PB95-963129
EPA/AMD/R04-95/214
March 1995
EPA Superfund
Record of Decision Amendment:
Wrigley Charcoal Superfund
Site, Wrigley, TN
2/2/1995
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United States
Environmental Protection Agency
Region IV
Amendment to Interim Action Record of Decision
Wrigley Charcoal Site
February 1995
AMENDMENT
TO THE INTERIM ACTION RECORD OF DECISION:
WRIGLEY CHARCOAL SUPERFUND SITE
WRIGLEY, HICKMAN COUNTY, TENNESSEE
FEBRUARY 1995
PREPARED
BY
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
DECLARATION FOR THE AMENDMENT
TO THE RECORD OF DECISION
SITE NAME AND LOCATION
Wrigley Charcoal Site
Wrigley, Hickman County, Tennessee
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected Interim Remedial
Action (IRA) for the Wrigley Charcoal Site, in Wrigley, Hickman
County, Tennessee, chosen in accordance with CERCLA, as amended
by.SARA and, to the extent practicable, the National Contingency
Plan. This decision is based on the administrative record file
for the Site.
The State of Tennessee concurs with the United States
Environmental Protection Agency on the selected Interim Remedial
Action as amended .within this document.
ASSESSMENT OF THE SITE .
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing this response action
selected in this ROD Amendment, 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)
supplemental sampling and analysis, and additional information
generated as part of the first phase of the Interim Remedial
Action (1993-1994), the U.S. EPA has modified a wide variety of
items that require immediate response action for the first step
of cleanup activities to be taken at the Wrigley Charcoal Site.
The major goal of these cleanup activities is to address the most
serious threats at the Wrigley Charcoal Site by removing
contaminated media from the Primary Site flood plain, remediating
wastes at the Storage Basin, and through limited access
restrictions at the Primary Site and the Storage Basin. The
cleanup activities as presented in this IRA Record of Decision
(ROD) Amendment will achieve significant risk reduction and will
prepare the Site for future remedial activities. Information
generated by these IRA activities will assist in the development
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
of the final remedial solution for the Wrigley Site.
The major components of the selected remedy include:
STORAGE BASIN ACTIVITIES
1) Removal, treatment (if necessary), and disposal of waters at
the Storage Basin. The approximate volume is estimated at
50,000 gallons;
2) Removal off-site of Storage Basin wood-tars and associated
contaminated soils, appropriate disposal and/or treatment,
or utilization of these wastes as fuel. The volume of raw
sludge is estimated.-at 300-400 cubic yards;
3) Associated wood tar contaminated soils at or below the
tar/soil interface will be removed for disposal in a RCRA
Subtitle D landfill. The volume of this material is
estimated at 200 cubic yards;
4) A minor amount of wood tar contaminated soil will be removed
from the Overflow Basin. This material is expected to be
less than 60 cubic yards and will be disposed in a RCRA
Subtitle D facility;
5) The existing Storage Basin clay berms will be. used for clay
cover material once the tar and associated soil has been
removed. Since the Storage Basin is perched on top of a
hill the finished upper surface can be contoured to conform
with the existing topography. An upper dome configuration
to enhance drainage is required to prevent infiltration of
water. The Overflow Basin will also be contoured to prevent
water from accumulating;
6) Air monitoring will be performed at the Storage Basin during
excavation and removal of wood tars;
7) At the conclusion of Storage Basin Activities, the road to
this area will need to be removed. This will prevent
unauthorized access to this area and help to reduce
vandalism.
PRIMARY SITE ACTIVITIES
1) The.Primary Site Smoke Stack and Retort areas will require
further removal of metallic or other debris and excessive
vegetation to aid in future sampling prior to cleanup. The
total amount of materials.removed from .these locations are
estimated at approximately 200 cubic yards. This debris
(including many empty drums) may be placed into an on-site
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
building or decontaminated (if necessary) and transported
from the Site to a recycling facility;
2} A small earthen dam will be eliminated by removing the lower
concrete wall. This activity is required since waters
accumulating at this location are likely entering an hidden
underground conduit and exiting a 16 inch pipe at the Still
House area. It is estimated that 10 cubic yards of non-
hazardous debris will be removed from this location. This
may be staged with other.concrete adjacent to this location
or disposed at a RCRA Subtitle D facility.
3) EPA plans to perform a minor investigative effort following
Phase II remedial efforts. During this effort, additional
monitoring wells and soil borings will be placed
downgradient of the Storage Basin and Still House foundation
sump. These monitoring points will serve to assess the .
impact, if any, of the Phase I remedial activities at these
locations. In addition, surface water samples should be
obtained from the leachate seeps in the spillway. This
information should determine if conditions have changed
since spillway reconstruction in 1993;
4) Air monitoring was recently conducted at the Site following
Phase I remedial activities. This monitoring was performed
to assess the impact, if any, of the Phase I-cleanup
activities. Once the final results of the data have been
submitted, they will be evaluated to determine if any
impacts have occurred. If adverse conditions are
identified, EPA and the State will determine how they can be
reduced, and implement an appropriate solution.
DECLARATION
The Selected Remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the IRA,
and is cost-effective. This remedy utilizes permanent solutions
and alternative treatment technologies to the maximum extent
practicable for this Site. This remedy does satisfy the
statutory preference for treatment as the principal element of
the remedy concerning the Storage Basin.
This IRA as Amended does not constitute the final remedy for the
Wrigley Charcoal Site. 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
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United States
Environmental Protection Agency
Region IV
Amendment to Interim Action Record of Decision
Wrigley Charcoal Site
February 1995
within five years after commencement of the remedial action as
EPA continues to develop final remedial alternatives for the
Wrigley Charcoal Site. The review will be conducted to ensure
that the remedy continues to provide adequate protection of human
health and the environment. Because this is an interim action
POD, 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.
<\6
Richard Green, Associate Director
Waste Management Division
Date
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
TABLE OF CONTENTS
1.0 INTRODUCTION -1-
1.1 Site Name and Description -1-
1.2 . Summary of Site History -3-
1.3 Waste Handling Procedures and Contamination
Problems -5-
1.4 Designation of Tar Wastes -6-
1.5 Explanation of Fundamental Remedy Changes -7-
2.0 DESCRIPTION OF ORIGINAL SELECTED REMEDY AND NEW PROPOSED
REMEDY -15-
2.1 Alternative 2 - Address Primary Site imminent
concerns as described in Tables 1 & 2 -16-
2.2 Alternative 3 Modifies Original Remedy as
described in Tables 1 & 2 -16-
3.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . . . -16-
3.1 Overall Protection of Human Health and the
Environment -17-
3.2 Compliance with Applicable or Relevant and
Appropriate Requirements -17-
3.2.1 Action Specific ARARs -18-
3.2.2 -Location Specific ARARs . -18-
3.2.3 Contaminant Specific ARARs: ....... -18-
3.3 Long-Term Effectiveness -19-
.3.4 Reduction of Toxicity, Mobility or Volume .... -19-
3.5 Short-Term Effectiveness -20-
3.6 Implement ability -20-
3.7 Cost -20-
3.8 State Acceptance -20-
3.9 Community Acceptance -21-
4.0 SELECTED REMEDY -21-
5.0 Statutory Requirements . -23-
5.1 Protection of Human Health and the Environment . -23-
5.2 Attainment of the Applicable or Relevant and
Appropriate Requirements (ARARs) -23-
5.3 Cost Effectiveness. -23-
5.4 Utilization of Permanent Solutions and Alternative
Treatment Technology or Resource Recovery
technologies to the Maximum
Extent Practicable -24-
5.5 Preference for Treatment -24-
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
6.0 Support Agency Comments -25-
7.0 . Affirmation of the Statutory Determinations -25-
FIGURES
FIGURE 1) MAP OF THE WRIGLEY CHARCOAL SITE -2-
FIGURE 2) MAP OF PRIMARY SITE STRUCTURES -4-
TABLES
TABLE 1) SIGNIFICANT DIFFERENCES BETWEEN ORIGINAL IAROD AND
MODIFIED ACTIVITIES -8-
TABLE 2) ADDITIONAL INTERIM REMEDIAL ACTION
ACTIVITIES (PHASE I) -12-
TABLE 3) STORAGE BASIN REMEDIAL ACTIVITIES INTERIM REMEDIAL
ACTION (PHASE II) -13-
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
AMENDMENT TO THE INTERIM ACTION RECORD OF DECISION
Summary of Remedial Alternative Selection
Wrigley Charcoal Site, Wrigley
Hickman County, Tennessee
1.0 INTRODUCTION
This document constitutes an Amendment to the September 1991
Interim Remedial Action Record of Decision (IAROD). This
document is necessary to adequately support and provide public
notice of a wide variety-of IAROD activity modifications and
several new activities. Work commenced on activities as
presented in the IAROD in October 1993. During the early part of
this IRA, a variety of additional information was generated that
EPA and the State of Tennessee believe should modify the existing
selected "Interim" Remedy. In response, the U.S. Environmental
Protection Agency (EPA) has prepared a ROD Amendment that
provides a full explanation and comparison of old and enhanced
Site IRA activities. Based on this new information, the IRA will
be divided into two phases: 1) Phase I that consists of the
majority of previously selected remedial items, and 2) Phase II .
that will consist of new activities.
Major 'differences in Phase I include: 1) the elimination of an
on-site consolidation area, 2) off-site disposal of tar-cubes,
metallic debris, waste, piles, and wood-tar wastes. New
activities to be conducted as Phase II of the IRA consist of: 1)
removal, treatment (if necessary) and disposal waters at the
Storage Basin, 2) removal off-site of Storage Basin wood-tars and
associated contaminated soils, appropriate disposal and/or
treatment, or utilization of these wastes as-fuel, 3) air
monitoring at the Primary Site and the Storage Basin, and 4)
additional monitoring wells and soil borings downgradient of the
Storage Basin and Still House foundation sump (this activity to
be conducted by EPA).
1.1 Site Name and Description
The Wrigley Charcoal Superfund Site (the "Site") is located in
Wrigley, Hickman County, Tennessee. This Site is approximately
45 miles southwest of Nashville, Tennessee. The Wrigley Charcoal
Superfund Site, as depicted in (Figure 1), consists of four
distinct areas: 1) the 35 acre Primary Site (acreage represents
the extent of industrial activities in the valley), 2) the three
acre Storage Basin (and an adjacent area called Clark Hollow), 3)
the forty acre Irrigation Field, and 4) the three and one half
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IRRIGATION FIELD
APPROXIMATE
PROPERTY
BOUNDARY
o tag xn 'tag 1000
GRAPHIC SCALE IN FECT
OVERFLOW
BASIN
PROJECT:
WRIGLEY CHARCOAL SITE
MAP TITLE:
FACILITY SITE LOCATION AREAS
PREPARED FOR:
U.S.E.P.A. REGION IV ATLANTA. GA
REMEDIAL PROJECT MANAGER - DA BELL
APPROXIMATE
PROPERTY
BOUNDARY
GLARK
HOLLOW
STREAM
"" ELEVATION
[ ___ J RESIDENTIAL
UNIVERSITY OF CINCINNATI
0098 Center Hill Rood
Cincinnati. OH 40224
DRW BY EBS
DATE 10/28/91
[~~1 INDUSTRIAL
CHK BY KMS
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
acre Athletic Field.
