial Chemical Company,  Inc.  (ICC) operated as  a solvent
reclaimer, extracting useable solvents  from chemical wastes by
distillation.   During the years 1963 to 1966,  ICC leased  lands
belonging to  L.B.  Ferguson, Sr. for storing reclaimable industrial
waste  solvents.  In practice, the  Ferguson property was used more
for drum  storage  than reclamation.  Materials  such as paints,
inks,  and solvents were brought to the  site in 0.2  mj  (55 gal)
drums  and stored  in drums and tanks prior  to reclamation.

      When "the original  landowners, Mr.  and Mrs.  L.B.  Ferguson,  Sr. ,
died  in  a car accident, the property ownership was placed in an
estate.   In  1967,  a dispute arose  between  the  heirs to the  Ferguson
                               167

-------
Figure 8-1.   Location  of Ferguson site  in  Rock Hill,
                    South Carolina.
                         168

-------
estate and ICC regarding the lease.   According to W.  D.  Neal ,
president of ICC, one of the property heirs demanded  immediate
payment of rent due.   Since ICC was  unable to make immediate
payment, ICC was informed that neither-officers nor employees
of ICC were allowed to enter the property for any purpose.  [8-1]

     ICC vacated the  site in 1967 and since that time has had
no dealings with the  Ferguson heirs.   ICC is a small, family-owned
corporation.  After vacating the property in 1967, ICC purchased
property outside of Rock Hill and moved thei r_ operations to that
site, where it now has a permitted  incinerator and landfill.

POLLUTION

     For a period of  four years, the South Carolina Department of
Health and Environmental Control (SCDHEC) tried to persuade the
Ferguson heirs and ICC to come to a  mutual agreement  for removing
drums on the Ferguson site.  The first SCDHEC site inspection  was
conducted in March 1978, revealing  2,500 to 5,000 corroded,
leaking drums.  These drums were unprotected from the elements
and placed directly on the ground.   Drums were stacked three  or
more high in many places and were either leaning or fallen over.
A large number of drums had also been stacked on the  bank of  a
small stream bordering the site.  There were no provisions to
prevent leakage of drum contents from entering the stream.
Brush growing around  the drums indicated that the site had not
been maintained for several years.                     x

     In October 1978, acting under  South Carolina's "Emergency
Regulations for Storage of Hazardous Waste", SCDHEC tried to  get
the two parties to voluntarily resolve the problem at the site,
requesting that a mutually agreed-upon plan be- submitted to
remedy the hazards.  Again conferences were scheduled to finalize
the agreement between the two parties, but no agreement could
be reached.  SCDHEC personnel re-inspected the site in July 1979
and collected representative samples for analysis to  determine the
toxicity of the material.  Analyses  revealed highly flammable
and toxic wastes.  The inspection also revealed no change had
occurred from the time of the previous inspection and that some
discharge into the environment was  occurring.

     In October 1979, samples were  collected from the site by
the U.S. EPA Surveillance and Analysis team out of Atlanta,
Georgia.  Analyses revealed hazardous substances similar to the
chemical compounds being incinerated and reclaimed at the new
ICC facility.  If these were the same wastes, they could be
expected to include dirty paint and  ink solvents consisting of
compounds such as xylene, ethyl chloride, diethyl carbomethoxy
phosphate, alcohols,  ammonia, and acetic acids.  Table 8-1 lists
concentrations of primary pollutants found in the drummed waste
                               169

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                   TABLE  8^1

1979 U.S.  ENVIRONMENTAL  PROTECTION  AGENCY
       DRUM AND  SOIL ANALYSIS  [8-1]
        Pollutant
                                    Concentration (mg/Kg)
                               Drummed Waste
                                              Soil
Lead
Chromium
Zinc
Copper
Napthalene
Dimethyl Phthalate
Bis (2-ethylhexyl) Phthalate
Aroclor 1 ,254
1,1,1-Trlchloro ethane
Benzene
Toluene
Ethylbenzene
20,430
. 3,450
1 ,987
125
82
1,500
1,800
67
26
93
340,000
7,400
394
335
1 ,471
175
ND
ND
1 ,800
ND
ND
ND
9.1
<5
ND * Not Detected.
                       170

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                                             .f-
and in the soil.   Concentrations of priority pollutants  in  excess
of background levels were not detected in the creek.   However,
the investigation was conducted in dry weather.  High concentrations
would be more likely in wet weather when rainfall  could  carry
ppllutants from the site surface into nearby drainage ways.

     Another site inspection was conducted by the  SCDHEC and U.S.
EPA Region IV Environmental Emergency Branch (EEB) in December
1979.  No significant change in site conditions was found.
Figure 8-2 displays the location of drums prior to remedial
activities.  The site is located near residences,  a heavily
traveled highway, and a stream.  If the stacked drums along the
stream edge fell  and ruptured, the stream could become contaminated.
In addition, it was suspected that large quantities of chemicals
had discharged into the stream over a period of years from 800
empty drums stacked at the edge of the stream.   However, stream
samples never indicated detectable contaminants.  In addition to
potential stream and soil contamination, the drummed chemicals
left on the Ferguson property posed a fire hazard.

REMEDIAL ACTION

     When it was determined that an agreement  between heirs of
the  Ferguson property and  ICC was unlikely to  be consummated in a
timely manner, EEB  initiated a  311 action to eliminate the fire
hazard and prevent  further contamination of the stream and soil.
Temporary containment measures  implemented by  EEB included
removal and relocation of  drums and construction of an under-
ground storage area.

      During cleanup operations, workers  used vinyl suits, plastic
splash guards, and  carbon  canister masks.  Oil  in a 23 m3 (6,000
gal )  tank was purchased and removed by Alternate  Energy Resources of
Augusta, Georgia.   The empty tank was repositioned and used for
storage of liquids  withdrawn from deteriorated  drums.  Chemicals
were  transferred from rusting  leaking barrels  to  durable containers
and  relocated away  from the stream.   The ground above the creek
was  leveled- with bulldozers and intact  barrels  were arranged in
rows  and  sections.   Earthen dikes were  constructed around each
section of drums.   To prevent  rainwater  infiltration, the sections
were  covered with  a  double  layer  of  0.1  mm  (4  mil) polyethylene
and  thence a 15  cm  (6  in.)  thick  layer  of clay to  prevent
infiltration of  rainwater.   Pipes were  installed  through the
cover to  vent any  build-up  of  pressure  inside  the  mound.  A dike
a'nd  diversion ditch was  constructed  around  the area  to divert
runoff and the area  was  seeded.   A  total of  1,835  drums were
moved to  the storage  area  and  800 empty  drums  were crushed' and
stored in  a  containment  trench.   The  complete  process took  the
contractors  (O.H.  Materials,  Inc.,  of Findlay, Ohio)  and the EPA
                              171

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                  °o0o°0o000°°°0oco Coo ^
Figure 8-2.  Location  of drums on Fenguson property.  [8-1]
                            172

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Region IV EEB about a week to
remedial  action was completed
about $55,000.
complete.
on January
This phase of
29, 1980 .at a
temporary
.e~ost of
     In mid-March 1980, approximately six weeks after completion
of the above activities, the SCDHEC noticed that the vent pipes
installed in the burial mound were discharing liquids resembling
contaminated rainwater.  It was speculated that the fumes from the
waste had decomposed the polyethylene cover allowing overlying
soil  to cave in.  Approximately 20 cave-in areas were noted in
the burial  mound.  It was suspected that rainwater had entered
the buried  sections containing the drummed waste through these
cave-in areas.

     Region IV  EEB responded promptly to clean up the contaminated
rainwater.   The water was  first pumped from the four disposal
sections and collected in the on-site bulk storage tanks.  A
collection  trench was constructed near the creek to prevent
spill drainage  entering the surface water.  The solvents were
sampled by  M&J  Solvents of Atlanta, Georgia to determine the
feasibility of  reclaiming them.  Samples were also taken of the
contaminated  rainwater and analyzed by an EPA contractor and the
SCDHEC.  Analyses revealed that the contaminated rainwater could
be processed at the Rock Hill Manchester Creek Wastewater
Treatment Plant; it was also determined that the solvents could
be reclaimed.

     Subsequently, the contaminated rainwater was hauled to the
treatment plant and 140 m3 (38,000 gal) of solvents were pumped
out of the  barrels and trucked to M&J Solvents in Atlanta.  The
emptied drums  were removed from the burial cells to a separate
diked area  where they were crushed for later disposal.  All of
the remaining  solids, contaminated soil, and empty damaged drums
were  consolidated,  crushed, and buried in saw dust pits.  The
pits  were then  covered with top soil and the area was seeded.
Approximately  70 drums, which were in good condition, were
consolidated and placed at the upper end of the site.  Approximately
7.6 to 11 m3 (2,000 to 3,000 gal) of wet sludge were left at the
site  in two tanks.

