United States
Environmental Protection
Agency
Region 4
345 Courtland Street. NE
Atlanta GA 30308
November 1980
904/9-80-059
v>EPA
National Waste Oil
Chattanooga, Tennessee
-------
-------
PREFACE
k
This report reflects the activities of the Environmental
Emergency Branch (EEB) Region IV, EPA, as it was concerned with
the captioned event. The report outlines the key actions of the
Federal On-Scene Coordinator, the Regional Response Team (RRT),
and state, local, and Federal members of the RRT. It reflects
the complexity of responding to environmental emergencies and
the need to coordinate and plan in advance for a major incident
such as this event.
This report is intended to satisfy the requirements of the
National Oil and Hazardous Substances Pollution Contingency Plan
and to help others learn from our experiences.
Al 4. Smith, Chief
Environmental Emergency Branch
Protection Age**
-211-4
2016°
-------
-------
TABLE OF CONTENTS
Section Page
1. SUMMARY 1-1
2. THE SITUATION 2-1
3. PHOTOGRAPHS 3-1
4. TASK GROUP REPORT 4-1
111
-------
-------
1. SUMMARY
Approximately 200,000 gallons of contaminated water were stored
at National Waste Oil, a private industrial waste disposal company in
Chattanooga, Tennessee, that had gone bankrupt. The water was contam-
inated with chemical wastes, oil emulsions, sludge, and unidentified
chemicals and had been stored on property uphill of the drainage pat-
tern of the Chattanooga drinking water system. During a two-year
period, several large and small spills from the site had affected
Chattanooga's sanitary sewer system and Citigo Creek, the city's
drinking water source. To deal with the environmental and health
problems associated with the spills, numerous cleanup attempts had
been made by the federal government. However, these resulted in only
temporary containment without producing a permanent solution to the
large and complex problem.
The Environmental Protection Agency (EPA) Region IV office in
Atlanta undertook the coordination of large-scale treatment, removal,
disposal, and site restoration. This effort required planning, time,
and funds. EPA was assisted by federal, local, and municipal agen-
cies.
It was necessary to develop an approach to removial that was dif-
ferent from what had been used previously at the site because of the
imminent hazard presented by several unprotected tanks and two large
pits filled with mixtures of emulsified oil and waste chemicals. The
presence of large volumes of phenolic compounds, some pesticides, and
chlorinated hydrocarbons in open pits made the cleanup area extremely
unsafe. Several workers who experienced nausea and developed skin
irritations from exposure to phenol had left the work area.
1-1
-------
EPA's approach to the total problem was three-fold:
1. Immediate removal and treatment of liquid waste from the two
pit areas to reduce the imminent health and pollution hazard.
This was achieved by using the sophisticated carbon treatment
techniques of EPA's Environmental Emergency Response Unit
(EERU).
2. Disposal of approximately 100,000 gallons of remaining liquid
stored in tanks. This required several months of planning
and consideration of options to recycle or reformulate the
contaminated material for possible industrial usage.
3. Long-range planning for site restoration and ultimate dis-
posal of large volumes of sludge and soil saturated with
contaminants.
As the cleanup process went on, the above-approach evolved into
two phases of activity:
Phase 1: Immediate removal of dangerous chemicals from the water
stored inside the facility and drainage of the pits, which re-
duced the possibility of additional spillage.
Phase 2: Disposal of approximately 100,000 gallons of the
remaining liquid waste and long-range planning and resolution
of the overall cleanup and restoration of the site.
In conclusion, a site containing large amounts of toxic and haz-
ardous substances that for years had threatened the public health and
environment in Chattanooga, Tennessee, was brought under control and
cleaned up at a relatively small expense. The positive attitude of
the participating agencies' personnel made the operation a success.
1-2
-------
2. THE SITUATION
Approximately 200,000 gallons of water contaminated with oil
emulsions and chemical wastes were stored at National Waste Oil, a
private industrial waste disposal company in Chattanooga, Tennessee,
that had gone bankrupt. The property was adjacent to Citigo Creek, a
tributary of the Tennessee River that is the water supply source for
Chattanooga. For two years, several large and small spills of oil
mixed with other contaminants had occurred at the site, resulting in
the contamination of the Chattanooga sanitary sewer system, Citigo
Creek, and the Tennessee River. Personnel from the United States
Environmental Protection Agency (EPA), Region IV in Atlanta, and the
Tennessee Water Quality Division had made numerous attempts to correct
the situation through legal enforcement and mechanical removal. These
efforts for the most part were futile because the company was insol-
vent and also because of the technical problems involved in removing
many layers of contaminants and then disposing of the removed
materials.
The health hazard presented by several unprotected tanks and two
large pits filled with mixtures of oil, water, and waste chemicals
necessitated a removal approach different from what had been used
before. Disposing of the pollutants would also require disposing of
residual materials. On July 21, 1978, a decision was made to activate
EPA's Environmental Emergency Response Unit (EERU) and the Mobile
Physical-Chemical Laboratory from Region II, Edison, New Jersey. EERU
would be responsible for separating pollutants from 80,000 gallons of
contaminated water at the site.
2-1
-------
The EERU is a mobile physical-chemical treatment system designed
to respond to, control, and treat spills in situations where the use
of complex cleanup equipment and techniques is not feasible or avail-
able. The system contains portable and semi-trailer-mounted equipment
with flexible capabilities for flocculation, sedimentation, filtra-
tion, and carbon absorption. Water can be processed at flow rates
between 380 and 2,270 liters per minute. The support equipment for
the system permits the treatment trailer to locate 150 meters from a
spill location. In Chattanooga, a single granular activated carbon
column and a sand column for final polishing were used.
