United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-91/087
September 1991
& EPA Superf und
Record of Decision:
Wrigley Charcoal, TN
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50272-101
REPORT DOCUMENTATION 11. REPORT NO. . I ~ 3. RecJpienh AcceMion No.
PAGE EPA/ROD/R04-9l/087
4. TlUe and SubdUe 5. Repott Date
SUPERFUND RECORD OF DECISION 09/30/91
Wrigley Charcoal, TN 6.
First Remedial Action
7. Authorla) a. Perlonning Organizadon Rept No.
8. Perlonnlng Orgalnlzadon Name and Addre.. 10. ProjectITaakJWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
1~ SpoMoring Organization Name and AcIdr... 13. Type 01 Report & Period Covered
U.S. Environmental Protection Agency
401 M Street, S.W. 800/000
Washington, D.C. 20460 14.
15. Supplementary Notea
18. Abalrac1 (Unlit: 2DfI worda)
The 8l-acre Wrigley Charcoal site is a former multi-use industrial operations area in
the town of Wrigley, Hickman County, Tennessee. Land use in the area is industrial and
residential, with approximately 1,000 people residing within a one-mile. radius of the
site. From 1881 to 1985, the site has been used mainly for pig iron and wood
retorting/wood distillation by-product manufacturing. Additional activities conducted
between 1978 and 1985 included usage of several remaining onsite buildings for metals
machining, copper recovery, and storage of drummed industrial wastes. Remaining
Primary Site build'ings used for these later activities include a warehouse; a dryer
building; a maintenance building; and a storage shed. Improper disposal procedures
have resulted in soil, sediment, and debris contamination by semi-volatile organic
compounds in coal-tars. (mainly PAHs & phenols), VOCs, metals, and,asbestos. EPA
investigations have identified four major areas of onsite contamination. These four
areas are as follows: the 35-acre Primary Site containing coal-tar contaminants; the
3-acre Storage Basin area, that also contains coal tar contaminants; the 40-acre
Irrigation Field (including an abandoned wastewater lagoon) that was used for spray
irrigation (disposal) and degradation of PAH and phenolic wastewaters; and the 3.5-acre
(See Attached Page)
17. Document Analysla L Descriptors
Record of Decision - Wrigley Charcoal, TN
First Remedial Action
Contaminated Medium: soil
Key Contaminants: VOCs, other organics (PAHs, phenols), metals (arsenic, chromium,
II. IdendfleralOpen-Ended Tenne lead), inorganics (asbestos)
c. COSA TI FleIdlGroup
18. AvailablUty Statement 18. Security Cia.. (Thla Report) 21. No. 01 Pagea
None 149
20. Security CI... (Thla Page) 22. Price
I Non.,.
.
(See AN$-Z38.18)
See 'fIlIlruclioflll on ReWiIN
(Formerly NTIS-35)
Departm&ntoICo~ce
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EPA/ROD/R04-91/087
Wrigley Charcoal, TN
First Remedial Action
Abstract (Continued)
Athletic Field, a field used by local residents, which is filled with blast furnace slag
and soil derived from the Primary Site from 1938-1950. The Primary Site, which includes'
a warehouse, a dryer building, a maintenance building, and a storage shed, was an
industrial production facility for iron, charcoal, and wood distillation products from
1888 to 1966. The Primary Site was later used for metals machining, storage of waste
products, and recovery of copper from transformers. The Storage Basin and Irrigation
Field were built in the late 1950s to receive wastewater from the Primary Site. In
1988, EPA performed a removal activity, which stabilized the site by installing clay
backfilled culverts covered with erosion control fabric; installing sheet piling to
stabilize the banks; retaining the tar pits; removing 8 cubic yards of asbestos
material; solidifying approximately 130 cubic yards of tar pit wastes, followed by
offsite incineration of the solidified material; establishing a vegetative cover for the
tar pit cover; constructing a spillway; and offsite landfilling of debris. This Record
of Decision (ROD) addresses interim remediation of remaining contaminated soil,
sediment, and debris, and will reduce the risks at the Primary Site and Storage Basin by
eliminating the most imminent and substantial threats while permanent solutions are
developed for the entire site. Future RODs may address remediation of the contaminated
Primary Site soil, tar pits and tar cubes, as well as Storage Basin; coal-tar wastes,
friable asbestos corrugated roofing material (ACM), and any onsite ground water
problems.' The primary contaminants of concern affecting the soil are VOCs; other
organics including PAHs, and phenols; metals including arsenic, chromium, and lead; and
asbestos, an inorganic.
. The selected remedial action for this site includes excavating, stabilizing, and
disposing of offsite approximately 15 cubic yards of metallic wastes from the burn pit;
consolidating and securing onsite approximately 120 drums of transformers; excavating,
incinerating, stabilizing, and disposing of offsite 14 waste drums, 29 cubic yards of
process tank sludge, and 122.5 cubic yards of black coal tar wastes located in three
separate areas; decontaminating the tanks; excavating and disposing of visibly friable
asbestos material in the soil and buildings within the Primary Site; re-engineering of
the spillway to accommodate flood waters; sorting and disposing of site surface wastes
and debris piles (including tar-cubes; pieces of ACM, crushed drums and metallic debris)
offsite, or temporarily consolidating these onsite for future remediation; conducting
soil investigations and continued sampling and analysis; and implementing institutional
controls including deed restrictions, and site access restriction such as fencing. The
estimated present worth cost for this remedial action is $984,998. O&M costs were not
provided.
PERFORMANCE STANDARDS OR GOALS: The remedy will attempt to meet RCRA LDR best
demonstrated available technology (BDAT) requirements for coal-tar wastes using
incineration and stabilization; and burn-pit wastes using stabilization.
Chemical-specific clean-up criteria include chromium 0.5-6 mg/kg, lead 0.1~3 mg/kg,
arsenic 0.3-1 mg/kg, and PAHs 0.5-20 mg/kg.
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RECORD OF DECISION
Remedial Alternative Selection
SITE NAME AND LOCATION
Wrigley Charcoal Site
Wrigley, Hickman County, Tennessee
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected early final action and
interim remedial action for the Wrigley Charcoal Site in Wrigley,
Tennessee developed in accordance with CERCLA, as amended by SARA,
and to the extent practicable, the National Contingency Plan (NCP).
This decision for remedial action is based upon the contents of the
Administrative Record file for the Wrigley Charcoal Site. .
The State of Tennessee concurs with the United States Environmental
Protection Agency on the selected early final action and interim
remedial actions. .
ASSESSMENT OF THE SITE
The Wrigley Charcoal Site (Figures 1-2) is located approximately
forty-five miles southwest of Nashville in the town of Wrigley,
Hickman County, Tennessee. Investigations identified four (4)
individual Site areas (Figures 3-6) where previous industrial
operations or related activities occurred intermittently from 1881 to
approximately 1985. Since 1985, trespassers have occasionally
vandalized the Primary Wrigley Site. These locations are the: 1)
primary Site; 2) Storage Basin; 3) Irrigation Field; and 4) Athletic
Field. At present, only the Primary Site and the Storage Basin were
found to contain hazardous material$ and significant contamination.
Actual or threatened releases of hazardous substances from this Site,
if not addressed by implementing the response action selected in this
ROD, may present an imminent and substantial endangerment to public
health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
Based on the Remedial Investigation and Feasibility Study (RI/FS) and
supplemental sampling and analysis, the u.S. EPA has identified
Alternative 3 (as described in the July 1991 Feasibility Study) as
the best course of action for the first step of cleanup activities to
be taken at the Wrigley Charcoal Site. The major goal of these early
final and interim activities is to address the most serious threats
at the Wrigley Charcoal Site by removing or consolidating
contaminated media at the Primary Site, and restricting access at the
-------
Primary Site and the Storage Basin. The interim activities will
achieve significant risk reduction while a final remedial solution
is developed. Additional goals of these early final and interim
actions are designed to prepare the Wrigley Site for future
remedial activities.
The components of the EPA selected early final action and interim
action include:
7 )
1 )
Metallic wastes in the maintenance buildings' burn-pit
will be excavated, transported, stabilized and disposed
of in an EPA approved RCRA facility. Transformers found
in the maintenance building will be staged with other
transformers found at the Primary Site in an on-site
consolidation area;
2)
Potential risks through dermal contact will be reduced at
the Storage Basin by fencing the area. This will
discourage and possibly prevent entry and disturbance of
this area until wastes can be appropriately eliminated
during later remedial activities;
3)
Process tank waste sludges will be excavated,
transported, incinerated, stabilized and disposed of in
an EPA approved facility. The metallic tanks will be
decontaminated, and sold as scrap;
4)
Black coal-tar sludge wastes on the ground from the
process tanks down to the North Fork of Mill Creek will
be excavated, transported off-site, incinerated,
stabilized and disposed of in an EPA approved facility;
Black coal-tar sludge wastes at the northeast corner of
the previous still house location will be excavated,
transported off-site, incinerated, stabilized and
disposed in an EPA approved facility;
5)
6)
Friable asbestos corrugated roofing material (ACM) will
be removed for disposal in an approved asbestos
landfill. Wastes are on the small building in front of
the maintenance building and broken ACM on the ground
near the dryer building, maintenance building, area near
the previous location of the still house, and in the old
tank battery. Also, ACM contaminated soils adjacent to
these wastes will be removed to an approved asbestos
disposal facility;
Exposed black coal-tar wastes in the spillway will be
excavated transported, incinerated, stabilized and
disposed in an EPA approved facility;
-------
12)
13)
8)
Twelve staged drums located near the maintenance building
and two drums in the storage shed, will be transported, "
with contents incinerated, stabilized and disposed of in
an EPA approved facility;
The spillway will be repaired and re-engineered to
accommodate the significant flood waters that frequent
this area. This may involve straightening and further
excavating the spillway down to the existing creek grade;
9)
10) . Site surface waste/debris piles that include tar-cubes,
pieces of ACM, transformer materials, crushed drums, and
other miscellaneous metallic debris and tar waste will be
sorted. Pieces of ACM will be disposed of with other ACM
previously described in item 6. Metallic scrap will be
transported off-site and disposed in an EPA approved
facility. [If during the Remedial Design (RD), it is
determined that metals debris is to remain on-site, this
waste will be placed in the on-site consolidation area.]
Materials such as tar-cubes and wastes tha~ may be
remediated during later remedial activities will be
stored in an on-site consolidation area;
11)
A limited investigative ,effort will be performed at the
Irrigation Field's three-quarter acre abandoned lagoon.
This activity will include a limited number of borings/
excavations near the previous location of the feed pipe
outflow;
EPA will negotiate with local
deed restrictions. Also Site
placards) will be implemented
Storage Basin;
municipalities to implement
access controls (fencing.&
at the Primary Site and
Sampling and Analyses:
Resampling of six monitoring wells and twelve
'piezometers at the Primary Site will provide an
assessment of the groundwater quality;
Soil sampling and analyses will be r~quired to
assess the need for any future remedial activities
behind the Athletic Field t~ the garden area;
Following the EPA early final and interim
activities, one round of residential well
sampling and analyses will be required to
that water quality has not been affected.
action
and spring
insure
-------
Activities in items 1, 3, and 8 are;nsidered to be early final
action activities. Burn-pit remediat~on will be an early final
action (however, the consolidation of transformers in activity 1
is an interim action). This pit will be cleaned up to acceptable
soil concentrations (except for lead which will be cleaned up to
1000 ppm), then backfilled with clean fill. Elimination of
process tank waste sludges is an early final action. Tank sludges
will be remediated and will meet criteria provided on page 42 of
this document. The process tanks will be decontaminated to
background levels. Elimination of the staged drums and
contaminants is also as early final action.
The EPA estimates that it will take 6 months to implement the
recommended alternative once the Remedial Design is complete.
These actions are estimated to have a total present worth cost of
$984,998.
STATUTORY DETERMINATIONS: DECLARATION
These early final and interim actions are protective of human
healtt and the environment, comply with Federal and State
applicable or relevant and appropriate requirements (ARARs) for
this limited-scope action, and are cost-effective. Portions of
this action are interim and are not intended to utilize permanent
solutions for any of the four Wrigley Charcoal Site areas. Other
portions of this action are considered to be early final actions
and utilize permanent solutions, and alternative treatment (or
resource recovery) technologies to the maximum extent practicable
given the limited scope of the action.
Because this action does not constitute the final remedy for the
Wrigley Charcoal Site, ~he statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a
principal element will be addressed by the final response action.
Subsequent actions are planned to address fully the threats posed
by the conditions at this Site. .
Since this action will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted
within five years after commencement of the remedial action as EPA
continues to develop final reme:.ial alternatives for the Wrigley
Charcoal Site. The review will be conducte: to ensure that the
,emedy continues to provide adequate protec'.~on of human health
.:.d the environment. Because this is an interim action ROD,
review of this Site and of this remedy will be continuing as part
-------
of the development of the final remedy for the Wrigley Charcoal
Site.
SEP 3 0 19~t
Date
9awbfh~,~
1"-Greer C. Tidwell
Reg~onal Administrator
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INTERIM REMEDIAL ACTION
RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
WRIGLEY CHARCOAL SITE
WRIGLEY, HICKMAN COUNTY, TENNESSEE
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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TABLE OF CONTENTS
Table of Contents
List of Figures
List of Tables
l.O,Introduction
2.0 Site Name, Location, and Description
3.0 Site History and Enforcement Activities.
3.1 Site History
3.2 EPA Involvement. . . .
3.2.1 EPA Removal Activities.
3.2.2 RI/FS Activities.
4.0 Highlights of Community Participation
5.0 Scope and Role of Response Action Within Site Strategy .
6.0 Summary of Site Characterizations.
Physiography and Topography
Surface Water Drainage.
Climatology
Demography and Water Use
Land Use and Site Access
Geology. '. . .
6.6.1 St. Louis Lim~stone .
6.6.2 Warsaw Limestone.
6.6.3 Fort Payne Chert.
6.7 Soils.. .. ....
6.7.1 Bodlne-Baxter-Ennis Association.
6.7.2 Mountview-Dixon-Bodine Association.
6.7.3 Humphreys-Ennis-Lobelville Association
7.0 Summary of Site Risks.
6.1
6.2
6.3
6.4
6.5
6.6
.
, .
.
, .
.
8.0 Summary of Alternatives
8.1 Alternative 1 .
8.2 Alternative 2 .
8.3 Alternative 3 .
.
9.0 Summary of Comparative Analysis of Alternatives
9.1 Overall Protection of Human Health and the Environment
9.2 Compliance with ARARs . .
9.2.1 Action Specific ARARs
9.2.2 Location Specific ARARs
9.2.3 Contaminant Specific ARARs .
9.2.4 CERCLA Waiver Criteria for ARARs
i
. 1
. 1i1
. 11i
. 1
. 1
. 4
. 4
. 9
. 9,
. ,10
.' 11
. 12
. 14
. 14
. 14
. 18
. 18
. 18
. 20
. 20
. 24
. 24
. 24
. 26
. 26
. 26
. 27
. 33
. 33
. 33
. 34
. 37
. 37
. 37
. 40
. 40
. 41
. 43
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9.3 Long-Term Effectiveness. .
9.4 Reduction of Toxicity, Mobility,
9.5 Short-Term Effectiveness
9.6 Implementability
9.7 Cost
9.8 State Acceptance
9.9 Community Acceptance.
or Volume
. 43
. 43
. 44
. 44
. 44
. 44
. 44
10.0 The Selected Remedy
11.0 Statutory Requirements
11.1 Protection of Human Health and the Environment.
11.2 Attainment of ARARs .
11.3 Cost Effectiveness
11.4 Utilization of Permanent Solutions and Alternative
Treatment Technology or Resource Recovery Technologies
to the Maximum Extent Practicable.
11.5 Preference for Treatment
. 44
. 45
. 45
. 45
. 45
. 46
. 46
11.6 Documentation of Significant Changes
12.0 Responsiveness Summary
. 47
. 49
12.1
12.2
12.3
Overview
Background of Community Involvement and Concerns.
Summary of Major Questions Raised During the Public
Meeting Held on July 25, 1991, and EPA's
Responses
12.3.1 Additional Comments on Behalf of the
Tennessee Farmers Cooperative
Comments During Meeting with Local Officials at
City Hall, Centerville, Tennessee, July 25, 1991 .
Written Comments Received During the Public
Comment Period and EPA's Responses to
These Comments
. 50
. 52
. 53
. 65
12.4
. 79
12.5
. 83
Appendices:
Appendix A: Soils Information from the Soils
Conservation Service
Appendix B: Copy of the Proposed Plan Presented at the Public
Meeting: July 25, 1991, Lyles, Tennessee
Appendix C: Sign-In Sheets From the Public Meeting: July
25, 1991, Lyles, Tennessee
Appendix D: Repository Information for the Wrigley Charcoal
Site
Appendix E: List of ARARs for the Wrigley Charcoal Site
ii
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Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
Figure 8
Figure 9
Figure 10
Figure 11
Figure 12
Figure 13
Table 1
Table 2
Table 3
Appendix F: Acceptable Soil Concentrations (ASCs) for
the Wrigley Charcoal Site.
Appendix G: Letters of Concurrence
LIST OF FIGURES
General Site Location Map
Facility Site Location Areas
Primary Site Layout
Map of the Storage Basin
Map of the Irrigation Field
Map of the Athletic Field
Map of the Central Basin
Site Topographic Setting
Mill Creek Drainage Basin'
.
.
Generalized Stratigraphic Column .
Cross~Section Layout Map
Cross-Section Respresentative of the Site.
General Soil Map
LIST OF TABLES
Activity Quantity/Cost Breakdown .
Glossary of Evaluation Criteria
Criteria to be Met for BDAT
iii
. 2
. 3
. 5
. 6
. 7
. 8
. 15
. 16
. 17
. 21
. 22
. 23
. 25
. ,
. 38
'. 39
. 42
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INTERIM ACTION RECORD OF DECISION
OPERABLE UNIT 1
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
WRIGLEY CHARCOAL SITE
WRIGLEY, TENNESSEE
1.0
INTRODUCTION
The Wrigley Charcoal Site was included on the National Priorities
List (NPL) in March of 1989 with a Hazard Ranking Score (HRS) of
36.14. This HRS score was developed after EPA's Region IV Field
Investigation Team (FIT) collected samples at the Site in 1986.
Approximately 81 acres at the Wrigley Charcoal Site were utilized
intermittently from 1881 to 1985 for a variety of industrial
operations. The majority of these operations consisted of pig iron
and wood retorting/wood distillation by-product manufacturing.
Remedial Investigation/Feasibility Study (RI/FS) activities were
initiated in August 1989 in response to the Site being listed on the
NPL. The RI report which examines contaminated media at the four
Site locations was finalized in July of 1991. The FS report which
examines alternatives for the early final and interim action was
submitted to the public information repository also in July of 1991.
The final report will become part of the final administrative record.
This interim action Record of Decision has been prepared to summarize
the remedial alternative selection process and to present the
selected remedial alternative, in accordance with Section
113(k)(2)(B)(v) and Section 117(b) of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA) as amended
by the Superfund Amendments and Reauthorization Act (SARA-P.L.
99-499). The Administrative Record file for the Wrigley Charcoal
Site forms the basis for the Record of Decision contained herein.
2.0
SITE NAME. LOCATION AND DESCRIPTION
The Wrigley Charcoal Superfund Site (the "Site") is located
approximately 45 miles southwest of Nashville, Tennessee (Figures
1-2). Based on available data, the Site contains four major areas of
contamination: the Primary Site; the Storage Basin; the Irrigation
Field; and the Athletic Field (Figures 3-6). The Primary Site is
located within a steep-walled valley while the Storage Basin is
located southwest of the Primary Site on top of a palisade adjacent
to the North Fork of Mill Creek valley. The Irrigation Field is
located on relatively flat lying property approximately 3/4 mile
northeast of the Primary Site and the Athletic Field resides within
the east neighborhood of Wrigley approximately 1/5 mile east of the
Primary Site. The Site's four contaminated areas as depicted in
(Figure 2) are summarized below:
-1-
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APPROXIMATE SCALE
.-. -
--- -
o
5 10 15
MILES
20
FIGURE 1
General Site Location Map
Wrigley Charcoal Site
-2-
-------
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FIGURE 2
Facility Site Location Areas
Wrigley Charcoal Site
-------
.0
1) Primary S~te (thirty-five acres represents the extent of
industrial activities in the valley);
2) Storage Basin and Overflow Basin (three acres);
o
o
3) Irrigation Field (forty acres) including the abandoned
wastewater holding area referred to as the lagoon;
o
4) Athletic Field (Also called L.A. Miller Park-three and
one-half acres).
3.0
3.1
.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Historv
The Primary Site (Figure 3) was ~sed for industrial operations such
as producing iron, charcoal, and wood distillation products
intermittently from 1881 to 1966. The businesses or individuals
involved in the industrial operations during ~his time period may no
longer exist and investigations are continuing to determine whether
or not there are Potentially Responsible Parties (PRPs) from this
time period to fund cleanup operations. The Site was purchased in
1966 by the Tennessee Farmers Cooperative (TFC) who are the present
owners of the major portion of the Primary Site. Also, according to
the TFC property boundary map (received July, 1991) they own the
Storage Basin and Athletic Field. The Irrigation Field is apparently
owned by a Ronald L. Bishop of Columbia, Tennessee.. Portions of the
Primary Site were also utilized from 1978 to 1983 (possibly as late
as 1985) by R.T. Rivers for metals machining, storage of waste
products obtained from other local industries, and recovery of copper
from transformers. These additional operations were conducted
primarily in three of the remaining on-site buildings; namely, the
dryer building, the maintenance building, and the storage shed.
The Storage Basin (Figure 4) located 1400 feet west of the Primary
Site was built in the mid to late 1950's to receive wastewaters from
the Primary Sites' industrial operations. The Storage Basin, similar
to the Primary Site contains coal-tar contaminants.
. The Irrigation Field (Figure 5) including the abandoned lagoon is
located 3500 feet northeast of the Primary Site. This location was
constructed in the late 1950's and also received wastewaters for
disposal from the Primary Site. Wastewaters were sprayed over the
field to biologically degrade phenolic and organic compounds.
The Athletic Field (Figure 6) is located 800 feet southeast of the
Primary Site in the eastern portion of the Wrigley community. The
section of property where the field now resides was filled in with
blast furnace slag and associated materials from 1938 to
approximately 1950. The field has b~en in use since the. early 1950's
and is still regularly used by local residents.
-4-
-------
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LEGEND
. ~~~~~E l~1~1':,., AND S£OI...ENI
. SURr ACE SOIL AND SUBSURr ACE
SOil SAIoIPLE lOCAIION
A PIEZOCONE SAMPLE lOCAIION
NOTE
srr nCURE 1 - J rOR LOCAIION or
OIH£R fACllIl'f SIIE AREAS.
FIGURE 4
Map of the Storage Basin
Wrigley Charcoal Site
-------
J
I
-.J
I
'L I /
,) ': (-/.,,,...
0"''''--1- ~( --':=:~~~~.---'-=~ '~;~,--~~~\jbr~~;
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(, I L---~' \.~ - -~1~~ ,r/j / -- . '-1 ;
R [ S I ~ l " C l ~ ,~
LEGftW
. ~~:~.:~[ L~~~I~'4~40 S£Olul ul
51 IRI AC[ SOil ""'40 SlJHSlJfH AU
. smt S~Pll lOlAIiOUS
/ - lIu,IS or rOHM(N SPHA't' AfnA
- - - fJ rUkMlR SPRAY' l1t4[
r.'x~ rORIA[R u.GOOtl AR[A
NO I L
~(r rIGUR( 1-3 fuR to<...,,'l(ms Of
OHtlH f ACllIlY' S,U AHlA.S
QUANTlTlfS OF INIFH[ST
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AH! A
I" HIM( If It
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I
FIGURE 5
Map of the Irrigation Field
Wrigley Charcoal Site
-------
I
00
I
--
~
- .-011(1.:...- -".. /..
. "-"'> ,...: ! i
-- 10 -',', "
./ _11 --",
\ 'V'
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c-~O'5 SJ-0"~)) /';:~:CJ - .
. R [S' 0 [.. C [s ://7 ~ /'/4~~==:":'<~ (".r /
I I I '.', 0 ("
. : ,: / ~-~y..~..1-
N ~~2.000 .t-' ! i ! I. 4'" ~.;;,'-'- <, s
:! :: I I '-. '. ~
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. \ ! i I I .+ . "', ".
, i i I I f i: B ALL "--'::">' 0
., I a ,I . .'
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LEGEND
SURr ACE
. SOIL SAIA:l~O SUBSURr ACE
LOCAIION (RI)
6 PIElOCONE SAIA~E
r\ lOCAIION
. SURr ACE AN .
SOil SAIA~EO SUBSURr ACE .
(ESO "lOCATION
. OECEIABER 1990)
...
.
-
FIGURE 6 ~
Map of the Athl --
Wrigley Ch etie Field
areoal Site
=-
-------
3.2
EPA Involvement
EPA became involved with the Wrigley Site as a result of the
submittal in December of 1985 of a preliminary Hazard Ranking System
score and request for emergency action by the Division of Superfund
in Tennessee. EPA personnel visit,:! the Site in January 1986, to
assess the need for emergency action. EPA later recommended that the
raw water intake at the Bon Aqua-Lyles Water District be relocated to
avoid potential site affects. In addition, EPA recommended
additional sampling to better define the extent and degree of
contamination at the Site, including collection of water samples at
the Bon Aqua-Lyles Water District int7ke. In April of 1986, EPA
subsequently performed a Site samplir." effort which confirmed the
presence of coal-tar contaminants at the Primary Site in leachate,
stream sediments and tar-pits. Highest levels of contaminants
reported during this sampling effort were: benzene (38 ppb), toluene
(308 ppb), phenol (10,600 ppm), and 2,4-dimethylphenol (177 ppm) in
tars located on the Site. Contaminants were also identified at the
Storage Basin in shallow sediments. These contaminants consisted of:
benzene (20 ppb), toluene (179 ppb), ethylbenzene (66 ppb), 2-4
dimethylphenol (330 ppm). Contaminants identified in the stream
sediment included: benzene (12 ppb), toluene (79 ppb), and 2-4
dimethylphenol (177 ppm). The Wrigley Charcoal Site was then ranked
utilizing the Hazard Ranking System (HRS) and generated a HRS score
of 36.14.
3.2.1
EPA Removal Activities
EPA's Removal Program initiated stabilization measures on the Site in
the summer and fall of 1988. Measures undertaken included:
o
Installation of two 48-inch culverts in the North Fork of
Mill Creek stream bed. Culverts were backfilled with clay
to prevent further erosion;
o
Three hundred feet of clean sheet piling removed
Peak oil Site (Hillsborough County, Florida) was
to the Wrigley Site. Sheet piling was installed
stabilize the banks retaining the tar-pits;
Seven samples were collected from the tar-pits., the
exploratory pit, and the dryer building;
from the
transported
to
o
o
Erosion control fabric and riprap were spread over the edges
of the culverts backfilled with clay;
Tar-pit wastes were solidified by mixing with sawdust;
o
-9-
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o
Materials such as mulch and later seed were spread to
establish a vegetative cover on the tar-pit cover and near
the culverts;
o
Reconstruction of the fencing (around the tar-pit area)
previously removed to facilitate Site work;
o
Suspected ACM was sampled at a ~uilding materials stockpile
near the still house. Eight yd of this material was
removed and disposed off-site at the James Brinkley Landfill
in "Bedford County, Tennessee. Based on sampling results,
the ACM contained 60% chrysotile asbestos.
In October of 1988, 130 yds3 of tar pit waste (excavated
during tar~pit solidification) material was trans"ported to
the Allied-Signal Facility in Detroit, Michigan for
incineration.
o
o
In 1989, the spillway was constructed at the southern
portion of the Primary Site adjacent to the culverts to
accommodate flood waters;
o
Approximately $2,000,000 was spent from the Federal
Superfund Program for these tar-pit solidification, removal,
disposal, and construction activities.
Following the EPA tar-pit stabilization activity and spillway
construction in 198"8-1989, the Bon Aqua-Lyles Water District primary
water intake was moved. This work, performed in 1989 by the Utility
District and the State of Tennessee, moved the intake from about 1.25
miles downstream of the Wrigley Charcoal Site on Mill Creek
(approximately 1000 feet below the confluence with the North Fork of
Mill Creek), to about one half mile upstream on Mill Creek, above the
confluence of Mill Creek and the North Fork. This activity
eliminated the possible threat of tar-pit contamination affecting the
public water supply via the raw water intake.
3.2.2
RIfFS Activities
In 1989, EPA contracted Ebasco Services Incorporated to perform the
RIfFS at the Wrigley Charcoal Site. Both the RI and FS were totally
funded out of the federal Superfund Program. The following list
presents the major events during the RIfFS:
o
August 1989: The initial Field Investigation began
o
September 1989 - September 1990:
analysis for the RI;
Ongoing sampling and
o
November 1990:
FS activities are initiated;"
-10-
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o
December 1990: EPA collected additional samples at the
Athletic Field and in the yards of private residences that
flank the Primary Site and Athletic Field (in the east and
west neighborhoods of Wrigley). Initial RI sampling and
analysis indicated elevated concentrations of metals, VOCs,
and dibenzofuran at the Athletic Field in isolated locations
outside the ballfield fence. Since dibenzofuran was
identified during the initial sampling, EPA took precautions
by taking additional samples in the town of Wrigley and
analyzed samples specifically for dioxin (no hazardous
dioxins were found in the town or neighborhoods of
Wrigley). All samples were taken to confirm and further
determine the extent of contamination.
o
April 1991: EPA collected additional samples at the Primary
Site and Storage Basin. Samples at the Primary Site were of
transformer waste in several buildings, waste samples at the
far southern portion of the Primary Site, and soil samples
were collected from the southern lawn of the old Bon Air
Chemical Company office adjacent to the Primary Site.
Additional samples were taken at the Storage Basin to
further evaluate contamination. These samples were taken at
the waterline and in the deeper sediments within the Basin.
o June 1991: The Revised Final RI is completed
o July 1991: The Revised Draft Final FS is completed.
o September 1991: The Final FS is completed.
4.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The first public meeting was held on October 24, 1988 at the East
Elementary School near Wrigley, to provide information and also to
answer citizens' questions concerning removal activities at the
Wrigley Site. Representatives from EPA and the State of Tennessee
provided details of activities taken to date, pertinent analytical
results and proposed activities to be completed in the future.
The second public meeting was held on October 29, 1989
Elementary School. The purpose of this meeting was to
citizens and other interested parties of the beginning
RIfFS.
at the East
inform
of the
The third public meeting to present the Proposed Plan for interim
action (including early final action activities) activities
concerning the Wrigley Charcoal Site was also held at the East
Elementary School on July 25, 1991. The notice of the public
meeting including information on availability of Proposed Plan and
RIfFS appeared in the Hickman County Times on July 15, 1991. An
-11-
-------
,additional article appeared in the Hickman County Times on July
22, 1991 reiterating the previously published information. The
Community Relations Plan for the FS (approved in 1990) lists
contacts and interested parties throughout government and the
local community that establish communication pathways to ensure
timely dissemination of pertinent information. The RI/FS and the
Proposed Plan were released to the public in July 1991. All of
these documents were made available in both the Administrative
Record at the information repository maintained at the Hickman
County Memorial Library. A public comment period was held from
July 15, 1991 to August 15, 1991. The Tennessee Farmers
Cooperative requested an 'extension to the public comment period.