The ROD Amendment is being issued by the EPA, however,
activities concerning the IRA (also known -as Operable Unit 1 (OU-
1)) are being conducted by the State of Tennessee through
Cooperative Agreements. Due to fundamental changes in the
Selected Remedy, the Agency has decided to amend the 1991 ROD
pursuant to the National Contingency Plan (NCP), 40 C.F.R.
Section 300.435 (c)(2)(ii).
This document includes information that will serve to clarify
information previously outlined in the IAROD. The Administrative
Record contains the information upon which the IAROD was based.
This IAROD Amendment and-supporting documentation will become a
part of that Administrative Record which is location in the
following places:
Hickman County Public Library
120 West Swan Street
Centerville, Tennessee 37033
(615) 729-5130
Superfund Records Center
345 Courtland Street, N;E.
Atlanta, Georgia 30365
(404) 347-7791 .
1.2 Summary of Site History
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 Storage Basin and
Irrigation Field were utilized by the Tennessee Products and
Chemical Corporation for the disposal contaminated Site
wastewaters beginning in the 1940's and continuing until the mid-
1960 's. The Athletic Field was constructed at the previous
location of a large ravine in the town of Wrigley. Slag and
soils derived from the Primary Site were utilized to fill this
area from 1938-1950 when the .field was opened. The field has
been in use since the early 1950's and is still regularly used by
local residents.
The businesses or individuals involved in the industrial .
operations during this time period no longer exist and previous .
investigations indicated there are no Potentially Responsible
Parties (PRPs) from this time period that may fund cleanup
operations. The Site was purchased in 1966 by the Tennessee
Farmers Cooperative (TFC) who are the present owners (as the
present landowners are a PRP) of most Site areas. Portions of
the Primary Site were also utilized from 1978 to 1983 by R.T.
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100 200 300
=s
GRAPHIC SCAIE IN FEET
I
1) PROCESS TANKS
2) DRYER BUILDING
3) MAINTENANCE BUILDING
4) CARPENTER SHED
5) RAIL HOPPERS
6) WAREHOUSE BUILDING
7) STORAGE SHED
8) SAWMILL
9) POWER PLANT STACK
10) PRODUCT TANK FOUNDATION
11) ELECTRIC SUB-STATION
12) RAW LIQUOR STORAGE
TANK FOUNDATION
13) FORMER RETORT AREA
14) TAR PITS
\x \ ^jjwit / 6 y *°-&\ \
^L^' yffXp,LLWAY < / \
\ -/ RIP-RAP \ / s \\
\ "'""" \/ ^S \\
^ ' __^- , " "^ ') ',
/ ~~ ^ - \ // //
/ \v/
APPROXIMATE AREA OK -/ P? /- "->\ ) ///
PRIMARY WRIGLEY SITE ^ ^> V / '
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}* 15) FORMER STILLHOUSE FOUNDATION
// 16) FORMER BLAST FURNACE AREA
.K
!/
PROJECT:
WRIGLEY -CHARCOAL SITE
MAP TITLE:
PRIMARY SITE LAYOUT
PREPARED FOR:
U.S.E.P.A. REGION IV ATLANTA. GA
REMEDIAL PROJECT MANAGER - D.A. BELL
PREPARED BY:
B3B UNIVERSITY OF CINCINNATI
\t* ^ 3890 Center Hill Road
gSq Cincinnati. OH 48224
FILE WRICOLO.OWO DRW BY EBS DATE 10/15/91
CHK BY KMS FIGORE 2
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
Rivers (another PRP) 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 (Figure 2).
1.3 Waste Handling Procedures and Contamination Problems
Much of the waste at the Wrigley Site was disposed into the
North Fork of Mill Creek. This practice occurred until the mid-
1940 's when the State of Tennessee requested that the TPCC
identify adequate alternatives to their waste disposal
procedures. The TPCC. constructed wastewater impoundments,
investigated spray irrigation and trickling filter technology in
an attempt to degrade phenolic and PAH contaminated wastestreams.
These attempts to reduce or impound contaminated wastestreams
inadvertently led to additional areas of contamination. In
addition, the overall condition of the facility-was poor and
spills of VOCs and semi-volatile organic compounds (SVOCs) were
commonplace.
The Primary Site is now abandoned but significant
contamination exists in abundant waste piles, soils, buildings,
tar-pits, and in the above ground storage tanks (called the
.process tanks). Variable levels of contamination-has been
identified in stream sediments, fish in the North Fork of Mill
Creek, and in the shallow groundwater. These areas contain
hazardous substances identified as phenol, 2,4-dimethylphenol,
benzene, toluene, polycyclic aromatic hydrocarbons (PAHs), an
abundant variety of metals, halocarbons, asbestos, and traces of
furans, dibenzofurans and dioxins.
The Storage Basin located 1400 feet west of the Primary Site
contains within the deeper sediments high levels of SVOCs, VOCs,
and metals.
The Irrigation Field (and associated wastewater collection
lagoon) located 3500 feet northeast of the Primary Site appears
to have relatively low levels of SVOC, VOC, and metals
contamination.
The Athletic Field is located 800 feet southeast of the
Primary Site in the east portion of the Wrigley community.
Athletic Field subsurface soil .analyses showed the presence of
relatively low levels of lead, copper, zinc PAHs, toluene,
xylene, and trace levels of dibenzofuran, furans and dioxins.
Contaminants are all at levels well below the level of concern
with the exception of one sample taken outside the outfield fence
that had elevated levels of metals. Follow-up sampling indicated
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
this was an isolated sample and that the soils do not pose a
problem at this location.
1.4 Designation of Tar Wastes
Wastes a.t the Wrigley Charcoal Site have been historically
discussed as coal-tar wastes from coking operations. These
wastes were previously considered to be K-listed RCRA wastes by
the Emergency Response and Removal Branch (ERRB) during an
emergency response effort in 1988. These wastes were handled by
ERRB as K087 (sludges from coking operations) wastes and. 130
cubic yards of tar waste was transported and disposed at the
Allied Signal facility in Detroit, Michigan. If the coking
operation designation were to be employed to describe Wrigley
Site wastes, process tank waste sludges could be classified as
K142 - tar storage tank residues from the production of coke from
coal or from the recovery of coke by-products produced from coal.
However, the Wrigley Charcoal Site never received coal for the.
manufacture of coke to fuel the blast furnaces. The Wrigley
Charcoal Site retorted (or distilled) local hardwood trees from
the 3,000-acre facility to produce charcoal for the pig-iron
blast furnace. Considering the fact that this Site never
formally maintained a coking operation, it is reasonable to
conclude that tar waste from the Wrigley Charcoal Site can be
referred to as "wood-tar" and not "coal-tar" that is a K-listed
waste under RCRA. While the Wrigley tars do not fit the profile
of a K-listed waste, it is important to note that the tars also
have constituents in which the K-listed wastes are based. These
constituents are phenol and naphthalene. Phenols have been
identified in very high concentrations at the Site and compounds
related to naphthalene (methyl-naphthalene) have also been
identified.
In spite of high concentrations of phenols, elevated PAHs, and
high levels of tentatively identified compounds which include
hydrocarbons, recently sampled wood-tar wastes have passed TCLP
tests conducted through TDSF. Based upon the above information,
the EPA Remedial and RCRA programs and TDSF consider this waste
to be classified as a RCRA solid waste and may be utilized as an
fuel in an industrial furnace or boiler. Since these wastes are
classified as RCRA solid wastes, they will not be subject to 40
CFR Part 260 which refers to Burning of Hazardous Waste in
Boilers and Industrial Furnaces (BIF Regulations). In the event
off-site incineration is elected, these wastes will not be
required to go to a RCRA permitted or interim status facility (in
other words a BIF facility). Any facility that does receive this
waste will be required by EPA and State of Tennessee to
demonstrate the material can be eliminated within specified
guidelines as set forth by the Air Pollution Division of the
State of Tennessee and 'the EPA, as well as demonstrate the
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
residual ash can be handled in accordance with protective
procedures that will be outlined as part of the forthcoming
remedial design.
In addition, the wood-tar wastes at the Wrigley Site have been
sampled for dioxins and all levels identified have been well
below the action level of 1 ppb. The State of Tennessee has
reviewed all of this data and has concluded that these trace
levels of dioxins, furans, and dibenzofurans do not present a
problem for off-site transport and incineration at a boiler- or
industrial furnace. In the event the material is utilized in a
boiler or industrial furnace, the facility that receives the
waste must apply for a.State of Tennessee permit for the
incineration of the woodrtar as well as present a compliance
monitoring plan that describes the regulatory limits that will be
maintained during the incineration of the wood-tars. The subject
incineration facility must also submit an evaluation of ash
handling and disposal procedures in order that the residual
material is handled in accordance with State and Federal
regulatory guidelines.
1.5 Explanation of Fundamental Remedy Changes
Significant modifications to the IRA are outlined in Table 1;
Additional activities that are now required as part of Phase I''
are summarized within Table 2. Phase II activities now required
at the Storage Basin are outlined in Table 3. The selected
remedy and subsequent modifications within this ROD Amendment
include many off-site disposal activities instead of temporary
storage in an on-site containment area. This change is required
at the Wrigley Site since: 1) much of the Site lies within the
100-year floodplain, 2) larger quantities of sludges were
encountered in the Process Tanks and at the Still House, 3)
vandalism and theft at the Site has recently become a significant
problem, and 4) certain mixed Site wastes have passed TCLP and
are suitable for disposal in RCRA Subtitle D facilities.
Concerning Site flooding, the flood of 1991 demonstrated that
this Site floods much worse than previously thought since several
areas outside of the 100-year floodplain were also affected.
Many areas that were not underwater during this flood were the
Sites of significant soil slumping, debris flows, and small
mudslides. Based upon our observations, the Primary Site and
Storage Basin area appear to be unfit as potential locations for
any type of on-site disposal (landfilling, etc). In light of
these difficulties, we have elected to transport and dispose of
many Site wastes. This provides more stable and safe Site areas
and will .significantly reduce the potential for Site wastes to
enter and affect the North Fork of Mill Creek, Mill Creek, and
the Duck River Drainage Basin.
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United States
Environmental Protection Agency
Region IV
Amendment to Interim Action Record of Decision
Wrigley Charcoal Site
February 1995
TABLE 1
SIGNIFICANT DIFFERENCES BETWEEN ORIGINAL IAROD
AND MODIFIED* ACTIVITIES
These modifications have already been accomplished
per State of Tennessee Field Changes with the exception
of Storage Basin remediation.
ORIGINAL ACTIVITY
MODIFIED ACTIVITY
1) Metallic wastes in the maintenance
buildings' burn-pit will be excavated,
transported, stabilized and disposed 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-srte
consolidation area.