The Mobile Laboratory is designed to provide on-site analytical
services during oil and hazardous substance spill response and cleanup
operations. It aids in the cleanup of spills by eliminating the time
that would be spent transporting environmental samples to distant lab-
oratories for analysis. The Mobile Laboratory is equipped with two
gas chromatographs with flame ionization and electron capture detec-
tors, an atomic absorption system, and an automatic sampling system.
The following is a chronology of Phase 1 of the cleanup opera-
tions.
Response and Observations: Chronological Events
July 21, 1978
Because of worsening conditions at the storage site and the po-
tential danger of contamination of the Chattanooga drinking water
system, a decision was made at EPA Region IV in Atlanta to mobilize
the EERU and move on-scene as quickly as possible. George Moein, the
On-Scene Coordinator (OSC) for the incident, obtained financial infor-
mation from the U.S. Coast Guard {USCG} second district office. He
also contacted the EERU project manager, Frank Freestone, and Dr. Joe
Lafanora of the same office to make arrangements for the transporta-
tion of the EERU and the Mobile Laboratory from Edison, New Jersey, to
Chattanooga, Tennessee. The OSC also received a telephone call from
Tom Ray, the attorney for receivership, who requested a meeting on
July 23.
2-2
-------
July 23. 1978
The OSC and the EERU arrived in Chattanooga at 2:00 p.m.
Arrangements were made for storing the equipment until July 24.
At 3:00 p.m., the OSC met Mr. Ray and they visited the National
Waste Oil site. The OSC observed a large number of drums inside the
^ fenced area. Some were full and others were empty.
^ A pit containing approximately four feet of oil was located next
to four large above-ground tanks. A depression around the tanks con-
tained oil and water. Shorter tanks located behind the large tanks
U were unprotected. Several other tanks were standing on the property.
s
Contaminated soil and puddles of water were found throughout the site.
A warehouse and adjacent offices were vacant, but additional drums
were in the warehouse. After a brief discussion with Mr. Ray concern-
, i ing cleanup strategy, the OSC left the scene to make arrangements for
transporting the EERU from Chattanooga to the facility site.
' The OSC requested that Chattanooga police patrol the work area
during the night to protect the EERU and support equipment. The de-
partment officer agreed. This request was made because of persistent
-" rumors of widespread vandalism in the area where National Waste Oil
was located.
. : l
July 24, 1978
. j
At 8:15 a.m., trucks and trailers brought the EERU and Mobile
Laboratory on-scene. Frank Freestone and the OSC started an inventory
of tanks to determine the extent of the treatable materials on-site.
Tanks were numbered and samples were drawn from each to determine the
-' contents and assign priority for treatment.
T. .
Tank II was full of water with some sludge in the bottom. All
water from this tank was treated through EERU. Later, additional
waste oil from the site was added to this tank for temporary
storage purposes.
Tank #2 was full of heavily emulsified oil and sludge. It could
not be treated through EERU.
2-3
-------
Tank #3 contained five feet of oil. It could not be treated
through EERU.
Tank #4 was full of water and emulsified oil. The contents of
this tank were treated through EERU. Later, waste oil from the
site was added to this tank for temporary storage purposes.
Tank 15 contained six inches of pure oil. It could not be
treated through EERU.
Tank #6 was full of water and emulsified oil. It was treated
through EERU.
Tank #7 contained a small quantity of oil. It was removed later.
Tank #8 contained a small quantity of oil and sludge. It was
removed later.
Charles Hunt, a previous partner with National Waste Oil, arrived
on-scene and accompanied the OSC to inspect the drums, a ditch, and
nearby Citigo Creek. Mr. Hunt stated that many of the drums had been
pumped out and were empty. He said that the used drums could be uti-
lized by the government for storage purposes.
At 10:00 a.m., the OSC left the scene to attend a meeting at the
Tennessee Valley Authority (TVA) offices with state, TVA, and munici-
pal officials. Attending the meeting were:
Jack McCormick - Tennessee Water Quality Control
Joe Hartman - Tennessee Water Quality Control
Phil Stewart - Tennessee Water Quality Control
Edwin Robertson - TVA, Water Quality and Ecology Branch
Drew Miller - TVA, Water Quality and Ecology Branch /
Tony Sklanka - Chattanooga Wastewater Treatment Plant
George Kurz -City of Chattanooga
Eugene Wright - Chattanooga Department of Public Works
George Moein - On-Scene Coordinator
2-4
-------
The purpose of the meeting was to advise the participants of
EPA's intentions and to coordinate the federal efforts with state and
municipal authorities. TVA had been involved in the cleanup effort as
well as the sampling program. It was agreed that EERU-treated water
would be released into the sanitary storm sewer under controlled con-
ditions (no more than 3,000 gallons per two-or-three-hour period).
The OSC agreed not to discharge anything greater than part per billion
concentration (20-100 range). The OSC asked Messrs. Wright and
McCormick about the possibility of discharging the liquid stored at
the Moccasin Bend sewage treatment plant into the sewer for treatment
under controlled conditions and ultimately discharging it into the
Tennessee River. Mr. Wright agreed with the approach and suggested
that the plant was capable of handling the quantity stored. Mr.
McCormick would not agree until additional tests had been made on the
chemical composition of the liquid. The OSC took this suggestion
under advisement.
At 11:20 a.m., the OSC returned to the scene with Mr. McCormick
and his associates. They were shown the samples taken from the tanks
and briefed on the operation of the EERU by Mr. Freestone.
At 1:45 p.m., the main unit became fully operational. The auxil-
iary generator provided the main source of electrical power. A city
electrician was in the process of attaching a line for power from the
city.
Later, Edwin Robertson of TVA arrived and observed the operation
with Joe Hartman and two associates from the state Water Quality
Control office.