A 30 day extension to the public comment period was granted, which
extended the comment period to September 16, 1991. All comments
which were received by EPA prior to the end of the public comment
period, including those expressed verbally at the public meeting
are addressed in the Responsiveness Summary (Section 12).
5.0
SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
The major goals of these early final and interim actions are to
reduce risks at the Primary Site by eliminating, or containing the
most imminent and substantial threats to'human health and the
environment while permanent solutions are developed for the entire
Site. Additional goals of this action are to reduce the risk of
dermal contact with wastes at the Storage Basin 'by restricting
access through fencing, and to perform confirmatory sampling and
analyses behind the Athletic Field to better define a small "hot
spot", and at ,the Irrigation Field to determine if compounds of
concern are present in the deeper soils of the abandoned
Irrigation Field lagoon.
The cleanup objectives for this interim action ROD are to remove,
treat or contain wastes at the Wrigley Charcoal Primary Site and
Storage Basin and to determine if further remediation is required
at the Athletic Field and/or Irrigation Field lagoon. These
objectives are also intended to reduce the risks from dermal
contact with coal-tar sludges and wastes, burn-pit wastes, drummed
wastes, and tar-cubes. The threat of exposure via inhalation or
incidental ingestion of contaminants such as asbestos, phenols, or
VOCs from exposed coal-tar wastes will be reduced. These early
final and interim actions are expected to reduce risks associated
with current as well as future exposure to the contaminants.
This is not the final action planned for the Site. These early
final and interim actions will be consistent with any planned
future actions, to the extent possible. Subsequent actions are
planned to define and address fully, additional significant
threats posed by the conditions at the Site. Later remedial
activities are tentatively intended to remediate the Primary Site
-12-
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tar-pits, contaminated Primary Site soils, tar-cubes, Storage
Basin coal-tar wastes, any additional coal-tar wastes identified
at any of the Wrigley Charcoal Site areas, any ACM determined to
be friable, and any groundwater problems at the Wrigley Charcoal
Site.
-13-
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6.0
SUMMARY OF SITE CHARACTERIZATIONS
This section reviews topics discussed in recent Site
characterizations that may influence early final and interim
action activities. A full description of contaminants at the
Wrigley Charcoal Site is presented in Section 7.0 (Summary of Site
Risks).
6.1
PhvsioqraDhv and TODoqraphy
The Wrig!ey Charcoal Site lies within the Western Highland Rim
(Figure 7) physiographic province, a rolling upland plateau
typically having from 200 to 300 feet of vertical relief. The
structure of the Western Highland Rim is controlled by the
Nashville Dome, which is the southern extension of the Cincinnati
Arch. Regional dips are to the west at less than 20 feet per
mile. A few minor folds as well as a number of high-a~gle gravity
faults have been documented.
The local setting and topography within approximately a 1 mile
radius of the site is shown in Figure 8. The main area of the
Site lies at elevations between 680 and 730 feet above mean sea
level (MSL).
6.2
Surface Water and Drainaqe
A well developed dendritic drainage system has formed throughout
the area of Hickman County and the Site, with drainage following
synformal valleys. The Wrigley Charcoal Site is located in the
valley of the North Fork of Mill Creek (also called the Warner
Branch and Blackwater Branch), which is in part supported by
surface drainage from the Primary Site and flows from northeast to,
southwest along the western edge of the Site. The North Fork of
Mill Creek flows into Mill Creek about a mile downstream from the
Site. Mill Creek is a tributary of the Piney River (Figure 9)
whic~ flows to the Duck River. The majority of the county is
drained by the Duck River, which is a tributary of the Tennessee
River.
, The North Fork of Mill Creek has its headwaters approximately 1.8
miles 'north of the site near the town of Lyles. It flows about
1.1 miles from the site to its confluence with Mill Creek (Figure
9). Mill Creek has its headwaters about S miles east-northeast of
its confluence with the North Fork, and about 1.Smiles southwest
of Bon Aqua Junction. It is fed by several perennial and wet
weather springs. Springs are common in the Mill Creek drainage
basin, and several are located in the immediate area of the
Wrigley Charcoal Site. There are two main sources for springs in
this area, the first being the highly permeable residual soils
, covering most of the area, and the s~cond being solution channels
in limestone-rich areas of the bedrock.
-14-
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---
.98
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at ~..
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t: a I u III U 1 r. Ollir dl U a !i loa (III j 1 u r
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FIGURE
7
Map of the Central
'l'ennessee
Bas: 1
-------
..
. ,
LEGEND
1) PRIMARY WRIGLEY SITE
2) IRRIGATION FIELD
3) STORAGE BASIN
A) ATHLETIC FIELD
-16-
o 2000'
I I
SCALf 1 : 24,000
CONTOUR INrcRVAl20 FEET
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-17-
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:I:
-------
6.3
Climatoloqy
There is no climatological reporting station in the town of Wrigley"
so the majority of the data presented in this section is from the
Dickson station approximately 15 miles northwest. The wind direction
information was acquired from the Nashville station approximately 45
miles north-northeast of Wrigley Site. The annual mean temperature
for the area is 59.9 degrees F., with January'being the coldest month
with a mean temperature of 40.8 degrees F. July is the warmest month
with a mean temperature of 79.1 degrees F. The average rainfall is
51.6 inches with the greatest precipitation generally occurring
during winter and spring. The average snowfall for the location is
10.9 inches. Winds within the Dickson-Wrigley area are generally
southerly (40 percent. south, 30 percent north, 14. percent west, and 8
percent east, and 8 percent calm). The mean number of cloudy days
reported from the Nashville station is 125 days/year with January
being the month with the most cloud cover with the mean of 16
days/month. The summer months June through September have the least
cloud cover and average 7 days/month. At the Dickson, ~ennessee .
station the mean date for the last spring occurrence of frost is 4/10
and the mean date for the first Fall occurrence is 10/23. The mean
number of days the temperature does not rise above 32 degrees is 9
days/year.
6.4
DemoaraDhv and Water Use
The town of Wrigley is the nearest community to the Wrigley Charcoal
Site. There are approximately 1000 people living within a one-mile
radius of the Site. Twenty-three residences are located along the
western ridge paralleling the Primary Site and approximately 18
residences are located along the eastern edge of the. Primary Site.
There are approximately 25 homes adjacent to the Irrigation Field and
15 homes adjacent to the Athletic Field. Almost all of the
residences are connected to the Bon Aqua-Lyles water utility and do
not require private wells for drinking water. In Hickman County,
approximately 5,500 residences are served by this water utility.
However, there are 9 residential wells within an approximate 1 mile
radius of the Site and it is likely that 3 of the wells are utilized
for drinking water.
6.5
Land Use and Site Access
The Wrigley Charcoal Primary Site area is not currently in use .but it
is conceivable that future industrial activities. could take place
here. Many of the larger buildings including the warehouse, dryer
and maintenance buildings are intact. Although it would be
expensive, these structures could be restored and utilized for future
industrial activities. The Site is readily accessed by anyone that
-18-
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ignores the warning signs and walks around the gates on the east
entrance or at the gate on the southwest entrance. There is no gate
on the road at the north entrance up the valley along the North Fork
of Mill Creek but access is difficult due to the excessive vegetation
and a 15 foot deep wash-out in the road. Access is needed to this
Site by the electric utility (Tennessee Valley Authority) that
maintains an electric sub-station at the north end of the Site, and
by the gas utility (East Tennessee Natural Gas Co.) that maintains a
natural gas pipeline located adjacent to the sub-station. The
natural gas pipeline runs east-west across this portion of the
Primary Site. The utility companies have previously contacted the
TFC to acquire a key for access of the east entrance. These utility
companies currently use the east road for access.
The Storage Basin is located in an isolated area southwest of the
Primary Site and has not been utilized for any waste water disposal
activities since 1966. At present, the Storage Basin is full of
water and is approximately 3-5 feet deep. An overflow tube connects
the Storage Basin to the Overflow Basin so that during heavy rainfall
events, excess waters flow into the Overflow Basin. within the
Overflow Basin is another overflow tube that relieves the Overflow
Basin of excess waters. This tube most likely discharges excess
waters into Clark Hollow north of the Overflow Basin. Within the
Storage Basin a thin drape of sediment covers coal-tar wastes in the
deeper sediments thereby isolating these deeper sediments. This
natural isolation of the contaminants gives the pond a very clean
appearance. The casual visitors which include walkers,
motorcyclists, hunters, and possibly fisherman are likely to use the
storage basin and overflow basin for recreational purposes.
The area is readily accessible by foot but vehicular traffic is
restricted by the steep grade of the small overgrown road that
connects the valley road with the Storage Basin.
At present, it is unlikely for this area to be used for residential
or farming applications due to its isolated location and rough
terrain.
The Irrigation Field has not been utilized for waste water disposal
since 1966. The Field is a relatively flat lying area that is
presently vegetated with small trees and weeds. The abandoned lagoon
at the weste~n edge of the Field is presently a swampy area that
contains some larger trees and abundant vegetation. At the southern
portion of the field are a line of homes that have been built since
the 1960's according to the Environmental Photographic Interpretation
Center (EPIC) photos.
It is possible that future uses of this location include
re~idential. Due to the Site being flanked by homes (south) and
churches (northeast), it is possible that the property could also be
-19-
-------
developed similarly. . It also is possible this property could be used
for farming. .
Although this area is readily accessible, thick underbrush, weeds and
small trees make access difficult. At present a small road is used
at the northern boundary of the Field for dumping of trash.
Prior to 1938 the Athletic Field (L.A. Miller Park) was the likely
location of a small dump for the town of Wrigley. From 1938-1950
slag and soils from the Primary Site were transported to this
location to. construct what later became the Athletic Field. This
location is presently a baseball field flanked by two roads and
surrounded by homes. At the far southern edge of the Field is a plot
being used for a garden. The plot is approximately 35 x 80 feet and
is located approximately 50 feet away from the location of the
samples collected during the RI which showed elevated lead levels or
"hot-spots". The field is used daily by children and others for
various activities. This location is also used for the Wrigley Day
event which is held on an annual basis on the last weekend of June. .
As many as 800 people have been reported to attend this function held
at the Field.
Future uses of this property are likely to remain the same since
this is the only location in Wrigley that could be used as an
Athletic Field. However, it is possible that the plot used for
growing vegetables behind the Field could be expanded to encroach on
the "hot spot" identified during the. RI.
6.6
Geoloqy
Three geologic formations, all of Mississippian age, occur in the
area of the Site. From youngest to oldest, the formations are:
1) The St. Louis Limestone
2) The Warsaw Limestone
3) The Fort Payne Chert
A stratigraphic column for the area is shown in Figure 10. In
addition, a cross-sectional layout map depicting Primary Site
cross-sections as presented in the RI are presented in Figure 11.
representative cross-section of the Primary Site north to south is
presented in Figure 12. Brief descriptions of the occurrence and
characteristics of these formations are presented below.
A
6.6.1
St. Louis Limestone
The St. Louis Limestone occupies the tops of the highest ridges
surrounding the Wrigley Charcoal Site. It consists of pale to dark
yellowish brown, fine to coarse-grained, thick-bedded, fossiliferous
-20-
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SYSTEM GROUP I FORMATION I THICKNESS LITHOLOGY
ST. LOUIS FORMATION SO' - 175' CARK GRAy TO GAAY
COo\AS' GA\lH£O G5HEI'AU y
""""~.8&OO€D
wfi'T'iRaliHCIJa Ua.EJ'T'OIIIIi..
C~OuUCJV( ~O $.IJroIII(~S
MEt;AMEC ~O C.AVS:S c:;t.I n.£ YWUr&AA
~Q.4l.AHO fill... ~
OV£;:WU'W!iH
WARSAW LIMESTONE 100' Gl'\AV ........~-CDOIiO
uWESTOreE. ~£L;.N
Z "'-"CiS Sluc.&C\,;S GAA" ~o
< q(0 0"ii1llllU_"
ii:
Vi
U1 .. --........ ----............ --- --.. ------.... ...--..--.... .......-..........---......... -...---- --....---.. ----- .... --- "'''''''-'''' --- ----.. "'-"" --......
Vi
U1
~ OSAGE FORT PAYNE CHERT 100' . 250' GRAY m kUI$W Qlll,Av
SlUC&OUS \.J~STCHE AHO
SHAL£ CONT"''''''' C>< £I'T
ITIOlHGiIII
.. .............-...... -----...... ............................-.................. -- -.. .......- .....- .. ..........--....-...-.. ----...- .. .......... --.........-..--..------.... -........
KINDERHOOK MAURY FORMATION O' - 5' GREEN TO GREENISH eRAT
SlI..TSiONS AHD ~y STON'
UPPER CHA TT ANQOGA SHALE
GASSAWAY MEMBER 10'.40' -..co F1SSU SHIU
COMI'ACT. wrTN ON~TI
NODULES. 00\II0 Gl'\AY
IILSTOHI ~""TlHGI
Z
:S
z
0 DOWELL TON MEMBER 10'.20' IL6CI< F1saau SHIU. 0"'"
> GRAV; IHTIRKOOUI
W aAYITQN&
a
HARDIN SANDSTONE l' - 15' w.S8fYI ,,", Q""""O
MEMBER IASHOSTONE.. U)C.AU.. Y
ONQP_nc IN "'STIRN
NIQHI.AHI) IIIGICN.
(MODIFIED AFTER SMITH, 1963)
FIGURE 10
Generalized Stratigraphic Column
wrigley Charcoal Site
-21-
-------
I
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FIGURE
11
Cross-Section Layout Map
Wrigley Charcoal Site
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LEGEND
SECTION 8-8'
~DR~
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FIGURE 12
Cross-Section B-B'
Wrigley Charcoal Site
- ----------------
-------
limestone that is loc~lly silty and cherty. It weathers to a
residual soil of reddish sandy clay containing blocks up to 10 inches
in diameter of variably colored, dense and partly fossiliferous ,"
dense, brittle, chert.
6.6.2
Warsaw Limestone
The Warsaw Limestone makes up the slopes of the ridges and some of
the lower ridge crests surrounding the Wrigley Site. The Warsaw
consists of light olive-gray to pale yellowish-brown, medium to very
coarse-grained, cross-bedded, styolitic, fossiliferous limestone.
The Warsaw weathers to a residual soil consisting of blocks of porous
to dense fossiliferous chert, embedded in reddish sandy clay with
sandstone cobbles and boulders. A sandstone outcrop, tentatively
ascribed to the Warsaw, has been described in the literature at
Wrigley near the mansion (previous Bon Air Company office).
6.6.3
Fort Pavne Chert
The Fort Payne Chert is the primary bedrock unit under the Wrigley
Site. There are two facies of the Fort Payne Chert in the area. The
upper unit, which is from 40 to 160 feet in thickness, consists of
brown chert plates and particles in a calcareous siltstone matrix,
locally mixed with fossil-fragmental limestone. The lower unit,
which is from 40 to 80 feet in thickness, consists of brown or gray
siltstone with scattered chert beds. The total combined thickness of
the Fort Payne in this area is approximately 300 feet.
The ground surface at the Primary Site averages about 30 to 40 feet
below the contact of the Fort Payne with the overlying Warsaw
Formation. This location suggests that the Site lies on the residuum
of the upper cherty facies of the Fort Payne. Because of placement.
of fill and waste (slag and tar) on much of the Site, the native
soils have not been observed at or near the surface in the southern
portion of the Site. In the northern portion of the Site, the soils
are very cherty and silty and contain variable amounts of sandstone
cobbles weathered from the overlying Warsaw.
6.7
Soils
A general map provided by the U.S. Soil Conservation Service (SCS,
1977) is presented for Hickman County. ,The map does not reveal a
great deal of detail but general unit boundaries are clearly
defined. As depicted in Figure 13, the soils in and around the
Wrigley Charcoal Site consist of the Bodine-Baxter-Ennis Association
(1), the Montview-Dickson-Bodine Association (2), and Humphreys-
Ennis-Lobelville Association (5). The valley where the Primary Site
resides in the Bodine-Baxter-Ennis soils. Further down the valley
southwest soils change at the confluence of Mill Creek to '
-24-
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j
j
GENERAL SOIL MAP
HICKMAN COUNTY, TENNESSEE
SOIL CONSERV ATION SERVICE
IN COOrF.£t,\TION WITII ,liE
SOIL CONSCRVATION f1ISlRlcr
o
I
2
I
6
I
8
I
4
I
A.,proalm8'. Sui. . MU...
Compilprt rrom Tpnnessee Genpral Highway Map,
Polyconic Projpction.
Grid ticks ha~e on T£'nnessee coordinate sy~tem.
LECEND
r:-;--1 8001NE-8")(T£R-ENN'S ,unci,lIion: Hilt, and u"", 4no""
~ dnlMd cherty tallt; on hipMy dl$wcrtd ",pI.un.
~ MOUNTVIEW-DICkSON-80DINE aJOCiariOfl: Gen.ly rollinllnd
~ rDllin.. dU9 ....II dr~ut.d lOfI, rhl! ~ ch~t.rr" on rhe hilltop' and
chrrry or th.. hil1s;dn; on bra.1d ,opt and ,.,rtau . Uk.. IRIS 0' hi..
.."diRI rid"".
o
'ICkWICK-'AOEN-ETOWAIl .JItoei.l'ifJn: wn'ly 'IMlinl fa hill."
dfto _"I drJiMd IOIlt 'ome or .nicn ate ......1.,: Oft inlftml'di,t8
and he'" '."Kn.
r-;::-l ENNIS-L08ELVllLE-HUMPHREYS ntOCl..lloft~ Uftt and Ift',ty
~ rnlll"l. ....., d'ai,wd .1I1d rtHtd..UIf'tV ...-11 dratned ,III In"",, an'" 'herry
"II 10'""; on firs' bonorm and I.. '."'lCft of Duck Ri.,.,.
r-:-1 HUMPf'REY~-ENN1S-lOBELVILLE ~,,«i~lIon: Genllv rollin, JnCI
~ I"..e-f, w"U dr~lInrd "nd mnd,"rJI~V w,,11 dUfnrd ,ill In,," and c!)ft'IV
tilr IO.lm,; on fir,. bolloml "nd low lerraces 0' creeks.
-25-
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to
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Humphreys-Ennis-Lobelville. The higher flat lands and hills that
surround the primary'Site where the Storage Basin, Athletic Field,
and likely the Irrigation Field reside consist of Mountview-Dickson"
-Bodine soils. Other soils units may be present to lesser degrees
and unpublished soils information obtained from the SCS indicates
that soils of as many as six series may be present at the Site or in
surrounding areas. Brief soil descriptions are presented below with
some overlap of soil associations. Therefore, this information will
not be repeated .for each association. Additional information is
presented in Appendix A.
6.7.1
Bodine-Baxter-Ennis Association
The Bodine Series consists of deep, somewhat excessively drained,
cherty soils on uplands. These soils have pale brown, cherty silt
loam A horizons, and yellowish brown and strong brown, cherty silt
loam and cherty silty clay loam B horizons which become increasingly
cherty with depth.
The Baxter Series consists of deep, well drained cherty soils on
uplands. They formed in material weathered from cherty limestone.
Typically these soils have a brown cherty silt loam surface layer
nine inches thick. '
The Ennis Series consists of deep, well drained, cherty moder~tely
rapid permeable soils that formed in alluvial sediments derived from
limestone, shale, sandstone, and loess. These soils are on bottom
lands, in narrow strips along drainways and in depressions.
6.7.2
Mountview-Dixon-Bodine Association
The Mountview Series consists of very deep, well drained soils
formed in a 2 to 3 foot thick silty mantle, presumably loess,
underlain by residuum of cherty or clayey limestone or by old
alluvium.
that
The Dickson Series consists of moderately well drained soils that in
a representative profile have a 7 inch brown silt loam layer. The
subsoil down to the fragipan at 25 inches is yellowish brown friable
silt loam. The fragipan which extends from 25 to 45 inches is
yellowish mottled and brittle silty clay loam. Below the fragipan is
yellowish red firm clay.
6.7.3
HumDhrevs-Ennis-Lobelville Association
The Humphreys Series consists of deep, well drained soils on
terraces. They formed in alluvium from cherty limestone, loess, and
shale.
-26-
-------
No additional information is available for this association in the
vicinity of the Site.
Other series present in this area include the Biffle and Sengtown
series. These series are briefly described below. However, these
soils series are less likely to be found at the Site but are found
throughout Hickman County.
The Biffle Series consists of moderately deep, somewhat excessively
drained, cherty soils on uplands. They have formed in residuum from
cherty limestone.
The Sengtown Series consists of deep, well drained, moderately
permeable soils. They formed in residuum weathered from cherty
limestone. They occur on sloping to steep uplands.
7.0
SUMMARY OF SITE RISKS
CERCLA directs that the Agency must protect human health and the
environment from current and potential exposure to hazardous
substances at Superfund sites. In order to assess the current and
potential risks for the Wrigley Charcoal Site, a risk assessment that
comprises Volume III of the RI Report has been conducted.
The results of the RI/FS (including risk assessment) indicated that
there are a wide range of hazardous materials and contaminants at the
Primary Site and Storage Basin. Additional information obtained
during 1991 for the Primary Site and Storage Basin supports limited
(early final and interim) actions at these two locations. However,
the information generated from these studies was inconclusive
concerning the extent of contamination for the Irrigation and
Athletic Fields. Additional information will be needed in order to
fully assess risks at the Irrigation Field and to identify the extent
of the "hot spot" behind the Athletic Field and the associated
risks. Results of this sampling will form the basis for future
actions to be taken at the Athletic Field and/or Irrigation Field.
The following summary lists specific early final and interim action
items (previously discussed on page 2) and associated contaminants
that may pose a potential threat. Long-term human health risk
calculations and environmental risks will be discussed during future
response actions. Early final actions concerning sludges and wastes
will be cleaned up to Acceptable Soil Concentration (ASC) levels as
presented in Appendix F.
1 )
Hazardous substances in the maintenance buildings' burn-pit
wastes at the Primary Site contain: 1) lead (1,600 ppm); 2)
chromium (270 ppm); 3) copper (7,900 ppm); 4) zinc (2,300
ppm); 5) nickel (160 ppm); 6) cadmium (36 ppm); and 7) barium
(120 ppm). The ASC for lead reported in the RI for the
Primary Site (light industrial use) is 121 ppm (the ASC for
-27-
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2 )
3)
copper is 3,200 ppm). On September 7, 1989, EPA established
an Interim Guidance for soil lead cleanup levels at Superfund
Sites (Directive 9355.4-02). This directive set soil lead "
cleanup levels from 500-1000 ppm depending on the land use.
EPA is considering 1000 ppm as a cleanup goal for the burn-pit
area since the Site is presently zoned, and expected to remain
in the future, a light industrial site. The amount of lead
noted in the burn-pit is significantly above the recommended
cleanup value of 1000 ppm, (and the amount of copper is
significantly above the ASC for copper). Therefore, EPA has
determined that a potential risk to human health exists due to
potential for dermal contact and/or incidental ingestion of
these wastes, and potential risks which exist to the
environment from migration of these wastes to the North Fork
of Mill Creek via groundwater.
Contaminants at the Storage Basin in the deep sediments
were identified during the April 1991 sampling event
conducted as a removal action. ,Samples of the deep
sediments identified 20 organic compounds and 9 metals. '
Contaminants in these sediments consisted of the following:
1) semi-volatile compounds (74,032 ppm including phenols at
26,700 ppm); 2) metals (6025 ppm), and 3) VOCs (610 ppm).
Since the ASC for carcinogenic PABs as reported in the RI
is 8.17 ppm, for non-carcinogenic PABs is 34,600 ppm, and
for phenols is 100, the Storage Basin area poses a
potential threat to anyone that may come into contact with'
wastes through dermal contact or incidental ingestion.
Therefore, due to the high level of PABs and phenols in the
Storage Basin sediments, and open access" EPA has
determined that this location also poses a risk to human
health and the environment.
The process tank coa~-tar wastes (mixed with soil and
debris) across the North Fork of Mill Creek at the Primary
Site were sampled and elevated levels of contaminants
identified. A total of 16 organic and 5 inorganic
constituents were identified. Contaminants consisted of
the following: 1) phenols (20,000 ppm)i 2) total PABs (737
,ppm)-including carcinogenic PABs (359 ppm); 3) VOCs (1750
ppm); 4) copper (2,400 ppm); 5) lead (340 ppm); 6) ~ickel
(110 ppm)i 7) zinc (110 ppm)i and 8) and barium (50 ppm).
The high levels of phenols, carcinogenic PABs, and VOCs
make the process tank wastes a potential risk to human
health by way of dermal contact, incidental ingestion, or
inhalation. Wastes are potential risks to the environment
since they are adjacent to the North Fork of Mill Creek and
periodically leak from the process tanks and can migrate
into the creek. Also, if these tanks were to rupture and
release into the environment the presently contained
wastes, the potential for significant health risks to
workers and the environment would be significant. These
wastes contain various carcinogenic chemicals such as:
PABs, VOCs, lead, and nickel.
-28-
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4 )
5 )
6)
7)
Periodically, black coal-tar wastes leak out of the process
tanks. These wastes, once on the ground, migrate down the
steep hill approximately 50 feet to the North Fork of Mill
Creek. Contaminant types are the same as the process tanks
but conc! ~rations of VOCs in this contaminated media are
likely tc ~e less dUe to volatilization. Risks associated
with these wastes are similar to process tank wastes.
Therefore, these also pose a potential threat to anyone
that may come in contact with the wastes. Also, wastes are
a potential threat to the North Fork of Mill Creek due to
the migration pathway from the tanks down the steep hill to
the creek.
At the previous location of the still house, black
coal-tars periodically bubble to the surface during the
summer. This has been noted to occur at the northeast
corner of the old foundation. Soil samples in the vicinity
of the foundation contain carcinogenic PABs (24 ppm).
Samples and analyses of the coal-tars ~hat bubbled to the
surface in the summer of 1991 have not been acquired,
however, it is likely that levels of PABs and other
contaminants are s~bstantially higher in these wastes than
in the adj~ent so~ls. Since the level of carcinogenic
PABs is 3 t~es that of the ASC (8.17) in the vicinity of
these coal-tar seeps, EPA also considers this location to
be a potential threat to human health due to the potential
for dermal contact. Also, wastes are a potential
environmental threat since they are adjacent to the North
Fork of Mill Creek and could readily migrate via surface
waters.
Roofin~ materials at the Primary Site were analyzed and
found to contain 60% chrysotile asbestos, 30% non-fibrous
binder, and 10% cellulose. Asbestos is a known carcinogen
for which a safe exposure level cannot be established and
studies have documented asbestos related diseases with
minim21 exposure. The EPA Region IV Asbestos Unit has
reviewed the FS for the Wrigley Site and has determined
that the friable material on the small building in front of
the maintenance building and any ACM on the ground poses a
potential risk to human health due to the potential for
inhalation of asbestos f_bers. These materials also pose a
potential threat to the environment since broken ACM sheets
may migrate via s_rface waters into the North Fork of Mill
Creek. Once ACMs get into the creek they can become
incorporated into adjacent (surficial) sediments, then
during dry conditions the materials may become airborne if
agitated.
During the spring floods of 19r.1, black coal-tar wastes
were exposed in the spillway. No sampling or analysis has
-29-
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8)
been attempted on these newly exposed materials. It is
likely these are similar coal-tar derivatives that have
been identified elsewhere at the Wrigley Site. At every
location analyzed for coal-tar wastes, the levels were
found to be above ASCs. There is no present reason to
assume that these coal-tar waste concentrations are below
ASCs. Risks associated with these contaminated media
likely pose a potential threat to human health through
dermal contact since wastes are exposed. Wastes also pose
a potential threat to the environment since they are in the
middle of the spillway and directly in contact with waters
of the North Fork of Mill Creek after significant rainfall
events.
Twelve staged drums are located near the maintenance
building and two drums are located in the storage shed. A
composite sample of solid waste (a waste characterization
for disposal) identified the following hazardous substances
(i.e.- contaminants) in the drums near the maintenance
building: 1) acetone (5.2 ppm); 2) benzene (100 ppm); 3)
toluene (1.9 ppm); 4) phenol (360 ppm); and 5) chromium (23
ppm). A composite sample of liquid wastes in drums in the
above location yielded: 1) napthalene (500 ppm); 2)
tentatively identified hydrocarbons (35,900 ppm); 3)
ethylmethyl benzene isomer (7,000 ppm); 4) tentatively
identified aromatics (9,200 ppm); 5) (1-methylpropyl)-
cyclohexane (4,500 ppm); 6) methylpropyl benzene isomer
(4,200 ppm); 7) methyl-methylethyl benzene isomer (7,000
ppm); 8) tetramethyl benzene isomer (3,400 ppm); 9)
undecane (22,000 ppm); 10) chromium (214 ppm); 11) copper
(35,700 ppm); 12) arsenic (37 ppm); 13) lead (544 ppm); 14)
manganese- (5,197 ppm); 15) nickel (3,429 ppm); 16) selenium
(64 ppm); and 17) zinc (755 ppm). Based on the above
analyses, these materials if left on-site, pose a threat to
public health due to potential exposure from dermal
contact, incidental ingestion, or inhalation. Also, the
potential exists for these contaminants to adversely affect
the environment. Contaminants may migrate into the
groundwater or surface waters if any of the drums develop
leaks. Also, if these drums were to rupture and release
the presently contained wastes to the environment, the
potential for significant health risks to workers and the
environment would result. These wastes contain various
carcinogenic chemicals such as benzene, PABs, chromium,
lead, nickel, and arsenic.
9)
Continued erosion by the North Fork of Mill Creek, adjacent
to the culverts in the spillway, increases the probability
that additional coal-tar wastes may be exposed. Wastes in
this area likely pose a potential threat to human health
and the environment due to dermal exposure or inhalation.
It will be necessary to reconstruct the spillway to prevent
further exposure of coal-tar wastes.