Interim Action Phase 1 remedial efforts identified 1) transformer
carcasses, and 2) transformers filled with non-PCB containing tar.
These materials will be transported and disposed in a RCRA
Subtitle D facility. In addition, at the present time the State of
Tennessee has determined that a Site waste debris can be
effectively removed from the flood plain and disposed in EPA
approved RCRA facilities. Given these circumstances, the on-site
containment facility will not be necessary.
2) Process tank waste sludges will be
excavated, transported, incinerated,
stabilized and disposed in an EPA
approved facility. The metallic tanks will
be decontaminated and sold as scrap.
Tank wastes were estimated at 29 cy. More raw sludge was
encountered below solid tar wastes. The increase amounted to
an additional 15 cy. The wastes have passed TCLP and can be
classified as non-hazardous solid wastes that may be recycled.
The concrete foundations will be decontaminated, removed, and
disposed of as construction debris in an EPA or State approved
landfill.
3) 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.
Mixed wastes and soil may be excavated, transported off-site,
and stabilized in an EPA approved RCRA Subtitle D facility. Due
to a very steep grade of the hill, the excavated area was graded
and seeded. The adjacent area was reinforced with riprap
extending approximately 20 feet down and towards the North
Fork of Mill Creek. This was needed to prevent erosion or
potential failure of this excavated area into the creek.
4) The surficial coal-tars at the NE corner
of the Still House are to be excavated to
approximately 1 ft. depth (3.5 cy)
The Still House foundation sump was excavated per State change
orders to approximately 4 ft (instead of 1 ft) during phase 1 of the
Interim Action. Approximately 45 cy of this material was
excavated. This material has passed TCLP and may be classified
as non-hazardous solid waste and recycled as fuel.
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United States
Environmental Protection Agency
Region IV
Amendment to Interim Action Record of Decision
Wrigley Charcoal Site
February 1995
TABLE 1
SIGNIFICANT DIFFERENCES BETWEEN ORIGINAL IAROD
AND MODIFIED* ACTIVITIES
These modifications have already been accomplished
per State of Tennessee Field Changes with the exception
of Storage Basin remediation.
ORIGINAL ACTIVITY
MODIFIED ACTIVITY
5} Friable asbestos corrugated roofing
material (ACM) will be removed for
disposal in an approved asbestos landfill.
Wastes are on the small building in from
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.
Visibly friable ACM was removed from the small building in front
of the Maintenance Building, and ACM on the ground may be
placed into 20 cubic yard containers. The ACM was tested and
disposed in an EPA approved landfill. Visual identification of
asbestos contaminated soils is difficult in areas of extensive
mixed wastes and debris piles. Therefore, removal of any
asbestos contaminated soils is to be performed as part of more
extensive excavation efforts (Operable Unit 2) at the Still House
since the Tank Battery, Dryer and Maintenance Buildings are
adjacent to this area.
6) Exposed black coal-tar wastes in the
spillway may be excavated, transported,
incinerated, stabilized and disposed in an
EPA approved facility.
Wastes located in the spillway were determined to be
predominantly soils blackened with charcoal. This material was
determined not to be teachable (passed TCLP) and contains no
raw coal-tar sludges. This material was disposed in a RCRA
Subtitle D facility.
7) 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.
Wastes in 14 deteriorating drums were emptied into 3 lined 20
cubic yard containers and sampled. Based upon the results,
these wastes were eliminated at an approved EPA facility. The
emptied drums were decontaminated and disposed.
8} 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 (additional
information concerning the spillway is
presented: on p, 47), This is considered to
be an interim activity;
No modification.
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United States
Environmental Protection Agency
Region IV
Amendment to Interim Action Record of Decision
Wrigley Charcoal Site
February 1995
TABLE 1
SIGNIFICANT DIFFERENCES BETWEEN ORIGINAL IAROD
AND MODIFIED* ACTIVITIES
These modifications have already been accomplished
per State of Tennessee Field Changes with the exception
of Storage Basin remediation.
ORIGINAL ACTIVITY
MODIRED ACTIVITY
9) 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 Remedial Design (RD) it is
determined that metals debris is to remain
on-site, this waste will be placed in the on-
stte consolidation area] Materials such as
ter-cubes and wastes that may be
. remediated during later remedial activities
will be stored in an on-site consolidation
area.
Tar-cubes were recently tested and passed TCLP. These cubes
and other materials containing low levels of contaminants were
disposed in a RCRA Subtitle D facility.
Waste debris piles were determined during sorting to contain
predominantly tar-cube chips and/or tar contaminated soils.
These entire remaining contents of these piles were excavated
and removed from the flood plain and disposed in a Subtitle D
facility. The materials did not require stabilization as during
testing, these wastes passed TCLP.
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 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;
No modification.
11) Site access controls including fencing
and placards will be implemented at the
Primary Site.
Due to the high probability of theft, steep Site valley walls, and
isolated Site location, gates and short sections of adjoining fence
were utilized at the east and south entrances of the Primary Site.
12) Sampling and Analyses
No Modification.
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United States
Environmental Protection Agency
Region IV
Amendment to Interim Action Record of Decision
Wrigley Charcoal Site
February 1995
TABLE 1
SIGNIFICANT DIFFERENCES BETWEEN ORIGINAL IAROD
AND MODIFIED' ACTIVITIES
These modifications have already been accomplished
per State of Tennessee Field Changes with the exception
of Storage Basin remediation.
ORIGINAL ACTIVITY
MODIFIED ACTIVITY
13) 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.
During OU-1 (Phase I) EPA and Tennessee evaluated the need for
immediate Storage Basin remediation. As Storage Basin waste
remediation appeared imminent and some of the wood-tar was
needed for a State treatabilrty study, a State field change was
made to regrade the road to the basin. Since Storage Basin
wastes are to be completely remediated, there will be no need to
fence the location following cleanup efforts. Once remedial
activities have been completed, the access road will be
eliminated with the area graded and seeded. Additional activities
for the Storage Basin are listed in Table 2.
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United States
Environmental Protection Agency
Region IV
Amendment to Interim Action Record of Decision
Wrigley Charcoal Site
February 1995
TABLE 2
ADDITIONAL INTERIM REMEDIAL ACTION ACTIVITIES
PHASE!
ADDITIONAL PHASE I ACTIVITY
ESTIMATED COSTS
TIME TO IMPLEMENT
1) Various debris (including scattered transformers)
was cleaned out of the Dryer building so that the area
could be utilized as a staging area during bad weather
conditions.
$2,500
1 Week
2) Slope stabilization was needed at the base of the
excavation near the North Fork of Mill Creek below the
Process Tanks. Approximately 3 cy of riprap, 3 cy of
borrow clay, and 20 linear feet of synthetic cover were
utilized to prevent excessive erosion of this area
adjacent to the creek.
$3,000
1 Week
3) Surficial waters originating from the unnamed
tributary next to Storage Shed are ponding down
stream in the former area of the retort sumps.
Portions of concrete slabs should be moved so waters
can flow freely through this area without entering any
relict Site piping that may discharge near the Still
-House.
$2,500
2 Days
4) Metallic and loose surficial debris should be
removed from an area around the smoke stack
northeast to the access road down to the North Fork of
Mill Creek. A geophysical survey will likely be
implemented in this area in the future in order to
identify any possible underground storage tanks that
may reside at this location.
$5,000
1 Week
5) While invasive activities were mandatory at the Still
House Foundation Sump (due to expansion of wastes
in this contained area), they have been kept to a
minimum during this Interim Action to reduce any
potential fugitive emissions. Rl data indicated that
invasive activities greatly increase the fugitive air
emissions. It will be necessary to monitor the ambient
air and take grab samples from the perimeter of the
Still House to better establish baseline VOC emissions
at this location. During this cooperative State/EPA
effort the data generated will assist with the selection
or art appropriate cleanup method for OU-2 which is
proposed to eliminate wastes at this location.
$2,000
1 Month
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United States
Environmental Protection Agency
Region IV
Amendment to Interim Action Record of Decision
Wrigley Charcoal Site
February 1995
TABLE 3
STORAGE BASIN REMEDIAL ACTIVITIES
INTERIM REMEDIAL ACTION PHASE II
ADDITIONAL ACTIVITY
ESTIMATED COSTS
TIME TO IMPLEMENT
1) Mobilization, demobilization and Storage Basin
preparation. Establishment of a new engineer's
, office in the vicinity of the Storage Basin requiring
all necessary utilities.
$10,000
1 week
2) .; Restrict access to the Site by installing a gate and
short sections of adjoining fence.
$2,000
3 days
3) Monitor air to develop baseline conditions at the
: basin. Implement an air monitoring program that
: will effectively monitor for, and identify any fugitive
emissions that may potentially be released during
Phase II of the Interim Remedial Action.
$3,000
1 month
4) '. Removal and treatment (if necessary based upon
analytical at time of removal) of approximately
' ', 850,000 gallons of water from basin.
$32,000
2 weeks
. 5} Removal and disposal of approx. 350,000 gallons
(1,785 cubic yards) of medium-viscosity wood tar
: waste. Disposal options for this material will be
outlined within the Remedial Design. At the present
time, the wood tar wastes pass TCLP and are
. designated a non-hazardous solid waste that may
: be utilized as a fuel in boilers.
$250,000
1 Month
6) Remove and dispose of approximately 2,100 cubic
yards of associated mixed wood tar and soil. This
material will also be considered a non-hazardous
.; solid waste and may be utilized potentially as a fuel
or disposed of properly in an approved facility in
the most conservative, safe, and effective manner
. as determined during the Phase II RD.
$113,000
2 weeks
7} Removal and disposal of wood tar residues and
mixed soils from the overflow basin. Based upon a
historical data search and photogrametric
evaluation, it appears that minimal amounts of wood
tar migrated from the Storage to Overflow Basin.
The present estimated volume of affected material at
this location is less than 50 cubic yards. This
material will be disposed in accordance with the
: final evaluation as presented within the Phase II RD.
$2,000
2 Days
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United States
Environmental Protection Agency
Region IV
Amendment to Interim Action Record of Decision
Wrigley Charcoal Site
February 1995
TABLE 3
STORAGE BASIN REMEDIAL ACTIVITIES
INTERIM REMEDIAL ACTION PHASE II
ADDITIONAL ACTIVITY
ESTIMATED COSTS
TIME TO IMPLEMENT
8) In the event that the wood tars are to be utilized as
a fuel, the Dryer Building will need to be prepared
for the blending of wood tars with sawdust.
Fugitive emission controls and additional
precautionary measures will be implemented (to be
outlined in the Remedial Design).
$4,000
1 Month
9) Utilize existing clay berms to establish a clay cover
to enhance drainage, prevent water infiltration, and
conform to existing topography. Drawings and
cross-sectional plan views will be provided within
the Phase II RD. Establish a vegetative cover
utilizing top soil and seed to prevent erosion of the
clay cover.
$12,000
1 week
10) Contour the surface of the Overflow Basin to
properly drain into Clark Hollow. Contouring will
conform to final Storage Basin surface and prevent
retention of water.