The OSC telephoned Tom Ray and discussed the day's events.
At 6:00 p.m., work stopped for the day.
July 25, 1978
At 8:20 a.m., the OSC arrived on-scene and talked with Mr. Free-
stone and the laboratory personnel. About 3,000 gallons of treated
water were ready for discharge. The OSC requested laboratory testing
of the effluent before final discharge was made into the sewer. The
analysis showed the concentration level of chlorinated hydrocarbons at
less than 19 parts per billion. The OSC authorized the discharge.
2-5
-------
The pumping and filtration continued without difficulty.
At noon, the OSC and Mr. Freestone arrived at the Moccasin Bend
treatment plant and met Mr. Wright, the assistant director. Mr.
Wright explained that when 20,000 gallons of liquid waste were brought
to the plant for temporary storage, they were placed inside a thick-
ener. This resulted in a strong odor problem in the vicinity and
necessitated adding another 20,000 gallons of water to the thickener
to dilute. When the thickener was observed closely, it was apparent
that large quantities of suspended solid had also been mixed with the
water. The suspended solid in water would have caused tremendous dif-
ficulty for the filtration process. Mr. Wright explained the capabil-
ities of the plant and restated its ability to process the liquid ade-
quately and safely. It was decided that the OSC should confer with
Mr. McCormick again and make arrangements that were mutually agree-
able.
At 2:00 p.m., a sudden heavy rainfall began and lasted most of
the afternoon. This slowed work progress to some degree.
At 3:00 p.m., Messrs. McCormick and Hartman arrived. Technical
discussions took place related to the toxicological and chemical
characteristics of hexachloronorbornadiene and heptachloronorborna-
diene, two of the compounds that had also been found in the water in
addition to oil. The OSC requested technical data from Region IV on
the chemicals.
The filtration process continued.
July 26, 1978
At 7:30 a.m., the OSC and Mr. Freestone met Uwe Frank, a chemist
from the Region II laboratory, and took him to the scene. Mr. Frank
remained for two days in an advisory capacity to the Mobile Laboratory
personnel. During a meeting with personnel of the Mobile Laboratory
and the EERU, the EPA chemists stated that they required laboratory
standards before they could test the influent and effluent for chlori-
nated pesticides and other hydrocarbons. Since TVA had done previous
sampling and analytical work for these compounds, a call was made to
the TVA chemist, Brian Jerome, to request the data. Mr. Jerome ex-
plained that they had used mass spectrometry and could not supply the
2-6
-------
standards. The OSC telephoned William Loy, EPA chemist at the labora-
tory in Athens, Georgia. The Surveillance and Analysis Laboratory
agreed to send the standards and an EPA employee brought the materials
that afternoon.
At 11:15 a.m., Phil Stewart of the state Water Quality Control
office and Frank Victory, James Spicer, and Ruth Yates of the state
Division of Solid Waste Management arrived on-scene and conferred with
the OSC. The OSC requested advice on a land disposal site where the
used carbon and sand could be disposed of properly. The state
officials could not suggest a site but said they would investigate.
The OSC explained that the government role would end once the oil and
water had been separated in the tanks and the diked area. The OSC
also stated that he was not authorized to commit federal funds for
large-scale soil removal and disposing of waste products. Discussions
ensued. The state Solid Waste Management officials were somewhat
uncertain on procedure for the final disposal of the solid and liquid
wastes.
The OSC telephoned the USCG second district comptroller's office
and requested an increase in the allocation of funds for the project
because of increased operational costs. The district office author-
ized the OSC to spend an additional $10,000.
At 2:00 p.m., the concentration level of oil and chemicals for a
discharge batch was less than one part per billion. This data was
relayed to the OSC by the laboratory personnel.
Curtis Groin of Groin Waste Oil Company in Chattanooga met with
the OSC and asked if he could buy the remaining oil at three cents per
gallon. The OSC explained that the oil was contaminated and added
that he would discuss the matter with state and EPA officials.
July 27, 1978
At 8:30 a.m., the OSC arrived on-scene and conferred with Mr.
Freestone and the EERU technicians.
The OSC telephoned Mr. McCormick and also spoke with Mr. Hartman
about the possibility of gradually discharging the water stored at the
Moccasin Bend sewage treatment plant into the sewer system for treat-
ment. Mr. Hartman said that TVA had not completed laboratory analysis
2-7
-------
of the water, but stated that if concentration levels were low, he did
not anticipate any problem with a gradual discharge. The OSC tele-
phoned Frank Victory to inquire about a possible land site for dis-
posal of the used carbon after completion of the EERU operation. Mr.
Victory stated that no decision had been made.
Mobile Laboratory personnel reported to the OSC the results of
their analysis of the water stored at the Moccasin Bend treatment
plant:
Hexachloronorbornadiene 0.5 ppm
Heptachloronorbornadiene 0.7 ppm
Heptachlor 0.2 ppm
The OSC relayed this information to Mr. McCormick, who said that he
would call TVA to ask whether the effluent samples from Moccasin Bend
had been analyzed.
The OSC spoke with Frank Victory, who said that the state would
allow disposal of the used carbon at a Chattanooga landfill provided
that certain conditions were met. The conditions and procedures would
be itemized in a letter that Mr. Victory would deliver.
At 4:00 p.m., Messrs. McCormick and Hartman arrived on-scene.
After some discussion, Mr. McCormick agreed to the proposal to grad-
ually discharge water at the treatment plant into the sewer system.
He also agreed to make arrangements with the sewer treatment authori-
ties. The OSC thanked the state officials for their assistance.
At 5:15 p.m., state personnel left the scene. At 6:00 p.m.,
operations ceased for the day.