-30-
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11)
10)
Primary Site waste/debris piles contain variable quantities
of potentially hazardous materials: a) ACM; b) tar-cubes;
c) crushed drums (contents unknown); and d) transformer
materials.
a) The ACM, as previously described, is of concern.
b) The tar-cubes are derivatives of the coal-tars generated
at the Primary Site. Due to waste characterization for
disposal analyses having extremely high detection limits
and high levels of organic carbon causing matrix
interference, PAH compounds were not definitively
identified. However, a cumulative total of 10 tentatively
identified compounds (TICs) yielded 920 ppm. It is likely
that these TICs are PAH compounds. Although the tar-cubes
appear to vary in composition from the raw coal-tar wastes,
the cubes pose a potential risk since they are composed of
pure coal-tar which is primarily PAH constituents. On the
7/26/91 Site tour with representatives from the State of
Tennessee, it was noted that melted tar from cubes was
oozing from the base of several waste piles adjacent to the
raw liquor storage tank foundation. These materials likely
pose a potential threat to human health and the environment
since contaminants are mobilized in summer and could
potentially be transported by surface waters to the North
Fork of Mill Creek.
c) Crushed drums pose a potential threat at the Primary
Site if found to contain hazardous compounds.
d) At present, little is known about the variety of small
transformers found at the Primary Site. On 4/26/91 several
were sampled, however, waste characterization data minimum
detection limits were too high to detect any compounds.
These transformers may contain hazardous materials and may
pose a potential threat at the Wrigley Site since they are
scattered throughout the Primary Site and readily
accessible to anyone that may contact them.
The Irrigation Fields' abandoned lagoon was found to
contain the following contaminants in sediments down to
approximately three feet: 1) phenol (13 ppb); 2) toluene
(11 ppb); 3) methylene chloride (120 ppb); 4) tetrachloro-
ethene (5 ppb); 5) lead (91 ppm); 6) arsenic (31 ppm); and
7) copper (1,200 ppm). These levels of contaminants are
not presently of concern. However, aerial photos taken
between 1958 and 1963 show similarities between the
Irrigation Fields' lagoon and the Storage Basin where high
levels of contaminants were identified. Similarities
between these two areas are: 1) size and shape of
containment area; 2) segregation of suspended particulates
-31-
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(in basin and "lagoon waters) away from the feed pipe
outflow as noted in the EPIC photos; and 3) historical
information that describes similar wast~water disposal
activities at both locations. Based on this information,
the deeper sediments at the Irrigation Fields' abandoned
lagoon may pose a potential threat to human health and the
environment.
12)
Site access controls at the Primary Site and Storage Basin
will reduce the risks associated with dermal contact or
other exposures to trespassers.
Eleven surface and subsurface soil c~mposite samples were
obtained at the Athletic Field (inside the outfield fence)
in December of 1990. Although hazardous substances were
found, these were all below levels of concern. However,
risks may be elevated behind the Athletic Fields' outfield
fence. One soil sample out of 6 samples obtained during
the RI at this location revealed: 1) lead (1,000 ppm); 2)
copper (69,000 ppm); 3) manganese (3,10~ ppm); 4) zinc
(42,000 ppm); 5) cobalt (81 ppm); 6) chromium (56 ppm); 7)
barium (640); and 8 ) aluminum (9,400 ppm) . Therefore, EPA
has determined that confirmatory sampling and analyses are
justified at this location to determine the extent and
associated risks of this "hot spot".
Actual or threatened releases of hazardous substances from-this
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment. These
early final and interim actions are necessary to achieve
significant risk reduction while developing a final remedial
solution for the Wrigley Charcoal Site.
13)
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8.0 SUMMARY OF ALTERNATIVES
8.1 Alternative 1: No Action
8.2
o
CERCLA requires that the "No Action" alternative be
considered at every site. This alternative must be
considered to serve as a basis for comparison of other
alternatives. Under this alternative, no sludge, soil,
sediment, groundwater, or debris cleanup, consolidation or
treatment would take place. The only reduction of
contaminant levels would occur via natural processes such
as dispersion or attenuation. The only costs associated
with the alternative pertain to institutional controls and
fees.
Present Worth (PW) Cost: $36,000
PW Capital Cost: $30,000
Time to Implement: 1 month
ALTERNATIVE 2: Limited Action
o
Deed Restrictions and Site Access Restrictions
(Institutional Controls) including: a 10-foot high
chain-link fence topped with barbed wire will be installed
around the Primary Site and the Storage Basin including the
Overflow Basin. Prior to installation, the areas of
fencing will be cleared for access as required for proper
installation. The fence would be equipped with a gate for
controlled access.
o
Warning signs and placards would be added and posted at
100-foot intervals along the fence. The areas to be fenced
are as follows: 1) Primary Site (6,280 feet), and 2)
Storage Basin (1,230 feet - including the Overflow Basin).
The total amount of fencing proposed for the two Wrigley
Site areas is 7,510 linear feet.
Present Worth Cost: $169,004
PW Capital Cost: $146,960 (fencing)
Time to implement: 3 months
This alternative will insure that Site access is limited through
installation of a security fence while also attempting to
establish controls that ensure proper maintenance of the Site
through deed restrictions. This alternative does not improve
residual risks above baseline conditions nor does it reduce
toxicity, mobility, or volume.
-33-
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8.3
1)
ALTERNATIVE 3: Earlv Final and Interim Action
Metallic wastes in the maintenance buildings' burn-pit will
be excavated, stabilized and disposed of in an EPA approved
RCRA facility. This activity will be a.early final
aC3ion. The approximate volume of this material is 15
yd. Transformers found in the maintenance building will
be secured with other transformers found at the Primary
Site in an on-site containment area for future action. The
total amount of transformers estimated at 120 drums. This
is an interim activity~
2 )
Risks will be reduced at the Storage Basin by fencing the
area. This will discourage and possibly prevent entry and
disturbance of this area until wastes can be appropriately
eliminated during later remedial activities. I~stallation
of the fence is considered to be an interim action (OSWER
Directive 93355.3-02)~
Process' tank waste sludges (29 yd3) will be removed,
transported, incinerated, stabilized and disposed of in an
EPA approved RCRA incinerator/lan~fill for disposal. The
metallic tanks will be decontaminated and sold as scrap.
This is a minor modification from the. proposed plan which
stated the tanks would be disposed of in an EPA approved
RCRA facility. Elimination of the process tanks and
sludges is an early final action~
3)
4)
Black coal-tar wastes on the ground from the process tanks
down to the North Fork of Mill Creek will be excavated,
transported, incinerated, stabilized and disposed of in an
EPA approved facility. The area has been visually
estimated at approximately 50 x 10 feet wi3h an average
thickness of 1.0 foot (approximately 19 yd). Removal of
this waste is considered to be an interim activity~
5)
Black coal-tar wastes at the northeast corner of the
previous still house location will be excavated,
transported, incinerated, stabilized, and disposed of in an
EPA approved facility. The approximate visual estimate of
the area is 10 x 10 feet. This ~mall area should be
excavated to approximately a one-foot depth, then
backfilled with cl~an fill. The estimated volume of this
material is 3.5 yd . Removal of these wastes is .
considered to be an interim activity~
6)
Visibly friable ACM will be removed, transported and
disposed of in an approved asbestos landfill. Most of the
-34-
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intact ACM on buildinS :~oofs appears to be in fair
condition. However, the visibly friable ACM on the small
building in front of the maintenance building should be
removed together with broken sheets ~f ACM on the ground
near the dryer building, ~ank battery, and previ~us
location of the still hou3e (approximately 20 yd or 0.5
tons). Visible ACM on soils associated with broken,
crushed, or sheet ACM that reveal light grey-white
colorat ~n (repre~entative of the ACM at the Wrigley Site)
will bE removed. An estimate of3ACM contaminated soils
that need to be removed is 20 yd . Removal of the ACM is
considered to be an interim activity;
7)
Expose~ black coal-tar waste visible in the spillway should
be ~xcavated, transported, incinerated, stabilized and
disposed of in an approved off-site facility. Wastes
should only be excavated until a reasonable margin (for
construction purposes) is established for the rebuilt
sp~llway. Approximate estimates for this waste are 100
yd. This is considered to be an interim activity;
8)
Twelve drums are located near the maintenance building and
two drums in the storage shed. Drummed wastes should be
transported, incinerated, stabilized, and disposed of in an
EPA approved facility. This is a modification from the
Proposed Plan and is considered to be an early final
action;
9 )
The spillway should be repaired and re-engineered to
accommodate ~e significant flood waters t;at frequent this
area. This may involve straightening and turther
excavating the spillway down to the existing creek grade
(additional information concerning the spillway is
presented on p. 47). This is considered to be an interim
activity;
10)
Site surface waste/debris piles that include tar-cubes,
p~~ces of ACM, transformer materials, crushed drums, and
otner miscellaneous metallic debris and tar waste will be
sorted. . Pi ~es of ACM will be removed and disposed of with
the ACM as :reviously described in item 6. Metallic scrap
would be transported and disposed in an approved EPA
facility. Materials such as tar-cubes and wastes that may
be remediated with later remedial activities would be
stored in an on-site con~~lidation area. This is
considered to be an inte. .m activity. '101ume estimates for
Site debris are presentee in table 1;
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12)
13)
11)
A limited investigation will be performed at the Irrigation"
Fields' abandoned 3/4 acre lagoon. This activity will
include several soil borings/excavations (to approximately
10 feet) and several additional soil samples at the
previous location of the feed pipe outflow. This activity
will determine whether wastes similar to those at the
Storage Basin are present in the deeper soils. This is a
modification from the Proposed Plan and considered to be an
interim activity;
EPA w~ll negotiate with local municipalities
restrictions at the Primary Site and Storage
access controls will be implemented (fencing
the Primary Site and Storage Basin. This is
activity;
to impose deed
Basin. Site
& placards) at
an interim
Sampling and Analyses:
Resampling and analyses of six monitoring wells and
twelve piezometers at the Primary Site will provide an
assessment of the groundwater quality;
Soil sampling and analyses will be required behind the
Athletic Field to the garden area. This will assess
the need any future activities in this area;
Following EPA activities concerning these early final
and interim actions, one round of residential well and
spring sampling and analyses will be required to
insure these activities have not affected water
quality.
Present Worth Cost:
PW Capital Cost: .
Time to Implement: 6 months
'At the end of the five-year period following this interim action,
a review will be conducted. If subsequent remedial activities
are initiated prior to the close of the five-year period following'
interim action, a review will be conducted prior to any initiation
of additional work at the Wrigley Charcoal Site. The review will
be conducted to insure that early' final activities are functioning
as designed and that the interim activities are, and have been
effective in reducing the threat to human health and the
environment.
$984,998
$787,810
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This alternative includes the institutional controls previously
described and also reduces the risks associated with various
contaminants at the Primary site. These early final and interim
action remedial measures are designed to reduce and eliminate some
of the most imminent and substantial dangers that reside at the
Primary Site and reduce risks associated with dermal contact at the
Storage Basin through access restrictions.
A breakdown of estimated volumes of on-site materials and the
removal/disposal costs are presented in Table 1.
This alternative retains the institutional controls discussed for
Alternative 2 and adds additional remedial measures that are
designed to reduce risks associated with some of the most imminent
and substantial dangers that reside at the Primary Site. Risk
reduction at the Storage Basin consists mainly of access
restrictions. The efforts included in this action specifically for
the Primary Site will achieve significant risk reduction early in
the Superfund process.
9.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section provides the basis for determining which alternative
1) meets the threshold criteria for overall protection of human
health and the environment and compliance with ARARs, 2) provides
the "best balance" between effectiveness and reduction of toxicity,
mobility, or volume through treatment, implementability, and cost,
and 3) demonstrates state and community acceptance. A glossary of
the evaluation criteria is provided in Table 2. .
9.1
Overall Protection of Human Health and the Environment
The only alternative that would sufficiently be protective of human
health and the environment would be Alternative 3. Alternatives 1
and 2 are not protective because they do not address the most
significant threats to human health and the environment at the
Wrigley Charcoal Primary Site or Storage Basin. Therefore, the "No
Action" alternative and Alternative 2 will not be considered
further in this analysis as options for the Site. Alternative 3 is
protective of human health and the environment since reduces or
controls significant, immediate, and potential threats from direct
exposure to hazardous contaminants at the Wrigley Charcoal Site.
Institutional controls will limit access to the Primary Site and
the Storage Basin which will reduce risks associated with these
contaminated areas. This alternative also provides the basis for
future actions.
9.2
Comcliance with Acclicable or Relevant and Accrocriate
Reauirements
Alternative 3 meets ARARs as applicable to excavation, trans-
portion, treatment, stabilization and disposal of contaminated
media such as coal-tar waste and sludge.
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TABLE 1
INTERIM REMEDIAL ACTION
ACTIVITY OUANTITY/COST BREAKDOWN
Primary Site Surface & Building Wastes
Material Ouantity Cost
1) ACM (small building) 0.5 tons $2,550
2) ACM Con tam. Soils 20 ydJ $8,350
3) Burn pit Wastes 15 ydJ $31,790
4) Empty Drums 200 drums $10,750
5) Staged Drums 14 drums $7,825
(Partially Full Drums)
6) Metallic Debris 100 tons $33,500
(if off-site disposal is elected)
Process Tank Waste.
1) Tank Wastes 29 ydJ $29,750
3) Contaminated soils 19 ydJ $36,540
2) Tank Removal, 17 tons $5,500
Disposal
Spillway Activities
1) Spillway wastes 100 ydJ $164,540
(approx. 160 tons)
2) Construction $200,889
Consolidation Area
1) Construct & move contaminated materials
into consolidation area $21,272
2) Materials stored in consolidation area:
a) 2 Ft. Tar Cubes 50 ydJ $17,825
b) Transformers 120 drums $14,625
c) Metallic Debris 176 ydJ $8,625
(if off-site disposal is not elected)
Other Costs
1) Investigative Activity $55,325
2) Fencing' Institutional Controls $146,960
3) Fees/Contingency: (metals on-site) $190,779
(metals off-site) $196,998
Total Costs:
$953,894 (metals debris placed in on-site consolidation area)
$984,998 (metals debris disposed off-site)
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TABLE 2
GLOSSARY OF EVALUATION CRITERIA
Overall Protection of Human Health and Environment addresses
whet.her or not a remedy provides adequat.e prot.ect.:.on and describes
how risks posed t.hrough each pat.hway are eliminated, reduced, or
cont.rolled through treatment engineering controls or institutional
controls.
Compliance with AltARs addresses whether or not a remedy ...ill
meet all of the applicable or relevant and appropriate requirements
of other Federal and State environmental statutes and/or provide
grounds for invoking a waiver.
Lana-Term Effectiveness and Permanence - refers to the magnitude
of residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time once
cleanup goals have been met. .
Reduction of Toxicity. lIobility. or Volume Throuah Treatment - is
the anticipated performance of the treatment technologies that may
be employed in a remedy.
Short-Term Effectiveness refers to the speed with which the
remedy achieves protection, as well as the remedy's potential to
create adverse impacts on human health and the environment that may
result during the construction and implementation period.
Implementability is the technical and
of a remedy, including the availability
needed to implement the chosen solution.
administrative feasibility
of materials and services
Cost - includes capital and operation and maintenance costs.
State Acce~Ance indicates whether the State
opposes, or has no comment on the Proposed Plan.
concurs
with,
Community AcceDtance - the Responsiveness Summary in the appendix
of th~ Record of Decision reviews the public comments received from
the Proposed Plan public meeting.
TABLE 2
Glossary of Evaluation Criteria
Wrigley Charcoal Site
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For materials such as tar-cubes, transformers and non-corroded
metallic material that may pose a threat to human health or the
environment, these wastes will be stored in an on-site consolidation
area. The storage of these wastes at the Wrigley Site is occurring
because remediation for these materials will be investigated and
accomplished as part of later remedial activities.
Wastes such as tar-cubes will be moved within the area of
contamination and will not invoke the Resource Conservation and
Recovery Act (RCRA) Land Disposal Restrictions (LDRs). However,
consolidation (i.e. - storage) of these materials on-site will
require that the RCRA storage ARARs be waived (See Section 9.2).
RCRA Subtitle C requirements are applicable when excavating and
transporting the soil. Safety precautions specified in RCRA must be
followed which include standards and requirements for owners and
operators of treatment, storage, and disposal (TSD) facilities.
A list of major ARARs that pertain to the Wrigley Charcoal Site
interim and early final actions is presented below-while a more
thorough description and explanation of major ARARs is presented in
Appendix E.
9.2.1
9.2.2
Action SDecific ARARs
o
RCRA Subtitle C: 40 CFR 260.1, 40 CFR Part 262, 40 CFR Part
462, 40 CFR Part 262, 40 CFR 264, 40 CFR Part 265.
o
Standards Applicable to Transporters of Hazardous Waste: 40
CFR Part 263.
o
Standards for Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities (TSDFs): 40 CFR
Part 264.
o
DOT Rules for Hazardous Materials Transport: 40 CFR Part
107, 40 CFR Part 171-179.
o
Location SDecific ARARs
Federal Protection of Wetlands Executive Order: E.O. 11990,
40 CFR Part 6, Appendix C.
o
Clean Water Act (CWA): 40 CFR Part 230, 33 CFR Parts
320-330.
o
The Fish and Wildlife Coordination Act: 16 USC 661, Section
404.
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9.2.3
o
The Fish and Wildlife Improvement Act of 1978: 16 USC 742a,
and the Fish and Wildlife Conservation Act of 1980: 16 USC
2901.
o
RCRA Location Standards: 40 CFR 264.18.
Contaminant Specific ARARs:
o
Reference Dose (RFD): as defined by IRIS (EPA Integrated
Risk Information System). TBCs for this interim action.
o
Carcinogenic Potency Factors (CPFs): TBCs for this interim
action.
o
EPA Health Advisories: TBCs for this interim action.
o
Clean Air Act (CAA): National Ambient Air Quality Standards
(NESHAPs) 40 CFR Part 50, National Emissions Standards for
Hazardous Air Pollutants (NESHAPs) 40 CFR Part 61, New
Source Performance Standards (NSPS) 40 CFR Part 60. These
are TBCs for the Wrigley interim action.
o
Clean Air Act (CAA): NESHAP standards 40 CFR Part 61 Subpart
M pertains to any renovation or demolition activities
concerning asbestos at the Wrigley Site. This may pertain
to removal of ACM from the small building adjacent to the
Maintenance Building. These are TBCs for the Wrigley
interim action.
EPA will attempt to meet "best demonstrated available technology
(BDAT) requirements (as described in RCRA LDR guidance, 9347.3-06FS,
9/90) for coal-tar wastes and burn-pit wastes at the Wrigley Charcoal
Site. If during remedial design, these requirements can not be
attained, EPA will obtain a treatability variance, and will attempt
to meet the treatability variance levels. Table 3 presents cleanup
criteria for the BDAT, and treatability variance levels.
The final cleanup levels for the interim activities are not address~.
in this ROD because such goals are beyond the limited scope of this
action. The final cleanup levels for interim activities will be
addressed by the final remedial action ROD for the Site.
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TABLE 3
BURN-PIT WASTES
Contam. Level TCLP Criteria (1. ~ ) Treatment
Lead 1600 PPM <300 PPM 0.1-3.0 PPM Stabilization
>300 PPM 99-99.9% " II
Chromium 270 PPM <120 PPM 0.5-6.0 PPM Stabilization
>120 PPM 95-99.9% II "
Nickel 160 PPM <20 PPM 0 . 5 -1. 0 PPM Stabilization
>20 PPM 95-99.9% II "
Arsenic 40 PPM <10 PPM 0 . 3 -1. 0 PPM Stabilization
>10 PPM 90-99.9% " "
PROCESS TANK SLUDGE AND SURFICIAL COAL-TAR WASTES;
Contam. Level TCLP Criteria (1. ~ I Treatment
PABs 737 PPM <400 PPM 0.5-20 PPM Incineration +
>400 PPM 95-99.0% Stabilization
Phenols 20,000 PPM <400 PPM 0.4-40 PPM Incineration +
>400 PPM 90-99.9% Stabilization
Lead 340 PPM <300 PPM 0.1-3.0 PPM * *
>300 PPM 99-99.9% * *
Nickel 110 PPM <20 PPM 0.5-1.0 PPM Stabilization
>20 PPM 95-99.9% " II
1) PPM of TCLP extract
2) Percent reduction of TCLP extract
* * Lead contained in the residual ash following
coal-tar incineration will be stabilized.
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9.2.4
CERCLA Waiver Criteria For ARARs
CERCLA Section 121(d) provides that under certain circumstances an
otherwise applicable or relevant and appropriate requirement may be
waived. These waivers apply only to meeting ARARs with respect to
remedial actions on-site; other statutory requirements, such as that
remedies must be protective of human health and the environment,
cannot be waived.
1 )
Interim Measures
The remedial action selected is only part of a total remedial
action that will attain such level or standard of control when
completed. [CERCLA Section 121 (d)(4)(A).]
2 )
Under measures set forth by the interim waiver, the RCRA
Subtitle C, 40 CFR Part 264 ARARs pertaining to permanent
storage facilities will be waived. Pursuant to the remedial
action selected, the tar-cubes and metallic materials will be
moved to the temporary consolidation area for future
remediation. Metallic debris will only be stored in the
on-site consolidation area if off-site disposal is not
selected during the RD. These materials will be consolidated
within the area of contamination (AOC), wastes and materials
such as tar-cubes were generated prior to 1980, and wastes are
not RCRA listed wastes. The final action will be in
compliance with all ARARs.
9.3
Lonq-Term Effectiveness
Excavation, transportation, incineration, stabilization, and disposal
for coal-tar wastes and sludges will achieve significant reduction in
the contamination and provide long-term effectiveness at the process
tanks. Also, excavation, transportation, stabilization, and disposal
of burn-pit wastes will provide long-term effectiveness at the
burn-pit. However, all the interim measures will not provide any
degree of long term effectiveness at the Wrigley Site. The EPA will
continue to evaluate long-term effectiveness and permanence as part
of the development of the final action for the Site.
9.4
Reduction of Toxicitv. Mobilitv or Volume
Alternative 3 does reduce toxicity, mobility, and volume of
previously described wastes at the Primary Site. Also, as these
wastes are removed, eliminated, or contained the potential for dermal
contact, migration, or bioaccumulation is greatly reduced. Proposed
activities for this interim action are intended to reduce present
risks associated with the most imminent and substantial dangers to
human health and the environment while preparing several of the Site
waste locations for future remedial activities that will eliminate
the wastes.
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9.5
Short-Term Effectiveness
Significant short-term effectiveness will result of the previously"
mentioned activities. The interim action is effective' in the
short-term because it would significantly reduce the potential
threats from contaminants at all of the activity locations previously
described. No adverse affects are expected during interim remedial
activities that could impact human health or the environment. Any
short-term risk to workers involved in excavation, transportation or
construction activities would be reduced through implementation of a
health and safety plan. Short-term risks will be slightly elevated
during excavation of the spillway, however, this area will be further
isolated from the waters of the North Fork of Mill Creek until
excavation and construction activities are completed. Protective
measures outlined in a health and safety plan will insure impacts
from these activities are minimized.
9.6
ImDlementabilitv
The implementability of an alternative is based on technical
feasibility, administrative feasibility and availability of services
and materials. There are no expected difficulties associated with
the implementation of Alternative 3 since only standard construction
techniques will be utilized.
9.7
Cost
Alternative 3 has a present worth cost of $984,998. Additional areas
of contamination that are not addressed during this interim action
are proposed 'for later remedial activities and the' costs of these
activities will be determined after additional information is
obtained. .
9.8
State AcceDtance
The State of Tennessee has assisted EPA
Site evaluations concerning the interim
has reviewed the Record of Decision and
these early final and interim actions.
in the review of reports and
action activities. The State
c~ncurs with the selection of
9.9
Community AcceDtance
Community response to the alternatives is presented in the
responsiveness summary (Section 12) which addresses comments received
during the public meeting and the public comment period.
10.0
SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the detailed
. analysis of the alternative, and public comments, EPA has determined
.that the activities as described in Alternative 3 (Section 8.3, p.
34) constitute an appropriate early final and interim action until a
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final action for the Site is determined.
The major goal of this interim action is to reduce risks at the
Primary Site by eliminating, or controlling the most imminent and
substantial threats to human health and the environment. Additional
goals of this action are to reduce the risk of dermal contact with
wastes at the Storage Basin restricting access through fencing, and
to perform additional sampling and analyses behind the Athletic Field
to better define a small "hot spot", and at the Irrigation Field to
determine if compounds of concern are present in the deeper soils of
the abandoned Irrigation Field lagoon.
It should be noted that some of the actions may be modified during
the RD/RA. These changes may reflect modifications resulting from
the engineering design process.
11.0
Statutory Reauirements
The u.s. EPA and TDEC believe that the activities included in the
interim action satisfy the statutory requirements of providing
protection of human health and the environment, attain ARARs directly
associated with this action and will be cost-effective. sections
11.1 thru 11.6 summarize the statutory requirements for the Site.
11.1
Protection of Human Health and the Environment
The activities previously described concerning this interim action
will provide protection of human health and the environment by
removing, treating, and disposing of coal-tar wastes and sludges, and
burn-pit wastes that contain significant levels of contaminants.
Additional protectiveness is provided by the removal and disposal of
the ACM, and drummed wastes, and through Site access and deed
restrictions. Implementation of the interim action activities will
not pose unacceptable short-term risks or cross media impacts.
Attainment of the Applicable or Relevant and Appropriate
Reauirements (ARARs)
The final cleanup levels for the Site areas where interim activities
are planned are not addressed in this ROD because such goals are
beyond the limited scope of this action. The final cleanup levels
will be addressed by the final remedial action ROD for the Site which
takes into account the potential migration of subsurface contaminants
to groundwater. ARARs for Site areas that will be addressed will be
met as previously discussed in Section 9.2 and Appendix E.
11.2
11.3 Cost Effectiveness
This early final and interim action remedy employs proven
technologies that will be applied to coal-tar wastes, burn-pit
wastes, and drummed wastes.
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The selec'ted remedy affords overall effectiveness proportional to its
costs. The selected remedy provides a sufficient margin of
protection, and is cost effective when the overall relationship
between cost and effectiveness is compared to other alternatives.
11.4
Utilization of Permanent Solutions and Alternative Treatment
Technoloqv or Resource Recoverv technoloqies to the Maximum
Extent Practicable
Portions of this action are interim and are not intended to utilize
permanent solutions for any of the four Wrigley Charcoal Site areas.
The objectives of this interim action are to reduce and/or prevent
current or future exposure from exposed contaminants at the Primary
Site and Storage Basin that pose the most imminent and substantial
threats to human health and the environment. 'Excavation, off-site
treatment and disposal of coal-tar and burn-pit wastes will achieve
some reduction in the contamination at the Primary Site. Early final
actions for coal-tar and burn-pit wastes intend to utilize permanent
solutions on a very limited basis for the primary Wrigley Site.
These activities will also serve to reduce potential complications
these wastes may have on future remedial activities.
The EPA will continue to evaluate long-term effectiveness and
permanence as part of the development of the final action for the
Site. Subsequent actions will provide a final resolution to Site
conditions which will be controlled through the selected interim
action. Utilization of permanent solution will be addressed in the,
final decision document for the Site. Portions of this interim
action are not designed or expected to be final, but represent the
best balance of tradeoffs among alternatives with respect to
pertinent criteria, given the limited scope of this action.
11.5
Preference for Treatment
The CERCLA statutory preference for treatment requires that waste
treatment be thoroughly evaluated and if possible, treated to reduce
or eliminate the threats from hazardous wastes or materials. The
preference for treatment beyond the scope of these limited actions
will be discussed in subsequent decision documents for the Site.
This interim action will not definitively address all of the
principal tnreats posed by the Site. Additional threats at the
Wrigley Charcoal Site will be addressed during subsequent remedial
activities., Tentatively, these subsequent actions have been
described to remediate the Primary Site tar-pits, contamiriated
Primary Site soils, tar-cubes, Storage Basin coal-tar wastes, any
additional coal-tar wastes identified at, any of the Wrigley Charcoal
Site areas, any ACM determined to be friable, and any groundwater
problems at the Wrigley Charcoal Site.
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11.6
Documentation of Siqnificant Chanqes
Comments pertaining to the Proposed Plan by the State of Tennessee
have lead to significant changes in the Interim Action selected for
the Wrigley Charcoal Site. The changes have been incorporated into
the discussion of the selected alternative (Alternative 3) in Section
8.3 of this document. These significant changes include:
1 )
Reduction in the amount of ACM to be removed from the Primary
Site;
2 )
Modifications to the spillway reconstruction at the Primary
Site;
3)
Modifications to the removal and/or disposal of waste/debris
piles at the Primary Site;
Modifications to the activities to be performed at the Storage
Basin;
4 )
5)
Additional coal-tar wastes near the still house foundation
have been added to the list of interim action activities.
The State of Tennessee has indicated that the friability of the ACM
has not been consistently determined. Since no analyses have been
conducted to determine the friability of the ACM, only the visibly
friable/broken ACM will be removed from the Primary Site. This
material consists of the broken sheets on the ground, soils adjacent
to these broken sheets, and the ACM on the small building in front of
the maintenance building. In the event that data suggests there are
additional risks with the remaining materials, appropriate me~sures
will be taken at that time.
Concerning the spillway at the southern end of the Primary Site, the
State of Tennessee has recommended that the spillway be further
excavated to bring it to the existing North Fork of Mill Creek grade
to reduce the threat of future erosion. The State has also
recommended that the two 48-inch culverts be removed. It appears
that the excavation of the spillway is more feasible than culvert
removal at this time. Excavation of the spillway is preferred since
the culverts are presently backing up sediment near the tar-pits and
deflecting waters of the North Fork of Mill Creek away from the
tar-pits and into the spillway. However, during the RD, all of the
options (including all of the State of Tennessee requests) previously
mentioned will be critically evaluated and an appropriate option will
be selected and implemented.
The waste/debris pile remediation at the Primary Site will also be
modified. Instead of removing all of the tar-cubes and disposing
off-site, these wastes will be stored in an on-site consolidation
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area for elimination during a later remedial activities. ARARs that
pertain to the treatment, storage, and disposal facilities (RCRA
Subtitle C, 40 CFR Part 264) are an ARAR. However, these materials
that were generated prior to 1980 will only be consolidated within
the area of contamination (AOC). Based on this information, these
ARARs will be waived for this activity because the storage will be
temporary and does not require measures designed to provide long-term
effectiveness and permanence. .Additionally, all other hazardous
substances found within these piles such as partially full drums, and
ACM will be disposed of off-site. Recyclable will also be removed. .
Substances that are identified as non-hazardous such as equipment,
etc., will be moved into one of the on-site buildings, or stockpiled
on-site.
Additional concerns about the Storage Basin were also submitted by
Tennessee. They have suggested the the wastes be left in-situ for
later remediation instead of stabilizing the. wastes and thereby
increasing the volumes of materials to be eliminated. EPA will
comply with this request until subsequent remedial activities are
implemented at the Site.
Additional coal-tar wastes (approximately 3.5 yd3) will be removed
from the northeast corner of the old still house. foundation. This
item is being added to the "list of interim action activities at the
request of the State of Tennessee. Coal-tar wastes at this 19cation
are noted to be above safe levels for carcinogenic PABs. A small
area will be excavated [10x10x1 (ft)] and backfilled with clean fill.
Concerning the process tanks, instead of disposing of the tanks in a
EPA approved RCRA facility, these tanks will be sold as scrap metal.
This information is is presented in this section as a clarification,
although this is not considered to be a significant change.