Cost included with
#9
3 days
[Potential Additional Phase II activity]
In tha event that elevated levels of fugitive emissions are
identified at the previous location of the Still House, this
area will be covered with a sufficient amount of clay/soil
to prevent release of contaminants to the air. The clay
will be obtained from the east hill borrow location
presently being utilized for Phase I construction
activities.
$2,000
1 Day
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
Site vandalism has recently been on the increase with placards shot or
stolen, locks on fences shot (one well lock also shot), tarps for roll-
off containers stolen, and sections of.fencing and gates damaged. At
this time the EPA and State of Tennessee believe that large sections of
high quality fence & gates would be a viable target for theft in this
remote area. For these reasons it has now been determined that short
sections of fence adjacent to gates will be utilized instead of
perimeter fencing. Several of these areas are remote and we do not
believe that the lack of perimeter fencing will pose a problem.
Trespassers have been noted to scale other fences at the Primary Site
and at the present time, we feel that short sections of fence adjacent
to gates will limit the amount of vehicular traffic that may enter
several specific Site areas under remediation.
2.0 DESCRIPTION OF ORIGINAL SELECTED REMEDY AND NEW PROPOSED REMEDY
The alternatives that EPA has evaluated for the Amended Interim
Action are described briefly below. EPA evaluated these options using
the nine evaluation criteria listed in Table 1.
Alternative 1: No Action
Cost: $0
Time to Implement: N/A
The EPA requires that this alternative be evaluated at every site to
serve as a baseline for comparison for all other alternatives
considered. Under this alternative, no remediation would take place.
The only reduction of contaminant levels that could potentially occur
would be via natural processes such as dispersion or attenuation.
There would be no associated costs with this alternative.
Alternative 2: Original Remedy - Thirteen remedial items as
presented in the ROD. All are small-scale
activities except for Spillway restoration.
Cost: $ 750,000 - $1,100,000
Time to Implement: 6 months
Alternative 3: New Proposed Remedy - Eliminates on-site
consolidation area, provides off-site disposal of
wastes, initiates large-scale remediation at the
Storage Basin as described in Table 3, expands
: . scope of Still House excavation, provides erosion
control at the hill adjacent to the Process Tank.
Cost: $800,000 - $1,200,000 (Costs = Phase 1 + Phase II)
Time to Implement: Including Phase 1-14 Months
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United States Amendment to Interim Action Record of Decision
. Environmental Protection Agency Wrigley Charcoal Site
Region IV . February 1995
2.1 Alternative 2 - Address Primary Site imminent concerns as
described in Tables 1 & 2, access restrictions at the Primary Site
and Storage Basin, and sampling and analyses to define feed pipe
outflow at Irrigation Field and hot-spot at Athletic Field.
The original 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. This alternative includes
implementation of institutional controls that.prevent the future use of
ground water at the Primary Site. This alternative reduces the risks
associated with various contaminants at the Primary Site but does not
address Storage Basin wastes. .
2.2 Alternative 3 - Modifies Original Remedy as described in Tables 1
& 2. Addresses remediation of Storage Basin wastes.
This alternative addresses remediation of the Storage Basin where
wastes are located at the top of a hill adjacent to the North .Fork of
Mill Creek. Medium-viscosity wood-tars reside under approximately 2-3
feet of water and 3 inches of silt and clay. Wastes did not present
the appearance of being exposed prior to preliminary activities
conducted by the State of Tennessee. However, at the present time the
State has removed a portion of the water at the basin and investigated
(via trackhoe) the extent of wood-tars throughout the basin. Given the
basins present condition, dermal contact with these wastes is probable
in the event individuals were to enter the basin. Although the berms
presently appear intact in spite of recent activities, slumping during
times of heavy precipitation has also been noted following the flood of
1991. The basin is also located in karst terrain and in the event the
tamped-clay bottom of the basin was compromised, wastes would likely
enter the karst network and future waste remediation of these wastes
would be impossible. Remediation of the Storage Basin would
essentially eliminate risks at this location. Any potential impact to
the .groundwater/air or from transport of wastes during remedial
activities will be monitored in order to insure that these activities
have no adverse impact to human health and the environment.
3.0 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 the IAROD.
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV . February 1995
3.1 Overall Protection of Human Health and the Environment
Considering the extent of contamination at the Wrigley Charcoal
Site, Alternative 1 would not be protective of human health and the
environment and will not be further considered. Alternative 2 is
protective of human health and the environment to the extent discussed
within the IAROD. Alternative 3 provides more protection since it
addresses and eliminates the Storage Basin, a major area of Site
contamination. In addition, alternative 3 adds additional air and
groundwater monitoring in order to .fully assess the impact of remedial
activities. Alternative 2 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
Primary Wrigley Charcoal Site and the Storage Basin. Institutional
controls such as deed restrictions will limit future use of these
locations which will reduce risks associated with these contaminated
areas. Alternatives 2 and 3 also provide the basis for future action
with the distinction between the two alternatives being that
Alternative 3 will eliminate the need for significant future actions at
the Storage Basin. Therefore, concerning overall protection of human
health and the environment, Alternative 3 provides significant
advantages over Alternative 2.
3.2 Compliance with Applicable or Relevant and Appropriate
Requirements
--Alternative 2 fully meets ARARs concerning the on-site consolidation
and temporary storage of waste and debris prior to remediation during a
later operable unit. Alternative 3 will also meet ARARs as applicable
to off-site disposal of Primary Site waste and debris. While neither
Alternative is considered to be the final Site remedy, Alternative 3 is
considered to be more protective because this action fulfills, for the
Storage Basin, the statutory preference for remedies that employs
traatment that reduces toxicity, mobility, or volume as a principal
element. Subsequent actions are planned to address fully the threats
posed by the conditions at this Site. Alternative 3 also totally
eliminates much of this Site debris through off-site disposal. This
prevents these wastes from either being on or adjacent to the flood
plain of the North Fork of Mill Creek or from potentially being
vandalized in the consolidation area as mentioned in the original
selected remedy. Tar-cubes, transformers and non-corroded metallic
material that has passed TCLP will be transported and properly disposed
in an approved facility instead of stored in an on-site consolidation
area.
Since wastes such as tar-cubes will not be moved within to an on-
sice consolidation area, the Resource Conservation and Recovery Act
(RCRA) Land Disposal Restrictions (LDRs) will not be. triggered. This
is a change from the original IAROD which indicated ARARs pertaining to
storage would need to be waived (previously discussed in Section 9.2 of
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, United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
the .IAROD). Concerning off-site transport and disposal of wood-tar
wastes, contaminated soil, and site debris, RCRA Subtitle C
requirements are applicable when excavating and transporting the soil
that does not pass TCLP. 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 of the IAROD.
3.2.1 Action Specific 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.
b: 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.
3.2.2 Location Specific ARARs
o 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.
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.
3.2.3 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
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
. Region IV February 1995
(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
(BDA.T) requirements (as described in RCRA LDR guidance, 9347.3-06FS,
9/90) for wastes to be treated at the Wrigley Charcoal Site. If during
remediation, these requirements can not be attained, EPA will obtain a
treatability variance, and will attempt to meet the treatability
variance levels. Table 3 of the IAROD presents cleanup criteria for
the BDAT, and treatability variance levels.
The final Site cleanup levels for the interim activities are not
addressed in the original IAROD or this IAROD amendment 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.
3.3 Long-Term Effectiveness _
Alternative 3 provides for excavation, transportation off-site and
incineration of Storage Basin wood-tars and appropriate disposal of the
residual ash will permanently eliminate wastes at this location. This
provides clear advantages over Alternative 2 since that does not
present any remediation at the Storage Basin. The same scenario is
applicable for Process Tank and Still House sump wastes at the Primary
Site. Also, excavation, transportation, stabilization, and disposal of
burn-pit wastes provides long-term effectiveness at the burn-pit.
However, all the interim measures will not provide any degree of long
term effectiveness for other highly contaminated areas at the Wrigley
Site. Primary Site areas such as the Tar Pits and Still House are
proposed for remediation during the next operable unit. Concerning
these Site areas, the EPA will continue to evaluate long-term
effectiveness and permanence as part of the development of the final
action for the Site.
3.4 Reduction of Toxicity, Mobility or Volume
Alternative 3 reduces toxicity, mobility, and volume of several
Primary Site wastes and eliminates wastes'at the Storage Basin. These
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
actions will significantly reduce the potential for dermal contact,
migration, or bioaccumulation of Site waste streams addressed through
these Interim Remedial. Actions. 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. Alternative 1 satisfies this requirement
concerning small-scale activities at the Primary Site. However,
Alternative 3 satisfies this requirement concerning both Primary Site
Interim Action Activities as well as the elimination of wastes at the
Storage Basin.
3.5 Short-Term Effectiveness
Alternative 3 will provide a much higher degree of short-term .
effectiveness than Alternative 2 especially where the Storage Basin
remediation is considered. The IRA 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 Storage Basin excavation, transportation or
construction activities would be reduced through evaluations performed
during the Phase II Remedial Design, and the Phase II health and safety
plan.
3.6 Implementability
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 either Alternative 1 or 2 since only standard
construction techniques will be utilized.
3.7 Cost
Tentative cost estimates provided by the State of Tennessee indicate
that Alternative 3 which includes remediation of the Storage Basin will
have a present worth cost of approximately $800,000 - $1,200,000.
Previous cost estimates for the associated with the original IAROD were
$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.
3.3 State Acceptance
.While the EPA is. the lead agency for the fund-lead Wrigley Charcoal
Site, the State of Tennessee is the lead agency for the IRA (OU-1) .
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. United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV . February 1995
The State has reviewed this document and concurs with the modified
cleanup strategy for the Site.
3.9 Community Acceptance
.Community response to the alternatives is presented in the
Responsiveness Summary (Section 8.0) which addresses comments received
during the. public meeting and the public comment period (Refer to the
Responsiveness. Summary for further information) .
Public notice of these activities and the Public Meeting appeared in
the Hickman County Times on October 31, 1994. The Public Meeting was
held on November 3, 1994 at the East Elementary School in Lyles,
Tennessee. The community.indicated that they support the cleanup
measures as they were presented at the meeting. Local citizens,
county, and state representatives were also supportive of the proposed
activities and were pleased that the cleanup of the Storage Basin was
to be accelerated by adding it as part of the first Operable Unit.
4.0 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 constitute an
appropriate interim Site remedy until a final action for the Site is
determined. _
Ths major components of the selected remedy include:
STORAGE BASIN ACTIVITIES
1) Removal, treatment (if necessary), and disposal of waters at the
Storage Basin. The approximate volume.is estimated at 50,000
gallons;
2) Removal off-site of Storage Basin wood-tars and associated
contaminated soils, appropriate disposal and/or treatment, or
utilization of these wastes as fuel. The volume of raw sludge is
estimated at 300-400 cubic yards;
3) Associated wood tar contaminated soils at or below the tar/soil
interface will be removed for disposal in a RCRA Subtitle D
landfill. The volume of this material is estimated at 200 cubic
' yards;
4) A minor amount of wood tar contaminated soil will be removed from
the Overflow Basin. This material is expected to be less than 60
cubic yards and will be disposed in a RCRA Subtitle D facility;
5) The existing Storage Basin clay berms will be used for clay cover
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
material once the tar and associated soil has been removed. Since
the Storage Basin is perched on top of a hill the finished upper
surface can be contoured to conform with the existing topography.