July 28, 1978
At 7:20 a.m., the OSC arrived on-scene and conferred with Mr.
Freestone and other personnel.
At 9:00 a.m., Al Smith, Chief of the Environmental Emergency
Branch of EPA Region IV, arrived on-scene and stayed until noon.
Shortly afterward, Tom Ray arrived. The OSC explained the re-
sponsibilities of future owners in terms of compliance with the Spill
Prevention regulations. Mr. Ray said he understood the process.
2-8
-------
The OSC telephoned Curtis Groin, who withdrew his proposal to
purchase the remaining oil at the Chattanooga facility because it was
highly contaminated.
At 10:30 a.m., Messrs. McCormick and Hartman arrived on-scene and
conferred with Mr. Smith and the OSC.
At 11:00 a.m., Mr. Victory and Ms. Yates arrived on-scene and
conferred with the OSC and other EPA representatives. The OSC had
decided that because of the difficulties involved in disposing of the
used carbon in Chattanooga, it should be disposed of or recycled at
Edison, New Jersey. Mr. Freestone and other EERU personnel had made
the necessary arrangements for the disposal of the used carbon. The
OSC relayed this information to state personnel and explained that
under present conditions it was not feasible for the government to
make disposal arrangements in Chattanooga. The larger problem of dis-
posal of sludge and residuals from the site was discussed again with
the state personnel and their assistance was requested. It was appar-
ent that the state was not in a position to provide an approved site
in Tennessee for this purpose. Therefore, discussions centered on
other alternatives, such as spraying for dust control, incineration,
etc. Also, suggestions were made to move the waste outside the state
of Tennessee, which would be highly expensive because of transporta-
tion and related costs. The meeting concluded without any significant
resolutions.
The OSC telephoned Marilyn Kelm of EPA's regional Office of
Public Affairs to discuss the news conference scheduled for July 29.
The OSC also telephoned Henry VanCleave of the Oil and Special Mate-
rials Control Division, EPA in Washington, DC, to brief him on prog-
ress to date.
Mr. Freestone reported that 55,000 gallons of water had been
processed through EERU and freed of oil and other chemicals.
July 29, 1978
At 8:00 a.m., the OSC arrived on-scene. EERU personnel had been
there since 6:30 a.m. preparing the unit to leave the area. At 9:10
a.m., Mr. McCormick arrived and discussed the press conference with
the OSC.
2-9
-------
At 10:00 a.m., the OSC and Mr. McCormick met with representatives
of the news media and answered questions related to cleanup and re-
moval phases at the National Waste Oil site. The OSC left the site at
11:00 a.m.
Analysis of samples collected before and during the first phase
of operations revealed a myriad of chlorinated hydrocarbons and other
organic chemicals including heptachlor, chlordane, isodrin, dieldrin,
endrin, hexachlorocyclopentadiene, hexachlorobenzene, and great con-
centrations of phenols. The distribution profile showed the greatest
concentration of phenolic compounds in the open pits with remaining
chemicals distributed somewhat evenly in the soil and liquids, both
inside and outside the tanks.
The filtration of liquid waste through sand and carbon columns
had progressed rapidly and without any significant problems. Chemi-
cals removed from the water by the granular activated carbon included
chlorobenzene, heptachlor, and other pesticide-related halogenated
organics as well as oil and oil emulsion. Concentrations of pesticide
contaminants were reduced from 1-5 ppm in the influent to 1-20 ppb in
the effluent. Petroleum oils were reduced to below the detectable
limits (1 ppm).
The 55,000 gallons of contaminated water that had been treated
by the system and the effluent were gradually discharged into the
Chattanooga sanitary sewer system with the approval of state and muni-
cipal authorities. Another 30,000 gallons of contaminated water were
discharged gradually into the Moccasin Bend sewer treatment plant for
ultimate disposal. The spent carbon and sand filters were shipped to
Edison, New Jersey, for recycling and disposal.
After the completion of this phase of the cleanup, there remained
the problem of disposing of approximately 100,000 gallons of highly
contaminated oil and tons of contaminated soil and sludge as well as
restoration of the site to resolve potential spillage and leachate
hazards.
During the following months meetings were held with EPA, TVA, the
state Water Quality Control and Solid Waste Management offices, and
the site's previous owner to formulate a plan. At a meeting on
October 24, 1978, in Chattanooga, a task force was formed and chaired
jointly by Mr. Moein and a representative of the Tennessee Water
2-10
-------
Quality Control office. The purpose of the task force was to initiate
a plan by December 6 that would include ultimate disposal of the waste
oil and contaminated soil.
It was the intention of the task force to find a means to recycle
the waste oil and to place it back into industrial use. This process
required several weeks of sampling and searching to locate an appro-
priate recycler with the capability to separate the contaminants from
the oil and reuse the oil. Much of the contaminated oil had been
removed from the Chattanooga site to a more secure storage site in
Knoxville, Tennessee, as an interim measure until a permanent disposal
site was found.
In November, a recycling vendor was located near Ashville, North
Carolina, that had the hardware and economic incentive to remove and
reprocess the waste oil from Knoxville. When the first load of oil
was shipped to North Carolina for processing, the overwhelming noxious
odors caused several of the recycler's employees to become ill during
the off-loading process. Therefore, the load was returned to Knox-
ville and the idea of recycling was abandoned by the task force.
The Region IV Environmental Emergency Branch requested activation
of the Environmental Response Team in order to better define the
nature of the waste and determine if its volume could be significantly
reduced by treatment of the aqueous portion through the EPA Mobile
Physical-Chemical Laboratory. From the depth profile obtained by sam-
pling, it did not appear that the use of the Mobile Laboratory would
be a cost-efficient method of reducing the volume of waste.