     Figure 8-3 displays the pit, barrels, and tank locations at
the site after  completion of the second set of remedial  activities.
Approximately  two weeks were required for the second temporary
remedial activity.  The second set of remedial actions cost
$88,000 bringing the total temporary remedial cost to $143,000.
Table 8-2 further defines the cost of the two temporary  contain-
ment  efforts*   As was stated before, this action was carried out
to minimize potential fire hazards and the possibility of a
chemical spill  reaching the nearby stream.  The permanent/long term
remedial action will be forthcoming when a legal determination
has been made  as to the responsible party.
                              173

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Figure 8-3.   Site layout  after  remedial  action
            at the Ferguson  property.  [8-1]
                      174

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       TABLE  8-2.
COST  OF CONTAINMENT  REMEDIAL MEASURES
    AT FERGUSON PROPERTY  [8-3]
         Item
                                     Expenditures by  Region IV EEB
                                I/2I/8U-      	3/I2/8U-	
           1/28/80
3/29/80
Total
Labor and  other expenses         $31,056
Per Diem                          3,640
Subcontractor: (subcontractor
  and rental equipment)           17,844
Miscellaneous  (stone, seed,
  sawdust, plastic, etc.)          2,512
Total                           $55,052
                           $56,259
                             6,232

                            22,968

                             2,667
                              .126
               $ 87,315
                  9,872

                 40,812

                  5,179
               $143,178
                                  175

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CONCLUSION

     When the environmental problems at the Ferguson property
were first discovered in 1976, SCDHEC tried to persuade both
parties to remove the corroded, leaking drums containing flammable
chemicals.  Neither the Ferguson heirs nor ICC were willing to
meet together and discuss and resolve the problem.  SCHEC did
not have legal power t'o force removal of the drums.  There were no
regulations governing how hazardous wastes could properly be
di sposed.

     Since neither the landowner nor ICC would accept voluntary
responsibility for the barrels, EPA resorted to 311 action to
contain the site for a two to four year period.  It was believed
that the temporary cleanup measures as outlined by EEB would keep
the cost down and 'would allow pressure to be maintained on one
or both parties to achieve permanent disposal of the barrels.
However, the first measures instituted by EEB were not adequate.
EEB was required to return to the site, remove the solvents, and
crush the drums.  The solvents were sent to a solvent reclaimer.
The crushed drums, solids, and contaminated soil were all buried.
The site was then regraded, diversion ditches were installed,
and the area was seeded.

     The total cost of the two temporary corrective actions was
approximately $143,000.  Both actions were to ensure no seepage
problem occurred while the State legally determined the responsible
party.  The State is responsible for ensuring completion of
permanent cleanup actions once the responsible party is "determined.
Permanent cleanup would include removal  of the remaining solvent
waste (i.e., drummed solvent waste and the oil sludge waste
located in the tanks).
                              176

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              SITE G REFERENCES AND BIBLIOGRAPHY
8-1   Personal  communication and file review with Gary Hogue,
     Environmental  Quality Manager, Catawba District, South
     Carolina  Department of Health and Environmental Control,
     Fort Lawn, South Carolina.  June 13, 1980.

8-2   Personal  communication and file review with Joe Young, U.S.
     Environmental  Protection Agency, Region IV, Residual
     Management Branch, Atlanta, Georgia.  May and June 1980.

8-3   Personal  communication with Jan Rogers, U.S. Environmental
     Protection Agency, Region IV, Environmental Emergency
     Branch, Atlanta, Georgia.  May, June, and July 1980.
                               177

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   APPENDIX 8-1



SITE 6 PHOTOGRAPHS
      178

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Site appearance prior to any remedial  action.
 During the first applied remedial  action the
 drums were placed in trenches and  a plastic
 liner placed on top prior to soil  addition.
                   179

-------
               i,.:  .,• '  :-« JPi.JWflP"«f   "   '- •'₯*'• -•*•"», -V ,-..!?» .:'•••!'--,-|
               \*jr,f* *^if*'**^*,--^ JV"';""r "'•	•4-'-«*^Ci-'!f"- -••-*"ftW
               Igji*"	j •:r^»^ '.	jlf ' _^my*- 	;.!.	'. ",..'.±i.,?,}i»L:r*,:•,.,:, .'.j±'£ilfJSir


             Burial  area following second  cleanup
^^^^!:^,i:j,:^::^i:_	:
        Drainage diversion ditches  around  burial  site.
                                  180

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 38 m3 (10,000 gal) barrel containing solvent sludge
   remaining at site pending further cleanup.

Approximately 70 barrels in good condition  left  at
            site pending further cleanup.
                       181

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                          SECTION 9

                            SITE H
                          3M COMPANY
                     WOODBURY, MINNESOTA
INTRODUCTION

     From 1960 until 1966, spent solvents and acids from the
Minnesota Mining and Manufacturing (3M) Chemolite and St. Paul
scotch tape, sandpaper, and chemical  manufacturing operations
were disposed in pits at a site in Woodbury Township, Minnesota*.
In May 1966, a nearby private well was found to be contaminated
with isopropyl ether, an organic solvent.  Subsequently, disposal
in the pits was discontinued and comprehensive monitoring of
other wells in the area initiated.  Based on the data collected,
it was determined that only the one originally affected well had
been contaminated with organic solvents.

     In January 1968, the waste in the pits was removed and burned
on-site.  Between 1966 and 1971, solvent waste produced by 3M was
sent to incinerator facilities off-site.  Better controls were
then exercised over in-house operations to reduce the amount of
waste requiring disposal.  In 1971, an incinerator was constructed
on-site by 3M to dispose of waste solvents.

     To prevent further migration of pollutants in the ground
water, four barrier wells were installed at the Woodbury site.
These wells are pumped continuously,  and discharged to the
Mississippi River.  Monitoring data collected since implementation
of these actions indicates that the barrier wells are effective
in preventing further contaminant migration.

SITE DESCRIPTION

     Figure 9-1  shows the location of 3M's Woodbury disposal site
in relation to Chemolite, Minneapolis, St. Paul, and the
Mississippi River.  The 3M Woodbury disposal  facility is located
on the eastern side of the Twin Cities Metropolitan Area.  The
3M Chemolite manufacturing facility which provited a major
portion of the waste disposed at the  Woodbury site, is located
about 6 km (4 mi) south of the Woodbury disposal facility.

     The normal  annual  precipitation  for the area is 66 cm (26 in.)
and the normal annual snowfall is 117 cm (46 in.).  The average
wind speed is 16.9 kph (10.5 mph).  The annual  daily maximum
temperature is approximately 12°C (54°F) with the monthly high
occurring in July at 28°C (82.4°F), and lowest  in January at
-6°C (21.20F).
                              182

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                          MINNEAPOLIS-ST.RAUL
                              AND VICINITY
Figure 9-1.   Location of 3M disposal  site
         •  in  Woodbury, Minnesota.
                     183

-------
     The geology in the area consists of Paleozoic bedrock over-
lain by glacial drift averaging 15 to 30 m (50 to 100 ft) thick.
The site lies in a buried glacial valley.  During an earlier
time period, the valley was apparently cut by a tributary which
fed into the nearby Mississippi River.  The channel  was subse-
quently filled with sand and gravel from more recent glaciation.
The buried bedrock channel trends in a northwest to  southeast
direction and was carved out of the Shakopee-Oneota  and Jordan
Formation.

     Beneath the glacial outwash, Platteville Limestone, a
medium dense gray shaley limestone, overlays the St. Peter
Sandstone.  The St. Peter Sandstone in turn overlays the
Shakopee-Oneota Dolomite, which overlies the Jordan  Sandstone.
The Shakopee Dolomite contains fractures possibly created by
previous glacial loadings.  The pits at the Woodbury disposal
site are located in the glacial outwash over the Shakopee Dolomite,
Therefore, it is speculated that if any contaminants reached
the Shakopee, easy access would be provided to the underlying
Jordan Aquifer.

     The outwash glacial material in the area is typically clay
and gravel.  The soil is a sandy loam provided by the glacial
material and is reasonably fertile.  The limestone provides an
alkaline pH to the soil.  The soil lends itself to drought
conditions due to its sandy nature.  The topography  of the area
is also influenced by previous glacial movements.  The land is
slightly rolling to flat with only minor ravine systems.

     There are no drainage creeks or rivers in the immediate
site area since the glacial till acts as a sponge.  The surface
drainage of the Twin Cities area consists of potholes, swamps,
lakes, and a few small  river tributaries to the Mississippi
and Minnesota Rivers.  Due to the nature of the glacial drift,
drainage channels appear for only a short distance before
terminating in marsh areas.  The only significant drainage rivers
in the area are the Mississippi and Minnesota.

     The primary commercial and residential water supply for the
area is ground water.  The Jordan Aquifer supplies water for
industries in the Twin Cities area.  Prior to installation of
the barrier wells, two bodies of ground water existed under the
pits in Woodbury:  perched water and the Jordan Aquifer.
Figure 9-2 displays a generalized geological cross section of
the area beneath the site.  Previous to barrier well installation,
the perched water located in the glacial drift below the pits
supplied water to shallow wells in the area.  However, within
                          well installation, all perched ground
                          had dissipated.  Thus, the only
three years after barrier
water in the glacial till
ground water.body now located beneath the old pit area is the
Jordan Aquifer.  While it existed, perched water in the glacial
                             184

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-1000
-800
                                                      SHAKOPEE-ONEOTA OOtDMITE
_600
_500'
                                                      JORDAN SANDSTONE
     ORIGINAL STATIC WATER LEVEL PRIOR TO BARRIER WELL INSTALLATION
  Figure 9-2.   Geological  cross section of area beneath
                 Woodbury  disposal site.  [9-1]
                                  185

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drift tended to flow southwestward to south toward the Mississippi
River.  The Jordan Aquifer, however, flows northwest from the site
toward Minneapolis and St.  Paul.

SITE OPERATION AND HISTORY

     In 1960, Terminal Warehouse purchased 12 to 16 ha (30 to 40
ac) of farmland in Woodbury, Minnesota for use as a waste
disposal  site.  Wastes from 3M manufacturing plants were hauled
and disposed by Terminal  Warehouse in unlined lagoons (.pits)
at the Woodbury site.  In August 1961, 3M purchased the land from
Terminal  Warehouse and continued to use it for disposal of waste
from their Chemolite plant (located in Cottage Grove, Minnesota)
and downtown St. Paul facility.  Pits on the property were used
by 3M for dispsoal of spent solvents, sludges, and solid wastes
(e.g., scrap plastic).  3M also permitted Woodbury Township to
dispose their municipal  waste in the southeast corner of the
property.  Figure 9-3 shows the location of the pits at the
Woodbury site.  The small amount of Woodbury municipal waste
disposed at the site was  segregated and kept outside the pit
areas used for solvent,  acid, and facility waste of 3M.