An upper dome configuration to enhance drainage is required to
prevent infiltration of water. The Overflow Basin will also be
contoured to prevent water from accumulating;
6) Air monitoring will be performed-at the Storage. Basin, during
excavation and removal of wood tars;
7) At the conclusion of Storage Basin Activities, the .road to this
area will need to be removed. This will prevent unauthorized
access to this area and help to reduce vandalism.
PRIMARY SITE ACTIVITIES
1) The Primary Site Smoke Stack and Retort areas will require further
. removal of metallic or other debris and excessive vegetation to
aid in future sampling prior to cleanup. The total amount of
materials removed from these locations are estimated at
approximately 200 cubic yards. This debris (including many empty
drums) may be placed into an on-site building or decontaminated
(if necessary) and transported from the Site to a recycling
facility;
2_); A small earthen dam will be eliminated by removing the lower
concrete wall. This activity is required since waters
accumulating at this location are likely entering an hidden
underground conduit and exiting a 16 inch pipe at the Still House
area. It is estimated that 10 cubic yards of non-hazardous debris
will be removed from this location. This may be staged with other
concrete adjacent to this location or disposed at a RCRA Subtitle
D .facility.
3) EPA plans to perform a minor investigative effort following Phase
II remedial efforts. During this effort, additional monitoring
'wells and soil borings will be placed downgradient of the Storage
Basin and Still House foundation sump. These monitoring points
will serve to assess the impact, if any, of the Phase I remedial
activities at these locations. .In addition, surface water samples
should be obtained from the leachate seeps in the spillway. This
information should determine if conditions have changed since
spillway reconstruction in 1993;
4) Air monitoring was recently conducted at the Site following Phase
I remedial activities. This monitoring was performed to assess
the impact, if any, of the Phase I cleanup activities. Once the
final results of the data have been submitted, they will be
evaluated to determine if any impacts have occurred. If adverse
conditions are identified, EPA and the State will determine how
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United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
they can be reduced, and implement an appropriate solution.
The major goal of this IRA is to reduce risks at the Primary Site by
eliminating, or controlling the most imminent and substantial threats
to human health and the environment and also to eliminate wastes and
associated threats at the Storage Basin. It should be noted that some
of the actions may be modified during the State Lead RD/RA. These
changes may reflect modifications resulting from the engineering design
process.
5.0 Statutory Requirements
The U.S. EPA and TDEC believe that the activities included in the
IRA 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.
5.1 Protection of Human Health and the Environment
The activities previously described concerning this IRA will provide
protection of human health and the environment by removing, treating,
and disposing of wood-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.
5.2 Attainment of the Applicable or Relevant and Appropriate
Requirements (ARARs)
For these IRA activities, the final cleanup levels are not addressed
in this, document 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. The Storage Basin cleanup is
considered an early final remedial action and the final cleanup levels
at this location will be addressed by the final remedial action ROD for
tha Site. ARARs for Site areas that will be addressed will be met as
previously discussed in Section 3.2.
5.3 Cost Effectiveness
'This IRA employs proven technologies that may be applied to wood-tar
wastes, burn-pit wastes, and drummed wastes. The selected remedy
provides overall effectiveness proportional to its costs. In the event
wood-tars are utilized as a fuel or in the manufacture of coke, these
applications both essentially recycle this waste stream and the overall
cost per ton ranges from approximately $150.00 to $250.00 according to
recent conversations with State of Tennessee personnel. This is
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------ ~~~~^^--~>'-M-v'»v-"--.-'^^
United States Amendment to Interim Action Record of Decision
Environmental Protection Agency Wrigley Charcoal Site
Region IV ' February 1995
significantly less than other remedial technologies such as thermal
descrption, solvent extraction, or on-site incineration. This is also
less than biotreatment although, for many of the remaining on-site wood-
tar waste streams, this may appear to be an appropriate, cost effective
technology. This has been evaluated and it has been determined by EPA
ORD that the concentrated wood-tars are not suitable for biotreatment.
However, biotreatment has been shown in treatability studies to have
application to low to moderately contaminated Wrigley soils containing
wood-tars. Any potential application of this technology will be
evaluated on remaining on-site waste streams during the preparation of
the next operable unit.
This 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.
5.4 Utilization of Permanent Solutions and Alternative Treatment
Technology or Resource Recovery technologies 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. Overall objectives of this IRA 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 wood-tar and burn-pit wasces achieves some
reduction in the contamination at the Primary Site. Early final
actions for wood-tar and burn-pit wastes are intended to utilize
permanent solutions on a very limited basis for the Primary Wrigley
Site. However, the early final action at the Storage Basin will fully
utilize permanent solutions, and either alternative treatment or
resource recovery to the maximum extent practicable. The early final
actions at the Storage Basin will effectively and completely eliminate
these wastes. 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.
5.5 Preference for Treatment
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; United States Amendment to Interim Action Record of Decision
} Environmental Protection Agency Wrigley Charcoal Site
Region IV February 1995
iThe 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. While the
preference for treatment is beyond the scope of many of the cleanup
activities, Storage Basin activities that will totally eliminate wastes
at; that location will satisfy this CERCLA statutory preference.
6.P Support Agency Comments
The State of Tennessee is the lead agency for the Interim Remedial
Action activities which are intended to: 1) eliminate several of the
most' immediate Site threats, and 2) temporarily address many other Site
threats. This IRA is also referred to as OU-1 and now consists of two
phases both of which will be State lead. As the support agency for
these interim activities, EPA has reviewed these issues with the State,
and in cooperation with the State of Tennessee has prepared this
Amendment to the IAROD. The EPA and State of Tennessee concur on the
activities as presented within this document. Future response actions
(OU-2 & OU-3) are expected to be EPA lead and will likely be designed
to fully eliminate several large areas of contamination at the Wrigley
Site.
7.0 Affirmation of the Statutory Determinations
Considering the modifications that have been made to the selected
remedy, the EPA and the State of Tennessee believe that the remedy, as
s-et forth in the ROD and modified by this BSD, remains protective of
human health and the environment, complies with Federal and State
requirements that are applicable or relevant and appropriate to this
Interim Remedial Action.
In addition, the modified remedy utilizes alternative treatment and
resource recovery to the maximum extent practicable for this Interim
Remedial Action.
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8.0 RESPONSIVENESS SUMMARY
The U.S. Environmental Protection Agency (EPA) established a
Public Comment Period from 11/7/94 to 12/7/94 for interested
parties to comment on EPA's Proposed Plan for the modification of
the Interim Remedial Action at the Wrigley Charcoal Site. No
extensions were requested to the Public Comment Period. A Public
Meeting was held on 11/3/94 and conducted by EPA and the State of
Tennessee at the East Elementary School in Lyles, Tennessee. The
meeting discussed the need for amending the present Interim Action
Record of Decision and past and present Site progress was
discussed. EPA and the State also discussed the approach to the
future remediation of the Site.
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 development and implementation
of the amended Interim Action ROD at the Wrigley Charcoal Site.
The Responsiveness Summary for the Wrigley Charcoal Site is divided
into the following sections:
8.1 Overview: This section discusses the recommended Interim
Action for the Site and the Public reaction to this
alternative.
8.2 Background of Community Involvement: This section provides a
brief history of community interest regarding the Wrigley
. Charcoal Site.
8.3 Summary of Community Concerns: This section provides
information on several of the most important community
concerns near the Site.
8.4 Summary of Major Questions Raised During the Public Meeting on
November 3, 1994, and EPA responses: This section presents
both oral and/or written comments submitted during the Public
Meeting and provides the responses to those comments.
8.5 Written Comments Received During Public Comment Period and EPA
Responses: This section presents letters or comments submitted
during the Public Comment Period and EPA's response to those
letters.
Appendix A: Contains the Proposed Plan that was
presented to the public on 11/3/94. This document was
also placed in the information repository and mailed to
those on the mailing list.
Appendix B:' Includes the name, address and phone number
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of the information repository designated for the Wrigley
Charcoal Site.
8.1 Overview
The Proposed Plan for Interim Action activities at the Wrigley
Charcoal Site was presented to the public in a fact sheet
released on 10/18/94 and at a Public Meeting on 11/3/94.
The major objectives and a description of the modified
approach to be implemented as the Interim Remedial Action are
presented below:
Removal and treatment (if necessary) of waters at the
Storage Basin.-Dependent upon analytical results, waters
will be either discharged to the North Fork of Mill Creek
or will be transported and disposed off-site in a
Publicly Owned Treatment Works (POTW);
Removal off-site of Storage Basin wood-tar wastes and
associated contaminated soils, appropriate disposal
and/or treatment, or utilization of these wastes as a
fuel ;
Removal of metallic or other debris in the area
surrounding the smoke stack extending to the Storage Shed
access road down to the North Fork of Mill Creek. This
material (including many empty drums) may either be
placed into the Storage Shed or decontaminated (if
necessary) and transported from the Site to a recycling
facility;
Promote effective drainage and prevent ponding of runoff
at the former location of retort sumps. This will likely
eliminate one of the sources of surficial waters entering
the still house area;
Provide better control over erosion and/or contaminant
migration at the still house area. This can be
accomplished by either utilizing and covering the
existing open drainage trench at the still house, or by
temporarily covering then grading and seeding the area;
Air monitoring at the Primary Site and Storage Basin will
provide additional assurances that the remedy is
performed in a manner protective of human health and the
environment ,-
Additional monitoring wells and soil borings downgradient
of the Still House foundation sump and the Storage Basin
will provide additional information concerning any
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potential impact of selected activities;
Surface water samples should be obtained from the
leachate seeps in the spillway. This information should
determine if conditions have changed since spillway
reconstruction in 1993;
Install short sections of fence adjacent to Site gates
instead of perimeter fencing. EPA and TDSF believe that
perimeter fencing would be a viable target of theft and
vandalism.
Implementation of these activities will greatly accelerate the
cleanup of the Primary Site and Storage Basin. This action
will achieve significant risk reduction early in the Superfund
process.
8.2 Background of Community Involvement:
Hickman County is primarily a rural community south southwest
of Nashville, Tennessee. The small community of Wrigley that
is located just west of State highway 100 is well aware of the
past activities that were conducted at the site beginning in
1881. Members of the community have attended the public
meetings and availability sessions.which included:
State and local officials, neighbors and other community
members interviewed periodically since June 1989 to as
recently as October 1994 did not indicate having ever received
or filed complaints or expressed concerns to local officials
except for a single complaint received in 1981. The Wrigley
Charcoal site's long history and presence in the community has
developed an attitude of acceptance and provided a sense of
local history to the community. Curiosity and interest are
more frequently encountered than concern. Community residents
spoke of taking walks and exploring the site and of children
playing on the site.