The group then began planning for a routine disposal method,
i.e., to locate an approved disposal site and transport the contami-
nants there. EPA, under the provisions of Section 311 of the Clean
Water Act, agreed to pay for the transportation and disposal of the
contaminated oil. In addition, EPA and the other task force agencies
made financial commitments for the disposal of contaminated soil and
restoration of the abandoned site.
An approved incinerator was located in South Carolina and about
100,000 gallons of contaminated oil were shipped there and incinerated
between December 1978 and February 1979. The question of soil dis-
posal and site restoration still remained unsolved and was the subject
2-11
-------
of differing opinions among the task force members. Legal complexi-
ties between the state's Attorney General's office and previous owners
of the company complicated plans for cleaning up the site because of
questions related to site ownership and liabilities.
Through legal negotiations, a previous owner who had recently
purchased the site from the bankruptcy court agreed to assume respon-
sibility for the cleanup of the site if a reasonable plan was sub-
mitted by the task force. The state Solid Waste Control office agreed
to a plan to cap the contaminated soil with layers of clay and top it
with soil and grass seed. This plan was eventually followed by the
new owner without any additional cost to state or federal agencies.
2-12
-------
3. PHOTOGRAPHS
3-1
-------
TEMPORARY POND HOLDING CONTAMINATED OIL
3-2
-------
3-3
-------
I
<
o
cc
u.
to
la
5
a
LU
UJ
CC
UJ
Ul
3-4
-------
cc
Ul
z
H
Z
UJ
5
oc
H
D
OC
Ul
ui
3-5
-------
oc
O
Sc
DC
O
OQ
Ui
J
00
O
D
OC
3-6
-------
o
uu
x
o.
X
i
Q
O
O
O
o
z
z
o
o
3-7
-------
HOLDING POND CONTAINING CONTAMINATED OIL
WITH PHENOLS AND OTHER CHEMICALS
3-8
-------
3-9
-------
-------
4. TASK GROUP REPORT
ON
NATIONAL WASTE OIL CORPORATION SITE
BY
DIVISION OF
SOLID WASTE MANAGEMENT
4-1
-------
Before summarizing this report, the Division of Solid Waste Management
thanks the designated personnel of the task force for the time and effort put forth
by the different agencies working on this complicated problem.
On October 2
-------
Approximate Amounts of Material For Disposal
(Over estimation)
17 barrels plastic covered (sludge, etc.)
Concrete pit with sludge (10'xl8'x3')
100 barrels sludge and materials
(approximately 10 gallon per barrel)
Diked area (sludge) (lOSW/'xl.J-1)
Diked area (soil) 2 U'xl05'x6')
Sides + (I'x27'x6l)
+ (2'x27'x6')
Bottom + (2'xl05'x27')
Sludge from tanks in Chattanooga and
Knoxville (approximately 27,000 gallons)
Total or
5.0 cubic yards
20.0 cubic yards
5.0 cubic yards
158 cubic yards
275 cubic yards
cubic yards
597 cubic yards
600 cubic yards
Assuming a density of 9 pounds per gallon.
4-3
-------
OO
\o
CM
00^
c
Ss^
till
oo
*
fs.
OO
O
U
a:
2
a
tu
4)1
C|
e
o
ons
o
I
00
g2
i 2.
+* cr
i*
»i «i
4> i
4,3
E
00
"O ZJ
c o*
2^= ^ «
22
HJS-O^E^ j{
«, *» 5 f t_ v
»2
uj (fl O fl t Q
J3 "^ J 2 w
E
5\
tN
1&1
* -a o
4> 3 ?
|5i
e
rx.
a^cf*
o .*>
'P
23
S.f
O ^-
3
JX
6
"
CJ
O
u
o
i
Q.
<
4)
*rf
ra
s
TJ
I
50
^C
'3
so
^
4)
a.
oo
^
I
f
?
V
o
Ul
2o .
<^ J3
o a.
5 *:
03;
O (J
m ;;
. ^3
38. 2S.
u
(0
cu
£
I8
2. >>
21
2s 2
_c
"3
n)
1/1
2 2
OJ <
U
yi
Z
aj
ir>
00
W) -^
fl nj
I
4)
«1
J= 2 It
Sf£
"^ *
Q «->
3 Sf
O "^
<>» Q
C
O
M
I
NO,
*
4-4
-------
As of this date, December 6, 1978, no response has been made by these companies.
7. Wheeling Disposal St. Joseph, Missouri
Clayton R. Buntrock
8. Browning Ferris Lake Charles, LA
Industries, Inc.
9. Sediment Remover, Inc. Lake Charles, LA
10.Roger Rental and CeiUerville, Miss.
Landfill
11. Browning Ferris Kansas Ctiy, Kansas
Industries, Inc.
John Dillow
12. RolJin Environmental Baton Rouge, LA
Services, Inc.
13. Browning Ferris Ind. Livingston, LA
14. Cleanland, Air, Plaque mine, LA
Water Corporation
15. Nuclear Eng., Inc. Louisville, KY
(site) Sheffield, Illinois
4-5
-------
Asphalt and Rock Material Cost
2" ashphait + 4" rock $2.20/yd2
2" asphalt + 6" rock $2.64/yd2
4" asphalt -i- 4" rock $3.51/yd2
4" asphalt + 6" rock $3.95/yd2
No grading or labor, just material
440 lb/yd2 4" asphalt
440 Ib/yd^ 4" rock
$11.65/ton + $1.50/ton hauled = $13.50/ton
Rock
$2.75/ton + $1.25/ton hauled = $4.00/ton
Tar and Gravel and Rock Material Cost
2 acres cost
$21,296
$25,555
$33,977
$38,236
2 acres cost
$12,487
$16,746
0.3 inch (tar & gravel) + 4" rock 1.29/yd2
0.3 inch (tar
-------
Stein Construction - Chattanooga
Removal and Hauling of sludge and dirt to Pinewood, South Carolina.