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12.0 RESPONSIVENESS SUMMARY
The U.S. Environmental Protection Agency (EPA) established a public
comment period from July 15, 1991 to August 15, 1991 for interested
parties to comment on EPA's Proposed Plan for Interim Action
activities at the Wrigley Charcoal Site. The Tennessee Fanners
Cooperative (TFC) requested a 30 day extention to the Public Comment
period. A 30 day extension was granted, and the extended Public
Comment period ended on September 16, 1991. A public meeting was
held on July 25, 1991, conducted by EPA at the East Elementary School
near Wrigley, Tennessee. The meeting presented the results of the
RI/FS undertaken at the Wrigley Site and proposed activities to be
performed during the interim action.
A responsiveness summary is required by Superfund law and regulations
to provide a summary of citizen comments and concerns about the Site,
as raised during the public comment period, and the responses to
those concerns. All comments summarized in this document have been
factored into the final decision of the interim action for the
Wrigley Charcoal Site.
This responsiveness summary for the Wrigley Charcoal Site is divided
into the following sections:
12.1 Overviewt This section discusses the recommended interim
action for the Site and the public reaction to this
alternative;
12.2. Background on Community Involvement and Concerns; This
section provides a brief history of community interest and
concerns regarding the Wrigley Charcoal Site;
Held on July 25, 1991, and EPA Responses; This section
presents both oral and/or written comments submitted during
the public meeting and provides the responses to those
comments;
flail, Centerville. Tennessee, July 25, 1991 This section
presents comments raised during the meeting with City
Officials in Centerville, Tennessee and EPA responses to
those comments.
12.5 Written Comments Received during the Public Comment Period
and EPA7a Responses to These Comments; This section
presents letters or comments subniitted during the Public
Comment Period and EPA's response letters.
Appendix B: Contains the Proposed Plan that was presented
to the public on July 25, 1991. This document was also
placed in the information repository and mailed to those on
the mailing list.
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Appendix C: Includes the sign in sheets from the public
meeting held on July 25, 1991 at the East Elementary School
near Wrigley, Tennessee.
Appendix D: Includes the name, address and phone number of
the information repository designated for the Wrigley
Charcoal Site.
12.1. Overview
The proposed plan for interim action activities at the Wrigley
Charcoal Site was presented to the public in a fact sheet released on
July 11, 1991 and at a public meeting held on July 25, 1991.
The major goal of this interim action is to remove or contain
contaminated media at the Primary Site, and to restrict access at the
Primary Site and the Storage Basin.
The major components of the interim action remedy include:
1) Metallic wastes in the maintenance buildings' burn-pit will
be excavated, stabilized and disposed of in an EPA approved
RCRA facility. The approximate volume of this material is
15 yd . Transformers found in the maintenance building
will be secured with other transformers found at the Primary
Site in a on-site consolidation area (total amount of
transformers estimated at 130 drums);
2) Risks will be reduced at the Storage Basin by fencing the
area. This will discourage and possibly prevent entry and
disturbance of this area until wastes can be appropriately
eliminated during later remedial activities;
3) Process tank waste sludges (29 yd3) will be removed ,
transported, incinerated, stabilized and disposed of in an
EPA approved RCRA incinerator/landfill for disposal. The
metallic tanks will be decontaminated, and sold as scrap;
4) Black coal-tar wastes on the ground from the process tanks
down to the North Fork of Mill Creek will be excavated,
transported, incinerated, stabilized and disposed of in an
EPA approved facility. The area has been visually estimated
at approximately 50 x 10 feet with an average thickness of
1.0 foot (approximately 19 yd3);
5) Black coal-tar wastes visible at the northeast corner of the
previous still house location will be excavated,
transported, incinerated, stabilized, and disposed of in an
EPA approved, facility. The estimated volume of this
material is 3.5 ydj;
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11)
12)
13)
6)
Removal of the friable (ACM) for disposal in an approved
asbestos landfill. Most of the intact ACM on building roofs
appears to be in fair condition. However, the visibly
friable ACM on the small building in front of the
maintenance building should be removed as well as broken
sheets of ACM on the ground near the dryer building, tank
battery, and previous location o~ the still house
(approximately 0.5 tons or 20 yd). Visible ACM on soils
associated with broken, crushed or sheet ACM that reveal
light grey-white coloration (representative of the ACM at
the Wrigley Site) will be removed. An approximate estimate
of3ACM contaminated soils that need to be removed is 20
yd .
7)
Exposed black coal-tar wastes visible in the spillway should
be excavated and disposed of in an approved off-site
facility. Wastes should only be excavated until a
reasonable margin is established for the rebuil5 spillway.
Approximate estimates for this waste are 100 yd .
Twelve staged drums are located near the maintenance
building and two drums in the storage shed. Drums wastes
should be transported, incinerated and/or stabilized and
disposed of in an EPA approved facility.
8)
9)
The spillway should be repaired and re-engineered to
accommodate the significant flood waters that frequent this
area. This may involve straightening and further excavating
the spillway down to the existing creek grade;
Site surface wastes/debris piles that include tar-cubes,
pieces of corrugated asbestos roofing, transformer
materials, crushed drums, and other miscellaneous metallic
debris and tar waste will be sorted. Materials such as
tar-cubes and wastes that may be remediated with later
remedial activities will be stored in an on-site
consolidation area. Volume estimates for Site debris are
presented in table 1;
10)
A limited investigation will be performed at the Irrigation
Fields' abandoned 3/4 acre lagoon. This activity will
include several soil borings/excavations (to approximately
10 feet) and several additional soil samples at the previous
location of the feed pipe outflow. This activity will
determine whether wastes similar to the Storage Basin are
present in the deeper soils;
EPA will negotiate with local municipalities
restrictions. Site access controls (fencing
will also be implemented at the Primary Site
Basin;
to impose deed
& placards)
and Storage
Sampling and Analyses:
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Resampling of the six monitoring wells and twelve
piezometers at the Primary Site will provide an
assessment of the groundwater quality;
Soil sampling and analyses will be required behind the
Athletic Field to the garden area, and will assess the
need any future activities in this area;
Following EPA activities concerning this interim
action, one round of residential well and spring
sampling and analyses will be required to insure the
interim action activities have not affected.water
quality.
The estimated cost for the interim action remedy is $984,998. It is
presently estimated that it will take 6 months to complete this work.
At the end of the five-year period following this interim action, a
review will be conducted. If subsequent remedial activities are
initiated prior to the close of the five-year period following
interim action, a review will be conducted prior to any initiation of
additional work at the Wrigley Charcoal Site. The review will be
conducted to insure that early final activities are functioning as
designed and that the interim activities are, and have been effective
in reducing the threat to human health and the environment.
The community, in general favors taking interim action for the
Primary Site and. the Storage Basin.'
12.2
Backaround.on Communitv Involvement and Concern
The'community of Wrigley is aware of activities that were conducted
at the Wrigley Charcoal Site beginning in 1881 and continuing
intermittently until the mid-1980's.
The first public meeting was held on October 24, 198e at the East
Elementary School near Wrigley, to provide information and a180 to
answer citizens' questions concerning removal activities at the
Wrigley Site. Representatives from EPA and the State of Tennessee
provided details of activities taken to date, pertinent analytical
results and proposed activities to be completed in the future.
EPA distributed a fact sheet in August of 1989 prior to having the
second public meeting held on October 29, 1989 at the East Elementary
School. The purpose of this meeting was to inform citizens and other
interested parties of the beginning of the RIfFS.
In December of 1990, another fact sheet was distributed prior to
sampling conducted at the Athletic Field and in the town of Wrigley.
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In July of 1991, the Proposed Plan fact sheet was distributed
explaining interim action activities. Availability of the Proposed
Plan was published in the the Hickman County Times on July 15, 1991
and again on July 22, 1991. The third public meeting to present the
Proposed Plan for interim action activities concerning the Wrigley
Charcoal Site was also held at the East Elementary School on July 25,
19~. At this meeting, concerns and issues were raised concerning
the contamination at the Wrigley Charcoal Site.
12.3
Summary of Maior Questions Raised Durinq the Public
Meetinq Held on July 25. 1991. and BFA ResDonses
Comment 1:
Response:
Comment 2:
~esponse:
Comment 3:
Response:
A private citizen wanted to know if there was going to
be any provision for monitoring the groundwater,
before, during, or after the cleanup?
The activities planned for this interim action are
surficial and it is not likely that these activities
will adversely impact groundwater downstream of the
Site. However, as an added protective measure, after
interim remedial activities are completed all
monitoring wells on Site, all springs, and all
residential wells within a one mile radius of the Site
will be sampled and analyzed (a single sampling and
analysis event).
A private citizen asked if Bob Powell (State of
Tennessee Superfund Representative) remembered that he
said they were expecting significant groundwater
contamination? (The citizen was unsure of the phase
that Bob may have been referring to or at what meeting
it was stated).
Bob Powell did not recall saying that he expected
significant groundwater contamination. Bob further
explained that the contaminated groundwater he believes
he was referring to was in an exploratory pit and was
surficial water or shallow perched groundwater. He did
not recall ever saying that there was a risk to the
groundwater.
Harold Taylor further summarized comments 1 & 2 by
stating, "1 think your question is, how are you going
to be assured on a routine basis that your drinking
water is safe"?
We cannot say at this time whether wells will be
sampled on a regular basis. The EPA will perform well
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Comment 4:
Response:
Comment 5:
Response:
Comment 6:
Response:
sampling on a scientific and technical basis that will
assure that there is no off-site'problems. One of our
biggest concerns was the potential for off-site
contamination and at present, EPA does not believe
there is a significant threat of off-site contamination
of groundwater.
A private citizen pointed out that if you start to
disturb the waste, it may leak into the cracks in rocks
and a year later show up in private wells.
As a protective measure, EPA will perform a round of
sampling as previously stated in the response for .
comment 1.
A private citizen mentioned that they read in the
proposed plan that the fish in the creek had some
contamination. Is it safe to eat the fish in the
creek?
Glenn Adams (EPA, Toxicologist) mentioned that no
contamination was found in the surface waters of the
North Fork of Mill Creek but the fish were sampled in
order to determine if any contaminants were. in them.
Trace levels of mercury, lead, and dioxin were
identified in the fish. Risk scenario calculations
were done to evaluate what the lifetime risk would be
from eating a half pound of fish per meal. 'The level
detected in the fish was 0.0002 ppb and the EPA
regulatory level was 0.0007 ppb.. So we have 3.5 times
less in the fish than the regulatory level. This is
. approximately equivalent to a one in one million risk
level and we do not feel that there is any danger or
. cause for concern from eating the fish.
A private citizen asked if Alternative 3 was definitely
what EPA is going to do?
EPA responded that comments to the Proposed Plan will
be accepted during ~he Public Comment Period. 'We are
going to meet with the State and discuss their
concerns. If we get significant comments that
indicates that any part of our proposed activities need
to be changed, and we find a valid and rational reason,
we then will. change the alternative. If for example,
we make any significant changes such as changing
remedial technologies from fencing to on-site
incineration, then we would come back to the public and
explain why the plans have been changed and get your
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Comment 7:
Response:
Comment 8:
Response:
Comment 9:
Response:
Comment 10:
Response:
comments prior to actually finalizing our
activities.
The private citizen that offered comment 6 further
stated that they thought that Alternative 3 was the
best solution.
A private citizen asked if the Bon Aqua-Lyles utilities
where we get most of the water, is that water safe?
The water intake was moved to above the confluence of
the North Fork of Mill Creek and Mill Creek. EPA and
the State of Tennessee have sampled the waters and
found no contaminants in either stream or at the old
water intake. The water intake was moved as a
precautionary measure since there was potential for
materials from the tar-pits to enter the North Fork.
However, since the tar-pit solidification effort in
1988, the potential for tar-pit failure has been
greatly reduced and possibly eliminated.
A private citizen asked if flooding had anything to do
with the decision to move the water intake?
No. Flooding did not affect the decision to move the
water intake. We presently have no reason to believe
that flooding would create any more contamination at
the previous water intake location.
Do you have any idea as to what the depth of
contamination may be?
The drilling data indicates that at the Primary Site
there is approximately ten to fifteen feet of slag, and
another ten feet of soil mixed with slag below that.
There also is a great deal of variation of depth of
these contaminants due to the geology and the extent of
the industrial activities. At the northern part of the
Site the bedrock is encountered at a depth more than
100 ft, even more in places. At the southern portion
of the Site the bedrock is very shallow and can be
encountered as little as five feet below the surface.
A PRP asked _f the contaminants identified at the
Wrigley Site will decompose or anything? Or is it here
to stay?
There is no question that since the plant ha~ closed
the North Fork of Mill Creek, Mill Creek, an~ all the
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Comment 11:
Response:
way down to the Piney River, appears to be cleaning up
slowly but surely on a natural basis. But there are
some peculiar problems at the Primary Site. It appears
that the geology controls to a large extent what flows
in and out of the Primary Site. It appears that
geologically the North Fork valley (where the Primary
Site is located) is a small basin. This basin has
trapped a lot of these contaminants both in the shallow
groundwater and the soils. Some of the samples taken
after the plant had been closed for twenty-five years
showed levels of contamination very similar to the
original composition of the raw liquors produced at the
plant. After twenty-five years these contaminants have
not deteriorated very much at all. As for the metals,
these are very persistent in soils and they will be
there for an even longer period of time.
A PRP stated, "Initially when it was discovered that
this material was seeping into the creek there, you
know, it was actually going into the water, could be
detected going into the water, but downstream ten feet
or twenty feet, there was more detection of it. Does
that mean that the levels of it going in were so small
that it distributed itself and dissipated before it
went very far? In that event, if it got down through
the ten or fifteen feet of debris that's in the ground
and got into the water table, is it likely that it
would take a tremendous concentration of it, just a
gusher of it go in to contaminate a well? Or could
little by little enough build-up seep through and go
down and contaminate the water table level out there?
There's all these springs in the area where the water
is just under the soil. At certain times of the year
you think it's a spring right there in the ground, so
there's a lot of water working, surface water, I
assume, or coming out of that hill or somewhere. But
if that ever finds its way down into the water table
and gets into the wells — you mentioned you tested
twelve wells. I wonder if that is the total number of
known wells that are being used out of that are subject
to this, and whether or not those people at one time
would have to give up those wells and go to our city
water for their water supply" ?
What we have determined thus far is that the
contamination that is getting into or that is migrating
on the Primary Site to Mill Creek is being dispersed
and diluted to the point where it is not detectable in
Mill Creek. That's good news for anybody below the
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Comment 12:
Response:
Site. But, as was stated previously, the peculiar
problems at the Primary Site stem from the geology.
This type of geology is referred to as karst and is
representative of all of the areas that encompass the
Wrigley Charcoal Site. The limestone that underlies
the Site areas has been corroded by the acidic waters
(rain water and surface water) which further enlarge
fractures and produces solution cavities. When these
enlarged fractures and solution cavities intersect, the
waters can then be transported down different migration
pathways many times at faster rates. This type of
scenario is very complicated.
Another problem with the karst geology at the Wrigley
Site includes the possibility of pulse flow. This
hypothesis basically suggests that waters and
accompanying contaminants may build-up or accumulate
until a heavy rainfall event mobilizes the contaminants
in pulses. EPA does not have all of the data they need
to support this hypothesis, so it will have to be
investigated further. However, it is possible that
this scenario applies to the Wrigley Charcoal Site.
Information pertaining to this issue will have to be
obtained at a later date to answer some of these
questions.
A PRP mentioned, "Let's get above the ground, get up on
the ground, you mentioned that the people trespassing
across the property or people that have a right to be
on the property, people that are in there picking
blackberries or hunting rabbits or deer, would they in
any slight way expose themselves to a health hazard?
I've been down there picking blackberries. Is this the
type material that could get into vegetation and
precipitate into -- suppose you had an apple orchard
down there, suppose there's an apple orchard in some of
that area, and there's fruit bearing trees. If you
went in and picked them, does this type of stuff leach
into something other than water, or fish that would
take enough food out of the stream to get into their
system, is this something that gets into the vegetation
and gets in a person's body" ?
EPA stated, "Yes, that was one of the things that we
looked at. When you have levels of contaminants in
soils, metals and these organics, that is one of the
pathways that they can get -- say if you have a
vegetable garden. And that was what we looked at. We
didn't look at blackberries, because we don't have any
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Comment 13:
Response:
good scientific data on how these metals are taken up
in blackberries. But we do as to some garden
vegetables and different things. That was one of the
pathways we looked at.
And it did show that if you plant a garden out there in
these soils, and there again the seventy year lifetime
is an average number and not for everybody. But, yes,
it would be a concern. It's not a great concern
compared to the other things, but that is — was a
concern. It was also looked at if hunters were coming
on the Site, the thing with deer or even rabbits, is
they seem to forage over a lot of acres. They don't
always get their food in the same spot, but get it each
day from — I think the average forage for one year is
about three miles, square mile area a day. And it was
deemed that the majority of the time they're on other
Site or other areas. So they wouldn't be obtaining
enough levels to be a problem if someone were hunting
out there. Now, the most likely thing with animals
where organics or these metals collect is if an animal
was to eat something contaminated is just like humans,
it's going to go to the organs as in the liver,
kidneys, the heart, things like that. So if there was
going to be a problem, that's where it would be. It
wouldn't be in the meat of those animals".
A FRF asked,"The people that would hash through the
property there, there's a path that goes across it.
Even though you have eighteen locks on that gate down
there and I can't get in, there's still a good beaten
path down there that there's traffic, foot traffic
across there day in and day out. I assume that the
asbestos that may be on the ground, on the buildings
could get airborne. Is this a threat to them or the
fumes or vapors that might come off of this if they did
it day in and day out"?
•
The broken pieces of asbestos roofing on the ground and
the roofing on the building in front of the maintenance
building that has been exposed to fire are a problem.
These materials are visibly friable and when they are
agitated by foot traffic, vehicular traffic, or by the
wind, it is likely that fibers are becoming airborne.
Information from the Asbestos Unit of the EPA indicates
that even minimal exposure of asbestos can cause health
problems or increased risks. So from a health
standpoint, the friable ACM appears to be a problem
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Comment 14:
Response:
Comment 15:
Response:
Comment 16:
in the short-term. It presently has not been
determined whether the non-friable ACM contributes to
problems or health effects associated with long-term
exposures. This will have to be investigated in the
future.
A PRP asked,"Not a likelihood of the vapors off that
would drift up and get up into the residential area,
ever I don't suppose"?
The air sampling that was conducted did detect some
contaminants but not at very high levels. These were
well within the EPA risk range. But based on the
lifetime exposure, for someone living in a residence
near the Site, the risks could be slightly elevated.
A PRP asked," Do you have any idea as to how it (the
Wrigley Charcoal Site) ranks with like Waynesboro or
Lewisburg? Is this the type of toxicants that are
there, are they less serious or more serious? Are you
dealing with the State of Tennessee with like problems
that are far more greater than this, or is this in the
range of being one of the serious ones also?"
EPA stated that this question comes up at every meeting
and it is very hard to qualify an answer. But each
site on the NPL is different. For example, the
Lewisburg Dump Site is approximately five acres and the
boundaries are pretty well established and EPA can
rationalize fairly easily what the remedies are. So a
site like that would be relatively low on the scale as
far as being a difficult site. The Wrigley Site is
much larger. It has a wide variety of contaminants
ranging from coal-tar wastes and metals to volatile
organic compounds and building material wastes. Also
the volume of contaminated material is much greater at
the Wrigley Site. Relatively speaking, the Site is not
nearly the health threat that it was years ago when
people were actually drinking or using contaminated
waters. Also years ago the North Fork of Mill Creek,
and Mill Creek all the way to the Piney River were
severely affected. So the way the Site was (when it
was in operation) from the EPA perspective, was one of
the worst sites perhaps that we had.
So to sum all of this up, of the twelve sites, based
upon a number of factors, Wrigley is probably somewhere
in the middle.
A PRP stated, "The cost of different remedies that have
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been proposed, the lady that spoke said she was in
favor of number 3. ' Evidently EPA is in favor of number
3 because of their experienc~. Basically I am in favor
of number 1 becaus~ of the potential disturbance. This
thing goes on and on. The cost to the government -- I
know that I'm going to get a bill for my part, you
know. But the cost to somebody, if the government pays
for it, I still pay for it. If I'm liable for some
portion, then I'm obligated in some way.
The disturbance of this material, there must be a
mammoth amount of highly contaminated materials to
slightly contaminated materials. I suppose there's a
cut-off point somewhere that you say, well, this is the
hot spot, we've got to concentrate on this, and if we
don't do anything else, we've got to do ,a good job of
this, and may leave some gray areas that will never
require anything other than letting nature take its
course or take care of it. But I'm wondering, you're
talking about spending very little to just have a
restricted deed. I've been notified that the deed is
already restricted. I could not sell my property
there. No one in their right mind would need to buy it
because it's a liability rather than an asset. Butthe
thought that the property may -- if you go into your
stage'3, that you've opened up something that you're
going to be the need to remove some stuff out of there
at another stage and another stage. And if I didn't
misread all of the misprints in the news paper, that
two million dollars had been spent to haul away some
tar, a hundred and thirty cubic yards of tar to be
burned equates. about fifteen thousand dollars for a
cubic yard. And that is just the tip of the iceberg as
to what might have to eventually be removed and
disposed of. .
I assume that the concentration of that tar
necessitated incineration, was very expensive to
dispose of that where if you were getting rid of
something of less concentration, you might be carrying
it away and burying it in an approved landfill and
might not have millions and millions of dollars worth
of cost to remedy the thing. I suppose I've predicated
my preference of always knowing where you're at. These
fellows that are concerned about the well water, they
are'desperate to make sure they don't start drinking
something that gets in their liver, you know.
And when this thing starts stirring, when you begin to
move that soil, if one of them gets sick, he's going to
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Response:
Comment 17:
Response:
be knocking on EPA's door and saying, now, come and
check my water. So you may set up an everlasting water
testing situation if it comes to that. But I'm sure
there's enough history of what you're doing in these
areas, you've had sites like this before -- and I guess
the American Creosote Site is the top of the list
because of probably some of the same types of materials
there. I understand it is very, very expensive
project. I don't know whether it's completed or not,
but I'm familiar with the site".
EPA mentioned that they were right in mentioning that
there is a lot of material at Wrigley. EPA cannot
clean up every ounce of material that is there because
it will not be cost effective. What we are having to
do with sites just like Wrigley is make a risk
management type decision that tries to segregate the
most toxic, the most mobile waste, and treat those
wastes, and do the less toxic, the less mobile waste,
just cap those and leave them on-site and monitor them,
basically make institutional controls and make sure the
property is not used in a way to disturb that in the
future. We have not made these decisions yet, however,
these types of decisions will be made in a prompt
fashion at the Wrigley Site.
A PRP indicated that they had received a few phone
calls about wanting to bid on the fence that EPA plans
to put up. The PRP also mentioned that these local
people would like to be considered and claims that they
are in the fencing business. The PRP did not know how
the contractors are selected.
EPA mentioned that when it is time to pick out a
contractor, the prime contractor will be chosen using
all the federal guidelines to placing contractors. EPA
is really the contracting agent that works getting the
bids, and we select, of course, generally the lowest
bidder that satisfies all of our requirements. That
bidder or prime contractor, of course, will usually go
out and solicit bids from subcontractors. If those
subcontractors who submit the best bids are in the
local area, then obviously they will do the work.
Also, in response to the statement concerning spending
taxpayers' dollars, we all are taxpayers, and I know
every time we spend anything in the country somebody
ends up paying for it. Superfund is not a direct tax
on private citizens. It's a tax on chemical
manufacturers and other things that don't come directly
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Comment 18:
Response:
out of your pocketbook. Naturally you go out and buy
those things that the chemical manufacturers make and
in turn they charge a certain percentage, and of
course, they charge whatever they think to the
consumer. It's certainly not a tax on the private
citizens directly.
.".
Concerning the amount you mentioned for the removal
effort in 1988. The amount of two million dollars you
mentioned was correct but there were a great deal of
other activities that were also part of this effort~
One hundred and thirty cubic yards of coal-tar wastes
were taken off-site and incinerated but it did not cost
fifteen thousand dollars per cubic yard to eliminate
these wastes. Other activities that were performed
during this effort include: tar-pits were solidified
and metal sheet pilings were utilized to reinforce the
bank of the pits; the North Fork of Mill Creek was
re-routed; two, forty-eight inch culverts were emplaced
in the North Fork of Mill Creek Channel; and a spillway
was built for a flood water overflow.
A PRP commented, "Am I correct in stating that those
buildings sooner or later will have the roofs removed
from them, that they will never be permitted to be used
as an ~ndustrial building, ever again, as we see it
right now? Will the time come that the buildings could
be taken down? Could they be removed from the Site?
Would this'be a disadvantage or would this be an
advantage, to have the buildings removed? When the
,asbestos, if it's eventually -- if that's a route
that's taken, when the asbestos and other contaminants
around the building areas are disposed of, would it
ever be permitted to -- for the buildings to be
demolished. As the owner of those buildings, it's
conceivable that they will deteriorate and one day
someone will trespass, and they will be injured, and I
will be responsible." I've had some offers for the
brick on those buildings. I think they're the most
valuable thing down there that could be taken out. . Do
you anticipate that in the future that those buildings
could be removed" from the Site?"
EPA has identified hazardous substances inside and on
the Primary Site buildings. Hazardous materials
contained inside these buildings will be cleaned up
during the interim action. The visibly friable ACM
will be removed from the small building in front of the
maintenance building, however, additional information
will be obtained and a determination made later
concerning the ACM on all of the other Site buildings.
EPA presently has not identified the need to demolish
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Comment 19:
Response:
Comment 20:
Response:
Comment 21:
tne buildings but are presently remediating hazardous
substances contained inside or on these buildings. EPA
cannot determine at this time whether the Primary Site
buildings will be demolished at a later date.
A PRP commented that they were informed in 1985 or 1986
not to disturb soil near the Primary Site buildings and
that they have honored that request.
Thank you for honoring the EPA request. Any
disturbance of these materials could potentially
mobilize contaminants in the Primary Site soils. Then
heavy rains could potentially transport contaminants
into the North Fork of Mill Creek.
A private citizen commented that all of their family
worked at the Wrigley Plant for years and years. Their
father came into contact with these materials at the
Site frequently for years and he lived to nearly
ninety. Most of the people that worked there are in
their seventies and eighties and, "we are not afraid of
the Wrigley Plant, maybe we should be but we are not.
I feel that the danger has already washed away from
there. These people are talking about their wells and
stuff coming into their wells. If anything was going
to come off of that plant into well water, it would
have already gone into their wells. That's the way I
feel about it. I know y'all are not too interested in
what I'm going to say, and what I am saying. But
that's the way I feel about it. I am not afraid of it,
and I live right in the middle of it. But what ever
you decide to do, we'll go along with anything that you
want to do down there".
EPA is very interested in peoples comments and opinions
concerning our proposed cleanup activities at the
Wrigley Charcoal Site. This is why the Public Comment
Period is provided, to allow time for anyone to commen~
on these proposed activities. The contamination at th,'
Wrigley Charcoal Site is a result of many years of
industrial activities that left a very wide variety of
contaminants at the Site. Many of the contaminants are
toxic and/or carcinogenic, above safe levels, and pose
unacceptable risks. According to the law (CERCLA)
these wastes must be remediated. This is why EPA is
presently cleaning up the Wrigley Site.
A PRP mentioned that they owned the Irrigation Field.
They mentioned that from what they heard the EPA was
going to select Alternative 3. Is Superfund going to
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Response:
Comment 22:
Response
Comment 23:
Response:
Comment 24:
Response:
pay for the expense of putting up a fence, sampling an~
analyses? How much am I supposed to participate as a
property owner?'
The Superfund is a fund that is set up by Congress for
the EPA to utilize in the clean up of hazardous waste
sites. The EPA enforcement program solicits or
encourages PRPs to either participate or to take action
in lieu of the federal government. These PRPs include
people that own or operated the site that caused the
release, people that generated material that is stored
on the site or is causing a release, or people that
transported material to the site, and that material is
causing a release.
The Agency is not after individuals who did not
participate in or had no knowledge of waste material
being on their property. It is recommended that you
talk with the EPA attorney about what you need to do as
far as an individual property owner.
What will the EPA do if contaminants begin to show up
in the wells after work is begun on Alternative 3?
EPA does not believe that the activities concerning
Alternative 3 will cause any off-site contamination in
private wells. As was stated previously, no off-site
contamination in wells has been identified thus far and
the activities suggested as part of the interim action
are mainly surficial. However, EPA will include a
single round of sampling and analyses to be performed
on the six monitoring wells and twelve piezometers at
the Primary Site, residential wells, and springs
following these interim remedial actions. This is
intended to insure that water quality has not been
affected.
What level did you work in?
They worked in level C but did get to a modified level
B when sampling the. Burn-Pit.
Were the people contracted for previous work all from
Georgia? .
For the RI, EPA used Ebasco Services Incorporated. The
contract was issued at headquarters. The contractors
bid for these contracts across the nation. Ebasco was
selected and conducted the work under the REM III and
ARCS IV contracts, but their contract has expired and
they will not be used for future work at our Site.
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COMMENTS ON BEHALF OF THE 'l'BNNBSSEE FARMERS
COOPERATIVE (TFC). A POTENTIALLY RESPONSIBLE PARTY (PRP)
Comment 1.
Response:
USEPA's proposed interim remedial action for Operable
Unit 1 does not consider that the TSD will require
appropriate characterization of wastes prior to
acceptance. The remedial alternative should consider
selection of an appropriate management outlet (e.g.,
resource recovery, land disposal, incineration, etc.)
once appropriate characterizations are completed. The
FS does not support the selection of incineration as an
interim response for Operable Unit 1. Any remedial
action should be conducted only after the target areas
have been characterized for remediation in their
entirety, and at such time a single remedial program
has been developed.
We have evaluated and responded to the need for
appropriate characterization of wastes in order to meet
any requirements for TSD facilities. According to
interim action guidance (9355.3-02FS-3, March 1991),
"interim actions may be taken early to mitigate the
more immediate threats". Also stated is that, "An
RIfFS report is not required for an interim action,
for the purpose of fulfilling the NCP's Administrative
Record requirements, there must be documentation that
supports the rationale for the action". Although the
EPA is not required to have an RIfFS for this action,
we have a recently completed a lengthy RIfFS for the
Wrigley Site.
In addition, a great deal of quantitative documentation
of contaminants at the Wrigley Site has been obtained
in a variety of studies since 1985 (reports such as the
1987 Weston Site Investigation and Tar-Pit Reports, and
site assessments conducted by the State of Tennessee,
1985-1986). Contaminants of concern have been
identified at levels well above safe levels at the
Primary Site and the Storage Basin, while contaminants
of concern have been identified at the Athletic Field
and Irrigation Field in lesser amounts. EPA has only
suggested taking action at the Primary Site and Storage
Basin and taking some additional samples behind the
Athletic Field and at the Irrigation Field in order to
evaluate the need for any future activities at these
locations.