Though EPA did not perform any formal community relations
activities at the site during the 1988 removal activities, EPA
was present at the State-sponsored public meeting at the East
Elementary School in Wrigley on October 24, 1988.
Representatives from EPA and the State of Tennessee provided
details of activities conducted to date, pertinent analytical
results, as well as proposed activities to be completed in the
future. A question and answer period followed these formal
presentations, during which the state and federal
representatives answered questions from 22 residents and
concerned citizens. The State, in conjunction with the EPA,
also provided a fact sheet to the community and news media
sources in October 1988. This fact sheet referenced EPA's
emergency removal activities at the site during the summer and
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fall of 1988, and identified both state and EPA contacts.
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
RI/FS. ' . .
In December of 1990, another fact sheet was distributed prior
to sampling conducted at the Athletic Field and in the town of
Wrigley.
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, 1991. At this
meeting, concerns and issues were raised concerning the
contamination at the Wrigley Charcoal Site.
Site and community visits continued throughout 1992 while the
remedial design was in progress. In 1993 another fact sheet
was. distributed and this coincided with the initiation of the
remedial action (Phase I). This phase was completed in July
1994.
8.3 Summary of Community Concerns
The Wrigley community's livelihood revolved around the
industrial operations at the plant. The perceptions of the
site contamination appear to vary among those formerly
employed at the site, those living near the site and those
residing some distance from the site or creek.
Since the state and EPA investigations have indicated
contamination associated with waste products on the Wrigley
Charcoal site, questions have been raised which may not have
been of concern previously to the former employees and their
families. In addition, the decision to relocate the public
.water intake (from downstream of the site below the confluence
of Mill Creek and the North Fork of Mill Creek to a point
upstream of the site on the main branch of Mill Creek)
previously created concern to not. only the public water
recipients but residences along the creek and trout fisherman.
Some residents of the community had expressed concerns that
relocating the water intake to the main branch of Mill Creek
would significantly reduce the water volume flowing through
the creek thereby negatively impacting growth potential in the
community. Similarly, trout fisherman in the area feel that
the dropping water level (resulting from drawdown at the
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relocated water intake) could reduce the trout population in
the creek.
Historically, everyone interviewed who lived in the area
during the operation of the Wrigley plant recalls the smell of
wood alcohol either from the creek as it flowed black to the
Piney River or in the air from the plant. Though the smell
has recalled fond memories for two area residents, several
neighbors found it offensive and recalled that it made
breathing unpleasant. Another recalled severe headaches and
even hospitalization as a child, which she attributed to the
wood alcohol fumes. One citizen recalled the wood alcohol
odor coming from Piney Creek as it .crossed his family's farm
over 13 miles away from where the Wrigley process water
discharges, other residents have indicated that the smell is
still present on rainy or humid days in some areas, including
at the old commissary building.
The smell of the creek was always connected to the fact that
it was black in color and, on some maps and by some people, it
is still referred to as Black Creek. Residents now seemed
astounded by the recollection but recall how it was then. One
woman recalls during her girlhood that she thought all streams
were black. Swimming and playing in the black water creek was
a common practice., but parents did caution the children not to
put their heads under the water. Two residents recalled the
slimy creek bottoms, while another recalled medicinal uses for
the water, including treatment for heat rasJies. A nearby
farmer said his cows and mules preferred the black water to
the clear water which was available, and noticed no ill
effects. In general, those closest to the site had a greater
acceptance of the poor stream condition. State records did
note complaints in the 1940's by downstream landowners.
Maintaining the present quality of the public water supply was
a concern of many residents. The state of Tannessee's
decision to move the water intake has alleviated the concern
of some residential water customers, while the concerns of
other residents will be alleviated only when the water intake
relocation is completed. For other residents, this decision
has apparently created concern as to what effects may result
from water that has been consumed in the past.
The most.noted recreational use of Mill Creek has been trout
fishing. According to local residents and wildlife officers,
the state has developed a very successful and popular trout
fishing program which also brings crowds from Nashville to
fish the creek. Regional trout fishing organization's have
indicated their concern and interest in activities relating to
the 'future quality and use of Mill Creek.
Health concerns varied considerably among the county residents
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interviewed. Many contacts never mentioned health concerns,
but only one said there was no concern. This resident
remarked how long everyone lived in their community,
referencing the number of healthy elderly And that most deaths
occur to individuals in their 80's. The County Health
Department, however, has received one comment concerning the
incidence.of cancer in the community. Those that mentioned
relatives and former Wrigley plant employees who have.cancer
or died of cancer wonder if it was due to working at the plant
or due to personal health habits, such as smoking. Health
concerns noted in the area included emphysema and leukemia.
One recalled the memory of seeing a relative covered in black
soot at the end of his shift six days a week over a thirty
year career.
Access to the site .-is uncontrolled. Most residents did not
know who owns or manages the site and rarely go on to the
property. Residents were aware that the site was used for
hunting and rifle practice. Children play on the site and
unidentified persons have been observed removing 'items from
the site. Several residents indicated that one or more
individuals have removed tars and charcoal bricks for heating
during winter. Two neighbors have reported fires inside the
abandoned buildings on the site, usually at night. A third
resident has been concerned about the flammability of the
charcoal remnants on the site and off, recalling accounts of
spontaneous combustion of charcoal dust, as well as having
been burned as a child while walking across-a'disposal area
where the athletic field is now located.
Most of the residents appeared unconcerned, apparently
confident that corrective actions were being taken by the
proper authorities. In general, the information about site
contamination provided in RI/FS and RD/RA documents summarize
what is known concerning Wrigley site conditions. This
information has been made available to the public and local
government officials. Presently, there is no formal or
organized community involvement with the Wrigley Charcoal
site. However, the county has an active environmental group
known as Hickman County Against Lethal Trash (HALT) which was
successful in preventing the construction of a hazardous waste
incinerator in the county and is very aggressive in protecting
the natural resources and environmental setting of the county.
Members of this organization indicated their desire to see
Mill Creek and the local groundwater resources protected from
contamination emanating from the Wrigley Charcoal site. They
are interested in having access to information regarding the
site, as well.
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8.4 Summary of Major Questions Raised During the Public Meeting on
November 3, 1994, and EPA responses:
Question: How can you prevent groundwater contamination while you
are cleaning the place up?
Response: All on-site cleanup activities will be conducted in order
to reduce or eliminate the impact to groundwater. Any
large excavations will be performed in coordination with
erosion and runoff control features. The majority of the
work conducted at the Site thus far has been performed
during the dry season from August to November. This has
served to prevent excavated material from being saturated
with water. In addition, excavated material has been
placed either temporarily under high density polyethylene
plastic or immediately into .roll-off containers for
transport. Both methods have been effective in reducing
the amount of water that enters the wastes which then
prevents the amount of potential fluid leaching from
excavated wastes that may enter the subsurface. In
addition to prevention of groundwater contamination, we
have also been better controlling potential surface water
contamination. The spillway reconstruction conducted in
1993 included erosion control features that prevented any
excavated wastes from re-entering the North Fork of Mill
Creek.
Question: Why would a well a mile downstream not have .any
contamination?
Response: It is very likely that the groundwaters downstream were
contaminated at one time. The reports performed by the
State of Tennessee in the 1940's (on the North Fork of
Mill Creek to the Duck River) indicated that the drainage
basin was contaminated for 26 miles downstream of the old
Wrigley Plant. Since that time until the closing of the
plant in 1966, the Tennessee Products and Chemical
Corporation was working with the State and a local
university to develop methods of reducing contamination
at the facility. As part of these efforts, after the
early 1950's significantly less contamination entered the
creek. After approximately 30 years of inactivity, much
of the drainage basin appears to have attenuated. It is
likely that the significant flood waters that frequent
this area have played an important role in reducing
contaminant persistence for both surface waters and
ground waters. Our sampling and analyses of groundwaters
in on-site wells indicates low to moderate levels of
contamination in only the shallow aquifer. While this
water can discharge via seeps into the creek, analyses of
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Question:
Response:
Question:
Response:
Question:
Response:
the creek indicate that levels are below the detection
level 50 yards downstream. This indicates that Site
contamination is not causing significant surface water
contamination downstream. Off-site residential well
sampling and analyses indicates no elevated levels of
site contaminants.
What about the old ballpark?
there?
Has anything been found
All of the sampling and analyses to date have only
identified one sample that had elevated levels of metals.
Additional follow-up sampling was performed to better
identify the "hot spot", however, no significant
contamination was identified. The Ball Field was built
from 1938 to 1950 at a location that was referred to by
local residents as the black dump. This originally was
a ravine utilized for dumping and burning of garbage, but
was subsequently filled i-n with slag, soils and debris
from the Primary Site. When completed, this location
served as the Athletic Field for the plant baseball team.
Initially, was the slag dangerous like when it was fresh
from the furnaces or whatever?
The slag originally contained high levels of metals
similar to other steel or smelter facilities.. However,
much of this slag has been exposed to the_elements for up
to 110 years and has subsequently leached. Toxicity
tests have been performed on this material and the
results show that although the slag still has moderate
levels of metals that the toxic metals cannot leach out
of the slag.
A county resident not living near the site mentioned that
they wanted their water tested since they heard that
people have been sick. They contacted the State and they
did not know anything, and they called State Superfund
and never got a call back.
While water well testing is many times performed at or
adjacent to a Superfund site, it is standard procedure
for the EPA or the State to test wells not associated
with the Superfund site. If a resident adjacent to a
Superfund site has any questions concerning their water
well, they can either call the State Site Manager for the
Wrigley Site at (615) 741-5941 or the EPA Remedial
Project Manager at 1-800-435-9233. If we not available
at the time of your call we will do our best to get back
with you to answer any questions.
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Question: A PRP wondered if the cleanup at the Storage Basin would
take about two months.
Response: It is likely that the cleanup of the Storage Basin will
take approximately two months if the weather cooperates.
This cleanup of wood tar involves excavation, and removal
off-site of the tar to be utilized as a fuel in a boiler.
It will be important to perform these cleanup activities
during appropriate weather since these wastes are located
at the top of a hill adjacent to the North Fork of Mill
Creek.
Question: A PRP asked if the Storage Basin was the only major basin
of tar other than the area on the side of Mill Creek (he
was referring to the North Fork of Mill Creek)?
Response: In addition to the Storage Basin and the Primary Site tar
pits is the Still House area which has moderate to high
levels of tar contamination, and the Retort Area which
has low to moderate levels of contamination.
Question: What is planned for the majority of the plant site area?
Is there another phase of cleanup scheduled?
Response: The first cleanup activitie is called .an Interim Action
(Operable Unit No. 1) . This action served to..
significantly reduce site risks in the short-term. The
second cleanup action called Operable 4Jnit No. 2 will
likely clean up site areas that pose a longer-term
threat. These areas include the Primary Site tar pits,
Still House and Retort Area.
Question: The material that is being taken out of the basin, will
it go to fuel conversion immediately, or will it be
stockpiled?