$100/cubic yard 600 cubic yards $60,000
Dressing up of site at $1*00 /acre (approximately two acres $2800)
Site scraped and put in diked area.
3" Clay soil over 1.5 acres @$4.50/cubic yard $2,718.
3" Top soil over 2 acres (9$6.50/aibic yard $5,238.
Grass $35 per/1000 square feet $3,049.
.0225 disposal cost per/lb. .02 jisposal cost per/lb.
$2*,539 Total disposal cost $21,812 Total disposal cost
60,000 Removal and haul 60,000 Removal and haul
2,800 Dressing site 2,800 Dressing site
2,718 Clay soil 2,718 Clay soil
5,238 Top soil 5,238 Top soil
3,049 Seeding 3,049 Seeding
$98,344 Total Cost $95,617 Total Cost
Ferguson
Total cost of work desired at site estimate in lump sum.
$850/load after 11 loads30 cubic yards per load.
$50,623 Lump sum $50,623 Lump sum
24,539 Total disposal cost 21,812 Total disposal cost
$75,162 Total Cost $72,435 Total Cost
(§.0225 @.02
Denny Dobbs
Total cost given between $70,000 and $80,000.
+24,529 +24,529
$94,529 $104,529 Total
$70,000 $80,000
+21,812 +21,812
591,812 5101,812 Total
3" clay soil (§ $3.50/cubic yard - 3" top soil @ $15.00/cu. yd.
Grading of site <§ $3.00/cu.yd.,- Seeding $1500 per/acre
4-7
-------
1.
2.
3.
5.
6.
7.
Summary
Oil must be removed from tanks in Chattanooga and Knoxviile to the
place designated by EPA for disposition. Any water in the above tanks, or
any water from the treatment process of the oil is to be handled by EPA,
the city of Chattanooga and Water Quality.
Sludge from the tanks, diked area, pit and barrels, plus soil surrounding
sludge in the diked area must be removed and transported to a site
designated for the handling of hazardous waste.
Tanks that are to be removed must be removed prior to grading and
covering of this site. Also, paint materials must be removed prior to
cleanup.
Dike area must be lined with 3" of clay, then filled by grading with a
portion of the surface soil from the site which is contaminated.
A 3" clay cap will then be added over the appropriate area of the site
which is considered the most contaminated.
A 3" layer of top soil should be added to the entire site approximately 2
acres.
The site should be graded to drain with some kind of vegetation added to
prevent soil erosion.
4-8
-------
December 5, 1978
Subject; Geologic evaluation of the abandoned National Waste Oil, inc. site in
Chattanooga (visited November 4, 197S).
Site: Approximately 2.0 acres of land owned by National Taste Oil, Inc.
Location} Chattanooga Quadrangle (IOS-SE)j located in East Chattanooga
approximately 1.2 miles southeast of the confluence of the Tennessee River and
South Chiekamauga Creek and just northeast of the Harry Defiutts Yards (see
accompanying topographic map).
Topography; The plant site and storage area of National Waste OU are situated In
an area of low relief and very gentle slopes. Total relief on the site Is less than 5
feet with slopes of less than 5 percent prevailing In the area. The site slopes gently
to the southwest towards a broad, shallow drainage way that drains into Citico
Creek approximately 200 feet from the site (see accompanying topographic map).
The site has been disturbed somewhat from hs original configuration as a result of
the storage facilities at the she. A small lagoon (1 25^25^ V) containing a mixture
of waste oib and water Is located In the western section of the site with several
storage tanks located in and around the lagoon. A small drainage ditch Is present
along the southwestern boundary of the site with some residuum having been pushed
up along the northwestern side of the site. Small amounts of spilled waste oil were
noted across the site as evidenced by dark-ctalned residuum. Several drums of
unknown waste materials were also observed on the she.
Bedrpcki Lithoiogy; According to the Geologic Map of the Chattanooga
Quadrangle ?ClM""'IQ>»SE)» 1964, by Flniayson, et. at, the proposeors!te is underlain
by th« tower part of the Chiekamauga Limestone of Oroovlcian Age (see
accompanying geologic map). The Chiekamauga Limestone in this area consists
primarily of light-gray to gray, fine- to coarse-grained, thin- to thick- bedded
limestone with some minor quantities of dark blodcy chert. A thin (4 feet) layer of
bentonhe b also located at the top of this lower section of the Chiekamauga;
however, ft b not thought to be present at the she. Several large loose and solid
pieces of gray limestone bedrock were noted at the she, primarily in the
i KM uieastein section*
Structuret The proposed site b situated in a folded and faulted region}
however, no major structural features are known to be present within a mile of the
she (see accompanving geologic map). Bedrock underlying the she strikes
approximately N 2^£ and dips to the southeast at approximately 5 to 10 degrees.
Minor fracturing of the underlying might have occurred as a result of past folding
and faulting in the region.
Weathering? According to the Soil Survey of Hamilton County, 1947, by Roberts
and Tyer, the she b underlain by Colbert and Melvln type soQs (see accompanying
soils mapX The Colbert Soils are present In the northeastern portion of the site and
consist of an upper surface soli, 3 to 3 Inches thick, of brownish-gray, triable silty
clay team that b underlain by a tight, tough, plastic clay or silty day loam to a
4-9
-------
depth of about 20 inches. Below these upper Layers Is a gray to yellow day. Plat
limestone fragments are common throughout the soil profile. These soils have very
low internal drainage with surface runoff being high as a result. Depth to bedrock
for areas underlain by Colbert soils generally ranges from 20 to 30 Inches. The
Melvin soils are present in the southwestern section of the site and consist of an
upper 8 to 10 Inches of dark-gray, sllty clay loam that Is underlain by a greenish- to
bluish-gray, heavy sticky, plastic clay or silty day. These upper layers are
underlain by a mottled yellow, gray, and brown plastic day. The Melvin soils have
very slow internal drainage with surface runoff being high as a result. These soils
are neutral to alkaline In most places.