EPA believes that the target areas have been
sufficiently characterized to initiate the proposed
interim action. Section 7.0 in the ROD (Summary of
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Comment 2:
Response:
Site Risks) clearly indicates that levels' of
contaminants that account for pQtential risks, and
contaminant levels are very high for coal-tar related
wastes at the Primary Site and Storage Basin (Samples
from the Storage Basin on 4/26/91 indicated very high
levels of contaminants). Also, the revised FS (Final
FS) has been revised to take factors such as
incineration and stabilization of wastes into account.
The Risk Assessment, though erred on the high side,
contains abundant uncertainties. Frequencies of
exposure are uncertain and were,therefore
unrealistically maximized. For example, it was stated
that "the risk estimates of exposure to contaminants at
the Primary Wrigley Site appear to be reasonable,
realistic estimates." This statement pertains to the
absorption of dust on a windy day and is based on
assumptions containing significant uncertainties. The
USEPA did not document any problems with dust at this
site and did not sample air for particulates. No
actual release was observed. The USEPA should be
required to provide 'a reasoned explanation for the
conclusion that the identified constituents would be
transported via the air route.
It is ,the general rule in risk assessments to estimate
frequencies of exposures and uncertainties. These
parameters that are estimated are utilized as constants
for single calculations, while several calculations can
be made using estimates to present a risk range. Given'
the nature of the voluminous wastes at the Wrigley
Site, and the high levels of PAD, metals, and VOC
contaminants in coal-tar wastes, and elevated levels of
metals in burn-pit wastes, EPA believes that the data
is relevant to conditions at the Wrigley Charcoal Site.
Exposure assumptions which are used in baseline risk
assessments (BRAs) are default values unless there is
more appropriate site specific information available.
. The exposure assumptions used in the Wrigley BRA were
not "unrealistically maximized". Anytime assumptions
are made concerning the risk there is a degree of
. uncertainty related. This does not mean that the
assumptions are therefore unrealistic. .
The exposure assumption to which this comment refers is
amount of soil ingested (100 mg/day) through the oral
pathway during recreational visits to the Site. This
soil ingestion rate is based on a 1989 EPA Directive
(9850.4). This rate accounts for incidental ingestion
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Comment 3 :
Response:
Comment :4
Response:
(i.e. hand-to-mouth contact after exposure to soils).
This incidental soil ingestion rate is further
supported in EPA's Standard Default Exposure Factors
guidance (Directive 9285.6-03) which was released on
March 25, 1991.
In nearly every case, the USEPA states that there are
"major uncertainties" in the risk analysis.
Although there are uncertainties in the risk analysis,
the high levels of contamination at the Primary Site
and the Storage Basin are clearly stated within the
RI/FS. Due to several uncertainties, EPA chose to
perform an interim action ROD. EPA Guidance (OSWER
Directive 9355.3-02 and 9355.3-02FS-3) indicates that
an RI/FS or Risk Assessment is not required to perform
an interim action. However, these documents also
indicate that sufficient documentation (in our case
analytical data) should be presented to support our
actions. EPA has presented overwhelming analytical
data on the high levels of contaminants at the Site,
and indicated which contaminants are above Acceptable
Soil Concentrations (ASCs) or above safe levels.
These data are sufficient to support any interim action
activities or early final activities at the Wrigley
Site.
The most significant risk identified by the USEPA would
be posed to workers during site remediation. It would
seem logical to conclude that security fencing would
provide necessary protection for the site until
Operable Unit 2 can be investigated. In this manner, a
single remedial action (interim or otherwise) for the
site as a whole can be defined. This methodology would
be equally protective of human health and the
environment and would certainly be a more cost
effective use of Superfund expenditures.
Installing a fence at the Primary Site will not reduce
the risks from exposed contaminants in coal-tars, the
burn-pit, or from contaminants contained in waste piles
that are readily accessible to trespassers (casual
viators, etc.). Alternative 2 will do nothing to
prevent ACM materials from becoming airborne or getting
into the North Fork of Mill Creek. The ACM corrugated
roofing sheets that have been torn from the buildings
by storm activity (see response to comment 10) are now
on the ground and have been crushed from hitting the
ground and by other adverse weather conditions.
Off-road vehicles that have been observed
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on the Primary Site run over these materials
periodically. Also trespassers that go around the
front gate and ignore EPA placards and get on to the
southern portion of the Primary Site can agitate these
materials. Installing a security fence will not reduce
risks associated with these materials.
Comment 5:
SPECIFIC COMMENTS to the PIRAP
Response:
USEPA's proposed off-site incineration/stabilization of
the wastes in the Burn Pit (Grease Pit) would be an
inappropriate remedy during Operable Unit 1 activities
since these wastes have not been thoroughly
characterized, their corresponding USEPA waste codes
have not been determined, and since the exposure risks
from these materials should be quite low. While the.
USEPA/ESD Region IV sampling and analysis did not
detect the presence of the 2,3,7,8 TCDD isomer(s) above
the detection limit in this material, other dioxin
isomers were detected. Dioxin treatment standards for
the listed dioxin waste codes F020 - F023 and F026 -
F028 are based on incineration that achieves a 99.9999%
destruction and removal efficiency{40 CFR 268.41).
Although the Burn Pit wastes do not appear to fit these
listed waste code categories, a possibility exists of a
potential lack of available incinerators or that these
wastes may not be accepted by any permitted TSCA
incineration facility. .
EPA disagrees with the statement that3these small
amount of wastes (approximately 15 yd ) have not been
thoroughly characterized. Early in the RI, Ebasco took
a sample for metals/dioxin analyses. The metals
analyses generated high values for metals that were not
found to be anomalous since the burn-pit contains
abundant metals shavings. The initial dioxin values
did appear to be anomalous since these were the only
dioxin values found to be above trace concentrations at
the Wrigley Site. EPA decided to resample the pit and
took 4 composite samples each containing 4 individual
samples on 4/26/91. The pit is small (75x5x3.5) so
this sampling effort evaluated the entire pit top to
bottom. This extensive analytical.effort indicated
that only trace amounts of dioxin reside in the
burn-pit (0.14-12 ppt TEQ, with 0.5-2.0 ppt 2,3,7,8
TCDD dioxin identified).
EPA agrees with the statement that the burn-pit wastes
do not fit the RCRA waste code categories for this
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Comment 6:
Response:
industrial facility, and at present, EPA intends to
excavate, transport, stabilize, and dispose of these
wastes in an approved facility. According to
information requested from Ebasco, it p=esently appears
that EPA will not have any difficulty in remediating or
disposing of these wastes in an approved facility (such
as a TSCA facility).
In light of the findings that current risks of exposure
. ~, these materials in the Burn Pit are apparently
considered quite low or non-existent, it does not seem
appropriate to target these for removal during the
Operable Unit 1 interim activities. It would be
equally protective of human health and the environment
and be more cost effective to incorporate the
remediation of these materials into a one-time
remediation event that could theoretically be conducted
for the entire Primary Site in the future. Th2re has
been no evidence provided that constituents contained
in the Burn Pit will migrate from this area. Any risk
of exposure can be removed through institutional
=ontrols such as barricades and a rigid protective
covering and would be a more appropriate use of
Superfund expenditures during the Operable Unit 1
interim activities, until characterization is
performed. This would be an equally protective and
cost-effective alternative which also would alleviate
the risk identified.
EPA does not believe that it would be more cost
effective to deal with all of these wastes ~n a single
event. Burn-Pit wastes are dissimilar from any other
wastes at the Wrigley Site and would require separate
remedial procedures to eliminate the wastes regardless
of whether these actions are taken now or during the
next operable unit. It appears more stringent
regulations combined with escalating costs would
indicate it would be less cost effective with time.
Further, any potential (redundant) future investigative
costs would add signific~nt costs to a very small
remedial ef:~rt on 15 yd of wastes.
Co.,trary to the statement that,"there is no evidence
tr : these materials do not migrate from the pit",
an,,-ytical data from the RI show elevated levels of
con~aminants directly behind the maintenance Duilding.
This is not surprising since trespassers and vandals
frequentlJ get into the maintenance building and get
into the pit. On several occasions during Site visits,
the RPM, OSC, and Tennessee Division of Superfund
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Comment 7:
Response:
Representative noted recently dumped Site equipment in
the pit and materials thrown from inside the pit onto
the concrete floor in the maintenance building.
Barricades and placards will not keep anyone out of
this area. Presently trespassers ignore the placards
on the Site gates and the buildings, including the
maintenance building. EPA believes that given the
previously stated Site conditions, there is presently
ample justification to remove these small amount of
wastes.
USEPA has not adequately established that risks to
human health or the environment are currently posed by
the Storage Basin (see page 1-61 of the Ebasco
Feasibility Study) because "risk-based calculations
contain appreciable uncertainty and should only be used
for qualitative assessments". The FS goes on to state
that "migration of these contaminants into the ground
water, surface water, and air should be evaluated prior
to quantification of risks associated with these
contaminants."
BPA determined in early 1991 that the preliminary data
and associated risk calculations based on these data,
as acquired and generated respectively by Ebasco did
not sufficiently characterize this area. Therefore,
BPA conducted a sampling effort at this location to
locate and characterize coal-tar contaminants that were
suspected to reside in the deeper sediments of the
Storage Basin. Although risk assessment data can be
important, exceedingly high contaminant levels cannot
be ignored. The very high levels of contaminants found
in the sludge samples taken in the deeper sediments are
above ASCs for many contaminants of concern.
Samples of the deep sediments identified 20 organic
compounds and 9 metals. Contaminants in these
sediments consisted of: semi-volatile compounds (74,032
ppm including phenols at 26,700 ppm), metals (6025
ppm), VOCs (610 ppm). The ASC for carcinogenic PABs as
reported in the RI is 8.17 ppm, for non-carcinogenic
PABs is 34,600 ppm, and for phenols .is 100. Due to the
high level of PABs and phenols in the Storage Basin
sediments, BPA has determined that this location also
poses a risk to human health and the environment.
There is no doubt that the coal-tar sludges located in
the Storage Basin sediments are so far, the most highly
concentrated (contaminant-rich) wastes at the Wrigley
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Comment 8:
Response:
Charcoal Site. Therefore, these wastes will be left
undisturbed in this remote location until future
investigative work can fully evaluate this area. EPA's
planned investigative work is consistent with comments
of the PRP as mentioned in comment 7.
It is not specified in the USEPA Proposed Interim
Remedial Action Plan (PIRAP) how USEPA intends to
stabilize the materials in the Storage Basin without
compromising future remedial actions. The soil mixing
stabilization method identified as appropriate by
Ebasco in the FS (pages 4-19 and 4-20) does not account
for the potential lateral flow of perched ground water
or leachate through the disturbed sediments. This
potential migration process could cause degradation of
ground-water quality if the sediments are disturbed in
this manner thereby compromising the effectiveness of
this proposed interim remedy. Based on the minimal
findings presented in the RI and FS, it does not appear
to be technically appropriate or cost effective to
include the proposed invasive/intrusive activities for
the Storage Basin as an Operable Unit 1 interim
remedial action item. Also as stated in the FS, the
Storage Basin sediments are to be capped after
stabilization. There has been no indication that
constituents are leaching from the Storage Basin based
on ground-water sampling. A more technically
appropriate and cost-effective interim remedy would be
to utilize institutional controls - such as fencing
rather than the proposed stabilization and capping.
Activities identified in the Proposed Plan for the
Storage Basin have been changed. At present,
disturbing these wastes may cause additional problems
at this location. For example, building a road to this
location (up the steep hill above the North Fork of
Mill Creek) will be costly, and provide easier access
to this location. In affect this would attract more
attention in this area. Stabilization of Storage Basin
wastes is justified, but only if this stabilization
effort can be accomplished without adversely affecting
the Storage Basin area. EPA has further evaluated this
activity and determined that the area should be fenced
and future investigative efforts initiated to determine
exact volume of contaminants and their impact on the
subsurface and adjacent Clark Hollow. EPA agrees with
the PRP concerning Storage Basin activities and are
reassured that the PRPwill support future
investigative efforts necessary to completely
characterize the Site.
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Comment 9:
Response:
The comment incorrectly states that findings at the
Storage Basin set forth in the RIfFS are minimal. As
stated in the response to comment 7, the sampling data
obtained on 4/26/91 reveals very high levels of PARs,
metals, and VOCs in the deeper sediments of the Storage
Basin.
Risks associated with the surface wastes/debris pile
have not been defined, with the possible exception of
asbestos. Most, if not all, of the these materials
have not been characterized for removal/disposal. Much
of the, material may be recyclable or reclaimable. The
tar cubes and transformer materials are either
uncharacterized or not fully characterized for
disposal. All of the asbestos-containing materials
appear to be non-friable corrugated transite or sheet
transite based on the description in the FS on page
1-27 and should pose no risk to workers or the
surrounding population. USEPA's recommendation of
these ACMs is based on presumed risk. It would appear
that the waste/debris piles were included within the
proposed Operable Unit 1 interim activities purely for
aesthetic reasons. Screening and segregation of the
surficial waste and debris piles would be a more
technicallyappropriat~ and cost-effective use of
Superfund expenditures during the Operable Unit 1
interim activities until the appropriate
characterizations have been made.
Information pertaining to the exact contents of the
wastes/debris piles has not been obtained. In order
for EPA to obtain this information, it will be
necessary to sort through these large waste piles and
identify all contents. For materials such as the ACM
and the tar-cubes, we have sufficient information to
warrant interim action activities. The ACM will be
removed from the piles, transported, and disposed of in
an asbestos landfill. The tar-cube waste
characterization for disposal data obtained in April of
1991, identified elevated levels of compounds in the
tar-cubes (coal-tar derivatives). This information did
register a cumulative total of 10 tentatively,'
identified compounds that yielded 920 ppm. It is likely
that these are PAR compounds. Although the tar-cubes
appear to vary in composition from the coal-tar, the
cubes pose a potential risk since they are composed of
pure tar which is primarily PAR constituents., Also,
these cubes melt in the summer and potentially can
migrate into the North Fork of Mill Creek~
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Comment 10:
Response:
Elimination of the waste/debris piles at the southern
portion of the Primary Site is not for esthetic
reasons. Some of the more significant levels of
contaminants of concern have been identified between
the still house foundation and the raw liquor storage
tank foundation. It is in this area that the majority
of the large waste/debris piles are located. It would
be impossible to take representative samples in the
subsurface if wastes from piles are migrating towards
EPA wellbores. Also, no future wells can be installed
at several strategic locations at the southern portion
of the Primary Site as long as the large waste piles
remain.
EPA will sort the wastes/pile constituents and
consolidate materials such as tar-cubes and metallic
debris in an on-site consolidation area. These actions
are cost effective use of Superfund expenditures and
will serve to alleviate the waste/debris problems at
the southern portion of the Primary Site.
There is no justification (technical, regulatory or
otherwise) for the removal and disposal of non-friable
asbestos from the site buildings or elsewhere from the
site. It is generally accepted by the technical
community that little or no risk is posed to a
population by such non-friable ACMs. Based on review
of the RI and FS for the site and the proposed interim
remedy for Operable Unit 1, the determination has not
been made as to whether the asbestos is friable vs.
non-friable. Any interim remedial action for the
remaining ACMs is based on presumed risk and would be
performed for aesthetic reasons. It should be noted,
based on two recent court decisions, that, under
circumstances, asbestos abatement costs may not be
recoverable under Section 107 of CERCLA even when the
asbestos has fallen from the building structure and no
longer serves its intended use (3550 Stevens Creek
Associates vs. Barclays Bank of California and
California Dept. of General Services vs. Blech). In
both the Stevens Creek and Calif. Dept of General
Services cases the courts found that Congress never
intended CERCLA to create a cause of action for
asbestos removal from commercial buildings. It is not
appropriate to include these ACMs as an interim
remedial action item during Operable Unit 1.
We have eliminated any remedial activities concerning
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Comment 11:
Response:
ACM that presently appears to be non-friable.
Subsequent investigative activity and analyses will
determine the exact state of this material. However,
broken sheets of ACM that have been previously torn
from the buildings by storm activity are friable.
Pieces of this material are scattered throughout the
southern portion of the Primary Site. There is no
technical or logical basis to call this material
non-friable since these once large roofing sheets of
asbestos have been crushed by weathering processes and
vehicular traffic (off-road vehicles, etc., as
witnessed by the the RPM and OSC during the April 26,
1991 sampling event). Further, trespassers that may
walk on-site may easily agitate this material as it is
loose throughout the southern portion of the Primary
Site. It is relevant to point out that if storm
activity can lift these roofing $heets of ACM from the'
buildings and it is highly probable that occasional
windy conditions mobilize crushed ACM particulates.
Also, heavy rainfall events mobilize ACM which flow by
way of surface waters to the North Fork of Mill Creek.
Based on this information, EPA believes that the broken
sheets of ACM on the ground at the southern portion of
the Primary Site pose a significant threat to human
health and the environment and recommend that all
friable ACM on the ground, as well as the visibly
friable ACM on the small building in front of the
maintenance building be removed to an'asbestos landfill
for disposal.
Process Tank contents on the Primary Site have not been
adequately characterized for USEPA's proposed
disposal. The indicated presence of dioxins in these
wastes may prevent off-site incineration. It would be
more appropriate to secure the tank and make the
necessary characterizations for disposal. Also, after
the tanks have been decontaminated, the steel should be
reclaimed as steel scrap, not disposed in a landfill.
The language in Section 121(b)1 of CERCLA makes clear
that "the President, shall select a remedial action...
that utilizes resource recovery technologies to the
maximum extent possible."
Samples have been taken from the process tanks with the
following information generated. A total of 16 organic
and 5 inorganic constituents were identified.
Contaminants consisted of: phenols (20,000 ppm), total
PABs (737 ppm)-including carcinogenic PABs (359 ppm) ,
VOCs (1750 ppm) , copper (2,400 ppm) , lead (340 ppm) ,
nickel (110 ppm) , zinc (110 ppm) , and barium (50 ppm).
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Comment 12:
Response:
C -y trace amounts of dioxin were noted (0.31-46 ppt
TEQ with no 2,3,7,8 TCDD dioxin detected). These trace
levels of dioxin were extremely low, no where near the
1000 ppt dioxin Toxicity Equivalent (TEQ) required to
take any acticC'. on this waste. However, the high
levels of phenols, carcinogenic PABs, and VOCs make the
process tank wastes a potential risk by way of dermal
contact or inhalation to human health. Wastes are
potential r~sks to the environment since they are
adjacent to the North Fork of Mill Creek and
periodically leak from the process tanks. EPA believes
that these wastes have been characterized sufficiently
to support the selected remedial alternative and
initiate remedial action.
Instead of disposing of the tanks in an EPA approved
RCRA facility, EPA will reclaim the steel tanks as
scrap in accordance wita CERCLA 121(b)1 and the
President.
The discolored soils adjacent to the Process Tank (page
1-25 of the Ebasco FS) have not been adequately
characterized with respect to health risks or for
disposal options. In light of these inadequacies, site
institutional controls, such as barricades or fencing,
would be a more technically appropriate Operable Unit 1
interim activity until characterization could be
conducted. In doing so, it would allow for a more cost
effective, one-time remedy of the site, which would
appear to be equally as protective of human health and
the enviro'-ant.
Given the composition of the process tank wastes, and
that these wastes have been observed by EPA (4/26/91)
leaking from the tanks, it is highly improbable that
the wastes become ncn-hazardous as they drop to the
ground and migrate down the hill approximately 50 feet
into the North Fork of Mill Creek. EPA guidance (OSWER
Directive 9355.3-02 and 9355.3-02FS-3) clearly states
that EPA may, "take quick action to protect human
health and the environment from an imminent threat in
the short-term while a final remedial solution is beLng
developed; or institute temporary measures to stabilize
the site or operable unit and/or prevent further
migration or degradation."
order to be protective of human health and the
environment, it is necessary to remove the tanks,
associated waste sludges in the tanks, and associated
wastes on the ground. Implementing barricades or
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Comment 13:
Response:
fencing would not remove or lessen the threat from
these wastes. In addition, it would not be cost
effective to perform more investigative work on
surficial wastes at this location due to the direct
(visually observed) correlation of the wastes in the
tank to the wastes on the ground. We agree that
additional investigative work (subsurface
investigations) should be initiated at the Site,
however, it is likely that between now and the future
remedial action takes place, these wastes will be
accessible to anyone that walks the steep hill adjacent
to the North Fork of Mill Creek, and wastes will
continue to migrate into the Creek.
The recent failure of the Storage Basin spillway
(constructed in 1988 by USEPA during an earlier removal
action) may have been the result of improper '
engineering design. Recent precipitation events caused
washout of the spillway area and have presumably
exposed site-related constituents in the older,
underlying sediments. The replacement of ,the rip-rap
in the spillway may not be the best engineering control
at this time in light of this recent earth failure. It
was stated inconclusively in the FS that these
constituents originated from the Tar pit area based on
aerial photographs. When considering the lack of
characterization of these materials and sketchy
information regarding their nature, USEPA's proposed
interim remedy of excavation and incineration is
unsupported and would not be appropriate for an interim
remedial action item for Operable Unit 1.
According to Brad Martin (Hickman County, Times), the
Memorial Day flooding event was the largest single
rainfall event in decades. Approximately 14 inches of
rain fell in a 24 hour period. Not only did EPA's
spillway encounter damage, but roads both above and
below the Primary Site were washed out. The location
. of the spillway is particularly bad since several
smaller unnamed tributaries intersect close to this
location. Given these conditions, and comments from
the State of Tennessees' Division of. Superfund, EPA
intends to re-engineer this spillway to accommodate the
significant floodwaters that frequent this area (also,
much larger riprap will be utilized). In order to
accommodate these waters, the spillway will need to be
excavated to the creek grade with coal-tar contaminants
excavated, transported, incinerated, and disposed of in
an approved EPA facility. '
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The wastes in the spillway are presently adjacent to
tar-pits. Regardless of the Ebasco statement in the FS
concerning the EPIC photos, EPA thoroughly examined the
1990 EPIC photos as well as photos from other sources
such as the 1987 Weston Report conducted for the State
of Tennessee. It is EPA's determination that the
tar-pit extended out (northeast) past the present
position of the North Fork of Mill Creek. According to
previous photos and historical information, this
corresponds to the present location of the spillway.
The large tar-pits were not the only industrial waste
area in this vicinity, there were also neutralization
pits that likely received raw coal-tar contaminated
wastes prior to dumping directly into the North Fork of
Mill Creek or pumping to either the tar-pits, Storage
Basin, or Irrigation Field. EPA has sufficient data on
coal-tar wastes in the vicinity of the tar-pits to
warrant remedial action. As stated previously, interim
remedial measures are intended to take quick action to
protect human health and the environment from an
imminent threat in the short-term and/or to stabilize
conditions to prevent further migration or
degradation. If interim remedial actions are not taken
in the spillway, more of these coal-tar wastes will
become exposed. The threat from dermal contact,
incidental ingestion, or inhalation of waste
particulates or vapors could present an increasingly
significant threat if action is not initiated.
PRP CONCLUSIONS
The most applicable interim action items for operable
unit 1 (Primary Site, Storage Basin, and Irrigation
Field Lagoon) are deed restrictions and institutional
controls, such as fencing, barricades, protective
coverings and placarding. The USEPA appears to have
misapplied criteria and data in arriving at conclusions
and in calculating the immediate and/or long term risks
associated with the site. This resulted in exaggerated
immediate health risks and potential environmental
impacts associated with exposure to the constituents at
the site. Furthermore, based on these apparent
incorrect conclusions, the USEPA has proposed an
inappropriate interim remedy which is unsupported by
the data compiled at the site. To elect to conduct
significant remedial action when the risk associated
with the site is either uncertain or non-existent in
illogical and technically incorrect. Therefore, USEPA
Alternative 2 would be the most appropriate selection
for interim remedy at the Wrigley Charcoal Site.
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Response:
In conclusion, any remedial action that would be
conceivably conducted should be conducted only after
the site has been characterized in its entirety, and at
such time a single remedial program is developed. An
interim remedial action for a single Operable Unit
should only respond to imminent risks to human health
and the environment and not propose excessive actions
for inconclusively defined risks.
EPA disagrees with the conclusions submitted in behalf
of the Tennessee Farmers Cooperative. EPA has applied
interim criteria accordingly and activities presented
are intended to be protective of human health and the
environment. Institutional controls and Site access
controls do not reduce the threats from readily
accessible, high levels of ph~nols, PABs, VOCs, and
metals, in contaminated materials identified for
cleanup as part of this interim action and does not
meet ARARs. Also Alternative 2 does not remediate
broken, crushed, or friable ACM that becomes
airborne.
Given the abundant information on coal-tar wastes at
the Wrigley Charcoai Site, EPA believes that.
conclusions drawn in the interim action ROD are
realistic and reasonably supported. EPA believes that
the conclusions drawn in behalf of the Tennessee
Farmers Cooperative are not reasonable, and their
recommended alternative (Alternative 2) will fail to
meet ARARs. Alternative 2 will not reduce toxicity,
mobility, or volume of readily accessible on-site
contaminants and will not be protective of human health
and the environment. It is therefore, illogical and
technically incorrect for Alternative 2 to be selected.
EPA has elected to implement Alternative 3 which will
meet all ARARs and will be protective of human health
and the environment. Contaminant level information
required to support interim actions or early final
actions on coal-tar wastes, burn-pit wastes, and ACM is
presented in the RIfFS. Interim action guidance
previously referenced. indicates that .a baseline risk
assessment does not have to support these interim
activities, and that more specific findings should be
included as part of subsequent investigations or
actions. However,.it should be noted that the baseline
risk assessment for the Wrigley Charcoal Site does
indicate that coal-tar associated wastes and burn~pit
wastes contain contaminants of concern that are above
acceptable levels. It is therefore appropriate to
-78-
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select Alternative 3 since it best satisfies the CERCLA
requirements (nine criteria).
12.4
Comments Durinq Meetinq With Local Officials at City
Hall, Centerville, Tennessee, July 25, 1991
In attendance:
1) Kenneth Wright (Mayor of Centerville)
~) James Coates (County Executive)
3) Harold Taylor (Chief, Kentucky/Tennessee Section, EPA)
4) Douglas Bell (Remedial Project Manager, KY/TN Section, EPA)
5) Suzanne Durham (Community Rel. Coord., KY/TN Section, EPA)
Comment 1:
Response:
Comment 2:
Response:
Comment 3:
Response:
Comment 4:
Response:
There was not much public interest in the Site but Brad
Martin of the Hickman County Times had run several
articles which is keeping the citizens informed.
Brad Martin has contacted the EPA and has been kept
up-to-date with EPA investigations and activities.
Was the groundwater monitored at the Site?
Both monitoring wells and piezometers were installed at
the Primary Site. Also, off-site residential wells and
springs were sampled within a one mile radiu& of the
Site.
Does EPA have any idea how much it will cost to clean
up the Wrigley Charcoal Site?
At present, EPA does not know how much the final
cleanup cost will be for the wrigley Charcoal Site. It
is presently estimated that the initial cleanup phase
(interim action) will cost approximately $1,000,000.
This action will address surficial wastes and the most
imminent and substantial threats to human health and
the environment at the Site. Subsequent investigations
will likely be required to further characterize other
areas of coal-tar wastes (such as the Storage Basin)
that will be remediated during as part of later
remedial activities. It is likely that these future
remedial activities will be costly since they will
eliminate large amounts of coal-tar wastes and
contaminated soils.
Are there any drums at the Site?
Where are they?
We at present, have identified fourteen drums at the
Primary Site that contain hazardous substances. The
remediation of these drums and the elimination of
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Comment 5.:
Response:
Comment 6:
Response:
Comment 7:
Response:
Comment 8:
Response:
Comment 9:
drummed wastes has been included as part of the interlm
action ROD.
Does EPA have a list of dangerous chemicals and does
EPA know whether or not these chemicals will affect the
people down there?
The EPA has just completed an RIfFS for the Wrigley
site and the state of Tennessee finished a study in
1987 that identified a wide variety of contaminants
contained at the four separate Wrigley Charcoal Site
areas. The contaminants are mainly: polycyclic
aromatic hydrocarbons (PABs), metals, volatile organic
compounds (VOCs), and asbestos containing material
(ACM) as roofing on Primary Site buildings.
At present, no adverse health effects have been .
. documented at the Wrigley Site, however, toxicological
data for these substances suggests that many are
carcinogenic and pose long-term risks for casual
visitors such as trespassers.
Is the water intake above or below the Site?
The Bon Aqua-Lyles water intake has been moved upstream
on Mill Creek. . This location is above the confluence
of the North Fork of Mill Creek and Mill Creek and will
not be affected from any adverse conditions from the
Primary Site.
What did EPA find at the ballfield?
The infield area of the ballfield was sampled in 1990
and the area behind the outfield fence was sampled in
1989. This data suggests that contaminants occur below
levels of concern in the surface soils in the infield.
However, one sample behind the outfield fence did show
elevated levels of metals such as lead. These levels
were just below the threshold level of concern.
Additional samples will be taken at this area to the
garden (approximately 100 feet southeast) to evaluate.
the need for remedial activities at this location.
Can kids play at the ballfield?
At the present time, EPA does not feel that the
ballfield poses a significant health risk.
Who owns the ballfield?
-80-
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Response:
Comment 10:
Response:
Comment 11:
Response:
Comment 12:
Response:
Comment 13:
Response:
Comment 14:
Response:
At the present time, information EPA has received from
the TFC suggests that they own the ballfield.
Did the Co-op. donate the ballfield to the recreation
association?
The EPA does not have any information that suggests
that this is true. This will have to be investigated
further.
How did we notify the public of the Public Meeting?
The public was notified by a public notice that was
published in the Hickman County Times on July 15, 1991
and also by the article by Brad Martin that appeared in
the Hickman County Times on July 22, 1991.
Could any of the materials at the Wrigley Charcoal Site
be sold for fuel?
Although much of the coal-tar wastes could potentially
be used as a fuel, it presently appears that it would
not be worth the risk for individuals or companies to
acquire these wastes and assume the risks and
liabilities associated with transporting, storinq, and
incinerating hazardous substances from this EPA
Superfund site.
What were the tar-pits used for?
Wastes that resulted from the retorting of hardwoods
for charcoal production were further refined in the
still house. The coal-tar fractions with the highest
amounts of impurities that could not be made into
tar-cubes, ended up in the large tar-pits adjacent to
the Primary Site. Later (after the mid-1950's) the
coal-tar wastes (still bottoms) were pumped to the
Storage Basin for containment and subsequent spraying
of wastes over slag piles, and also to the Irrigation
Field for storage in the lagoon and subsequent spraying
over the field to biologically degrade contaminants.
Tar-pit wastes have also been identified in the Storage
Basin but have yet to be identified in the Irrigation
Field lagoon.
If these materials were ignited, would they continue to
burn?