Response: The wood tar waste from the Storage Basin will be
utilized as a boiler fuel. The tars will be excavated
and placed immediately into roll-off containers. No wood
tars will be stockpiled at any time at the Storage Basin.
However, it is likely that the blended material, will be
stockpiled for short periods of time at the Dryer
Building until it is transported via roll-off container
to the appropriate facility selected by the State of
Tennessee .(as the State is the lead agency for this
remedial action). During blending operations these tars
will be mixed with shreaded wood at a ratio specified for
optimum operating conditions for the selected unit.
Question: A PRP asked how many truck loads do you anticipate will
come out of this site?
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Response: It is difficult to develop exact numbers but we can give
an estimate. If the quantity of wood tar and
contaminated soil ranges up to 800 cubic yards, then if
20 cubic yard roll-off containers are utilized there will
be approximately 40 truck loads of material transported
from the Storage Basin. This material is planned to be
moved to the Dryer Building for blending. It is likely
that the volume of material will be doubled at this
point, yielding approximately 80 truck loads of material
from the Dryer Building to the receiving off-site
facility.
Question: Is the debris around the smokestack area to be cleaned
up?
Response: The metallic and other debris around the smokestack is to
be cleaned up as part of the second phase of the Interim
Action. This is planned for early 1995.
Question: A PRP stated that they were interested in utilizing their
on-site buildings. Are the buildings going to be
utilized for fuel conversion? If so is this going to go
on indefinitely?
Response: During RD/RA Negotiations for the Interim Action, EPA
offered any PRPs the opportunity to participate in the
cleanup which included hazardous wastes within several
on-site buildings. Now that EPA and- the State of
Tennessee have devoted significant resources toward
remediating wastes in these buildings it is not
appropriate for any PRPs to utilize these areas for
industrial activities.
It is very likely that during the second phase of the
Interim Action the dryer building will be utilized for
the blending of wood tar with shreded wood. This process
will not go on indefinitely. This work is expected to
last approximately six (6) weeks.
Question: What type of ground monitoring will you do on the
groundwater and wells when you start excavating all that
waste?
Response: All of the on-site wells and off-site residential wells
(previously utilized as monitoring points) will be
sampled again to make sure that remedial efforts have not
created any adverse conditions. During the excavation of
any on-site waste, a variety of precautions will be taken
so that wastes do not enter the North Fork of Mill Creek
or the ground water.
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Question: Will there be any random sampling of wells downstream?
Response: Off-site random sampling is not standard operating
procedures at Superfund sites. However, downgradient
areas that could potentially be impacted from the Site
are evaluated as part of these investigations. This is
the case at the Wrigley Site and previous sampling and
analyses indicated no significant detections of any
contaminants off-site. We intend to continue to evaluate
any downgradient wells associated with the Site to better
assess these remedial efforts.
Question: Have you.all ever done a study of deaths within this area
from cancer? If you have, have you ever found any
significant increase in deaths by cancer in the Wrigley
area or Mill Creek area?
Response: No organization has undertaken this type of study.
Studies such as this will be conducted under extreme
circumsances, but under normal circumstances it is
unlikely a costly, very involved study like this will be
initiated. An organization such as the Agency for Toxic
Substances and Disease Registry (ATSDR) could undertake
such a task by first performing a health assessment and
then an evaluation of significant health impacts
associated with a Superfund site. ATSDR has done a
preliminary health assessment for the Wrigley.Site. If
any additional information is obtained, -it would be very
helpful if ATSDR would provide updated reports. EPA
intends to pass on additional comments and any new
information to ATSDR to assist them in pursuing these
activities.
Question: What is the last day for phase three? What is the
completion date there? What will the site look like when
it is completed?
Response: At the'present time, we do not know all of the details
for the Operable Unit No. 3 at the Wrigley Site. Our 3-
Operable Unit strategy involved first addressing the most
immediate problems first as part of the Interim Action
(Operable Unit No. 1) , then during Operable Unit No. 2 we
intend to address several major areas of tar
contamination, and last, Operable Unit No. 3 is intended
to address any shallow groundwater concerns at the.south
end of the Primary Site (no other groundwater concerns
have been identified) . As part of our operable unit
strategy, we have been eliminating sources for potential
shallow groundwater contamination. In this manner, much
if not all of the source for groundwater contamination is
expected to be eliminated by the end of OU-2 remedial
efforts. This will be confirmed at the end of OU-2.
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Also, during the development of OU-2 remedial activities
groundwater associated difficulties are to be re-
assessed. If these are confirmed to be relatively
confined and minor (as they presently are), then a minor
remedial measure will likely be added to OU-2. In the
event there are any remaining (significant) groundwater
problems delineated after OU-2, then OU-3 will proposed
and then implemented.
Question: Will there be a third phase to the cleanup?
Response: As was stated above, if after OU-2 there is the need for
OU-3, then it will be proposed and implemented.
Question: Are there any holdovers from the old Tennessee Products
Corportation? .-
Response: At the present time, no information has been obtained
that would clarify this question.
Question: What is the greatest contaminant in that area?
Response: The single most significant and prevalent contaminant at
the Wrigley Site are phenols. The next most common Site
contaminants are the polycyclic aromatic hydrocarbons
(PAHs) > a wide variety of- metals, and volatile organic
compounds (VOCs).
Question: What is the estimated cost of this phase, and are the
funds available to complete the clean-up?
Response: The costs for the first phase of the Interim Action have
been approximately $450,000. The costs for the second
phase of the Interim Action which include all on-site
construction and remediation are estimated at $200,000.
This brings the total cost of the Interim Action (OU-1)
to approximately $650,000.
Question: is there a buyer for the fuel?
Response: Due to this Site being a Superfund Site, the EPA and the
State of Tennessee are obligated to dispose of the wood
tar waste in a safe and effective method. It may only go
to facilities that are approved by the State and EPA for
this activity (and not simply to anyone that wishes to
purchase tar to be utilized as fuel). It is likely that
this will be an inexpensive manner for disposal of tar
wastes but additional transportation and regulatory costs
must be included as well. The final costs of this
remedial activity will not be known until the State has
decided which facility is most appropriate. At the
present time, we estimate it will cost between $200 to
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$500 per cubic yard to dispose.
For this Interim Action the State has been granted the
lead by the EPA. As part of the cleanup of the Wrigley
Site, both EPA and the State have looked into various
options of waste disposal or utilization of the tars as
a fuel due to its high BTU value. While it appears that
this material satisfies criteria'that would allow its
classification as a RCRA solid waste (which would allow
it to be utilized at more facilities) , both agencies wish
to dispose of this material in a conservative manner.
This is simply due to the fact that the wood tar waste
closely resembles coal tars or other tar compounds that
are more strickly regulated.
Question: If the receiving facility does not pay for the fuel, will
they charge you (referring to the State of Tennessee) to
burn it?
Response: The receiving facility will be required to meet all
stipulated requirements for transporting, receiving, and
utilizing such materials. Given these requirements, it
is probable that the receiving facility will charge to
acquire this material.
8.5 Written Comments Received During Public Comment Period and
EPA Responses: _
One written comment was received by EPA during the Public
Comment Period. This letter included several questions from
a resident located approximately 1 mile downstream of the
Site. These questions are as follows: 1) What will be done
during the removal of waste (digging, loading, etc.) to keep
materials out of the.North Fork of Mill Creek, and 2) after
the waste is removed, how will the surface be sealed to
prevent future ground water contamination or contaminated
surface water runoff downstream.
Response: During the State-Lead Remedial Action, engineering
controls have been implemented such as screen, mesh, rip-
rap, catchment ponds, and/or stream diversion, or other
mechanisms to prevent sediment mobilization. Similar
mechanisms will be employed to prevent sediment or
contaminant mobilization in surface or subsurface waters.
Every attempt has been made to conduct activities during
appropriate weather conditions to further prevent any
mobilization of contaminants.
Waste locations have been determined,and where.wastes can
be identified at or above levels of concern (Action
Levels), they are being completely remediated. At these
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locations, there will be little need for employment of a
mechanism to "seal" contaminants in since they are being
competely removed. These locations include the worst
areas on the Site which are the Tar-Pits, Storage Basin,
and Still House. At other locations where contaminants
have been identified at lower levels such as the Retort
Area and at several Primary Site "hot spot" soil
locations, the extent of the cleanup is planned to be
delineated as part of the Final Site Remedy (to be
developed likely during 1996). These marginally
contaminated areas have been analyzed to determine if
hazardous substances could potentially leach from the
soils. Thus far, all marginally contaminated areas pass
these leachability tests referred to as TCLP tests.
Soils passing these tests are not expected to experience
any further leaching into the groundwater so again, it
would not be appropriate to "seal" these areas based upon
the trace or low levels of contaminants identified.
APPENDICES
Appendix A: Contains the Proposed Plan that was presented to
the public on 11/3/94. This document was also placed in the
information repository and mailed to those on the mailing list.
Appendix B: Includes the name, address and phone number of the
information repository designated for the Wrigley Charcoal Site.
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APPENDIX A
Proposed Plan for ROD Amendment
-------
U.S. EPA ISSUES PROPOSED PLAN TO
MODIFY INTERIM ACTION RECORD OF DECISION
WRIGLEY CHARCOAL SITE
WRIGLEY, HICKMAN
COUNTY, TENNESSEE
EPA
REGION IV
October 1994
INTRODUCTION
The U.S. Environmental Protection Agency (EPA), in cooperation with
the Tennessee Division of Superfund (TSDF), has begun the Federal
"Superfund" process to address environmental contamination at the
Wrigley Charcoal Site (the "Site") in Wrigley, Hickman County,
Tennessee (Figure 1) . The Site was included on the National
Priorities List (NPL) in March of 1989, and since this -time has
been handled by the EPA. One important exception to the overall
Site management has been the recently initiated Interim Remedial
Action. The State of Tennessee has accepted the cleanup
responsibilities under Cooperative Agreements with EPA to begin
cleanup activities at the Wrigley Site.
This Fact Sheet Summarizes:
Modifications to the Interim Remedial Action;
Status of Wrigley Charcoal Site Activities;
* Underlined words are defined in the Glossary at the end of
this Fact Sheet
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IRRIGATION FIELD
APPROXIMATE
PROPERTY
BOUNDARY
MO 900 V50 1000
csa-i L.j
GRAPHIC SCALE IN FEET
OVERFLOW
BASIN
PROJECT:
WRIGLEY CHARCOAL SITE
MAP TITLE:
FACILITY SITE LOCATION AREAS
PREPARED FOR:
U.S.E.P.A. REGION IV ATLANTA. GA
REMEDIAL PROJECT MANAGER - D.A. BELL
APPROXIMATE
- PROPERTY
BOUNDARY
CLARK
HOLLOW
STREAM
730
LZJ RESIDENTIAL
UNIVERSITY OF CrNCINNATI
BOSS Contor Bill Bond
Cincinnati. OH 46BS4
DATE 10/28/91
DRW BY EflS
t ] INDUSTRIAL
CHK BY KMS
-------
This fact sheet is being issued in order to provide notice of
proposed modifications to the September 1991 Interim Remedial
Action Record of Decision (IAROD) for the Site, and to familiarize
the public with the current actions that have been underway at the
Site since October 1993.