     Little is known about actual operations at the disposal site.
No records were kept as  to type and quantity of wastes disposed.
It has been estimated that 153,000 nP (200,000 yd3) of wastes
were disposed in the area.   The waste consisted of solvent
contaminated material, adhesive, rolls of film, rags, resins,
and off-specification materials.  About 50 percent of the liquid
waste consisted of an estimated 760 m^ (200,000 gal) of isopropyl
ether.  It has also been  estimated that 23,000 m3 (6,000,000 gal)
of wet scrap was disposed at the site.

     The solvents deposited at the site had been used as carrier
agents to maintain a fluid condition of the adhesives applied
on scotch tape and sandpaper.  The chief solvent used as a carrier
agent was heptane.  Other solvents used were acetone, isopropyl
ether, and toluene.  Highly flammable liquid waste was sent to
a private incinerator facility in Newport, Minnesota.  Less
flammable liquid wastes  and solid wastes not accepted by the
Newport facility were placed in pits at the Woodbury site.
     Prior to 1963, various acids, primarily
dumped in limestone pits at the site.  In late 1963
Minnesota Water Pollution Control Commission (MWPC)
3M that ground water contamination could occur as a
their practices.  They recommended that the dumping
discontinued and that all other wastes be placed in
These recommendations were accepted and implemented
1963 a limestone pit was constructed at the Chemolite plant and
disposal of acids was discontinued at the Woodbury facility
sulfuric,  were
      ,  the
       i nformed
       result of
       of  acids be
       clay pi.ts.
       by  3M.  In
                              186

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     - TO COUNTY 19
                     COTTAGE GROVE TOWNSHIP
Figure  9-3.   Configuration of  waste disposal  pits
             at 3M  Woodbury site.  [9-2]
                          187

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      When  evidence  of  ground  water  contamination appeared  in 1966,
 3M  stopped  all  disposal  activities  at  the  Woodbury site.   House-
 keeping  practices were  improved  to  decrease the amount of  waste
 being discarded.  Wet  scrap was  sent to  Shakopee, Minnesota
 for incineration from  1966 to  1971.  In  July  1971, an incinerator
 was put  into  operation  at the  Chemolite  plant  facility.

 POLLUTION

      In  May 1966, a  private well  near  the  site was found to be
 contaminated  with isopropyl ether,  one of  the  solvents disposed
 in  the pits.  Eighteen  residential  wells were  sampled in Woodbury
 Township and  Cottage Grove Village  around  the  disposal area.
 Based on results obtained, it  was determined  that only the
 originally-identified well was contaminated;  none of these other
 18  wells had  any trace  of organic chemical contamination.

      By  August  1966, all the wells  in  the  area had been sampled
 and use  of the  disposal  site had  been  discontinued.  A consulting
 engineering firm was retained  by  3M to determine the extent of
 the  problem and to recommend a solution.   A 61 m (200 ft)  deep,
 30  cm (12 in.)  diameter  test well was  drilled on September 13,
 1966.  Figure 9-4 locates the  contaminated well (at the
 Schussler residence) in  relation  to the disposal site and  the
 test  hole  (called Observation  Well  A).   Drilling of the test
 well  stopped  at two levels in  the glacial  drift, three levels in
 the  Shakopee-Oneota Dolomite,  and one  level in the Jordan
 Sandstone.   Water samples were collected from each level  for
 analysis.  Water samples were  also  collected from two 3M existing
 5 cm  (2 in.)  observation wells and  the caretaker's well  located
 at  the disposal  site.  One of  these is  located in the northwest
 corner of the site,  one  in the southwest corner, and the
 caretaker's well is  located east  of the disposal area between
 the  two observation  wells.   The observation wells bottom in the
 St.   Peter Sandstone  and  their well screens are open to both
 glacial drift and sandstone.

      Analysis on the wells showed contamination in the glacial
 drift and upper levels  of the Shakopee-Oneota Dolomite at a
 depth of about 61  m  (200 ft).   Contamination was found to
 decrease substantially  with increasing  depth.   Insignificant
 trace contaminants  were  detected  in the Jordan Sandstone.
 Isopropyl ether was  the major pollutant, with concentrations
 varying from 4 to 5  ppm  in  the shallow  drift to less  than 0.1
 at 47.5 to  61.0  m (156  to 200 ft).
ppm
     Since confirmation of contamination in the upper ground water
aquifer, regular monitoring of nearby, residential  wells has
been conducted.  Ten area wells are now sampled once every two
months by the Department of Health and 3M.   Previously,  3M had
sampled 52 wells in the surrounding neighborhood on a bi-monthly
                             188

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                                             WOODBURY
                                               A 41
                                             TTAGE GRQ<
                                             TWP
LEGEND
  OBSERVATION
  WELL

  REMOVAL
  WELL

   BARRIER
   WELL
  Figure  9-4.   Location  of contaminated  Schussler well
               and barrier  wells. [9-1,  9-3]
                             189

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schedule.  The 10 wells that are presently being sampled are
located in glacial material and have shown no contamination
except for nitrates from barnyard runoff.  Schuss-ler's well was
the only well found to be contaminated with organics.   As a
result of barrier well water withdrawal, the glacial  perched
water was drained and Schussler's well went dry in about 1970.
Subsequently, a new well was installed for the Schussler residence,
which retrieves ground water from the Jordan Aquifer.   Figure
9-5 exhibits the combined concentration of isopropyl  ether and
other compounds at the old shallow Schussler well.  The new
Schussler well has never shown any isopropyl ether contamination.

REMEDIAL ACTION

     Based upon the determination that the major contaminants
were located in the perched shallow ground water, the  following
remedial actions were initiated:

     • All disposal activities at the site were discontinued.
     • New waste was
       facility.  In
       the Chemolite
sent
1971
facility
 to  an  outside  incinerator/disposal
,  an incinerator  was  constructed  at
     to  burn  acceptable  wet  scrap,
     • Waste within the pits was removed and burned.

     • Four barrier wells were installed to create cones of
       depression in the ground water down-gradient from the
       site.  The effect of these cones of depression was to
       prevent contaminated ground water from migrating further
       down-gradient and to remove the ground water that had
       already been contaminated.  The water thus removed was
       to be discharged directly to the Mississippi River.

     • A regular monitoring program of residential wells in
       the immediate vicinity of the disposal site was
       instituted to detect contaminants in the ground water.

     Several alternatives were considered for reducing and
disposing the solvent and scrap waste located in the  pits.   For
lack of other viable alternatives, it was decided that the  waste
would be excavated from the pits and open burned.  It was
postulated that a time limited, large-scale burning project
would rid the pits of solvents judged to be the source of ground
water contamination and would shorten the time necessary to
return the ground water quality to acceptable levels.
     A trial open cell test burn was
A drag line was used to excavate the
the burning process, the drag line
                conducted in August 1967.
                waste from the pits.   During
              was used to mix the burning
                              190

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300O-


2800-


2600-


2400-


2200-


2000-


BOO-


1600-


1400-


I2OO-


IOOO -


 800-


 60O-


 400


 200
BARRIER WELL
NO I          BARRIER WELL
INSTALLED      NO. 2
1/2/68        INSTALLED
            6/26/68
     SOND   JFMAMJJ  A S  0  N  D
             -<	1968	=»
                             JFHAHJJASOND
                             —:	1969	=*»
0  F  M  A
-S	1970-
        Figure 9-5.   Sum of  the concentration  of isopropyl  ether,
         isopropanol,  and dichloromethane for  shallow well  at
                             Schussler residence.
                                      191

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 mass and to accelerate the burning efficiency.   Following the
 test, samples of the remaining residue were collected for analysis
 The volume of the waste subjected to  the test  burn  had been
 reduced by 95 percent.  Subsequently,  the residue was soaked
 with water and no contaminants were dectected  in  the  wash water
 As  an extra precaution, the burned residue was  placed above
 ground, diked, and observed over a period of time before  burying
 1 t *

     _Based on good results obtained from the test burn,  3M
 obtained permission from Woodbury and  Cottage  Grove for  full-
 scale burning of all  wastes.   Burning  was conducted in January
 1968 to take  advantage of the  good air quality, low temperatures,
 and  low vapor pressure.   Burning was conducted  continuously
 until  all  waste  had been burned.   It is  estimated that 153,000 m3
 (200,000 yd-3)  of waste was burned during this period.   During the
 burning the air  was monitored  with a network of fixed  sampling
 stations and  one mobile  station.   Four fixed stations  were placed
 near residences  on each  of the four sides  of the property; one
 fixed  station  was  placed in  the  Village  of Cottage Grove
 mobile  unit,  provided  by the City of St.  Paul,  sampled at
 various  locations  in  the burning  area.   Air  was monitored
 carbon  dioxide,  sulfur dioxide,  suspended  particulate  matter,
 and  settleable particulares.   A .weather  station located near the
 burn area  provided data  on wind  direction,  speed, and  ambient
 temperatures.