The tar-pit materials have been stabilized (solidified)
with sawdust but would likely burn. The coal-tar
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Comment 15:
Response:
wastes at the Storage Basin are more likely to burn
since they have not been stabilized. However, the
Storage Basin coal-tars are under 1-5 feet of water and
are well protected from ignition sources, and the
tar-pits are under a thin cap of clay which serves to
isolate the wastes.
Does-vegetation grow on the Irrigation Field?
At the present time, the Irrigation Field is covered
with vegetation. The majority of the Field is covered
with brush and small trees while the abandoned lagoon
has larger trees. '.
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12.5. Written Comments Received Durinq the Public Comment Period
and BPA's ResDonses to These Comments:
It should be noted that there were no written comments from private
citizens concerning the EPA proposed interim remedial activities at
the Wrigley Charcoal Site. Comment letters included in this section
are from: 1) the State of Tennessee; 2) the Tennessee Historical
Commission; and 3) and the u.S. Department of the Interior (Fish and
Wildlife Service). Response Letters from the EPA are also included
in this section.
-83-
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2.
STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
July 3 1, 1991
Mr. Harold Taylor
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
RE: Wrigley Charcoal Superfund
Site 41-504
Dear Mr. Taylor,
The following comments concerning the draft ROD are being submitted
following revie'~ by personnel from the Tennessee Division of
Superfund (Division). The main thrust of these comments is to focus
only on those areas where defined hazardous substances exist and
are deemed to require proper remediation. .We have eliminated
concern from those items that are considered more "ho~sekeeping"
in nature. These comments are presented on an item by item basis:
1.
The Burn Pit. The Division is not in agreement with EPA
concerning this area. The latest round of analytical results
indicates that no significant contamination exists, therefore
expending funds for remediation is not justified. ""'It is
suggested that from a standpoint of usability and any direct
contact concerns that might exist, the burned and unburned
transformers in any locality on the site could be deposited
in the pit and then capped with concrete to the existing floor
level. This would mitigate the direct contact potential and
prevent infil tra.tion into the pit potentially. impacting
groundwater with metals or other residual organics that might
exist. .
The Storaae Basin. The Division is not in agreement concerning
the proposal for this area. EPA has suggested a stabilization
measure !nvol v!ng mixing the coal tar der! vat! ves on the
bottom of the pond with saw dust and then capping. The
Division does not consider the known conditions in this area
significant enough to warrant this type of action. There are
several reasons as follows: .
A. .
The underlying geology is not very well understood.
Therefore it is not certain if disturbing the pond
sediments would exacerbate the problem or not. The area
is known to be karst and could potentially be
destabilized.
...~.
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B. Presently, it is not believed that the storage basin is
causing significant groundwater problems/ based on
several roui.ds of residential well sampling. Disturbing
the area coi.ld potentially alter this.
C. Currently, the area is not a high traffic area due to
difficult access conditions. Creating a new road to
access the area could potentially generate interest in
the area by local citizens causing greater potential for
direct contact exposure.
D. Since stabilization was to only be a temporary measure
followed up with removal, treatment or incineration
within two years, this expensive stabilization measure
seems unwarranted particularly since the waste has been
in it's present locality for 40 or so years.
E. The stabilization could potentially double the quantity
of waste to be dealt with in the future making
remediation more expensive.
The Division is in agreement that the storage basin and/or the
overflow basin should be fenced to discourage direct contact
with the ponds and left until other coal tar derivatives are
remediated on the site. It is also suggested that the storage
pond be dewatered lowering the head and reducing the potential
of groundwater migration.
3. The Site Surface Waste/Debris Piles. The Division is in
agreement with EPA that aspects of this material need to be
addressed in an interim measure. However, our concern is
primarily with the hazardous materials in these localities.
Such items as the tar cubes, friable asbestos materials, and
metals that are potentially leachable. It is our contention
that some of 'the debris/waste could be staged in a more
organized/controlled manner without expensive disposal
offsite.
4. The Asbestos Corrugated Roofing Material. The Division is not
in agreement with EPA concerning removal of this material.
There are several items of concern that support this opinion
which are as follows:
A. The definition of friable is not consistent between the
two agencies. To the Division most of the material is not
considered friable due to the concrete content which
makes it very durable. EPA needs to define friable.
B. Most of the asbestos roofing material is still very much
intact on the buildings and not releasing fibers to the
atmosphere. This is particularly true with the limited
amount of traffic through the site.
-------
C. The cost is prohibitive considering the impact that it
is currently considered to be having.
D. With the roofing intact the buildings have potential
value as work zones during future remedial activities at
the site. It is suggested that PRP's should be involved
in funding activities such as this.
The Division is in agreement that any roofing material that
is known to be releasing fibers to the air on the ground
should be removed.
5. The Process Tanks. The Division is in agreement with EPA that
the process tanks and any residual tar stained soils should
be removed.
6. The Spillway Area. The Division does not completely agree with
EPA concerning this area. Although we do agree that any
contaminated tars, charcoal fragments, and lifts of slag etc.
that generate leachate should be excavated, we propose further
excavation of the spillway to bring it to the existing creek
grade reducing the threat of future erosion. It is
recommended that the original creek channel be opened (ie.
remove the two 48-inch culverts that are not able to channel
the creek flow at flood stage). The spillway could then be
excavated down to the existing creek grade thus widening the
channel. This is suppcrtad by the fact that the sheet pilings
are sufficient to retain the bank holding up the tar pits and
thus if the culverts were removed the creek would not be as
erosive. There appears to be sufficient material (ie. rip-rap)
that has washed down the creek that could be used to reline
the altered creek channel and with removal of contaminated
material the greatest cost would probably be labor and
equipment and not materials.
7; Deed Restrictions and Institutional Controls. The Division
agrees with this proposal. This is particularly true since
several surrounding property owners are trying to sell their
properties.
8. Irrigation Field. The Division does not agree with EPA about
putting a fence around the small pond in this area. The pond
is very overgrown at present and not very accessible. It is
thought that if cleared out to install a fence then it would
be subsequently more accessible and draw attention to the
area creating a greater potential for direct contact exposure.
The Division is recommending the above comments with respect to the
cost share that the State of Tennessee is required to make. The
Division would prefer to allocate funds to actual source removal
measures. Funding for such a project as the clean up of the Wrigley
Charcoal site has been planned for, however, these funds are
limited and the Division therefore wants to prioritize funding for
actual site clean up.
-------
The Division is in agreement wi~h EPA that further sampling and
groundwater investigation is warranted at the site. This should
include some residential well sc~pling at some point during the
remediation. Also it was noticed :hat in the foundation of the old
Dryer building there were several areas where tar was oozing up to
the surface during very hot days. These areas should be considered
for interim action as well.
The above comments are being offered for consideration in altering
the Draft ROD. If necessary we are willing to meet with you and
discuss any differences that may exist. If you have any questions
concerning this response please call me at (615) 741-6287.
Sincerely yours,
p~ l.-. ~. S ~ ",.J2a.:R..
Ralph M Sinclair, Ph.D
Director, Division of Superfund
.
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,, •:%
"*7 ? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
i r ^
lto^ REGION IV
345 COURTLAND STREET. N.E. •
ATLANTA. GEORGIA 3O36S
August 19, 1991
Ralph M. Sinclair, Ph.D., Director
Division of Superfund
Tennessee Dept. of Environment and Conservation
706 Church Street, Suite 200
Nashville, Tennessee 37243-1358
RE: Response to State of Tennessee Comments on the Proposed Plan for
the Wriolev Charcoal Site, Wriglev, Tennessee
Dear Dr. Sinclair:
Thank you for your prompt responses concerning the proposed interim
remedial activities at the Wrigley Charcoal Site. We greatly
appreciate the Division of Superfund's interest in pursuing
remediation of this Site.
We are in agreement with the majority of your comments and are in the
process of modifying the feasibility study and draft Record of
Decision (ROD) to reflect those concerns. Fortunately, we were lucky
enough to have Mess'r. David Randolph, Bob Powell, and Dan Roop to
discuss Tennessee's comments with during a site visit on July 26th.
Although we intend to transmit to you the draft ROD and Final
Feasibility Study very shortly, we wanted to briefly respond to
Tennessee's concerns by way of this letter and alert you to any
technical differences which need to be resolved before a final ROD is
signed. Our comments on your concerns are presented on an item by
item basis:
1) The Burn-Pit: We agree with Tennessee that the burn-pit does not
appear to have any significant organic contamination (dioxins or
PCBs). However, the concentrations of metals, particularly lead,
is of concern to us. Samples collected during the RI showed lead
concentrations in the waste up to 1600 ppm. This lead level is
well above recommended soil lead level of 1000 ppm for soil in
residential areas. Also, soils may contribute to contamination
of groundwater. Therefore, it is our recommendation to remove
this waste material and dispose of it properly at an approved
off-site facility. The cost of disposal for the estimated twenty
cubic yards of material should be minimal.
Printed on Recycled Pacer
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2) The Storage Basin; We accept your proposal and are modifying our
approach accordingly.
3) The Primary Site Surface Waste/Debris Piles; Ditto of above.
4) The Asbestos Corrugated Roofing Material; Because this is an
interim action, and is not final, we will agree to leave the bulk
of the non-damaged asbestos containing roofing materials (ACM)
for the present. We will propose removing the ACM that :.re
presently on the ground, in waste/debris piles or friable on the
small building in front of the maintenance building. We will
defer a final decision about the ACM until additional laboratory
analyses or. soils and roofing materials, and on-site asbestos
monitoring can be conducted to better define the potential
problem with asbestos.
5) The Process Tanks; We are in agreement on this element.
6) The Spillway Area; We are in agreement with the majority ; your
concerns, but feel that a buffer zone or deflection will be
needed adjacent to the tar-pits to prevent further erosion. We
are presently estimating the costs of these activities.
7) De j Restrictions and Institutional Controls; We are in agreement
on this element.
8) Irrigation Field; We are in agreement on the element. It may be
productive to do sor? minor exploration in this area during the
interim action to assure that no deeper contaminates are present.
As we have discussed previously, we are in the process of drafting
the ROD and will get the draft to you as soon as Dossiblc- In the
meantime, should you or your staff wish to discuss these comments,
please feel free to contact me or Doug Bell at (404) 347-7791.
Ha/old" W. Taylo/^Jr^/Chief
Kentucky/Tennessee Remedial Section
North Superfund Remedial Branch
Waste Management Division
cc: Doug Bell
Suzanne Rubini
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T::.JNESSEE HISTORICAL COMMISSic-N
:.:- =~C.~.:'A';":(
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Suz~~~e
:ur~a:n
=:?A-!\;:GIC:1 :V
345 Ccu~~!and Strg~~.. ~E
Aclar.c3. GeQrgia 30365
Re:
E?A. ~~IGLEY C~RCOAL I~A. ~~IGL~;. ?IC~,~~ COu~TY.
De~r '\!$. Durham:
Tb.; ~bove-re:=renc~d unde;':GL.~i:l~ ::~S :e-=~ r~t..:o:.::¥ed ~i:~ ::'eg=.:-: :';i1:~~~~:
HistJ.ic Preservation Act c~m9Iia~c~ ~j :je ~ar~i=ipati~g f~der~: ag~~cy':: ::3
designated representative. Procedu:~s f:r i~plementing S~cticn loa o~ t~e Ac: are
codified at 36 eFR 800 (51 FR31::'5. September 2, 1986).
In order to. complete our revie!~ of this undertaking, t~is office will ne~c: !C
receive from you a detailed and clearly marked CSGS auad ~aD indicating the ex~::
location of each specific project activity and a clear project narrative
Upon receipt of the additional information. we will complete our review of this
undertaking as expeditiously as possible. Until such time as this office has
rendered a final comment on this project. your Section 106 obligation has not
been met. Questions and comments may be directed to Joe Garrison (6l5)742-6i20.
Your cooperation is appreciated.
S~t~
Herbert L. Harper
Executive Director and
Deputy State Historic
Preservation Officer
HLH: jyg
-------
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UNITED ST ATES ENVIRONMENT AL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
August 8, 1991
Mr. Herbert L. Harper
Tennessee Historical Commission
701 Broadway
Department of Conservation
Nashville, TN 37243-0442
Dear Mr. Harper:
This letter is in response to your recent letter dated July 17,
1991. We have recently mailed to Mr. Joe Garrison of your
agency the Proposed plan Fact Sheet describing all activities
concerning the Interim Action (Operable Unit 1) proposed to take
place at the Wrigley Charcoal Site. We have also made several
attempts to contact Mr. Garrison by phone to discuss our
proposed activities, however, our calls have not been returned.
The Historic Structures I have discussed previously with Mr.
Garrison (in April) are the Mansion adjacent to the Primary
Industrial Site (referred to as the Primary Site) and the old
smoke stack in the middle of the Primary Site. None of the
proposed activities for the Interim Action would affect or
impact either of these structures.
Per your request, we do not have a USGS Quad map that reveals
any relevant detail for the structures in question. However, we
will send you copies of an Army Corps. of Engineers map that we
use for a detailed basemap. Additional information on the
Wrigley Charcoal Site can be obtained in the Repository located
at the Hickman County Memorial Library on West Swan Street in
Centervi~le, Tennessee. All 14 volumes of our studies, aerial
photos, and correspondence can be viewed at this location.
Also, Mr. Bob Powell (Superfund State Representative) located in
Nashville will be able to answer any questions you may have and
he also has copies of the same information that is located in
the Repository. He can be reached at (615) 741-5940.
The Proposed Plan Fact Sheet that was sent to Mr. Garrison
contains a summary of all proposed activities and serves as a
project narrative.
PrInted on Reoced Paper
-------
We are aware of our Section 106 commitment and.feel that we have
made reasonable attempts to contact the Tennessee Historical
Commission concerning our plans at the Wrigley Charcoal Site.
If there are any future problems'with communication, I suggest
that you contact me directly for any additional information or
assistance at (404) 347-7791.
Sincerely,
L?~ ~. /~
Douglas A. Bell, P.G.
Remedial Project Manager
KY/TN Remedial Section
North Superfund Remedial Branch
Waste Management Division
..
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TENNESSEE HISTORICAL COMMISSION
701 BROADWAY
DEPARTMENT OF CONSERVATION
NASHVillE. TENNESSEE 37243-0442
6151742-6716
August 13. 1991
Suzanne Durham
EPA-REGIO~ IV
345 Courtland Street. ~E
Atlanta. Georgia 30365
Re: EPA. WRIGLEY CHARCOAL IRA. WRIGLEY. HICKMAN COUNTY.
Dear Ms. Durham:
The .above-referenced undertaking has been reviewed pursuant to Executive Order
No. 12372 and Section 106 of the National Historic Presp.rvation Act for
compliance by the participating federal agency or applicant for federal
assistance. Procedures for implementing Section 106 of the Act are codified at
36 CFR 800 (51 FR 31115. September 2. 1986)
Based on the documentation submitted. it is our opinion that due to the location.
scope and/or nature of the undertaking. and/or the size of the area of project
impact. the undertaking will have no effect on National Register of Historic
Places listed or eligible properties either because none exist in tne area of
project impact or because the undertaking will not alter any characteristics of
an identified eligible or listed property which qualify the property for listing
in the National Register. or alter such property's location. setting or use.
Therefore. this office has no objections to proceeding with the project.
If you are applying for federal funds. license or permit. you should submit this
letter as evidence of compliance with Section 106 to the appropriate federal
agency. which. in turn. should contact this office as required by 36 CFR 800 If
you represent a federal agency. you should submit a formal determination to this
office for comment. Questions or comments should be directed to Joe Garrison
(615)742-6720. Your cooperation is appreciated.
:II:;:J'( ~
Herbert L. Harper v
Executive Director and
Deputy State Historic
Preservation Officer
HLH/ jyg
-------
--
United States Department of the Interior
FISH AND Wll.DLIFE SERVICE
Post Office Box 845
Cookeville, TN 38503 .
.
-
-
-
-
.
August 16, 1991
Hr. Douglas A. Bell, P.G.
Remedial Project Manager
Kentucky/Tennessee Remedial Section
North Superfund Remedial Branch
Waste Management Division
U.S. Environmental Protection Agency
345 Courtland Street, H.E.
Atlanta, Georgia 30365
Dear Hr. Bell:
Thank you for providing us with copies of the Proposed Plan, Revised Final
Remedial Investigation. and Revised Draft Final Feasibility Study for the
Wrigley Charcoal Superfund Site in Wrigley. Tennessee. We were pleased to
note that some biological sampling has been conducted in the aquatic habitats.
and that the planned future resource 'studies include additional sampling and
subsequent tissue analysis of biota from these habitats as well as ~errestrial
sampling on the Primary Site. We would, however. like to see the terrestrial
sampling and subsequent tissue analysis extended to include the Irrigation
Field Site. Additional studies which would be useful include mussel surveys
. on Hill Creek and North Fork Creek. and mist-net surveys for bats over these
same streams. It would also be beneficial to convene an E-TAG meeting to
discuss this site. since one has not yet been held.
Thanks again for the opportunity to review the documents. and don't hesitate
to call if we can be of assistance.
Sincerely.
dM~
Lee A. Barclay. Ph.D.
Field Supervisor
RLW
xCs
Hr. Jim Lee. Regional Environmental Officer, Atlanta
.
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APPENDIX A
Soil Information Summarized From Unpublished Soils
Survey Data (Soils Conservation Service, 1977)
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Bodine Series
The Bodine Series consists of deep, somewhat excessively drained,
cherty soils on uplands. These soils have pale brown cherty silt
loam A horizons, and yellowish brown and strong brown cherty silt
loam and cherty silty clay loam B horizons which become very cherty
with increasing depth. Bodine soils are on sharply dissected
uplands. Slopes commonly are 20 to 50 percent and range from 5 to 60
percent. The soil formed in residuum weathered from cherty.
limestones, and locally there may be a small component of loess in
the upper part. The thickness of solum and depth to cherty limestone
bedrock is more than 60 inches. The amount of fragments of chert
ranges from 20 to 80 percent by volume in the A horizon, from 35 to
80 percent is the upper part of the B horizon, and from 35 to 85
percent in the lower part of the B horizon. The control section
averages between about 35 and 80 percent by volume fragments of
chert. The fragments are mostly 4 inches across, but some are as
much as 2 feet across. The soil is extremely acid to strongly acid,
except where the surface layer is limed. Runoff is moderate and
permeability is moderately rapid. Select estimated soil properties
for the Bodine Series are presented below in Table A-1.
Baxter Series
The Baxter Series consists of deep, well drained cherty soils on
uplands. They form~d in material weathered from cherty limestone.
Typically these soils have a brown cherty silt loam surface layer
nine inches thick. The subsoil from 9-10 inches is strong brown
cherty silty clay loam. From 10-32 inches is red cherty silty clay.
And from 32-48 i~ches is red cherty clay.
TABLE A-1: ESTIMATED SOIL PROPERTIES FOR THE BODINE SERIES
Depth Clay Moist Bulk Density Permeability
(in) (') (g/cmJ ) .( in/hr)
0-8 8-20 1. 35-1. 55 2.0-6.0
0-8 8-20 1. 35-1. 55 2.0-6.0
0-8 8-20 1. 35-1. 55 2.0-6.0
8-24 20-35 L 40-1. 60 2.0-6.0
24-72 23-38 1. 40-1. 60 2.0-6.0
The subsoil from 48-75 inches and the substratum from 75-90 inches is
mottled red cherty clay. Slopes range from 2-60 percent. Select
estimated soil properties for the Baxter Series are presented below
in Table A-2.
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TABLE A-2:
Depth
(in)
0-9
0-9
9-18
18-48
48-99
ESTIMATED
Clay
(%)
12-27
27-35
18-40
40-80
40-80
SOIL PROPERTIES FOR THE
Moist Bulk Density
(g/cm3 )
1.20-1.40
1.20-1.45
1.30-1.55
1.30-1.55
1.30-1.65
BAXTER SERIES
Permeability
(in/hr)
0.6-2.0
0.6-2.0
0.6-2.0
0.6-2.0
0.6-2.0
Ennis Series
The Ennis Series consists of deep, well drained, cherty moderately
rapid permeable soils that formed in alluvial sediments derived from
limestone, shale, sandstone, and loess. These soils are on bottom
lands, in narrow strips along drainways and in depressions. Slopes
range from 0 to 5 percent. Solum thickness ranges from 25 to more
than 60 inches. Depth to bedrock ranges from 5 to 15 feet. Reaction
ranges from very strongly acid through medium acid in each horizon.
The content of fragments of chert, gravel, or cobblestones ranges
from 15 percent to 35 percent by volume except the C horizon ranges
up to 55 percent. The control section centers on 25 percent clay and
ranges from 18 to 32 percent clay and sand coarser than very fine
sand ranges from 8 to 45 percent. Ennis soils are well drained.
Runoff is slow and permeability is moderately rapid. Flooding is
rare to occasional for brief periods. Select soil properties for the
Ennis Series are presented below in Table A-3.
TABLE A-3: ESTIMATED SOIL PROPERTIES FOR THE ENNIS SERIES
Depth
(in)
Clay
Moist Bulk Density
(g/cm3 )
Permeability
(in/hr)
0-10
10-60
12-25
18-32
1.30-1.45
1.35-1.50
2.0-6.0
2.0-6.0
Mountview Series
The Mountview Series consists of very deep, well drained soils that
formed in a 2 to 3 foot thick silty mantle, presumably loess,
underlain by residuum of cherty or clayey limestone or by old
-------
alluvium. Slopes range from 0 to 15 percent. The texture is silt
loam or silty clay loam. The solum thickness and depth to bedrock
exceeds 60 inches. The upper solum formed in a silty mantle,
presumably loess, and commonly is about 30 inches thick but ranges
from about 22 to 36 inches. This overlies a lower solum developed in
residuum of cherty limestone or in old alluvium. The content of
coarse fragments, commonly fragments of chert, ranges from 0 to about
5 percent in the upper 30 inches and from about 5 to 35 percent below
that depth. Transition horizons have characteristics similar to
adjacent horizons. Reaction of each horizon is very strongly acid or
strongly acid, except the surface layer, which is less acid where
limed. Montview soils are on gently to strongly sloping broad
ridgetops and plateau-like areas. Montview soils are well drained.
Runoff is medium and permeability is moderate. Select estimated soil
properties for the Mountview Series are presented below in Table A-4.
TABLE A-4: ESTIMATED
Depth Clay
(in) (%)
0-8 15-25
8-30 20-35
30-78 35-55
SOIL PROPERTIES FOR THE
Moist Bulk Density
(g/cm» )
1.35-1.55
1.40-1.60
1.30-1.50
MOUNTVIEW SERIES
Permeability
(in/hr)
0.6-2.0
0.6-2.0
0.6-2.0
Dickson Series
The Dickson Series consists of moderately well drained soils that in
a representative profile have a 7 inch brown silt loam layer. The
subsoil down to the fragipan at 25 inches is yellowish brown friable
silt loam. The fragipan which extends from 25 to 45 inches is
yellowish mottled and brittle silty clay loam. Below the fragipan is
yellowish red firm clay. Slopes range from 0-12 percent. Select
estimated soil properties for the Dickson Series are presented below
in Table A-5.
TABLE A-5:
Depth
(in)
0-7
7-25
25-48
45-65
ESTIMATED
Clay
(*)
15-28
18-30
20-32
38-50
SOIL PROPERTIES FOR THE
Moist Bulk Density
(g/cmj )
1.30-1.55
1.35-1.55
1.55-1.75
1.35-1.55
DICKSON SERIES
Permeability
(in/hr)
0.6-2.0
0.6-2.0
0.06-0.6
0.2-0.6
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Other series presented below may be found in localized Site areas.
However, these soils series are less likely to be found at the Site
but are found throughout Hickman County.
Humphrevs Series
The Humphreys Series consists of deep, well drained soils on
terraces. They formed in alluvium from cherty limestone, loess, and
shale. Slopes range from 0 to 12 percent. The texture is cherty
silt loam or cherty silty clay loam. Solum thickness ranges from
about 30 to 60 inches. The soil ranges from very strongly acid to
medium acid in each horizon, except the surface layer which is less
acid where limed. The amount of fragments of chert or of gravel in
the solum ranges from 15 percent to about 35 percent by volume. The
amount of chert or gravel below the solum ranges to 50 percent.
Humphreys soils most commonly are on low terraces but some areas are
on footslopes. These soils formed in alluvium washed from soils
developed mainly in cherty limestone residuum, but in many places it
contains materials from loess and shale. They are well drained;
runoff is medium or slow. Permeability is moderately rapid.
Biffle Series
The Biffle Series consists of moderately deep, somewhat excessively
drained, cherty soils on uplands. They have formed in residuum from
cherty limestone. Slopes range from 5 to 60 percent. Biffle soils
are on sloping to very steep convex ridgetops and side slopes. The
upper 10 to 20 inches of Biffle soils on the lower part of many of
the side slopes have been influenced by soil creep or colluvium or
both. The thickness of solum and depth to a paralithic contact range
from 20 to 40 inches. Depth to hard bedrock is greater than 60
inches. Fragments of chert, dominantly 20 to 10 mm but ranging up to
2.5 cm, range from 15 to 35 percent by volume throughout the solum.
Reaction is extremely acid to strongly acid. Biffle soils are
characterized by moderately rapid permeability. Runoff is medium.
Senatown Series
The Sengtown Series consists of deep, well drained, moderately
permeable soils. They formed in residuum weathered from cherty
limestone. They occur on sloping to steep uplands. Slopes are 5 to
35 percent. The texture is cherty silt loam. The thickness of solum
and the depth to limestone bedrock are greater than 70 inches. The
soils are strongly acid to medium acid, except the surface layer is
less acid where limed. The chert content averages between 15 and 35
percent in the solum. Runoff is medium and permeability is moderate.
-------
APPENDIX B
Copy of the Proposed Plan Presented at the Public Meeting:
July 25, 1991, Lyles, Tennessee
-------
SUPERFUND
EP A. Region 4
PROPOSED PLAN FACT SHEET
------------~------------------------
...
.~
INTERIM REMEDIAL ACTION
AT THE
WRIGLEY CHARCOAL SITE
WRIGLEY, TENNESSEE
-----------------------
July 1991
----------------------------------------------------------------
INTRODUCTION
The Proposed Plan* for the Interim Remedial Action is . .
issued to describe the alternatives that the U.S. Env.ironmental'
Protection Agency (EPA) has considered for the cleanup of the
Wrigley Charcoal Rational Priorities List (RPL) Site (the
Site) located in Wrigley, Tennessee (see figure 1). This plan
presents an evaluation of cleanup alternatives, including the
alternative preferred by the EPA. The alternatives summarized
are described in greater detail in the Remedial Investigation
(RI) and Peasibility Study (FS) Reports which are available,
with the Site's Administrative Record, at the information
. rePository ~ocated at the Hickman County Public Library, 120
West Swan Street, Centerville, Tennessee.
The.alternative EPA prefers represents a preliminary decision,
subject to a public comment period. Section 117(a) of the
Comprehensive Bnvironmental Response, Compensation and
Liability Act (CBRCLA) of 1980, as amended by the Superfund
Amendments and Reauthorization Act (SARA) of 1986, requires
publication of a notice and brief analysis of a Proposed Plan
for site remediation. This plan provides background information
on the Site, describes the remedial alternatives, provides the
rationale for identification of the preferred alternatives,
and outlines the role of the public in helping EPA make a final
decision on a remedy.
EPA encourages the public to submit written comments on all
alternatives presented in this plan. Public comments may result
. in selection of alternatives other ~han the ones preferred by
EPA for the Site.
* Highlighted terms are defined in the glossary at the end of
this fact sheet
-1-
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PRIIo\ARY
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Figure 1)
Hap t"
o the W
COliS ist ' rigley Ch
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Athletic Fi ur area.. I) Site in Wri .
eld, and 4) {the Primary ~ley,
rrigati ite,
on Field.
Tennessee
2) Storag; The Site
Basin
.
-------
SITE BACKGRO{jNii
The Wrigley Charcoal Superfund Site, as depicted in Figure 1,
consists of four distinct areas:
o
1) primarY Site (thirty-five acres represents the extent of
industrial activities in the valley);
2) Storage Basin and Overflow Basin (three acres and an
adjacent area called Clark Hollow that is approximately
thirty acres);
o
o
3) Irrigation Field (forty acres) including the abandoned
wastewater holding area referred to as the lagoon;
o
4) Athletic Field (three and one-half acres).
The Primary Site (Figure 2) was used for industrial operations
such as producing iron, charcoal, and wood distillation products
intermittently from 1881 to 1966. The businesses or individuals
involved in the industrial operations during this time period no
longer exist and previous investigations. have indicated there are
no Potentially Responsible Parties (PRPs) from this time period
to fund cleanup operations. The Site was purchased in 1966 by the
Tennessee Farmers Cooperative (TFC) 'who are the present owners of
all four Site areas. Portions of the Primary Site were also
utilized from 1978 to 1983 by R.T. Rivers for metals machining,
storage of waste products obtained from other local industries,
and recovery of 'copper from transformers. These additional
operations were conducted primarily in three of the remaining
on-site buildings; namely, the dryer building, the maintenance
building, and the storage shed. Both past and present owners and
operators may be considered PRPs. Previous activities left
contaminants at several locations at the Primary Site that will be
addressed during this effort. Proposed EPA efforts are intended
to address the following: .
o
The Grease-Pit (referred to as the Burn-Pit since various
materials were burned there);
Waste debris piles in the southern portion of the Prima~
Site that contain crushed drums, tar-cubes, tars from open
sumps at the Still House, and corrugated asbestos
containing roofing materials (ACM) torn from Site
buildings, now on the ground;
o
o
ACM on Primary Site buildings such as the Dryer Building,
Maintenance Building, Storage Shed, and other small Site
buildings; .
o
The Spillway adjacent to the culvert in the southern
portion of the Primary Site.
-3-
-------
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the Primary Site showing building and activity
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OUANTlTlES or INTEREST
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-------
The Storage Basin located 1400- feet west of the Primary Site was
built in the mid to late 1950's to receive wastewaters from the
Primary Sites' industrial operations. A relatively small amount -
of excess wastewater that was not eliminated through evaporation
was likely spray irrigated over slag and a small field in order to
biologically degrade phenol and organic compounds in the -
wastewater. These areas are adjacent to the Storage Basin in
Clark Hollow. The Storage Basin, similar to the Primary Site
contains contaminants in coal-tars that will be addressed in this
response action. The following contaminated media are proposed to
be addressed at- the Storage Basin:
o
Waters contained at the Storage Basin;
The Storage Basin sediments.
o
The Irrigation Field (including the lagoon) loCated 3500 feet
northeast of the Primary Site, was constructed in the late 1950s'
and also received wastewaters for disposal from the Primary Site,
but on a much larger scale than the Storage Basin. Wastewaters
were sprayed over the field to biologically degrade phenol and -
-organic carbon. . Proposed EPA ac~ivitiesatthe Irrigation Field
will restrict access to the small lagoon by fencing the area.