Hydrologyi Surface; Surface runoff from the proposed site drains to the south-
western corner of the site and then to the south towards Cltico Creek, located
approximately 200 feet south of the she (see accompanying topographic map).
Runoff from the site Is* moderately high due to the fairly Impermeable soils at the
site. However, the gentle slopes at the she In combination with the disturbed
nature of the she from post operations has resulted In localized areas with the
potential for ponding rainfall. In addition, evidence at the site indicates that
surface runoff from the area northeast of the site drains through the entrance gate
and across the site to the southwestern comer. A small drainage ditch was also
observed along the southwestern boundary of the she which drained to the
southwestern comer.
Subsurface: Site specific data on ground-water conditions existing In the
vicinity of the National Waste Oil site is unavailable at this time. However, the
occurrence and movement of ground-water in the underlying bedrock is controlled
by secondary openings such «s joints, fractures, and solutional openings In the
bedrock. Depth to ground water In this area is probably about 30 to 40. feet with
the direction of ground water flow most likely being towards the Tennessee River,
a natural ground-water discharge point.
Recommendations; Based upon the above information, as well as the attached
waste and soil analysis, the following recommendations are made with regards to
the disposition of this she:
1) Ail waste liquids and sludges contained on the site should be removed from
the she and properly disposed.
2) A minimum of one foot of soil should be excavated from the bottom and
side of the lagoon located on the she with additional excavation possibly
necessary depending upon conditions encountered in the field.
3) A minimum of 3 inches of soil should be graded from the surface of the
affected area and placed Into the excavated lagoon. A minimum of 3
Inches of compacted day should be placed on the floor and sides of the
lagoon prior to filling.
») A minimum of 3 inches of compacted sihy clay or clay and 3 Inches of
suitable topsoll should be placed over the affected area.
5) The area should be properly graded to facilitate runoff and to minimize
erosion (sediment transport) at the she.
4-10
-------
The above recommendations have been determined necessary In order to minimize
the potential for degradation to surface and ground Waters in the area as well as
potential subsequent health problems.
John MTHInes
Geologist
km 2/14,2/16
4-n
-------
VMllULf crATftl OOTKEKMEST
Memorandum
TENNESSEE VALLEY AUTHORITY
TO - i Al*n E. fiaalley» Mnager, Support Bervleec, 12^1 fcOXB,. Chattanooga.
no* r'UmiA G.'Carpenter, Saperrifior, Analytical Section, 150 bQlB, Chcttanoogi
DATE :*lteoeBfcer 1, ISTtJ -
AlAETETOLL """WiT* FBGK 1ATHBUL WASTE OIL SOIL 8AHPUS -
atttcfaei tet*. were obtained tnm tbe coil »aaples collected from
Vaste Oil Control* Inc. site on loujjbcx 15, 1978*
«ftr*rta were sereaied co. g»c rhTnantngvattiii equipped with flaw iooixatli
and «lAetzm captart detectors. TTOK thLa data it VBS ceea that
irtaberg G-3, G-13, and G-19 cnntAlnr^ sufficient lerels of cootomi-
to nrraat fortiwr «tod7. A portion of each of. these extracts
elacced 19 fer eelae edirrantt ogrgpiiy witb flnrlsil snd the eloattea vere
£ty CC «itb electron capture detection. The three
extract* were also examined by QC/M5 operating in ttoe electron ta$act
. Tbe three extracts vere found to be bearilj t~ytj**i ****4 with slljhatic
"hydrocarbon* Which, interfered with tie deteralnittioo of low lercl cotrta»-
imats ty GC/85« A etaqiuwd not pmloosly reported In ^prli».r «ork oo
fomd la B««ple maber 6-3. ,. - :'- :,.-..^
= - -i;-£.=-
G. CariM&ter
- ,'- J -f- * « - '
*"-»-
':^-*~ -«V '. - <"."- .-
4-12
-------
Aattoritr
Dlri*' '. of CEcrlrooBatAl KUnaiag
Laboratory
CaBeaatntLana in P*rta per Milling (foxy
totsia)
Control
2.9
<»ffL
<;cn
860
G-12
'<-ai'
-.at;
:«-3fc -f-; <»OL \ '^.-^ai" t -<-
!>: : '-.s- --- . . -'.-r:'-1 £ ':# .-.-. 'V '.'
;V :.. . ' ..'- -/- -" *.--&>i:;.;.3J:-/-<:»<;.--:..:
:-' .-r »» ---.' -- »- '-'. ^ '* *',, '!" ' - .' ^- -
r -'.! -..'- .,-- - --^- .:. --.-:' -' .--- -«i-! ^M;-- ' £"-'-"
>ft: -. . ,-..,-, -I.?;.- . "!'t' ":-v'T-f-;J''A :'.'; ..'
; ;- ^^^l'i:--: r - "--::"'"- c :>S-:* ft^illi^v^ ^ r^r
' -; i#-." >-- -- ' - --:- .; 4-;>^:S:-:< . ~ -..'.-:.
' ^i ;laatlar»e^ "far glectrcct caytSi.^ OC ' *
"' [ ! \ . ... . .. ..:..;>.:*.«$;;!_:.:;;_._? ._-,_:
:- 'la :inaiyMd tor a/te """^^:i^- '*--:^ ;
. .;* . IMM»1J»--VI. w^ w.fim> _^ :..-:S.v,..;.;, .a.iT:.j..-; ..:*.