      Although  a  S1'9nificant  amount  of  smoke  was generated  during
 the  burning,  excessive  concentrations  of  air pollutants were not
 detected  by the  monitoring  stations.   Occassionally a  slight odor
 was  noticed at one of  the  sampling  stations, and as  the intensity
 of the  odor increased, the  burning  was reduced.  The air monitoring
 program  carried  out during  the burning period by 3M did not
 indicate  any potential health  or  vegetation  damage.   Growth
 were conducted on  collected ash  in  the air sampling  network
 determine  the  composition  and  effect of  the  ash fallout on
 future  vegetation.  The  ash was basically  carbonaceous and
 determined  that  it would not adversely effect vegetation
 area.
                        The

                       for
                         tests
                         to

                        it was
                      in this
     Once the burning was completed
ceramic scrap, etc.) and ashwall wa
and observed for a period of time,
The waste was reduced by more than
then allowed to take root naturally
now cover most of the land and only
are noticeable.  3M personnel have
claiming that this allows rainwater
percolate downward, in the process,
the soil to the ground water.  Once
can be extracted by the barrier we!
,  the remaining residue (metal,
s  piled above ground, diked,
and then buried in the pits.
99 percent.   Vegetation was
.  _Native grasses and trees
 minor erosion-worn areas
chosen not to fill the pits,
 to accumulate and subsequently
 flushing contaminants in
 in the ground water, these
Is .
                             192

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     Based upon a
contamination was
from the disposal
hydrologic study,  it was determined that
confined to shallow depths in one direction
area, with the Schussler being at the leading
edge of contaminant migration.  Therefore
to operate continuously were installed to
contaminant migration and remove existing
the ground water.  The first barrier well
                         barrier wells designed
                        prevent further
                        contamination from
                        (No.  1) went i nto
operation in January 1968; the last barrier well (No. 4) went
into operation in 1974.
from the Jordan Aquifer
not contaminated and is
from the perched ground
The four wells withdraw
Originally, water from
excavated disposal pits
this practice has since
       Barrier Wells 1  and 3 withdraw water
        Ground water in the Jordan Aquifer is
      used to dilute the contaminated water
      water withdrawn by Barrier Wells 2 and 4.
      a monthly average of 0.16 m^/sec (3.6 mgd)
     Barrier Well  1  was recycled back to the
      to flush contaminants
      been discontinued.
lodging in the soil
     Presently, approximately 60 percent of the withdrawn water
from the Woodbury site is used at the Chemolite plant as non-
contact cooling water.  The remainder of the withdrawn water is
discharged directly to the Mississippi River.

     Table 9-1 provides performance data on the four barrier
wells. (The location of these wells was shown in Figure 9-4.)
Figure 9-6 demonstrates that a decrease in concentration of
isopropyl ether has been experienced since the introduction of
the barrier wells.  Table 9-2 displays 19 priority pollutants
which were foilnd in the discharge water.  The discharge system
consists of a 10 km (6 mi) underground forcemain privately owned
by 3M and which allows effluent discharge into th.e Mississippi
River.  The forcemain consists of 5,000 m (16,400 ft) of 46 cm
(18 in.) diameter iron pipe and 3,286 m (10,782 ft) of 46 cm
(18 in.) diameter asbestos cement pipe.  After pumping water
through  the  forcemain, the water flows down-gradient to the
Chemolite facility, and is discharged into a ravine which empties
.into the Mississippi River.

     The barrier wells are expected to operate indefinitely since
they now serve another function as a supply of cooling water.
Pumping is continuous.  When the wells were first installed,
power failure due to electrical storms occurred frequently
shutting the  pumps off.  To correct the problem, the pumping
station was automated and a telephone circuit installed to relay
problem information to the Chemolite personnel.  The systems are
checked once  each day.

     Initial  attempts to use the withdrawn water resulted in
build-up of iron oxide, manganese oxide, and iron bearing bacterial
slime in th.e  piping.  As a corrective measure, chlorine is added
initially to  the well discharge to inhibit iron reducing bacteria
and a stabilizing chemical (Nalco 345) added to prevent precipi-
                             193

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TABLE 9-1.  HORSEPOWER AND DISCHARGE OF BARRIER WELLS
Well
No.
1
2
3
4
Motor
Horsepower
75
40
50
125
Average Discharge
(rn^/mi n)
0.38
2.65
1 .89
4.54
         1  m3/min = 264.2 gal/min
   TABLE 9-2.  3M WOODBURY WELLS PRIORITY POLLUTANT
                   SAMPLING RESULTS
      Priority Pollutant
                                    Concentration
                                       (ug/1)
   1,
   1
Benzene
1 ,2-Dichloroethene
  1 ,1-Trichloroethane
 ,1-Dichloroethane
1,1 ,2-Trichloroethane
2,4,6-Trichlorophenol
Parachlorometa cresol
Chloroform
Ethylbenzene
Methylene Chloride
Phenol
Bis  (2-ethylhexyl) Phthalate
Diethyl Phthalate
Toluene
Tri chloroethylene
Endosulfan-Alpha
Endrin  Aldehyde
Heptachlor Epoxide
BHC-Alpha
 1
 3
 1
 3
 4
 1
 1
 5
 4
 8
<1
 9
 2
 2
 1
<0
 0
<0
<0
                                             01
                                             14
                                             01
                                             01
                          194

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  75


  70
OJ
01 cc
m 65
t-
o>
> 60
*£


| 55


, 50


| 45


1 40


I 35
•*•>
LU
^_ 30

">,
| 25


I 20
(/I

" 15


  10


   5
                       Barrier Well No. 1
        T"
        68
             69
                  70
nr
 71
i	r
 72   73
   Year
T
 74
     75
~r
 76
     77
          78
  <>• 25
    20
     15
     10
                        Barrier Well No.  2
          NH
               NM
                    70
     NH = Not measureable
     T  = Trace
     *  = No peaks observed
  —r~
   71
                                  73    74
                                  Year
                                            T


                                            75
                                                76
                                                     77
                                                          78
Figure  9-6.   Graphs of  isopropyl  ether measurements
              for  Barrier  Wells  Nos.  1,to 4.
                             195

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Figure 9-6  (.Continued)
                                   Barrier Well No.  3
            800 _
            , 700
            600
            500 -•
            400 '
            300 •
            200 -
            TOO -
                   68
                        69
                             70
                                  71
                                        72
1
73
Year
                                                   1
                                                  74
     A
                                                                  77
                                                                       78
                                   Barrier Well  No. 4
              85
            £75
            01

            5 65
             .45
              25
                           To
                                                    76
"7T
              7s"
                                      Year
                                        196

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tatlon of iron and manganese oxides.  To prevent discharge of
chlorine into the Mississippi River, the withdrawn chlorinated
well water is dechlorinated with sulfur dioxide prior to
discharge.
     In 1972, a $4.6 million incinerator
Chemolite to burn industrial liquid and s
wastes which had previously been placed i
disposal site.   The incineration system i
handling building, five 38 m3 (10,000 gal ,  	 ...  . . .,	 .._
storage, a specially designed feed system for 0.21  m3 (55 gal)
drums, a large rotary kiln with secondary
high energy Venturi scrubber for air poll
water treatment facility, and a 60 m (200
stack.
                           was constructed at 3M
                           emi-liquid chemical
                           n pits at the Woodbury
                           ncludes a large materials
                           ) tanks for^liquid waste
                            combustion chamber,
                           ution control,  waste-
                            ft) high discharge
     Not counting the amount spent on development and operation
of the incinerator, 3M has spent over $7 million dollars to date
in correcting environmental problems at the Woodbury disposal
site.  In addition, approximately $95,000 is spent annually on
continued operation of the barrier well system.

CONCLUSION
     When ground water contamination was first identified at the
Woodbury 3M facility, 3M immediately took responsible actions to
mitigate and correct the problem.  Previous practices
stopped, an investigation was undertaken to determine
of the problem, and corrective actions were initiated
                                        were
                                        the extent
     Within on
from the pits
that such open
regulations.
had not formul
burning, and h
promulgated ai
operation was
solvents causi
e and a half years, the waste had been removed
and burned.   It should be noted that it is unlikely
 burning would be allowed under current air quality
However, the Minnesota Pollution Control  Agency
ated an air  control policy at the time of the
ad neither established a permitting system nor
r pollution  regulations.  At the time, a  burning
selected as  the best method of disposing  of the
ng the ground water contamination.
     The use of four barrier wells appears to have effectively
reduced the migration of contaminants from the area.   Presently,
3M uses some of the withdrawn water as a non-contact coolant
and, therefore, has chosen to derive benefits from money spent
on a system used to correct a pollutant problem.

     In general, the Minnesota Pollution Control Agency has been
pleased with the efforts and prompt action of 3M and believes
that the barrier well system is an appropriate corrective action.
Likewise., good public relations exist between 3M and the Town of
Woodbury and Village of Cottage Grove and several public meetings
have been conducted over the years to discuss the problem.
                             197

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             SITE H  BIBLIOGRAPHY AND REFERENCES
9-1    Personal communication with Russel Susag, Millard Goldsmith,
      and Michael  Santoro, 3M, St. Paul, Minnesota, June 26, 1980.

9-2    Clarified aerial  photo, Sl/2 Section 35T 28N R 21W,
      Washington County.  G-209 Mark Hurd Aerial Survey, Inc.
      April  1976.