The Athletic Field- is located 800 feet southeast of the Primary
Site in the eastern portion of the Wrigley community. The section-
of property where the field now resides was filled in with blast
furnace slag and associated materials from 1938 to approximately
1950. The field has been in use since the early 1950's-aftd is
still regularly used- by local resident.s. -.. . .
EPA INVOLVEMENT
EPA became involved with the Wrigley Site as a result of the
submittal in December of 1985 of a preliminary Hazard Ranking
System score and request for emergency action by the Division of
Superfund in Tennessee. E~A personnel visited the Site in January
1986, to assess the need for emergency action. EPA later
recommended that the raw water intake at the BOB Aqua-Lyles Water
District be relocated to avoid potential site affects. In
addition, EPA recommended additional sampling to better define the
extent and degree of contamination at the Site, including
collection of water samples at the Bon Aqua-Lyles Water District
intake. EPA subsequently performed a Site sampling effort which
confirmed the presence of benzene, toluene, ethylbenzene, phenol,
and 2,4-dimethylphenol in tars located on the Site.
The EPA then compiled detailed information about the Site and used
a mathematical formula to rank the Site. This formula is called
the Hazard Ranking System (HRS) and it generates a Hazard Ranking
System score from 0 to 100. This score estimates the impact the
-5-
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Site may hav~ on the public health and the environment. Any Site
that scores above 28.5 is placed on the National Priorities List
(NPL) and is then eligible for federal assistance through the
Superfund Program. The Wrigley Charcoal Site generated a HRS
score of 36.14.
EPA's Removal Program initiated stabilization measures on the Site
in the summer and fall of 1988. Measures undertaken included:
o
installation of two 48-inch culverts in the North Fork of
Mill Creek and stabilization of the bank retaining the tar-
pits using sheet piling;
o
solidification of the tar-pits' contents, and
reconstruction of the fencing (around the tar-pit area)
previously removed to facilitate Site work (EPA, 1990).
o
As a result of the stabilization and construction activities at
the Site, in October of 1988, 130 cubic yards of tar pit waste
material was transported to the Allied-Signal Facility in Detroit,
Michigan for incineration. ..Approximately.$2,000,000 'was spent
from the Federal Superfund Program for these remoyal activities.
On October 24, 1988, a Public Meeting was held at East Elementary
School in Wrigley, to provide information and also to answer
citizens' questions concerning removal activities at the Wrigley
Site. Representatives from EPA and the State of Tennessee
provided details of activities taken to date, pertinent analytical
results and proposed activities to be completed in the future.
In 1989, EPA contracted Ebasco Services Incorporated to perform
the RIfFS at the Wrigley Charcoal Site. Both the RI and FS were
totally funded out of the federal Superfund Program. The
following list presents the major events during the RIfFS:
o
August 1989: Tne initial Field Investigation began
o
Ongoing sampling and
o
September 1989 - September 1990:
analysis for the RI;
November 1990: EPA reviews contractor information and
suggests taking additional samples at several Site
locations as a precaution, and FS activities are initiated;
o
December 1990: EPA collected additional samples at the
Athletic Field, in the yards of private residences in the
East Neighborhood and the West Neighborhood. Initial RI
sampling and analysis indicated elevated concentrations of
metals, VOCs, and dibenzofuran at the Athletic Field in
isolated locations outside the ballfield fence. Since
dibenzofuran was identified during the initial sampling,
-6-
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EPA took-precautions by taking additional sampies in the
town of Wrigley and analyzed samples specifically for
dioxin (no hazardous dioxins were found in the town or
neighborhoods of Wrigley). All samples were taken to
confirm and further determine the extent of contamination.
o
April 1991: EPA collected additional samples at the Primary
Site and Storage Basin. Samples at the Primary Site were
of transformer waste in several buildings, waste samples at
the far southern portion of the Primary Site, and soil
samples from the southern lawn of the mansion property
(Walton residence) adjacent to the Primary Site.
Additional samples were taken at the Storage Basin to
further evaluate contamination. These samples were taken
at the waterline and in the deeper sediments within the
Basin. . .
o
June 1991: The Revised Final RI is completed
July 1991: The Revised Draft Final FS is completed. The
Final FS with the public responses to EPAs Proposed Plan.
and Public Heeting (called the.Responsiveness'SI1111111Ary) is
expected to be-completed in late. August .of- 1991.
o
The Findings of the RI and the additional EPA sampling confirmed
the presence of many contaminants at the Primary Site and three
other Site areas. . The present status of the Wrigler Site and
contaminants identified are discussed in the follow~ng section.
1)
. RESULTS OF. TBB RBMBDIAL IRVBSTIGATIOR
The PrimarY Site and the three other areas of Site related
activity are now abandoned but past industrial activities
left significant contamination at the Primary Site and
Storage Basin with lesser amounts of contamination at the
Athletic Field and. Irrigation Field. .
Primary Site contamination exists in abundant waste piles,
soils, buildings, tar-pits, above ground storage tanks
(called the process tanks), and stream sediments of the
North Fork of Mill Creek, and shallow groundwater.
These areas contain contaminants identified as phenol,
2,4-dimethylphenol, benzene, toluene, polycyclic aromatic
hydrocarbons (PABs), halocarbons, asbestos, traces of
furans, dibenzofurans and dioxins, and an abundant variety
of metals.
At. the southern portion of the Primary Site is the drainage
culvert and spillway built in 1988 to stabilize the
tar-pits. This Emergency Response and Removal activity
has been effective in reducing the potential release of
large volumes of pit wastes into the North Fork of Hill
-7-
-------
2 )
3)
4 )
5)
Creek< . However, recent flooding in the North Fork Valley
has washed away a portion of ~he spillway adjacent to
culvert installed in 1988. The flood waters uncovered an
old portion of the stream channel that was apparently
coa~ed with layers of coal-tars that likely overflowed or
leaked i- the past from the tar-pits into the creek.
Athletic Field soils were sampled during the RI in August,
1989, and analyses showed the presence of relatively low
levels of lead, copper, zinc PABs, toluene, and
dibenzofuran in surface samples. However, one sample
10 '!.ted on the south edge of the Athletic Field .;:lowed a
re.~tively high level of lead. Therefore, EPA collected
more samples in December of 1990 and that analysis
confirmed the presence of the contaminants. This
resampling effort detected contaminants generally below
levels of ccncern. Due to continued concern Q~out
potential hot spots, it will be necessary to perform an
additional (future) investigation to assure that no actions
are needed at the Athletic Field.
Initial sampling and analyses of the surficia~ water and
surface sediment at the storaqe Basin indicated
contaminants of concern were present but in lower
concentrations than at the Primary Site. Additional
samples taken within the basin (April 1991) indicated that -
the deeper sediments conta~n high levels of PABs, VOCs, and
metals.
Soils at the Irriqation Field were determined to have
relatively low levels of contamination as a result of past
wastewater disposal activities. Several metals are
slightly elevated at the location of the abandoned lagoon
which was located in the middle of the Irrigation Field,
but at present they do not appear to pose a threat to human
health and the environment. At present, our data from the
Irrigation Field indicates there are no risks to the nearby
residents at this location. However, since limited samples
were taken from inside the actual lagoon, it will be
necessary to further evaluate the area at a later date to
confirm our data and support the conclusion that the entire
lagoon area has only slightly elevated levels of metals.
Future i~vestigative activities will likely consist of soil
samples, soil bcrings, and perhaps monitoring wells.
Information concerning the blast furnace slag indicates it
~s a source for some of the metals contamination identified
at the Primary Site and other areas. Large quantities of
slag were produced by the Wrigley Charcoal Plant and this
~ste was used to grade and fill the Athletic Field and
?ortions of the town of Wrigley that surround the Athletic
Field. Other construction activities that utilized slag
-8-
-------
include: building elevated railroad spurs at the Primary
Site, grade and fill activities in Clark Hollow for
railroad spurs and wastewater treatment filters, and
disposal activities in portions of the valley that produced
slag pile~ that are as large as. 40 feet high and 60 feet
wide that extend intermittently for 2.5 miles.
SUMMARY OF SITE RISKS
During the RI/FS, an analysis was conducted to estimate the health
or environmental problems that could result if the contamination
at the Site was not remediated. This analysis, commonly referred
to as a Baseline Risk Assessment, focused on the health effects
that could result from long-term direct exposure to Site
contaminants as a result of dermal contact with soil or water,
ingestion of Site contaminants, ingestion of fish from.the creek,
or exposure to airborne contaminants. .
The major cause of concern at the Primary Site is from oral and
dermal exposures to Site wastes such as PABs, heavy metals,
volatile organic compounds, traces of furans/dioxins, and asbestos
contained in waste piles and roofing. The current risks at the
Primary Site are elevated for casual visitors that may subject
themselves to repeated exposures of various Site contaminan.ts.
Risks associated with ingestion of water or fish from the North
Fork of Hill Creek are slightly elevated. In order to determine
the full extent of contamination in the creek and the fish,
further investigation will be needed. The fish in the creek were
found to contain low levels of various metals and traces of
furans/dioxins.
Present information indicates the risks associated with the slag
are very low. However, it is likely that the slag was initially
the source that produced many of the metals hot-spots at the
Primary Site and other Site areas.
Samples taken directly within the ballfield in April 1991
indicated that low levels of metals, PABs, and toluene are
present. Three samples taken in 1989 immediately behind the
outfield fence contained levels of contaminants that are slightly
above acceptable levels, however, in order to expand upon that
data, EPA sent a sampling team to the Site in December 1990. The
team grided off the field and collected 11 composite samples at
depths ranging from 0 - 18 inchs. These samples revealed levels
of. metals within acceptable limits. Based upon the review of the
additional sampling, the overall risks at the ballfield associated
with ingestion or contact with soils appear to be low and no
carcinogens. were identified at this location.
The investigative work that has been completed to date does not
indicate risks are elevated at the Irrigation Field. In order to
-9-
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confirm thi~ ~dditional samples will need to be taken.
For more detailed information on the risks associated with the
Wrigley Charcoal Site, please refer to the Baseline Risk
Assessment report (volume III) in the Remedial Investigation.
This report along with other important Site documents are located
at the information repository in Centerville, Tennessee.
SCOPE AND OBJECTIVES OF RESPONSE ACTION
Using the information gathered during the Remedial Investigation,
Baseline Risk Assessment, and additional sampling i :formation
obtained by EPA during 1990 and 1991, EPA identified the following
interim remedial action objectives for the cleanup of the Wrigley
Charcoal Site:
o
Prevent direct contact with soil and waters at the Storage
Basin and minimize potential contaminant migration;
Prevent direct contact or ingestion of the contaminated
soil/solids in the Burn-Pit;
o
o
Prevent contact with contaminated debris such as transformer
materials, tar cubes, asbestos materials, metallic waste
materials, process tanks and associated contaminants and
soils, and empty drums on the Primary Site;
Prevent further direct contact/ingestion and contamination of
the site soil or groundwater through migration of"
contaminants from the surface waste debris on the Primary
Site;
o
o
Prevent direct contact and ingestion of contaminated soil at
the Irrigation Field lagoon.
o
Prevent inhalation of fibrous asbestos containing material
contained in roofing on Primary Site buildings;
Remove coal-tar contaminated sediments in the Primary Site
spillway.
o
o
Provide additional information on the groundwater quality at
the Primary Site and soil quality in surficial soils behind
the Athletic Field.
An Interim Action ROD (Operable Unit 1) for the Site is proposed
to address the most imminent and substantial threats to human
health and the environment by controlling exposure to contaminated
materials and reducing the potential for migration of contaminants
into surrounding soils, sediments, and surface water.
Factors that may determine the distribution of contamination are:
-10-
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1) the amounts and types of contaminants contained at the
Wrigley Charcoal Site and three other Site areas;
2) the complex geoloqy (limestone terrain that exhibits numerous
sinkholes) of the Site and adjacent area;
3) the complex near-surface and sub-surface groundwater flow
within the steep-walled valley of the Primary Site; and
4) the complicated histories and impact of the three other Site
areas. . .
In order. to determine the final remedies needed to clean up the
Wrigley Charcoal Site, these four factors were analyzed to
determine the overall impacts of the Site and.estimate the affect
on potential receptors. It is presently estimated that the
cleanup of the Wrigley Site can be performed in three (3) separate
cleanup efforts called Operable Units. The first cleanup ,
activity at the Wrigley Site will be an Interim Action proposed to
remedy the most immediate threats to public health and the
environment by controlling and removing various contaminated '.
materials. The second operable. unit.. as described in -the FS would
remediate wastes stabilized during the first operable unit at the
Storage Basin and remediate the Primary Site tar-pits and soils.
Operable Unit 3 is tentatively proposed to remediate any
groundwater problems at the Primary Site.
All remedial alternatives under consideration are presented
below. The FS Report presents a more thorough description and
evaluation of these alternatives. The Administrative Record,
which contains the FS Report along with other documents and
correspondence that are used to decide' the Site remedy(ies), is
available for public review at the site information repository at
the. previously listed address.
SUMMARY OF ALTERNATIVES
The following summary 'lists the three (3) remedial alternatives
under cons~deration for the actions to be taken at the Primary ,
Wrigley Site. The FS Report contains a more detailed evaluation
of each alternative.
1)
2)
No Action;
Limited Action: Fencing/Deed Restrictions (institutional
controls), Site monitoring;
3)
Institutional Controls plus:. Soil capping with
stabilization at Storage Basin; removal-offsite
stabilization and disposal of the wastes in the Burn-pit of
the Maintenance Building; removal of Site surface
wastes/debris piles; removal of the asbestos corrugated
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roofing material on the Maintenance Building, Dryer
Building, Storage Shed, and other small buildings with the
tiles; removal of the process tanks and associated
contaminants; removal of contaminated soils from the
process tank area down the hill to the North Fork of Mill
Creek; resampling of Primary Site monitoring wells; and
additional soil samples behind the Athletic Field.
All but one (Alternative 1) of these alternatives involve
restrictions on land/well use at the Site and upkeep of the fence
and property. Monitoring of the Interim Action will not be
necessary since none of the actions are considered to be final.
Monitoring programs will be proposed implemented during later
operable units to assess the effectiveness of the final remedy
( ies) .
ALTERNATIVE 1:
o
No Action
*
Present Worth (PW) Cost: $36,000 - 54,000
PW Capital Cost: $30rOOO - 45,000 (institutional controls)
O&M Costs: $6,000 - 9,000 (Engineering controls & permitting fees)
Years to Implement: 2 months to implement deed restrictions,
restrictive covenants, or local ordinances restricting ttse of Site
activities.
CERCLA requires that the "No Action" alternative be considered at
every site. This alternative must be considered to serve as a
basis for comparison of other alternatives. Under this
alternative, no soil, sediment, groundwater or debris cleanup,
containment or treatment would take place. The only reduction of
contaminant levels would occur via natural processes such as
dispersion or attenuation.
ALTERNATIVE 2:
o
Deed Restrictions and Site Access Restrictions
(Institutional Controls) including: a 10-foot high
chain-link fence topped with barbed wire will be installed
around the Site areas of concern. Prior to installation,
the areas of fencing will be cleared for access as required
for proper installation. The fence would be equipped with
a gate for controlled access. Warning signs and placards
would be added and posted at 100-foot intervals along the
fence. The areas to be fenced are as follows: 1) Primary
Site (6,820 feet), Storage Basin (1,230 feet - including
the Overflow Basin), and the former lagoon area of the
* Cost ranges are presented due to uncertainty of exact volumes of
contaminated media, and variable remediation costs.
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,"
Irriqation Field (575 feet). The total amount' of fencing
proposed for the three Wrigley Site areas is 8,085 linear
feet.
Present Worth Cost:
PW Capital Cost:' .
PW 0 & M Cost:"
Years to Implement:
$184,441 - 278,662
$153,701 - 230,552 (fencing, & fees)
$30,740 - 46,110 (deed restrict., etc.)
2 months
This alternative will insure that Site access is limited through
installation of a security fence while also establishing ,controls
that ensure proper 'maintenance of the Site through deed
restrictions. This alternative does not improve residual risks
above baseline conditions. Any reductions in toxicity, mobility,
and volume are the same as those discussed for alternative 1. It
is assumed that natural processes would eventually reduce most
well established contaminants to safe levels.
ALTERNATIVE 3
o
Institutional controls.at the.primary Site, Storage Basin,
and former lagoon of the Irrigation Field~
Stabilization/clay covering of wastes at the Storage Basin~"
o
o
Removal/offsite stabilization and disposal of the wastes in
the Burn-pit of the Maintenance Building~
Removal of Site surface wastes/debris piles~
o
o
Removal of the asbestos corrugated roofing material on
several Site buildings. These buildings are the
Maintenance Building, Dryer Building,. Storage Shed, and
small building in front of the Maintenance B~ilding.
Removal of the process tanks and associated contaminants. .
Tank wastes will be taken to an EPA-approved RCRA '
incinerator/landfill while the tanks will be
decontaminated, and transported to an EPA-approved RCRA
landfill for disposal.
o
o
Removal of contaminated soils from the Process Tanks down
to the North Fork of Mill Creek. The area measures
approximately 50xlO feet with an average thickness of 0.5
feet~
o
Exposed coal-tars and soi!s in the spillway should be
excavated, and incinerated,offsite. The spillway should be
regraded and lined with larger riprap. These recently
exposed materials have not been thoroughly evaluated,
however, aerial photographs suggest that this is the same
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ma~ertal as in the tar-pits. A preliminary estimate of 150
yd has been made and a rough est :.mate of $50,000 to
remove these contaminated sedimencs.
*
Additional Sampling: Resampling of the Primary Site
monitoring wells and additional soil samples should be
taken from behind the Athletic Field to the garden.
Present Worth Cost:
PW Capital Cost: .
PW 0 & M Cost:
Years to Implement:
$1,032,773 - 1,549,162
$786,217 - 1,179,326
$196,555 - 294,833
6 months
This alternative retains the institutional controls discussed for
Alternative 2 and adds additional remedial measures that are
designed to reduce and eliminate some of the most ~mminent and
substantial dangers that reside at the Primary Site and Storage
Basin. The wastes in the Burn-Pit will be excavated, stabilized,
and transported to a EPA approved RCRA incinerator/landfill. The
Burn-pit would then be backfilled with clean fill and covered with
a concrete slab. Stabilization of wastes followed by addition of
a clay cover will reduce risks.at the Storaqe Basin while
preparinq the wastes for elimination durinq a later operable
unit. This cap is also designed to promote runoff and drainaqe,
and prevent erosion. The cap will be properly qraded and seeded
to promote a thick veqetative cover. Remedial measures will also -
include the removal of Primary.Site surface debris/waste piles.
Recyclable non-hazardous material will be separated out and
nonrecyclable material will be disposed in an approved and
permitted sanitary landfill. Resamplinq of the Primary Site
monitorinq wells is recommended in order to estimate annual
fluctuations in contaminant and water levels. Finally, additional
soil samples are recommended between the Athletic Field fence to
the garden area. Thi. is recommended because one sample behind
the fence exhibited lead levels slightly above the threshold level
of concern. This indicates that additional sampling is
warranted. Operation and 8aintenaDce activities for the interim
action at the Sit~ is not anticipated to be needed for an extended
t~me period because final remedies will replace many of the
interim actions being proposed. However, costs are included as
estimates for gene~~l upkeep and maintenance of fencing,
s .bilized areas, e~c., until final remedial measures can be
u: ertaken durinq operable units 2 and 3.
T~..s alternative achieves the CERCLA statutory preference for
removal and/or treatment as a principle element of the re':.edy for
the Burn-Pit, Primary Site waste/debris piles, Storage Bas~n
wastes, process tanks/wastes, asbestos corrugated roofing
materials on Primary Site structures, and contaminants in the
spillway. .
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EVALUATION OF ALTERNATIVES
The EPA preferred alternative for the remediation of the. Wrigley
Charcoal Site is Alternative 3. This alternative appears to
represent the overall best remedy for the Site. While
Alternatives 1 and 2 do not achieve the CERCLA statutory
preference (NCP Requirement) for reduction of toxicity, mobility,
or volume through treatment, Alternative 3 does meet this
requirement for contaminants in many of the Primary Site locations
as well as the Storage Basin.
ANALYSIS
Overall Protection of Human Health and the Environment
The only alternative that would sufficiently be protective of
human health and the environment would be Alternative 3.
Alternatives 1 and 2 are not protective becau~e they do not
address the most significant threats to human health and the
environment at the Wrigley Charcoal Primary Site and Storage
Basin. Alternative 3 is protective of human health and the
environment since it remediates the:. burn-pit. wastes; Storage
Basin wastes, Primary Site wastes/debris piles, process tanks, and
asbestos corrugated roofing. .
Compliance with ADDlicable or Relevant and ADDroDriate
Reauirements
Alternatives 1 and 2 would not meet State and Federal Applicable
or' Relevant and Appropriate Requirements (ARARs). Alternative 3
meets ARARs as applicable to excavation and transport of
contaminated soil and waste debris. Although it is not required
that interim remedial actions satisfy ARARs and guidance To Be
Considered (TBCs), all requirements for off-site disposal of the
materials removed during this action will be met. Resource
Conservation and Recovery Act (RCHA) Subtitle C requirements are
applicable when excavating and transporting the soil, and certain
safety precautions specified in RCRA must be followed. These
include standards and requirements for owners and operators of
tra~sport and disposal.(TSD) facilities. This alternative also
complies with the BPA's Groundwater' Protection Strategy Policy
(TBC requirements) by reducing the possible migration of
contamination from the Burn-Pit soil/solids and Storage Basin
sediments into the groundwater/surface water. Alternative 3 will
also be in compliance with Land. Disposal Requirements (LDRs).
Reduction of Toxicitv. Mobilitv or Volume
Alternatives 1 and 2 do not involve the treatment
previously described Site wastes so there will be
reduction in the. toxicity, mobility, or volume of
Alternative 3 does reduce toxicity, mobility, and
of the
no direct
these materials.
volume of
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previously described wastes at the Storage Basin and Primary
Site. Also, as these wastes are removed or eliminated the
potential for bioaccumulation is greatly reduced. However,
these Altern~;ves do not reduce the toxicity, mobility, and
volume of contaminants not addressed in Operable Unit 1 and none
of the activities are considered to be the final remedy. Proposed
activities fOf-Vthis interim action are intended to reduce present
risks associated with the most imminent and substantial dangers to
human health and_the environment while preparing several of Site
waste loc&ti~or future remedial activities that will eliminate
the wastes.
Lonq-Term Effectiveness
Alternatives 1 and 2 do not provide any degree of long-term
effectiveness and permanence concerning the majority of activities
proposed for Operable Unit 1. Alternative 3 will remove Primary
Site Burn-Pit wastes; waste debris piles; process tanks and
associated wastes/soils; asbestos roofing; and asbestos
contaminated soils will have long-term effectiveness by
eliminating risks from these contaminants. Activities proposed to
stabilize and cover wastes at the.Storage.Basin are rtot intended
to be effective in the long-term. This activity is consistent
wi~h interim action policy and intended to prepare the wastes for
elimination in the next operable unit. These activities will not
provide any degree of long-term effectiveness for contaminants in -
the soils and the groundwater at the Primary Site not addressed in
Operable Unit 1. Cleanup activities for these contaminants will
be addressed in Operable Units 2 and 3.
Short-Term Effectiveness
There will be no short-term impacts connected with Alternatives 1
or 2. The interim action is intended to remove/reduce contaminant
levels immediately at several Primary Site locations and the
Storage Basin. Therefore, significant short-term effectiveness
will result of the previously mentioned activities. Potential
impacts associated with Alternative 3 could result from excavation
and transport of contaminated soil and waste debris. Potential
threats to the public result from direct contact with contaminated
soil and/or inhalation of volatile vapors and contaminant dust.
An approved Health and Safety Plan will be prepared and followed
to minimize the potential threats to workers performing the
excavation. Short-term impacts to the North Fork of Mill Creek
should be minimal since precautions will be taken during spillway
excavation to divert any water away from the excavated area until
the work has been completed. Short-term impacts to the North Fork
will also be minimal during process tank/waste/soil removal as
precautions will be taken to prevent contaminants from entering
the creek.
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,"
ImDlementabiri tv
The implementability of an alternative is based on technical
feasibility, administrative feasibility and availability of
services and materials. All of the Alternatives are readily
implementable. Alternatives 1 and 2 will require either No Action
or minor institutional activities that will require no activities
that would create a implementation problem. For Alternative 3
there will be little or no implementation difficulties since only
standard construction techniques will be utilized for excavation
and transportation of wastes in the Burn-Pit, and stabilization
and covering of wastes at the Storage Basin.
Cost
Alternative 1 contains a present worth cost ranging from '$36,000 -,
54,000. The present worth value represents the total cost of
activities including remediation, expressed in today's dollars.
The estimated present worth cost for Alternative 2 ranges from
$184,441 to $278,662. Alternative 3 has a present worth cost
ranging from $1,032,773 to $1,549,162. Additional areas of
contamination that are not addressed during Operable "Unit 1
activities are proposed for Operable unit 2 , 3 and the costs of
these activities will be determined after additional information
or a supplemental RI/FS is obtained. .
State AcceDtance
The State of Tennessee has assisted EPA in the review of reports
and site evaluations. The State has reviewed and,tentatively
agrees with the activities proposed as Operable Unit 1 for the
Wrigley Charcoal Site and is awaiting public comment before final
concurrence.
Communitv AcceDtance
Co~unity acceptance 'of the various alternatives will be evaluated
during the public comment period. The public comments will be
summarized and included in a responsiveness summary that will be a
portion of the ROD for the Wrigiey Charcoal Site.
U.S. EPA'sProDosed Plan for Remedial Action
Based on the RI/FS, the U.S. EPA has identified Alternative 3 as
the best course'of action for the first step of cleanup activities
to'be taken at the Wrigley Charcoal Site. This first phase of
cleanup activities (Operable Unit 1) is designed to lay the ground
,work for future remedial activities to take place during Operable
Units 2 and 3.
U.S. EPA's preferred course of action includes:
o
Removal/offsite incineration/stabilization of the wastes in
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o
the BUrn-pit of the Maintenance Building;
Stabilization of Storage Basin coal-tar wastes found in
deep sediments in order to minimize migration of
contaminants without compromising any potentially
applicable remedial actions in the future. Following
stabilization, a thin covering of soil and clay will be
applied over the stabilized wastes that will prevent
infiltration of water and will promote drainage. The
entire cover will be graded and seeded to promote a thick
cover of grass and the entire Storage Basin area will be
fenced (including the Overflow Basin).
o
Removal of Site surface wastes/debris piles that include
tar-cubes, pieces of corrugated asbestos roofing,
transformer materials, crushed drums, and other
miscellaneous metallic debris and tar waste;
o
Removal of the asbestos corrugated roofing material on
several Site buildings. These buildings are the
Maintenance Building, Dryer Building, Storage Shed, and
small building in front of the Maintenance Building;
Removal of the proces8 tanks and associated 30 yd3 of
contaminants. Tank wastes will be taken to an EPA-approved
RCRA incinerator/landfill while the tanks will be -
decontaminated, and transported to an EPA-approved RCRA
landfill for disposal.
o
o
Removal of contaminated 80ils from the Process Tanks down
to the North Fork of Mill Creek. The area measures
approximately 50xlO feet with an average thickness of 0.5
feet;
o
Exposed coal-tars and soils in the spillway should be
excavated, and incinerated offsite. The spillway should be .
regraded and lined with larger riprap.
o
Deed restriction8 and Site access controls (fencing'
placard8) at the Primary Site, Storage Basin, and
Irrigation Field Lagoon;
*
Re8ampling of the monitoring wells at the Primary Site
will provide an assessment of the groundwater quality,
and 80il sampling behind the Athletic Field to the
garden area will assess the need any future activities
in this area. .
The EPA estimates that it will take 6 months to implement the
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. .
recommended al~ernative (number 3) as Operable Unit 1. at a cost of
$1,032,773 to $1,549,162.
The preferred alternative for this First Operable Unit is
recommended to address contaminants and control site access at the
Primary Site,. Storage Basin, and Irrigation Field lagoon. The EPA
selected alternative to be implemented as Operable Unit 1 will
also reduce the risks at the previously described locations and
prepare the Primary Site and Storage Basin for future (perceived)
remedial activities in Operable Units 2 and 3. EPA also
recommends monitoring wells at the Primary Site be resampled and
soil samples be taken from the behind the Athletic Field to the
garden near the trailers.
SummarY of Statutory Findinas
In summary, the preferred alternative represents the best balance.
among the criteria used to evaluate remedies. 'Based on the
information currently available, EPA has determined that the
preferred alternative would be protective of human health and the
environment, would satisfy the requirements of all ARARs, and
would be cost effective.
THE COMMUNITY'S ROLE IN THE SELECTION PROCESS
EPA solicits input from the community on the cleanup methods
proposed for each Superfund response action. E~A has set a public
comment period from July 15, through August 15, 1991 to encourage
public participation in the selection process. The comment period
includes a public meeting at which EPA will present. results of the
RI/FS Reports and the Proposed Plan, will answer questions, and
receive both oral and written comments. The public meetinqis .
scheduled for 7:30 pm, July 25, 1991, and will be held at the East
Elementary School near Wrigley, Tennessee. . Comments will be
summarized and responses provided in the Responsiveness Summary
section of the Record of Decision (ROD). The ROD is the
document that presents EPA's final selection for cleanup.
During the comment period, interested members of the community may
submit written comments to Ms. Suzanne Durham, the EPA Community
Relations Coordinator for the Wrigley Charcoal Site at the address'
listed later in this fact sheet. Comments must be postmarked no
later than August 15, 1991. ..
EPA is soliciting public comments about the most acceptable way to
clean up the Wrigley Charcoal Site. The Proposed Plan and the
RI/FS Reports have been placed in the information repository and
Administrative Record for the Site. The Administrative Record
includes all documents such as work plans, data analysis, public
comments, transcripts, and other relevant material used in
developing the remedial alternatives for the Wrigley Charcoal
Site. These documents are available for public review and copying
at the following locations:
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Hickman.County Public Library
120 West Swan Street
Centerville, TN 37033
(615) 729-5130
Librarian/Director: Mary Pruett
HOURS OF OPERATION: Mon: 11-7, Tue-Wed-Fri-Sat: 9:5
Thur: 8-12, Sunday & Holidays Closed
Copy Machine Available: 15 cents per copy
Records Center
U.S. EPA - Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-0506
Contact: Mr. Tom Love
HOURS OF OPERATION: Monday
LIST OF CONTACTS
- Friday 8 - 5
Douglas A. Bell
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-7791
Suzanne Durham
Community Relations Coordinator
. U.S. EPA-Region-IV
345 Courtland St., N.E.
Atlanta, Georgia 30365
(404) 347-7791
Sharon Chandler
Technical Assistance Grants
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-2234
Robert Powell
Tennessee Department of Environment
Environmental Field Office
537 Brick Church Park Road
Nashville, Tennessee 37243-1550
(615) 741-5940
and Conservation
GLOSSARY OF EVALUATION CRITERIA
OVerall Protection of Human Health and the Bnvironment: addresses
whether or not a remedy provides adequate protection and describes how
risks are eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
Compliance with AHARs: addresses whether or not a remedy will meet
all of the applicable or relevant and appropriate requirements of other
environmental statutes and/or provide grounds for invoking a waiver.