^-^.^ .. _ -. - _ _: .q4T;4SvS>Y^1;V-:*':'u.l..- '
: jl"-|i":: -'. ': " ''-"'".' * ~?VV^;:f ^-^;i;:.;:.-^--,
; :-^X.*U;-".-:.: s- ,,.:..=,;- ^^--l^f'H ^ ?.-^l
&?
"'..!''-.
i j-.i- ';
^' J-^-|'
v:Vi?."
'.'--«^;:
..i1'?.
.-;,/>
'-tt
I '? ,**:^.- f"*-' ' '*-'' Z»*C-.' '" ^ '*.'**'* '*'^ ""''" W-**' '{',' '-7i "*--*
V .!, '
jt"
: ifci,-?.s5'-i'x i^'-i
4-13
-------
36
30
24
18
CENTRAL
BUILDING
35
29
23
17
I!
34
28
22
16
10
33
27
2!
15
32
26
PARKING AREA
SAMPLING
STATIONS
SAMPLING GRID LAYOUT
NATIONAL WASTE OIL CONTROL, INC.
GRID LAYOUT 11/14/78 SAMPLING-11/15/78
4-14
-------
WAT lu (s)
OCT 3 1
RAY B.ANTON
:uO*«* W rownkla. M.O.. M P H
STATE OP TENNESSEE
DEPARTMENT OF PUBLIC HEALTH
NASHVILLE 37ZI8
621 Cordell Hull Building
October 27, 1978
Mr. Tom Tiesler
Solid Waste Disposal Division
320 Capitol Hill Building
Nashville, Tennessee 37219
Dear Mr. Tiesler:
Enclosed is a copy of analytical results of a sample collected
recently and submitted to this Division for analyses. I hope this
data will be of help to you. If we may be of further service,please
let us know.
Sincerely,
I
O.D. Xeaton,Chief
Laboratory Section
Division of Water Quality Control
ODK/plp
Enclosure: P - 331
4-15
-------
ORGANIC LABORATORY ANALYSIS REPORT
Field Log. No.
Laboratory
Sample No, P- Jj Y Date Received: /fc////7/ Date Completed; /<£>
Sample Collected By: /?// /^ JC /W 4/afr/Date Collected: /g>/£
Sample Source
-------
NATIONAL WASTE OIL MEETING
Chattanooga, Tennessee
October 24, 1978
Terry K. Cothron
Jack McCormick
Joe Hartman .
James S. Morris
D. A. Barnect
J. Clement Burdick III
Ralph H. Brooks
CDR Ralph W. H. Bartels
Robert H. Wolle
Anne L, Asbell
Richard E. Kargraves
Ron Wene
Rita Davenport
Howard Zeller
George J. Moein
Frank Victory
Jerry M. Loftin
Ruth Yates
Stephen Swann
Dvayne Frye
Don A. Owens
Larry D. Watson
Tennessee Division of Water Quality Control
Tennessee Division of Water Quality Control - Chatt.
Tennessee Division of Water Quality Control - Chatt,
Tennessee Valley Authority - Environmental Planning
2nd Coast Guard District - St. Louis, MO
Tennessee Valley Authority - Environmental Planning
Tennessee Valley Authority - Environmental Planning
2nd Coast Guard District - St. Louis, MO
Deputy Commissioner for
Tennessee Department of Public Health
Attorney, E?A
Tennessee-American Water Company
Vice-Pres-Mgr. Tennessee-American Water Company
EPA, Solid Waste
EPA, Enforcement - Atlanta
EPA - Atlanta
Tennessee Division of Solid Waste Management -
Nashville
Tennessee Division of Solid Waste Management -
Nashville
Tennessee Division of Solid Waste Management -
Nashville
U.S. Coast Guard - St. Louis, MO
Tennessee Division of Water Quality Control - Knoxville
Tennessee Division of Water Quality Control - Knoxville
Tennessee Division of Water Quality Control - Knoxville
4-17
-------
Meeting - November 1, 1975
N a me
Jack McCormick .
Alan H. SmaHey
William F. Victory
Ron Wene
Eugene G. Wright
Char!ie Hunt
Joe Hartman
Wi11iam H. Howard
Rita Davenport
George J. Moein
Organi zati on
Tennessee W.Q.C. - Chattanooga
TVA - Chattanooga
SWM - Nashville
Tennessee- American Water Company
City of Chattanooga
North American Environmental Corp,
Tennessee W.Q.C.
Hamilton County Health Oept.
U.S.E.P.A. Solid Waste - Atlanta
U.S. EPA, Atlanta
4-18
-------
Meeting - November 27, 1978
Name
Frank Victory
Ruth Yates
Jack R. McCormick
Joe Hartman
Eugene G. Wright
Doye Rowland
Alan H. Smalley
Rita Davenport
George J. Moein
Charlie Hunt
0 r g a n i z at ion
Div. of Solid Waste Management - Nashville
Div. of Solid Waste Management - Nashville
Div. of W.Q.C. - Chattanooga
Div. of W.Q.C. - Chattanooga
City of Chattanooga
Oiv. of Solid Waste Management - Nashville
TVA - Chattanooga
US EPA. , Atlanta
US EPA, Atlanta
North American Environmental Corp.
4-19
-------
-------
U S. Environmental Protection Agency
Librsr". ""<"" W'\ PM-211-A
401 M Street. S.W.
Washington, DC 2046Q .-J
-:-t,':- .- ' - -it/"-!-'''"'' . ' % . -! -,^- <.. ,','C" '' ....
-------
#v
------- |