9-3    Personal communication and file review with Gary Kimball,
      Minnesota Pollution Control Agency, Division of Water
      Quality, Permits  Section, Roseville, Minnesota.  June
      25 and 27, 1980.
                              198

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   APPENDIX 9-1



SITE H PHOTOGRAPHS
       199

-------
                  :j:^imm^^^.^i^^m.^^^^j^^^

                  *v^t^'vf^.v;:^
                   -•---:.!--,->; " i,-Hi,-    ... -V-^KH   ,  . ••, -.,  ....  :.-.• ,**.«.»
Overall  appearance of excavated pit area
         at  Woodbury Disposal  pits
                    200

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                             ;'/'V.«
                 •^
The structure in the middle of the photo shelters
            one of the barrier pumps
           3M's  Chemolite  Incinerator

                      201

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                           SECTION 10

                             SITE I
                  WHITEHOUSE/ALLIED PETROLEUM
                     JACKSONVILLE, FLORIDA
INTRODUCTION

     Seven waste oil  pits near Whitehouse,  Florida have been  a
surface and ground water pollution problem  for many years.   Allied
Petroleum Products Company, a waste oil  reclaimer, constructed
the f:irst of these pits in 1958.   The pits  were used for the
disposal of waste oils for about  ten years.   In 1969,  Allied
abandoned the pits and filed for  bankruptcy.   Subsequently,  the
City of Jacksonville moved to reinforce  the  earthen dikes around
the ponds and built a limestone filtering system for the water
in the pits to prevent pollution  problems.   However, due to
budget  constraints the City was  forced  to  discontinue further
remedial measures in 1975.

     One of the pits ruptured in  June 1976,  spilling its contents
onto an adjacent property and into a creek.   After the spill,
analyses conducted by the U.S. Environmental  Protection Agency
(EPA) on the remaining oil showed that the  PCB concentration
exceeded the federal discharge limit of 1 ppb.  Subsequently,
EPA, State of Florida, and City officials developed a
comprehensive plan to dispose of  the remaining oil and pollutants
including (1) immobilization of the oil  on-site to prevent further
spillage, and (2) drainage of the ponded oils through  an on-site
treatment system to maintain PCB  concentrations in site
effluents at less than 1 ppb.

     After dewatering, treated soils were mixed with the remaining
sludge to combine with the oily matter.   Next a layer  of packing
material, consisting of a foam rubber and upholstery material
from car seats and other dry material, were layered on top of
this mixture.  Finally, a layer of fill  dirt was used  to cover  the
area.  Subsequent remedial actions performed during the summer
of 1980, included covering the site with impermeable soil,
revegetating the site, rerouting drainage,  and creating a fence
or barrier to restrict public access.

SITE DESCRIPTION

     The Whitehouse/Allied Petroleum site is located in Duval
County  in northeastern Florida approximately 16 km  (10 mi) west
of downtown Jacksonville., The site is situated between Machelle
Dri-ve and Chaffee Road north of U.S. Highway 90.  The site
consisted of seven pits covering a combined area of approximately
                              202

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24,000 rrT or 2.5 ha  (250
the seven pits was in an
depths from 1.5 to 4.6 m
of the site are shown in
,000  ft   or  6  ac).  The alignment of
 east-west  direction with  estimated
 (5  to  15 ft).   The location  and layout
 Figures  10-1,  10-2, and 10-3.
     The climate of Jacksonville and vicinity is  humid subtropical
with warm, wet summers and mild, relatively dry winters.   The
average annual temperature is 20°C (68°F)  and the average  annual
precipitation is 138 cm (54 in.), most of  this in late spring
or early summer.  The average annual  snowfall  is  a trace.

     The topography of Duval  County is mostly low, gentle  to  flat,
and composed of a series of ancient marine terraces.   Surface
drainage from the site occurs through two  drainage ditches which
surround the site on three sides.  These drainage ditches  combine
with McGirts Creek which empties into the  St.  Johns  River
approximately 16 km (10 mi) southeast of the site.  The area  in
the vicinity of the site is rural to residential.  There is some
agriculture in the area, but  most of the land is  forested  with
pine trees harvested for pulp production.   The elevation of the
site is approximately 23 m (75 ft) above sea level.

     The principal aquifer for municipal,  industrial,  and  domestic
water supplies in the area of the Whitehouse site is  a sequence
of permeable limestones known  as the Floridan Aquifer.  Overlying
the Floridan Aquifer from a depth of 30 to 160 m (100  to 525  ft)
are confined or secondary aquifers in clays, sands,  and limestones
of the Hawthorn Formation.  The water table or unconfined  aquifer
in undifferentiated PIio-Pleistocene deposits consists of
alternating beds of sand, clay, and sandy  clay to a  depth  of
about 0 to 30 m (0 to 100 ft).  The water  table and  secondary
aquifers of the Hawthorn Formation are used primarily  for  domestic
purposes.  At Whitehouse, the water table  is generally within  1.5 m
(5 ft) of the land surface and the potentiometric surface  of  the
Floridan Aquifer is about 13  m (43 ft) above sea level or  9 m
(30 ft) below the~land surface.  Ground water flow for the water
table is to the west towards  McGirts Creek.  A well  log of the
subsurface at the Whitehouse  site is provided in  Appendix  10-1.

SITE HISTORY AND POLLUTION

     The Whitehouse/Al1ied Petroleum oil pits were operational
between 1958 and 1968.  They were used during this period
as a disposal site by the Allied Petroleum Products  Company,  a
waste oil reclaimer, for the disposal of acid sludges, clay wastes,
and waste oils from their processes.  The Company used oil, such
as used motor and transformer oil, for their crude.   This  crude
was acid- and clay-treated to produce a motor oil and  the  waste
from this operation was dumped into the pits.  The seven waste
oil pits were abandoned in 1969 when the Company went  bankrupt.
The City of Jacksonville acquired a third of the property  by  tax
default.
                              203

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Figure 10-1.  Lo'cation of Whi tehouse/Al 1 led
               Petroleum site.
                      204

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                                          NEW DITCH TO BE -
                                          CONSTRUCTED
                                TRIBUTARY
              LIMESTONE FILTERS 	
              AND SETTLING PONDS(I968)
              CARBON ADSORPTION
              TREATMENT PLANT
                 258 O
                ABANDONED OIL
                SLUDGE P'l.TS 1-7
                                                              UNBWED ROAD
                       WRM POND
                    (REPORTED SPRING)
                              Ol58
                      200m
 Q263  PERIMETER DITCH-


O233
                                                  O APPRO*. LOCATION
                                                     OF PRIVATE WELL.
            200   4OO   600 FT.
Figure  10-2.    Layout  of  Whitehouse  oil  pits   (1976)
                                     205

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                                                         to
                                                         OJ
                                                         c
                                                         o
                                                        •r—
                                                         in
                                                         s-
                                                         OJ
                                                        -o

                                                        -a



                                                         to

                                                        •r—
                                                         Q.


                                                        •r~
                                                         O

                                                         O>

                                                         3
                                                         o
                                                        JC
                                                         o
                                                        q-
                                                         o
                                                        CO
                                                         I
                                                        O
                                                        S-
                                                        ^3
                                                        C7)
206

-------
level  was not controlled,  began
separator in conjunction with a
an attempt to dewater the pits.
     On several  occasions  levees  from the  waste oil  pits  ruptured
following heavy  rainfalls.   In 1967 Pit No.  7  ruptured  spilling
its contents onto adjacent  private property  and into McGirts
Creek.   The City of Jacksonville  Mosquito  Control  Branch,
recognizing the  threat of  other pits rupturing if  the water
                    -- •   •      to build a two cell  oil/water
                                limestone  filtering  system in
                                 The City  attempted  to  reinforce
the ponds' retaining walls  to prevent further  pollution problems
in 1967, 1972, and 1974.   An attempt was made  to have the White-
house site declared a mosquito control  project, along with an
adjacent swamp area since  the swamp could  not  be properly
drained without  addressing  the oil pits first.  The  request was
denied by the Florida State Bureau of Entomology in  1974.   In
1975 an attempt  was made to obtain Florida State Department of
Environmental Regulation pollution restoration funds to rectify
and close out the problem area.  This request  was  also  denied.

    To compound  the situation, erosion caused  by motorcycle
and four-wheel drive vehicles weakened the retaining berms.
On June 29, 1976, after abnormally heavy precipitation, the
retaining berm of Pit No.  6 on the western edge of the  site
collapsed during some minor repair work by Mosquito  Control
Branch personnel.  The resulting breach allowed approximately
                       - -'      '     ' waste oil material and an
                                     water to flow into McGirts
                                     collection basin.  An oil
                                     U.S. Coast Guard, a private
                                                              (BESD)
757 m3 (200,000 gal)  of the captured
undetermined amount of highly acidic
Creek and the adjacent natural  water
spill emergency was declared and the
consulting firm, and the Bio-Environmental  Services  Division
of the Jacksonville Department of Health,  Welfare,  and Bio-
Environmental Services were mobilized under the direction of the
Oil Spills Group of the EPA Region IV Environmental  Emergency
Branch.  Cleanup measures were initiated on the evening of
June 29, 1976.
    Waste oil  remained  in
 completed on  May  15,  1977
 high  concentrations
 pH  of less  than one.
 like  fluid,  floating
            yel1ow-colored
 a  thicker,
 25  percent
                          six.pits until  cleanup measures were
                            The wastes left in the pits contained
                     f PCB's, lead, and other metals, and had a
                      The lighter weight material, a black, oil-
                     on top had segregated in some areas into
                          greasy material.  It contained 10 to.
            water  and  a  30  percent  oil mixture consisting of 50
 percent  homogenized oil.   Approximately  1 m  (3  ft)  of this
 material  floated  over a  layer  of water and bottom oil sludge.
 The  top  of  the  sludge was  unstable  becoming  firmer with depth.
 Total  thickness of  the  sludge  was  2  to 3  m (6 to 10 ft).   In
 1974,  there  was  an  estimated
 raimwater,  and  sludge  in  the
                              7,500
                              pi ts.
                                   m
3 (1,982,000 gal)  of oil
                              207

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REMEDIAL ACTION

First Phase

    Initially the EPA and the Coast Guard had concentrated their
efforts on cleaning up the spill and stabilizing the walls of
the pits to prevent further collapse.  However, it was recognized
that the remaining six oil pits presented a potential for a
similar or possibly larger spill unless corrective actions were
taken.  Therefore, EPA and Coast Guard officials authorized the
use of federal Emergency Contingency Funds to (1) cleanup the
existing oil spill, (2) repair the oil pit filter system origin-
ally built by the City of Jacksonville, and (3) provide material
for the construction of access roads to each of the six remaining
pits so that pump-out operations could proceed.  Total cost for
the above operations was estimated at $100,000.