Long-term effectiveness and permanence: refers to the ability to
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maintain reliable protection of human health.and the.environment over
time once cleanup goals have been met.
Reduction of toxicity, mobility, or volume: is the anticipated
performance of the treatment technologies a remedy may employ.
Short-term effectiveness: involves the period of time needed to
achieve protection and any adverse impacts on human health and the
environment that may be posed during the construction and
implementation period until cleanup goals are achieved.
Xmplementability: is the technical and administrative feasibility of
a remedy, including the availability of materials and services needed
to implement the chosen solution.
Cost: includes capital and operation and maintenance costs.
.State Acceptance: indicates whether, based on its review of the RI/FS
and Proposed Plan, the State concurs with, opposes, or has no comments
on the preferred alternative.
CnBm,nfty Acceptance: will be assessed in the Record. of Decision
following a review of the public comments received on the RI/FS Report
and the Proposed Plan.
GLOSSARY
~fnf.trative Record: A file which is maintained and contains all
information used by the lead agency to make its decision on the
selection of a response action under CBRCLA. This file is required to
be available for public review and a copy is to be established at or
near the site, usually at an information repository. A duplicate file
is maintained in a central location, such as a reqional BPA and/or
state office. .
ARARa: Applicable or Relevant and Appropriate Requirements. Refers
to the Federal and State requirements that a remedy that BPA selects
must attain. These requirements may vary from site to site.
Baseline Ri.k A8Se8888Dt: An assessment which provides an evaluation
of the potential threat to human health and the environme~t in the
absence of remedial action.
BioacCU8Ulatedl The escalating accumulation of toxic materials that
occurs within the food chain of an ecosystem.
Carcinogen: Any substance that prod~ces cancer.
Ccmprehensive BnviroD88Dtal Response, COIIp8Dsation, and Liability Act
(CBRCLA): A Federal law passed in 1980 and modified in 1986 by the
Superfund Amendments and Reauthorization Act. The Acts created a
special tax that qoes into a trust fund, commonly known as Superfund,
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to investigate-and cleanup abandoned or uncontrolled hazardous waste
sites. Under the program, EPA can either pay for site cleanup when the
responsible parties cannot be located or are unwilling or unable to
perform the work, or take legal action to force responsible parties to
cleanup the site or reimburse EPA the cost of the cleanup.
Groundwater: Underground water that fills pores in soils or openings
in rocks to the point of saturation. Unlike surface water, groundwater
cannot clean itself by exposure to sun or rapid aeration. Groundwater
is often used as a source of drinking water via municipal or domestic
wells.
Information Repository: A file containing current information,
technical reports and reference documents regarding a Superfund NPL
site. The information repository is usually located in a public
building that is convenient for local residents, such as a public
school, city hall, or a library. As the site proceeds through the
Superfund Remedial Process, the file at the information repository is
continually updated.
Institutional Controls: Legal, non-engineering measures to prevent
human exposure to cOAtaminants at haiardous waste sites.
Interia Action: An interim action is limited in scope and only
addresses areas/media that will be followed by a final or later
operable unit ROD. Reasons for taking an interim action could include
the need to: 1) take quick action to protect human health and the
environment from an immiment threat in the short term, while a final
remedial solution is being developed; or 2) institute temporary
measures to s~ahi1ia. the.it. or operable unit and/or prevent further
migration or degradation.
Monitoring: The continued collection of information about the
environment that helps gauge the effectiveness of a cleanup action.
Operable Unit: A term used to describe a separate action undertaken
as part of a Superfund site cleanup. Operable units may address
geographical portions of a site, specific site problems (such as
contaminated groundwater), or interim actions that will be followed by
subsequent actions which fully address the scope of the problem.
Operation and Maintenance: Activities conducted at a site after a
Superfund site action is completed to ensure that the action is
effective and operating properly. In the case of the Interim Action,
long-term operation and maintenance activities will not be needed since
final remedies included in later operable units are proposed to remove
many of the contaminants or problems.
Organic Compounds: One of two large classes of chemical compounds:
organic and inorganic. The term "organic" is used to describe
substances that are primarily composed of carbon, hydrogen, and
oxygen. Examples of organic compounds include petroleum products such
as solvents, oils, and pesticides.
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Phenols: Organic compounds that are byproducts of wood distillation,
petroleum refining, tanning, and resin manufacturing. They are a major
constituent in coal-tars.
Polycyclic Aromatic Hydrocarbons (PABs): A group of organic compounds
characterized by a fused ring-like molecular structure. PABs are
common environmental pollutants that are produced by the incomplete
combustion of organic materials. These compounds occur in the exhaust
from motor vehicles and other gasoline and diesel engines, the
emissions from coal-, oil-, and wood-burning stoves and furnaces,
cigarette smoke, and charcoal-broiled foods.
Potential Responsible Parties (PRPs): This may be an individual, a
company or a group of companies who may have contributed to the
hazardous conditions at a site. These parties may be held liable for
costs of the remedial activities by the EPA through CERCLA laws.
Preferred Alternative: After evaluating and examining the various
remedial alternatives,EPA selects the best alternative based on
relevant cost and non-cost factors.
Proposed Plan: A fact sheet summarizing EPA's prefe~~ed cleanup
strategy for an NPL site, the rationale for the preference and reviews
of the alternati~espresented in the detailed analysis of
the remedial investigation/feasibility study.
Resource Conservation and Recovery Act (RCRA): A Federal law that
established a ~egulatory system to track hazardous substances from the
time of generation to disposal. The law requires safe and secure
procedures to be used in treating, transporting, storing, and disposing
of hazardous substances. RCRA is designed to prevent new, uncontrolled
hazardous waste sites.
Record of Decision (ROD): A public document that explains which
cleanup alternative will be used at a National priorities List site and
the reasons for choosing that cleanup alternative over other
possibilities. . .
Remedial Alternatives: A list of the most technologically feasible
alternatives for a remedial "strategy.
Remedial Inve8tigation and Peasibility Study (RI/PS): Two distinct
but related studies, normally conducted together, intended to define
the nature and extent of contamination at a site (RI) and to evaluate
appropriate, site-specific remedies necessary to achieve final cleanup
at the site (FS).
Responsiveness S1111n1U1ry: A summary of oral andlor written public
comments received by EPA during a comment period.
Riprap: Assorted sizes of concrete or stone blocks used to reduce the
erosion by water in the stream or spillway.
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Superfund ~ud8ent8 and Reauthorization Act (SARA): Modifications t~
CERCLA Enacted on October 17, 1986.
TECHNICAL ASSISTANCB GRANTS (TAGS}: As part of the Superfund program,
EPA provides communities with an opportunity to apply for Technical
Assistance Grants (TAG's). These grants of up to $50,000 are designed
to enable community groups to hire a technical advisor or consultant to
assist them in interpreting and commenting on site findings and the
planned cleanup. Citizens who are interested in the TAG program may
obtain on application package by calling or writing to the appropriate
address listed above.
A group of organized citizens known as "Hickman County Against Lethal
Trash (HALT)" expressed interest in obtaining a TAG. EPA submitted a
TAG Guidance Manual and an application to the group in September 1989.
--------------------------------------------------------------------
MAILrNG LIST ADDITIONS
Complete the address form below and mail to the address
provided to receive information regarding the Wrigley
Charcoal Superfund Site.
Name
Address
City, State, ZIP
Affiliation
Phone
Suzanne Durham - Community Relations
u.S. Environmental Protection Agency
345 Courtland St., N.E.
Atlanta, GA 30365
Coordinator
- Region IV
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.-
APPENDIX C
Sign-In Sheets From the Public Meeting:
. July 25, 1991, Lyles, Tennessee
"
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NAME/ADDRESS{fEl.EPIIONE NUMBER
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WRIGLEY CHARCOAL SUPERFL;;[) SITE
INTERIM ACTION ROD rlEETING
SIGN-IN SHEET
July 25 J 1991
REPRESENllNG
ADD TO
MAILING lJSI"7
(pU!A.SB a lOCK)
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NAME/ADDRBss/IEU!pJJONB NUMnI!R.
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WRIGLEY CHARCOAL SUPERFUND SITE
INTERIM ACTIDN ROD MEETING
SIGN-IN SHEET
July 25, 19n
IU!PRCSENnNG
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MA.JuNG usn
(PLl!AsBalECK)
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WH.IGLEY CHA!{COAL SUPERFlI:;[) SITE
INTERIM ACTION ROD MEETING
SIGN-IN SHEET
July 25. 1991
REPRlJSENIlNG
ADD l.U
MAlUNG usn
(pU!ASI! OlliClC)
HOW DID
YOU W'AR 01'
11 us MI.!1!llNG 7
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-------
APPENDIX D
Repository Information for the Wrigley Charcoal Site
-------
Wriqlev Charcoal Site Respository
Hickman County Memorial Library
120 West Swan Street
Centerville, Tennessee 37033
(615) 729-5130
Librarian/Director: Mary Pruett
HOURS OF OPERATION: Mon: 11-7, Tue-wed-Fri-Sat: 9-5,
Thur: 8-12, Sunday & Holidays Closed
Copy Machine Available: 15 cents per copy
-------
APPENDIX B
A Review of all potentially applicable ARARs for
the Interim Action at the Wrigley Charcoal Site
-------
carT NIl IIIAIfT -SPECI F I C AlMa AlII T1C8
..11ilCf CllMCIW. 51 n, "I GlFf, TEJlllESSEE
THE SAlt DlI8181i WATO ACT (SOWA) prOllLll;aud lIatiONl Pr;/II8ry Drinking Wattr Standard II.JIi-
Cont..inlnt L8¥8l1 (Mels) (40 CfR Part 141). Mels arl enforceable stand8rdl for cont..inlnts In publfe
drinking \MIter I~ly syst... They coneider not only he.ltll fKtors, but also the eeono8ic and t8dlnl~l
feasibility of r_Ing I cont..inlnt frt8 . \MIttr s~ly syst_- EPA ilIa Ilso prQp)led l18Jti- Contl8i-
nant L_l Cio8l1 (MelGa) for severll org."ic and inor!l8l'lic c~ ;n drinking IIIIter. MelGa arl
non-enforclable ;uiael inn that do not conliaer till tKhnical fe..Ibi l I ty of cont..inlnt r-Il.
Seeondary IIICls (40 CFR Plrt 143) .re not enforclable, but Irl Intended IS SlUiael Inn for cont..inlntl tllat
may .averslly If feet the aesthetic quality of drinking IIIIter, such IS tastl, odor, color, and appearenel,
Ind ..y detlr public Kceptanel of drlni:Ing watlr provided by pubic watlr syst_. The SOw. IICLs are
Ippllcable to intlrl. r.-dial Ktione for the Wrigley Charcoal Site. SeeOt'dlry Mels and MelGa Irl TlCa
for the sltl. licit dirctly _liable fOf' Interi. action ~ial altenwti- fOf' ~nbll Unit ~.
EPA IlEALTi ADYlscalES Irl non-enforceabll guldelinn (TICs) developed by tile EPA OfficI of Drinking Water
for ch..Icals tllat ..y be Intenaittently encountered in public water supply syst_. Health .avisories
.re Ivailable for short-tena, longer-tena, and lifetl.. Ixposures for I 10-kg child and/or. TO-kg .ault.
Health advisories ..y be pertinent for intlri. r88ldial actlone involving groundwater, ISpeeillly for
cont~Inants that Ire not r.oullted under the SOWA.
EPA NIIIBT YATO QUALITT alTOIA (AWQC) arl non-enforclabll guiael inn (TICs) that ...rl developed for
pollutantl In surfKI watlrs pursuant to Seetion 304(a)(1) of till Cllan Watlr Act. Although AWQC .rl not
ll9allyenforceabll, tlley hIve been used by 88nY Stat.. to devllop enforclable IIIItlr quality stand8rdl.
Aa a result, they should be conliaered aa potentill ARAaI, al speeifled by CUCLA. AWCIC .rl Ivai labll for
thl proteetion of h~ hlalth frOll exposurl to cont..Inanu in drinking IIIIter IS ...ll as frOll Ingestion
of ~tie biota and for thl proteetlon of frllh\MItlr and saltwater ~tlc llfl. AWQC I118Y be conlldered
for Ktlone that Involve ;r~atlr trlat~t and/or dlschar;es to surfael watlr. licit dirctly appllca-
bll fOf' Interi. action r~ill altenwti- fOf' ~ll Unit ~.
IfFODa DOSE (IAt), II aeflned in IRIS (thl EPA Integrlted Risk Infort8tion Syst_), Is an Istl..tl
(wltll In:erUInty spamlng perhapa an order of ","'tude) of a daily exposurl to thl h~ population
(including senaltive subgroupa) thlt Is liklly to Oe without an Ippreelabll risk of delltlrlous Iffeets
during a llfl-tl... IFDs Irl developed for chronie and/or sUbchronic h~ Ixposurl to hazlrdoua
ch..Icall and Irl baled on thl aSlu.ptlon that tllrlsholdl Ixilt for clrtain toaie Iffeetl. Thl RFD II
usually IxpresSed al an aeceptaell doll (III) per I6Ilt body ...igllt (kg) per ~It ti- (day). Thl RFD il
derived by dividing till no-obalrved-adversl Iffeet l_l (IIOAIL) or thl l_t-obalrved-.aversl IHeet
llvel (LOAEL) by ." In:lrtainty fKtor (UF) tl... a 80dlfying factor (IIF). Thl USI of In:lrtlinty flctors
and 80difying facto... Is dlscUised In thl EPA, OfficI of R..larch and Devll~t (ORD) Hlalth Effeeu
A..es_t S_ry Tael.., First QU8rter FY1989 ("ardl 1989 - ORD[JID-6I9]) (EPA, 1989c:). RFDI .re T8CI
for thl Wrigley Chlrcoal Site.
-
CAlCIIOIiEJIIC POTDCT FACTCIIS (CPF) are used for ..ti..ting tile lIfltl.. probability (aslu.d TO-Ylar life.
span) of h~ reeepto... contrKtlng caneer u a result of IXposurl to kncM\ or suspeeted carc:inog_.
These factors are e-rally reported in ~Its of kg-daY/III and are aerlved through an ISS~ low dosage
linear rllltlon8hlp and an Ixtrapolatlon frOll lIigll to low-dole rlSporwes aetel'llined frOll II~ or ani..l
studies. Caneer risk and CPFI ere _t cCIIIIDIly Isti..ted tllrough the use of I linelrized IILIltisuII
extrapolation IlXiel applied to ani..l bioa.NY resultl. Tile yalue used In reporting the Ilope factor II
the ugger 95 Dlreant confldenc:e li.it. CPFs are TICs for tile Wrigley Charcoal Sitl.
T. CLEAI All M:r (W) conelat. of tllr.. progr- for r~lr_tl that My be AAAI.: lIatlonal All!bient
Air Qu8llty Stend8rd8 (NAAQS) (40 CFI Part 50), National E8ilalons Stend8rd8 for Hlzard0u8 Air Pollutants
(IIESNAP.) (40 CFI Part 61), end New SourCI PlrfonI8nCe Stend8rd8 (NSPS) (40 CF. Plrt 60).
IIESMAPs, whfch are ..f..fon .tend8rd8 for sourc:e types (1.1., Industrial catl9Ori..), tllat ..it haz.rdous
air pollutants, are not lIklly to be applicaele or relevant and approprlatl to the wrigllY Charcoal Sitl
bec:8uae ttI8y ..,.. d8oIeloped fOt' . lp8Ciflc: lourel. -
Thl EPA ....,t.... dI. Itt.f_t and ..Intenencl of pri..ry and leeondary NAAClS, to proteet publ Ie hlal tll
and p&.tIl fe _U.re, rl8fl8Ctively. Th..1 stend8rds are not sourc:e-speeifle, but ratller arl Nit ional
li.itatfons on --iant air Intandld to proteet public 1I..lthand ...lfar.. Stat.. arl rlSporwibll for
1..",,1,.. eClSlpliancl with till NAAClS. R~ir_tI In an EPA.epproved St.tl l~l_Utlon Pl." (np) fOf'
the 18pl_t.tfon, ..intenencl and anforc_t of NAAClS, are potential AAAI. for tile wrigley Charcoal
Sitl. .
liSPS are ..ubllalled for new aourc.. of air _i..ione to _url tllat till new at8tionary lourc:.. recU:8
..I..lons to . .Ini_. These IUnd.r. arl for catesorl.. of IUtlonary sourCI tll.t c_. or contributl
to Ilr pollution dI.t ..y endanger public: IIlalth or ...lfarl. Stend8rd8 Ire ba.ed I4'CIn till best
~treted uchnology (lOAf). NSPS Irl g_rally not appllC:able to CnCLA Interl. r-.dlal Ktfone, but
MY be rllevant and appropriate to thl Wrigley Charc:oal Sitl If the pollut."t(l) _hted and the
technology -.played during tile cllanup action Irl lufflc:iantly 11.llar to the pollutant and lourc:.
CltegOry regulated by an liSPS and Irl well-suited to the cirCU8ltanc.. It the sitl.
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-
- .
LOCATICII-SP£CIFlC' AlMa A8 TICa
I8IG1Ef awtaw. SITE, ..IGU!, TEJaESSEE
FEDEIIAL PlDllCrICII or ~U8I ElEDlTIV£ OIDEI (E.O. 11990) provides 'or conslderltlon of weU....
~rl". Intert. r8ldtal actlorw. Tltls Executiv. Order Is to be considered a. i",l_ted by EPA'.
AU8\8t 6, 1M Policy on Flood Plains end Wetl..... bsesS8lf'lts for CERCLA Actions (CERCLA COIIIf:IUInC8
Policy). E.O. 11990 requires Federll Igeneies, In carrying out tlt.ir responsibilities, to take ICtfan
to .Inl.lla tit. destruction, lOl', or degrad8tlon of wetlands end to pres.rve and enhance tit. natural
and beneficial values of wetlanca. According to tlte pIotIllslted ,definition of national ..eU.,... (40 CF.,
Plrt 6, Appendl. C), tit. only Ir.a of tit. Wrigley Charcoal Sit. tltat appe.rs to qualify a. a wetlend
Ir.. I. In tit. vicinity of location LE.Ol on tit. Primary Wrigley Sit.. 'or tit is relson, 1.0. 11990 I.
alXlllcabl. to ICtlons Uken at tit. WrialltY Cltarcoal Sit..
TIE l1li.--.,. SPECIES M:T or 1971 (16 use 1531) (40 CFI Part 502) provides for consideration of th.
impact. on end8ngerid end thr.atened .pecies end tltelr critical Itabltat.. Tltl. ICt requires Federal
Igencles, In consultltlon ~itlt tit. Secretlry of tit. Int.rlor, to ensure tltat any action autltorlzed,
,fl6lded or carried out by tit. agency I. not likely to jeoperdlze tit. continued ..Istenc. of any end8n.
g.red or thr.atened species or Idv.rs.ly affect Its'crltlcal Itabltlt. A r.view of the Ivallabl. Infor.
mation indicates that no State or Federal ly.l Isted endang.red or thr.atened species Ir. ~ to
DeMllln8ntlv or seasonallv reside In tit. Irel Investloated.
TIE Fill A8 WILDLIFE exaDlUTICII M:T (16 use 661) provides for consideration of th. Impacts on wetll.
nds end protected habitat.. Tit. act requires tltat Federll action for tit. 8Odificatlon of any body of
~t.r .ust consult ~Ith th. approprlat. stat. Igency ,.,rcl.ing jurisdiction ov.r ~ildlif. resourc., to
cons.rve tho.. resources. Consultltion ~ith th. u.S. FIM and WildUf. S.rvice I. required beclUS.
tlt.r. Ir. ..etl.... or critical Itabltats In th. Ir.a of tit. Wrigley Charcoal Sit.. Th. FI.h end Wlldllf,
Coordination Act is IIXIUcabl. to actions Uken at tit, sit..
TIE Fill A8 WILDLIFE I~ M:T Of 1971 (16 use 7102a) end Th. FisII and Wildlife Conservltlon Act
2L.l2A2 (16 use 2901) provide for considerltion of tit. impacts on wetlands and protected ItabiUts.
8eclUS. th.r. a,.. wetllnda or critical habi-tats In th. lrea of tit. Wrigley Charcoal Sh. th.s. ICts ar.
IlXIliclbl. to ICtions tlken It th. sit.. . , .
EPA'S -~TD PIOTECTICII STlATE8'I (EPA, 1984) policy I. to protect gr~t.r for Its highest
present or potenttal beneficial us.. TIt. strat8IY designates thr.. cla..es and .ev.rll s*lus.. of
wet.r .. follow:
el..a 1: Special Gr~ter . Wat.rs thlt Ir. highly wl,.r.,l. to cont_lnatlon and are .hlt.r
Irreplac.abl. sources of drtnktng ...t.r or ecologically vital habitat..
Cla.. Z: Current end Potenttal Sources of Drinking Water and w.c.,.. Naving Oth.r leneflclal -Us.. .
Wat.r. that are currently used or that ar. potentially avallabl..
Si.D:l... 21 corwtltl of gr~ter ""Itl ~hh total dls.olved solidi great.r than 10,000~. Thil
...ter can be truted, and it I. a potantlal sourc. of drlnkl". ...t.r end oth.r beneficial uses.
Cl... 3: Gr~ter Not a Potant'al Source of Drink'ng Water and Llaited leneftctel U.. . el... 3
gr~ter ""it. a,.. furt"... ~Ividld Into two cl...es.
Si.D:l... ]A 'ncludls g~ter WI't. that are h'ghly to 'ntll"8ld'ately Intercomacted to adjacent
grcua.ater Witt. of . "'gher cl"'lIdIor aurface ...ters. They aay, .. a result, be contributing to
the dltr8d8t'an of the edjacent ...tlrs. They.y be ~ged .t a .'aUar level.. ella. 2 gr~t.r,
dependl", "'*' the potent,.l for pr--=Ing Idv..... Iffect. on the quaUty of adjacent ...ters.
Si.D:l... 31 f. I'88trtcted to g~ter characterized IDr . low dltr.. of tntercomactfon to adjacent
surface we.,.. or other .rcua.ater Wilt. of . higher cll" ~Ithln th. Cl...lflc.t'on levlftl'Are..
Th... II'CUIdII8t8r .... natur.Uy 'sol.ted froa sources of drinking ...ters tn .uch . ...y th.e th.re II
little potlntf.l for pr~l". adver.. effect. In ~lity. They II.". low r..ourc. values out.l. of
alnf", or _t. d'1p0881. .
.
~ ....... ... edJ..c to eM Yrfgl., awa.l Siee f. cl_fffed - . Cl- 21 ~df8r. lilt
directly ...,Ucabte for tntert. actton .....,.t elt8mlttws for """'..,,--,'e OIW.
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ACTICII-SP£CIFIC AUla AID TICa
llllCOlET 0WIaw. SITE. IllICOlET. TE8IIIESSEE
ICIA SUlTITLI C IE&UlATIOMS r~lata the treat88nt, torage. 8nd disposal of hazardous ..ste frQ8
g_ration tJll"OUIh ulti-te disposal. In TetYleSs.., thil progr- il .a.inilhred by the Ternes...
Depart88nt of PublicA] ,. ,AU1A\Divilion of Solid Waste Nanag-..nt. In general, ICRA Subtitle C
requir..entl for the treatment, Itorlge. or disposal of hazlrdous waste will be ~licable if:
.....
.
The waste II a listed or characteristic Wlste under ICIA, 8nd
.
The Wlste wal treated, stored, or dispoled (II defined In 40 CFI 260.10) after the effective
date of the ICtA requir888nts under considerltlon, or
.
The activity at the CEICLA site constitut.. current treatment, Itorage, or dispolal II defined
by ICU.
ICIA Sl8T1TU C IEClUIISElTS ..y be relev8nt 8nd 8R)rQFiue lOtI." the Interl. r8lll8d1il action consti-
tutes generation of a hazard0u8 "Ite. on-lite letiviti.., mandated by a Federally-ordered Superfund
cleanup, .uat c~ly with the luC8t8ntive requir..ents (i.e., pir8itl) of ICRA. All ICRA Subtitle ~
requir8n8ntl MUst be _t if the cleanup il not under Federal order and/or lOtI." the hazardous wast. s
moved off-lite.
The fOllowi". requlr_tl Included In the ICRA Subtitle C I~luions Ny pertain to the Wrigley
Charcoel Site:
.
Hazardous Wllte generator requlr8lentl (40 CFI Part 462).
Transportation requir8lentl (40 CFI Pert 262).
.
i .
I
.
Standards for owners and coerltorl of hlzardous WlIte treatment, storlge, and disposal
faciliti.. (40 CFI Part 264).
Interi. ItatUi Itandard. for ownerl 8nd operetorl of hazardous Wllte treatment, Itorage, and
dispo.al fleillti.. (40 CFI P.rt 265). A generator who treetl, Itor.., or dilpol.. of
hazardoua waste on-lite 8USt C08ply with ICRA Stlndar~ Acollcable to Generators of Hazardous
!!!!II (40 CFR Part 262). Th..e standaroa Include lII8I'Iif..t requlr8lentl, pre-trlnaport
requir888ntl (I.e., peckagl"., 18bell"., placardl".), recOrd-keepi". and reporting. The Itan-
dera- are applicable to letlons taken at the Wrigley Charcoel Site that constitute generation
of a hazerdous Wllte (t.e. lIIIIV8n8nt of hazardous waste out of the area c:. :ont..ination).
STAID... NlPt.ICAILI TO ~TEIS OF WMDCIJS WASTE (40 CFI Part 263) Ire ~tlcable to off'sitl
tranaportatlon of hazerdoua walt. frQ8 the Wrigley Charcoal Sit.. Th... rl9Ulatlons include require-
mentl for cOMplianc. with the -.nif..t and record-keepi". lyat... and requir888ntl for l-.edlate letion
and cl~anup of hazardous wast. dlschari.. (IDIIls) ca..ri". transDOrtation-
STAIIJMDS FGI ~ AID CllElATOIS OF ~ WASTE T1£ATIEJIT FACILITIES (TSOF.) (40 CFR Plrt 264)
ar. ~llcabl. to Interi. r8l8d111 letlons taken at the site and to offllt. facilities recllvi".
hazardoua wast. frQ8 thl lit. for tr.at88nt and/or dllpOlal and h.Ye a ICIA Part' per8it if the litl
II not a Federally ord8red crRC1A cleanup- Standara- for TSOFI include requlr--.ntl for preparednes.
and pr...,..,tion, r.le... fra solid wast. 8In88888nt ~itl (I..., corrective action requir_u),
cloaure and PD8t-cloaure care, tent lyat..., surfac. l~tI, wast. pil.., landfllll, and
incinerators.
~
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."
APPENDIX F
Acceptable Soil Concentrations CASCs) for the Wrigley
Charcoal Site
-------
APPENDIX F
ACCEPTABLE SOIL CONCENTRATIONS (ASCS') FOR THE
WRIGLEY CHARCOAL SITE (PPH)
Combined Target Risk <=1.0E-5
CARCINOGENIC COMPOUNDS ASCI 11 (PPM) BACKGROUND RME (PPM)
Dioxin TCDD TEQ «10-6) 5.22£-05 ND (2) 1.0E-3 (3)
Carcinogenic PARs 8.17 ND (2) ( 4 )
NON-CARCINOGENIC COMPOUNDS
Alkyl Benzenes 5,450 ND (2) ( 4 )
Barium 4,330 15-72 72
Copper 3,200 ND-38 38
Mercury 26.0 ND 0.1
Manganese I 17,300 210-740 740
PARs 34,600 (4) ( 4 )
Lead 1,000 (5) 8.6-17 17
Phenols 107 ND (2) 480
Antimony 34.6 ND 20
-
Zinc 17,300 34-340 340
* Numbers in parentheses following ASCs are defined below:
1) Percentage confidence that a soil cone. less than this value will
achieve the 1E-05 (1E-06 for dioxin) target risk or a 1.20 hazard
index using the stated exposure assumptions.
2) No organic contam. detected other than total organic carbon.
3) Based on currently accepted target concentration of 1000 ppt TEQ
4) Value varies with specific compounds in group
5) Recommended lead cleanup level for a light industrial site
-------
APPENDIX G
Letters of Concurrence
-------
STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
Sep,:e:7lbe:- 11,
199~
Mr. Douglas A. Bell, P. G.
Remedial Project Ma~ager
Nort~ Superfund Remedial Branct
USEPA - Region IV
345 Courtland St., N.E.
Atlanta, GA 30365
RE: Wrigley Charcoal Superfund Site #41-504
wear Mr. Be.:.l:
Personnel from the Division of Superfund of the Tennessee Department
of Environment and Conservation have reviewed the above re:erenced
document and find it acceptable to meet the desired objectives for
the site. We concur that addressing the surface waste debris is the
appropriate first step. This off ice agrees that once the s i t:e
surface material is removed, the more important aspects of the site
can be addressed such as the tar pit waste and the determlnation of
groundwater conditions, etc.
The only comment concerning the Draft ROD is an explanation of some
of the costs. An estimate of $49,000 to collect and contain
transformers in drums and stage them on site appears somewhat
excessive. Also, we request a schedule of events when it is
formulated. This Division feels that the study of the spillway
redesign should proceed the actual field implementation, thereby
allowing review of the design. It is desired that this office be
allowed an appropriate review and comment period prior to final
design.
If you have any further comments or questions
response please call me at (615) 741-6287.
concerning
this
Sincerely yours,
lJflV~R~
Field Office Coordinator
Division of Superfund
-------
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"
TENNESSEE DEPARTMENT OF CONSERVATioN
ENVIRONMENTAL FIELD OFFICE
537 BRICK CHURCH PARK DRIVE
NASHVILLE, TENNESSEE 37243-1550
September 25~ 1991
Mr. Douglas A. Bell, P.G.
Remedial Project Manager
North Superfund Remedial
345 Courtland St. N.E.
Atlanta, Georgia 30365
Branch
RE: Wrigley Charcoal Sit~ #41-504
SUbject: Acceptance of the Final Interim Action ROD
Dear Mr. Bell:
Personnel of the Tennessee Division of Superfund have reviewed
the Final Interim Action ROD for the Wrigley Charcoal Site and
find it acceptable to meet the present objectives for eliminating
surficial concerns at the site. Thank you for your consideration
and inclusion of Our alternatives for interim action at various
areas of the site. It'is our desire to continue working with you
to achieve a well thought out and effective cleanup of this site
minimizing costs to all parties concerned.
If you have any further comments or questions concerning State of
Tennessee involvement in this matter please contact me at (615)
741-6287 or ~obert Powell, Project Manager, at (615) 741-5940.
Sincerely,
R~" f\,\. ~',.,~.~
Ralph M. Sinclair
Director
Division of Superfund
.
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