    After the EPA enacted the federal response to the oil spill,
disposal became the next major obstacle.   The spilled material
was disposed in a proper manner in Duval  County.  To eliminate
the imminent threat of another spill from the pits, alter-
native and more econcomical  disposal sites were sought.  The
City proposed several  sites  but could not get approval from
the State to use them.  Because of the lack of a suitable dis-
posal  site or method,  a ten  day delay was encountered.

    The delay allowed the agencies to become more familiar with
the material in the pits.  It was determined that the only
feasible means of disposal was to reactivate the oil/water
separator and filter system  the City had  employed during
previous efforts.  This would allow the pits to be dewatered
and eliminate the threat of  another major spill.

    The City of Jacksonville suggested that after the pits were
dewatered they would mix the remaining oil  and sludge with dry
trash  and dirt and fill  all  the pits.   Because of the emergency,
State  and City agencies agreed to the following at a July 6,  1976
conference:
    1 .   On an
        would be used
        construct the
emergency basis, Mosquito Control  Branch
        to re-establish the filter beds
        necessary pit access roads.
 equipment
and
        The dewatered pits could be designated as a
        landfill.   Material  such as dry tree limbs,
        building materials,  and any other absorbent
        would be employed to stabili
        at the bottom of the pits.
        be selected loads of refuse
                                      dry trash
                                      leaves,
                                      materials
                      ze the sludge remaining
                      These materials  were  to
                      from the City-operated
                             208

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         disposal  sites.   The  absorbent  materials  would  be
         deposited in  the  pits, which  had been  emptied  of the  oil
         and oil  emulsion  and  the  materials  graded and
         compacted  by a  crawler  tractor.   Upon  completion  of
         the filling and  after consolidation of  the debris,
         portions  of the  pit embankment  walls  would be graded
         over the  pit  to  provide  soil  cover  for  surface  drainage.

     3.   The necessity for a sani tary. landf i 11  application  and
         operating permit  would be waived.   State  Water  Pollution
         Control  personnel would  monitor the leachate  from  the
         defluidized stabilized system and  from-time to  time
         would report  the  need to  haul away  additional petroleum
         residues  at the  expense  of the  City.

     The dewatering operation  was  one day from start-up  when  the
EPA received word  from the Coast  Guard that  there  was  a  possibility
the oil  in the pit was contaminated with PCB's.   Until then,  the
spill  had been handled as  a routine oil  spill.   This new informa-
tion not only halted the  entire operation,  but required  the
chemical analysis  of the  material  in  the pits  and  surface and
ground water monitoring.
                            )
     After evaluating  the  data, three alternatives were  considered
by the EPA Regional Response Team for the ultimate disposal  of
the PCB contaminated waste oil:

     1.   The impounded material would not be treated on-site.
         Rather,  all of the PCB contaminated waste oil would  be
         placed in sealed  containers  and shipped to an approved
         facility.  A conservative estimate  of the amount of
         contaminated material was made and  using  a Rollins
         Environmental Services price sheet, it was calculated
         that approximately $7.5 million would be  needed.  This
         estimate  did not include labor charges.  It was obvious
         from the cost figures, together with the  fact that
         federal  funds were no longer available, that this  was
         not a viable alternative.

     2.  The impounded material would be discharged without
         treatment and the remaining oil and sludge disposed
         at an approved facility.   This alternative was  finally
         rejected because the cost of hauling the  semi-solid
         materials was still prohibitively high and data
         suggested that concentrations of PCB's exceeding 1 ppb
         could be expected in any water discharged to McGirts
         Creek.  At that time, the EPA was recommending that
         manufacturers not exceed 1 ppb of PCB in  any discharge.

     3.  The oil  would be immobilized on-site and  a water treatment
         system designed that would produce an effluent less  than
                               209

-------
         1  ppb PCB.  Since current technology was available
         for producing an effluent of 1  ppb using activated
         carbon, this appeared to be the best of the alternatives.

     The task of immobilizing the oil was assign'ed to the City
of Jacksonville in conjunction with the  EPA Region IV Residual
Management Branch and the Florida Department of Environmental
Regulation.  The remedial action selected included draining as
much water as possible through a treatment system and stabilizing
the remaining fluids.  The treatment system was designed by the
EPA and modified by City employees during construction to treat
and dewater all the pits (the City Finance Committee approved
$13,000 for the project).  The system included (1) treatment of
water which had been drained from the remaining oil  pits to
separate the oil and water;  (2) two limestone filtering beds to
neutralize acid and filter out oil, metals, and other contaminants;
and (3) a carbon mixing and  settling system to adsorb and remove
PCB's.  The treatment system was devised to be practical,
inexpensive, easy to operate, and have the capability to reduce
the PCB level below 1 ppb for all water  discharged to McGirts
Creek.  The system was to be a temporary measure and only minimum
maintenance would be required.

     It was obvious from the initial discovery of PCB's in the
pits that the only effective treatment of the water would be
with activated carbon.  Research and practice had shown that
carbon adsorption was the best available field method for removing
PCB's from wastewaters.  Carbon adsorption systems in industrial
applications could remove PCB's from wastewater effluents to
concentrations less than 1  ppb; however, these systems all
employed carbon adsorption columns and the carbon column was not
the best method of treatment in this emergency situation for the
following reasons:
     1.  Construction of the
         and time-consuming.
         required additional
columns was considered too costly
 Also, the columns would have
pumps.
         Due to the limited laboratory facilities nearby and
         the inconsistent quality of the influent, it would have
         been difficult to determine when the carbon in the
         column had become saturated.

         Replacement of carbon in column would be difficult.
         Moreover, the oily water would tend to coat the surface
         of the granular coarbon and reduce its adsorption
         effectiveness.

         Granular activated carbon was twice as expensive as
         powdered carbon.  Moreover, the nearest source was
         approximately 965 km (600 mi) from the spill site.
                              210

-------
     A system using powdered activated carbon for removing  PCB's
from water had never been employed in other than
laboratory-scale experiments.   These experiments all  yielded
treated effluent PCB levels well  below the acceptable level  of
1  ppb.  With these results and previous experience in the  use of
activated carbon for removing  organics from water, a  treatment
system was designed using powdered activated carbon.  [10-2]
                treatment system consisted of four units:  (1)  a
                 (2) a carbon mixing chamber, (3)  a sedimentation
                 sand filter (see Figure 10-4).   A collection
                 collect water draining from the oil  pits.   When
                 was collected, the sump pump directed the  liquid
     The carbon
collection sump,
basin ,  and (4)  a
sump was used to
sufficient water  ____ .-.. ______ ,  ____  _______  .
to the  carbon mixing chamber at  a  rate  o,f 227  1/min  (60  gal/min).
The carbon slurry was injected at  a  concentration adjusted  to
maintain an effluent concentration of less than 1 ppb  of PCB  in
the waste.  The chief goal  of the  sedimentation basin  was  to
provide adequate  detention  time  for  gravity sedimentation  of  the   -
carbon  and absorbent contaminants.  A final sand filter  was
provided to filter the effluent  prior to discharge into  McGirts
Creek.

     After dewatering, fuller's  earth was mixed with the remaining
oil and sludge to combine with the oily matter.  Fuller's  earth
is a semi -pul veri zed clay which  absorbs oil and water  rapidly.
Laboratory experiments had  shown this mixture  was stable and
did not release oil  or sludge even when submerged in water.
Approximately
was  mixed in
              7,200 metric tons (8,000 tons) of fuller's earth
              this manner.
     To provide adequate control over the mixing operation, a
batching pit was prepared just south of Pit No. 4.  Pumpable
material was taken out of the pits and placed into an 11 m3
(3,000 gal) settling tank.  Water obtained from the settling
tank was drained to Pit No. 7 and passed through the treatment
system.  The remaining settleable material was mixed by heavy
equipment in the batch pit and then placed in the oil pit which
was being closed out.
     The sludges remaining in the
a layer of clean trash consisting
wood chips to form a matrix which
                        in the pit bottom.
                        this material to a
over the viscous sludge
sludge was displaced by
The more viscous" siudge remained in place and
absorbed and solidified under the pressure of
The minimum thickness of trash overburden was
depth required to  support heavy equipment and
of the pit material.
                                  pit were stabilized by placing
                                  of scrap lumber, trees, and
                                  penetrated into and bridged
 The less viscous
centralized location.
   in time was
   the overburden.
   .determined by the
   prevent swelling
      Auto  shredder waste, consisting primarily of upholstery
 and  similar  absorbent  and highly compressible material, was
                               211

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  CARBON
  MIXING
  CHAMBER-
£*
•

>*M
iT-^
f
A


. , — N
EV


i ' '
. i < .
• , , •



                                                FINAL
                                                DISCHARGE
  COLLECTION SUMP


    SHED
SEDIMENTATION BASIN



   PLAN
                                     RNAL
                                      FILTER
                    ACTIVATED CARBON
                       DRUMS
                    (NO SCALE)
Figure  10-4.   Carbon adsorption treatment
        ,    plant for  PCB's.  [10-2]
                          212

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placed above the clean trash for support.   This  sealed the
surface voids in the trash and provided a  base for the mixture
of oil and fuller's earth placed in a layer above it.   In this
way, the fuller's earth mixture provided an impermeable blanket
that kept rainwater from percolating downward.  This was to
eliminate the major driving force for ground water contamination
migration and keep the viscous sludge and  fugitive oil in a
state more conducive to solidification over time.  A final layer
of clean fill dirt was placed above the clay blanket and graded
to take maximum advantage of the natural slope of the site for
drainage (see Figure 10-5).

     After treatment of water and sludge had been accomplished
and the pits filled and packed, several drainage ditches were
constructed around the former pits to help divert runoff through
the limestone filters and to intercept ground water entering the
site and leachate leaving the site.  The basic plan was to take
maximum advantage of the site topography to isolate the pits
hydraulically from the surrounding ground  water.  This process
was completed on May 15, 1977.

Second Phase

     Because stabilization efforts were not permanent or completely
effective, a permanently stabi1ized area became  necessary to
eliminate the seepage of contaminated material.   On June 30, 1980
the City of Jacksonville agreed to assume  responsibility to""
accomplish  the  following  tas'ks:

     1.  Covering the entire site with soil.

     2.  Vegetating the cover material.

     3.  Rerouting surface drainag%.

     4.  Erecting a fence to restrict public access.

First, the entire site was covered with 46 cm (18 in.) of soil
purchased  under  City contract.  The first 15 cm  (6 in.) of the
material consisted of tight clay and the top 30  cm (12 in.) was
borrow fill dirt  (primarily sand).  The cover material serves
several purposes.  It provides  a  thick  uncontaminated  zone  to
permit a good growth of grasses.   Cover material was also used
to  level out the  irregular surface settling that had occurred.
By  establishing  a good drainage gradient and a continuous clay
blanket across  the site surface, downward percolation of  rainwater
has been minimized.  Grasses help  to remove surface water through
evapotranspiration.  This  in turn  has  reduced the hydraulic
gradient on  the  contaminated material  and the forces tending to
cause  it to migrate through the berms  and off site.
                               213

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                                          200
                         CLEAN CURT FILL
                        \   X   \  X
                       vOIL/FULLERS EARTH
                                                        20-30 cm
                                                        13-25 cm
          / / / / s*™,SHREDDER ytSTE/  / /  /  /  7,6cm.min,
                            CLEAN TRASH
                                                         90cm. mm.
        I cm * 0,39 inches
Figure  10-5.   Pit profile  after stabilization.  [10-2]
                              214

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    A major effort of this project was  to  reroute  drainage  on
the north edge of the pits.   The new ditch has  routed  drainage
around the contaminated area,  thus eliminating  the opportunity
for rainfall  to carry contaminants from the site.   At  the  same
time the new ditch was being excavated, the old ditches  were
filled with clay materials to prevent lateral  movement away
from the site.  An attempt was made to  scrape  all  the  contam-
inated material out of this area and place it  atop the pits
for proper burial prior to filling the  old ditches.
    Extensive vandalism has occurred in the past at the site.
Cars, four-wheel  drive vehicles,  and motorcycles have used the
      allowing little vegetation  to grow.   Because of the impor-
      of establishing and maintaining adequate ground cover,  a
      may be installed.  The fence and signs would serve as a
serious warning to the public of  the hazardous nature of some
of the material buried there and  of the desire to restrict
access as a public safety measure.  If an  attempt is not made
to restrict site access, much of  the improvement associated
with the proposed project could be lost over a fairly short time,
area,
tance
fence
    The total cost
the first phase of
May 15, 1977) was estimated
for these costs is shown in
most of this cost was borne
addition, a cost of $67,191
of remedial action beginning

MONITORING
                   to the City of Jacksonville and the EPA for
                   remedial  action (between June 29,  1976 and
                            at $250,000.   A partial  accounting
                            Table 10-1.   It should be noted that
                            by the City  of Jacksonville.   In
                            was projected for the second  phase
                             in July 1980 as shown in Table 10-2
    As a result of the PCB contamination, a
and analysis program was initiated in which
                                            full  scale
                                            samples of
creek, ground water, raw water
water  (from nearby homes) were
                               (in the pits), sludge,
                               taken and analyzed 'for
                                An initial  monitoring
                               BESD analyzing samples
 samp!ing
 the
and well
PCB's,
effort  on
from four
heavy metals, phenols, and pH.
July 13, 1976 consisted of the
private water supply wells in the vicinity of the Whitehouse
site for possible contamination  (see Figure 10-2 and Table 10-3).
The results of the analyses are  contained in Table 10-4 and
indicate that the water quality  in these wells was not affected
by the oil pits.  The iron and phenol contents of two of the
wells were considered slightly high; however, the iron content
is not unusual for shallow wells in  Duval County, and the.phenol
content was not so high as to require closing of the water
supply for drinking water purposes.  Surface water samples were
also obtained from the limestone filtering system and McGirts
Creek, and analyses revealed  no  PCB's were present.

    At the request of EPA, a  sampling team from the EPA Athens
Laboratory was dispatched to  the Whitehouse site on July 20, 197,6
Samples were obtained on July 21, 1976 from the sidewalls of
                              215

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TABLE  10-1.    PARTIAL  REMEDIAL ACTION  COSTS  FOR FIRST  PHASE
Cost Item
Vehicles/Equipment/Personnel
Supplies, Fullers Earth, Etc.
Services and Charges
Capital Outlay
Mosquito Control Costs
Total

6/29/76 thru 7/9/76
$34,325
-
—
3,433
—
$37,758
Date

8/04/76 thru 9/30/76 10/1/76 thru 2/01/77
$17,417
27,688
485
4,657
17,902
$68,149
$36,118
2,691
—
—
40,745
$79,554
Total
$ 87,860
30,379
485
8,090
58.647
$185,462.
           TABLE  10-2.
PROJECTED  REMEDIAL  ACTION  COSTS
 FOR  SECOND  PHASE
                                Item
                                                        Cost
                        Cover Material  (sand and clay
                         borrow fill dirt)                  $33,848
                        Equipment Use (lease Mosquito
                         Control Gradal and operator plus
                         borrowed front-end loader)            4,000
                        Site Vegetation                      12,620
                        Night Security                       1,048
                        Port-0-Let Rental                       85
                        Fencing or Other Access
                         Restricting Means                  .11,600
                        Clearing and Grubbing                   290
                        Miscellaneous Equipment, Supplies
                         and Materials
                        Total
                                        216

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TABLE  10-3.   DEPTH  OF MONITORING  AND PRIVATE WELLS
         Wei 1 Number
Depth (m)
           EPA #1
           EPA #2
           EPA #3
         U.S.G.S.f!
         U.S.G.S.#2
         U.S.G.S.#3
    158 Machelle Drive
    233 Machelle Drive
    258 Machelle Drive
    263 Machelle Drive
 21-24
 15-18
  6-9
  5-6
  5-6
  5-6
Unknown
   41
Unknown
Unknown
    1 m = 3.3 ft.
                           217

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-------
the pits.  No bottom sludge samples were obtained due  to  the
unknown depth and the hazards involved in reaching the center
of the pits.   The analyses indicated that PCB's  were present  in
the sludge of five of the six oil  pits in concentrations  ranging
from 8.7 ppm to 23.3 ppm.  Because PCB's are soluble in an  oil-
water mixture at low pH,  it was anticipated that PCB's were being
discharged from the pits.  Complete analytical  results are
listed in Tables 10-5 and 10-6.  Quantitative tests for copper,
lead, zinc, cadmium, and  chromium, as expected,  appeared  in
insignificant quantities.  These are typical metals found in  the
waste oil process so these results were not surprising.

     The EPA Surveillance and Analysis Division  (S&A), due  to
manpower shortages, was only able  to lend limited sampling  and
analysis support after the initial oil sludge samples  were  handled.
Treatment system samples  were split between S&A  and the BESD.
This procedure produced a lengthy  "turn-around  time" for  actual
results.  In order to obtain a more rapid indication of PCB
removal, the BESD was requested to run chemical  oxygen demand
(COD) tests.   Organic contaminants are expected  in any oily
waste and these contaminants will  tend to occupy adsorption sites
on the carbon filter along with the PCB's.   Hence, COD tests
will indicate an increase or'decrease in the effectiveness  of
removal of all the organics (both  toxic and non-toxic) by the
carbon.  A correlation exists between removal of organics and
PCB reduction, therefore, lower COD values  indicate lower PCB
concentrations.  Also, the COD tests were less  expensive  and  a
more rapid indicator of PCB removal efficiency  than direct  PCB
analysi s .

     The initial discharge on September 20, 1976 was analyzed
for PCB's and COD.  Samples were taken from the  water as  it
entered Pit No. 7 and from the effluent as  it entered  McGirts
Creek.  Then the treatment process was discontinued until treatment
efficiency results were obtained.   These results indicated  that
the PCB concentration was below 1  ppb in the effluent  and that
the carbon feed was initially correct.  Using the COD test  as  an
indicator, the PCB concentration was kept consistently below
Ippb in the effluent.  Samples were obtained once each day  that
the system had been running.  Some results  of effluent monitoring
are shown in Table 10-7.   It should be noted that the  carbon
mixing proportions were continually adjusted based upon laboratory
analysis with the goal of keeping PCB levels in  the effluent
well below 1 ppb.

     Another problem considered was that of migration  of PCB's
to the ground water table.  To assist in determining the  extent
of migration from the pits, the EPA Region IV Residual Management
Branch contracted a consultant to perform a ground water  study
of the Whitehouse site.  The objective of the study was to  ascer-
tain whether or not migration of hazardous wastes had occurred in
                               219

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TABLE  10-5.    INITIAL  PCB  ANALYSIS  OF  SLUDGE  SAMPLES
Location
Pit No.
Pit No.
Pit No.
Pit No.
Pit No.
Pit No.

1
2
3
4
5
6
PCB
PCB
Aroclor 1242
6.0
10.0
NO
9.3
6.9
3.3
Concentrations
PCB
Aroclor 1254
2.8
3.5
ND
4.3
3.7
2.3
(ppra)
PCB
Aroclor 1260
5.6
9.7
ND
7.6
6.5
3.1
PCB
Total
(ppm)
14.4
23.2
—
21.2
17.1
8.7
         ND = Not detectable
   TABLE  10-6.    QUANTITATIVE  ANALYSIS  OF  OIL  SLUDGE
Sampl e
Number
2
3
4
5
6
7
Total Metals
Lead
2,800
5,300
1,830
1,320
2,640
7,060
From Ashed
Copper
25
37
15
8
31
62.5
Sludge -
Zinc
56.5
43
17
6
24
56
Wet Weight of Sludge
Cadmium
0.6
0.5
0.3
0.2
0.3
0.8
(u.9/9)
Chromium
7.5
11
4
8
9
12
                              Qualitative Scan of Oil  Sludge
                           Elements Detected in Sample  From Pit 2
        Lead
        Cerium
        Lanthanum
        Barium
        Antimony
        Tin
        Cadmium
        Silver
        Ruthenium
        Molybdenum
        'Zirconium
        Strontium
Rubidium
Bromine
Selenium
Arsenic
Gallium
Zinc
Copper
Nickel
Cobalt
Iron
Manganese
Chromi urn
Vanadium
Titanium
Scandium
Calcium
Potassium
Chlorine
Sulfur
Phosphorous
Silicon
Alumi num
Magnesium
Fluorine
                                   220

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           TABLE  10-7.   ANALYSES OF TREATMENT  SYSTEM
                       REMOVAL EFFICIENCIES
Date
9/20/76
9/25/76
9/26/76
9/28/76
9/29/76
9/30/76
10/1/76
10/6/76
10/7/76
10/8/76

PCB
(ppb)
-'-
0.73
0.56
2.22
7.7
• 0.93
1.49
1.15
0.66
0.62
Influent
COD
(ppm)
369
—
1 ,068
--
988
932
942
1 ,068
1,000
1,225

Carbon
(ppm)
27.0
10.7
10.7
10.2
10.2
28.6
28.6
25.9
43.5
43.5
Effl
PCB
(ppm)
<0.2
ND
ND
0.26
0.4,
0.99
0.29
0.14
<0.2
<0.2
uent
COD
(ppm)
66
399
282
--
419
394
463
399
571
372
Percent
PCB
Removal
_ —
—
—
88
95
1
81
88
70
68
ND = not detectable.
                                221

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the ground water adjacent to the waste oil pits (see Figure 10-3).
In September 1976,three piezometers were placed to depths of 10,
18, and 24 m (30, 60, and 80 ft) (see Appendix 10-1  for well
log)  and were developed using compressed air.  After pumping
each well at a rate of about 0.3 I/sec (5 gal/min) until  clear
water was obtained, water samples were obtained for chemical
analyses.  Water quality analyses on the three wells indicate
that ground water contamination may have occurred to a depth of
at least 24 m (80 ft) beneath the oil pits.   The results  of the
three samples from the EPA wells are summarized in Table  10-4.

     Under a cooperative program between the City of Jacksonville
and the U.S. Geological Survey (U.S.G.S.), three additional
wells were installed around the site perimeter in early 1977.
These wells along with the wells drilled by  the consultant
contracted by the EPA were monitored periodically.

     In 1979 an increase in leachate from the site was .noticed in
the perimeter ditches which surround the site.  This leachate
had a slight oil sheen and odd odor.  Biological and chemical
sampling upstream and downstream from the site indicated  that
the leachate was having a detrimental effect on the quality of
the water.

     To determine the effect of the leachate from the site on
the biota of McGirts Creek, macro-invertebrate samples were taken
by the Florida Department of Environmental Regulation (DER) on
October 11, 1979 and December 6, 1979.  During the October sampling,
33 types of organisms were found present in  a tributary upstream.
Each time a sample net ran through the substrate it was teeming
with organisms.  The bottom was a mixture of aquatic grasses,
sand, and detritus.  The tributary had all the indications of a
healthy aquatic environment.  Downstream from the site, only
four types of organisms and a total of eight organisms had been
found after two and one-half hours.  No vegetation was present
in the water.  The only growth on the bottom was described as a
"sewage slime".  Chemical analysis of water  samples revealed
toxic levels of heavy metals, traces of PCB's, and extremely low  pH.

CONCLUSION

     When the retaining berm of the waste'oil pit collapsed
contaminating  McGirts Creek with the highly acidic oil and sludge
in 1976, EPA and the City of Jacksonville took actions to correct
the problem.  Within one year, the waste either had been  removed,
treated, or stabilized within the pits.

     The main problem facing the project since the first  cleanup
efforts began in 1967 was the financial constraints  within which
it had to operate.   If City crews had been given the proper funds
in 1974 and 1975 and allowed to complete the dewatering operation,
                              222

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the oil  spill  in 1976 could have been averted.   However,  the
possibility of future spills would have remained unless  the
waste oil  and  sludge (the ultimate source of pollution)  were
part of the cleanup program.  Therefore, the 1976 spill  did
bring the seriousness of the problem to the attention of the
EPA and City officials, resulting in a comprehensive effort to
mitigate the problem.

    The carbon filter was successful.  PCB concentrations in the
effluent were  maintained below 1 ppb.  However,  short term
analysis of the stabilization efforts indicates  that the oil
sludge has not been totally stabilized.  Numerous leachate o.ut-
croppings have been noted along the eastern and  western  margins
of the site.  In addition, the sampling of McGirts Creek in
1979 and 1980  has shown a severe disruption of  the local  biota
downstream from the Whitehouse site.  Evidence  indicates toxic
leachate is leaving the site and migrating into  McGirts  Creek.
Some of the possibilities for the above problems include the
following:  (1) the decomposition of the truck  and auto  shred-
dings from the acid sludge, (2) an insufficient  value of
absorbent material added to"1 the acid sludge and  oil, (3) high
ground water levels, and/or (4) the absence of  a site covering
to prevent rainwater infiltration.

    The second phase of remedial action which began in 1980
may alleviate  many of the problems.  A new ditch has been
constructed up-gradient from the site and several existing
ditches are being filled with clay material.  The effect should
be to lower the ground water table and to divert ground  and
surface water  around the site.  The clay cover  should consid-
erably reduce  the seepage of .toxic wastes into  the ground water.

    Even though the second phase should considerably reduce
the pollutants in the ground water and McGirts  Creek, chances
are that some  problems will continue at the site and more money
will be required to permanently stabilize and/or isolate the
wastes to protect the surface and ground water  of the area.
Frequent monitoring will be required to ensure  future problems
do not develop.
                             223

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              SITE I REFERENCES AND BIBLIOGRAPHY
10-1  Bentley, C.B., "Aquifer Test Analyses from the Floridan
      Aquifer in Flagler, Putnam, and St. Johns Counties,
      Florida".  U.S. Geological Survey Water Resources
      Investigation 77-36.  1977.

10-2  Stroud, Fred B., Raymond T. Wilkerson, and A.I. Smith,
      "Treatment and Stabilization of PCB Contaminated Water
      and Waste Oil:  A Case Study".  Proceedings of 1978
      National Conference on Control of Hazardous Materials.

10-3  Personal communication with Jan B. Rogers, Raymond T.
      Wilkerson,  and Fred B. Stroud, Environmental  Emergency
      Branch, Region IV,  U.S.  Environmental  Protection Agency,
      Atlanta, Georgia.   July  23, 1980.

10-4  Personal communication with Gary V. Weiss, Jacksonville
      Department of Health,  Welfare,  and
      Services.   Jacksonville,  Florida.
Bio-Envi ronmental
July 24, 1980.
                             224

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   APPENDIX 10-1



WELL LOG FOR SITE I
        225

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                WELL LOG AT WHITEHOUSE OIL PITS
            Descripti on
Depth
 (m)
Black silty sand, with trace of clay (fill)
Very fine to fine dark gray sand, oily matrix,
  with traces of silt and clay
Very fine to fine, dark brown sand, with traces
  of silt and clay
Very fine to fine, dark brown to black sand,  some
  cementation, with trace of silt
Very fine to fine, reddish brown sand
Very fine, olive green sand, with traces of silt
Very fine, silty, light gray sand
Very fine, greenish-gray sand
Very fine, light gray sand, with traces of silt
  and clay
Very fine green sand with light to medium gray  shell
  fragments interbedded with clay and silt
                f-
Silty green clay with traces of shells and very
  fine sand, with one thin bed of weathered coquina
  at 34 to 35 m of depth
 0-2

 2-5

 5-7

 7-8
 8-9
 9-12
12-14
14-16

16-22

22-26

26-37
1  m = 3.3 ft
                              226

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   APPENDIX 10-2



SITE I PHOTOGRAPHS
      227

-------
The Whitehouse site in July 1980.
 Outcrop of oil sludge (July 1980)
                    228

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  011  pit  being filled with  refuse (1976)
1  Oil  storage tanks and fuller's earth mixing
  operations (1976).
                      229

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 Aerial  photograph of the Whitehouse oil  pits  (1976),
       Oil  flowing to  McGirts  Creek from
                 ruptured pit  (1976)
•U.S. OOVERSHEHT PRINTING OFFICE: 1981-0-720-016/5987
                            230

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