As part of the public participation requirements under section
117 (a) of the Comprehensive Environmental Response, Cop«>Ti«ation
and Liability Act of 1980 (CBRCIA), as amended by the Superf""fl
Amendments and Reauthorization Act of 1986 (SARA), EPA and the
State of Tennessee have the responsibility to inform the public
about the Superfund activities at the Site.
SUMMARY OF SITE HISTORY
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 Storage Basin and Irrigation
Field were utilized by the Tennessee Products and Chemical
Corporation for the disposal of contaminated Site wastewaters
beginning in the 1940's and continuing until the mid-1960's. The
Athletic Field was constructed at the previous location of a large
ravine in the town of Wrigley. Slag and soils derived from the
Primary Site were utilized to fill this area from 1938-1950 when
the field was opened. The field has been in use since the early
1950's and is still regularly used by local residents.
The businesses or individuals involved in the industrial operations
during this time period no longer exist and previous investigations
indicated there are no Potentially Responsible Parties (PRPs) from
this time period that may fund cleanup operations. The Site was
purchased in 1966 by the Tennessee Farmers Cooperative (TFC) who
are the present owners (as the present landowners are a PRP) of
most Site areas. Portions of the Primary Site were also utilized
from 1978 to 1983 by R.T. Rivers (another PRP) 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 (Figure 2).
WASTE HANDLING PROCEDURES AND CONTAMINATION PROBLEMS
Much of the waste at the Wrigley Site was disposed into the North
Fork of Mill Creek. This practice occurred until the mid-1940's
when the State of Tennessee requested that the TPCC identify
adequate alternatives to their waste disposal procedures. The TPCC
constructed wastewater impoundments, investigated spray irrigation
and trickling filter technology in an attempt to degrade
wastestreams that contained phenols and polycyclic aromatic
hydrocarbons (PAHs). These attempts to reduce or impound
contaminated wastestreams inadvertently led to additional areas of
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1) PROCESS TANKS
2) DRYER BUILDING
3) MAINTENANCE BUILDING
4) CARPENTER SHED
5) RAIL HOPPERS
6) WAREHOUSE BUILDING
7) STORAGE SHED
8) SAWMILL
9) POWER PLANT STACK
10) PRODUCT TANK FOUNDATION
11) ELECTRIC SUB-STATION
12) RAW LIQUOR STORAGE
TANK FOUNDATION
13) FORMER RETORT AREA
14) TAR PITS
15) FORMER STILLHOUSE FOUNDATION
16) FORMER BLAST FURNACE AREA
^a=.^-X W^nm
\ / RIP-RAP
V -"""
APPROXIMATE AREA OK -s'
PRIMARY WRIGLEY SITE
< - \J
- ^-"~~~^ 11 //
"- -" . \\///
OO§\N }(//
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-j-
contamination. In addition, the overall condition of the facility
was poor and spills of VOCs and semi-volatile organic compounds
(SVOCs) were commonplace.
The Primary Site is now abandoned but significant contamination was
identified in abundant waste piles/ soils, buildings, tar-pits, and
in the above ground storage tanks (called the process tanks). Much
of the raw waste sludges reside in the Primary Site tar pits, still
house, and retort area. Significant contamination has also been
identified at the Storage Basin. These areas contain tar waste
sludges which contain hazardous substances identified as phenol,
2,4-dimethylphenol, benzene, . toluene, Polycyclic Aromatic
Hydrocarbons (PAHs), a variety of metals, and low levels of
halocarbons. While traces of furans, dibenzofurans and dioxins
have been identified in the waste sludges, all levels identified
have been well below levels of concern.
Low to moderate levels of contamination have been identified in the
shallow groundwater at the southern end of the Primary Site.
Studies indicate that there are no detectable contaminant levels in
ground or surface waters off-site. In addition, all residential
wells were sampled during the Remedial Investigation/Feasibility
Study (RI/FS) and no contaminants were detected in any of the wells
surrounding the Site.
SUMMARY OF SITE RISKS
During the RI/FS from 1989-1991, 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, focussed on the
health effects that could result from long-term direct exposure to
high concentrations of the contaminants as a result of dermal
contact with soil or water, ingestion of Site contaminants or fish
from the creek, or exposure to airborne contaminants.
The major causes of concern at the Primary Site and the Storage
Basin are from oral and dermal exposures to Site wastes such as
PAHs, 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 contaminants. The State of Tennessee and EPA have
noted that it is difficult to keep trespassers out of the Wrigley
Site; however, recently installed gates and adjacent short sections
of fence have served to keep unauthorized vehicles from entering
contaminated Site areas.
Risks associated with ingestion of water or fish from the North
Fork of Mill Creek are only slightly elevated. Metals and other
Site contaminants were believed to have entered the stream at the
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back of the maintenance building from the burn pit. This pit was
cleaned up during Phase I of the Interim Remedial Action (October-
December 1993) and follow-up sampling of the North Fork of Mill
Creek will evaluate the effectiveness of these actions. Risks from
dermal exposures to leaking process tank wastes were also
eliminated during Phase I of the Interim Remedial Action (IRA).
The process tanks were removed, decontaminated and the metal
recycled. The associated wastes were removed and temporarily
stored in roll-off containers for a Treat ability Study in June
1994.
The overall risks identified for samples taken immediately behind
the Athletic Field are associated with ingest ion or contact with
the surface soils. No carcinogens were identified at this location
but the hazard index used for non-carcinogens is slightly above the
acceptable level. However, numerous samples taken directly within
the Athletic Field in April 1991 revealed consistently lower levels
of non-carcinogenic contaminants indicating that the associated
risks are lower than previously thought.
Sampling and analysis were conducted at the Irrigation Field during
the RI/FS. These analyses have determined that there are very low
or trace levels of site contaminants at this location and there are
no significant risks at this location.
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.
EXPLANATION OF FUNDAMENTAL REMEDY CHANGES
Significant modifications are now being considered for the Interim
Remedial Action. During the early part of this IRA, a variety of
additional information was generated that EPA ?.nd the ,State of
Tennessee believe should modify the existing selected Interim
Remedy. In response, the EPA will prepare a ROD Amendment that
provides a full explanation and comparison of old and enhanced Site
IRA activities. Based on this new information, the IRA is proposed
to be divided into two phases: 1) Phase I that consists of the
majority of previously selected remedial action items, and 2) Phase
II that will consist of new activities.
Major differences in Phase I include: 1) the elimination of an on-
site consolidation area, 2) off-site disposal of tar-cubes,
metallic debris, waste, piles, and tar wastes.
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.->.->.^U^...:-."^.-_->.-^
New activities to be conducted as Phase II of the IRA consist of:
STORAGE BASIN ACTIVITIES
1) Removal, treatment (if necessary), and disposal of waters at the
Storage Basin. The approximate volume is estimated at 50,000
gallons;
2) Removal off-site of Storage Basin wood-tars and associated
contaminated soils, appropriate disposal and/or treatment, or
utilization of these wastes as fuel. The volume of raw sludge
is estimated at 300-400 cubic yards;
3) Associated wood tar contaminated soils at or below the tar/soil
interface will be removed for disposal in a RCRA Subtitle D
landfill. The volume of this material is estimated at 200 cubic
yards;
4) A minor amount of wood tar contaminated soil will be removed
from the Overflow Basin. This material is expected to be less
than 60 cubic yards and will be disposed in a RCRA Subtitle D
facility;
5) The existing Storage Basin clay berms will he used for clay
cover material once the tar and 'associated soil has been
removed. Since the Storage Basin is perched on top of a hill
the finished upper surface can be contoured tc conform with the
existing topography. An upper dome configuration to enhance
drainage is required to prevent infiltration of water. The
Overflow Basin will also be contoured to prevent water from
accumulating;
6) Air monitoring will be performed at the Storage Basin during
excavation and removal of wood tars;
7) At the conclusion of Storage Basin Activities, the road to this
area will need to be removed. This will prevent unauthorized
access to this area and help to reduce vandalism.
fRIHARY SITE ACTIVITIES
1) The Primary Site Smoke Stack and Retort areas will require
further removal of metallic or other debris and excessive
vegetation to aid in future sampling prior to cleanup. The
total amount of materials removed from these locations are
estimated at approximately 200 cubic yards. This debris
(including many empty drums) may be placed into an on-site
building or decontaminated (if necessary) and transported from
the Site to a recycling facility;
2) A small earthen dam will be eliminated by removing the lower
concrete wall. This activity is required since waters
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-_-s.-i
accumulating at this location are likely entering an hidden
underground conduit and exiting a 16 inch pipe at the Still
House area. It is estimated that 10 cubic yards of non-
hazardous debris will be removed from this location. This may
be staged with other concrete adjacent to this location or
disposed at a RCRA Subtitle D facility.
Air monitoring was recently conducted at the Site following Phase
I remedial activities. This monitoring was performed to assess the
impact, if any, of the Phase I cleanup activities. Once the
results of the data have been submitted to EPA from the laboratory,
they will be evaluated to determine if any impacts have occurred.
If adverse conditions are identified, EPA will determine how they
can be reduced.
EPA plans to perform a minor investigative effort following Phase
II remedial efforts. During this effort, additional monitoring
wells and soil borings will be placed downgradient of the Storage
Basin and Still House foundation sump. These monitoring points
will serve to assess the impact, if any, of the Phase I remedial
activities at these locations.
The selected remedy and subsequent modifications that are proposed
include many off-site disposal activities instead of temporary
storage in an on-site containment area. On-site containment of
Wrigley wastes and in particular, the on-site containment or
storage of raw wastes such as flammable wood tars would potentially
be difficult due to the recent increase in vandalism. The overall
volume of tar waste will increase if Storage Basin wastes are now
to be added into the original volumetric estimate. Given the
increase in tar waste due to the potential remediation of the
Storage Basin, it would be inappropriate to temporarily contain
large quantities of tar sludges in the Primary Site 100-year flood
plain or adjacent areas. In the case of the Storage Basin,
increasing instability of this area indicates it is inappropriate
to allow wastes to remain at this location which is at the top of
a steep hill in karst terrain.
Concerning flooding of the Primary Industrial Site, the flood of
1991 demonstrated that this Site floods much worse than previously
thought since several areas outside of the 100-year floodplain were
also affected. Many areas that were not underwater during this
flood were noted to have significant soil slumping, debris flows,
and small mudslides. Based upon our observations, the Primary Site
and Storage Basin area appear to be unfit as potential locations
for any type of storage of wastes. In light of these difficulties,
we have proposed to transport and dispose of many Site wastes.
This would provide more stable and safe Site areas and would
significantly reduce the potential for Site wastes to enter and
affect the North Fork of Mill Creek, Mill Creek, and the Duck River
Drainage Basin.
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^
DESIGNATION OF TAR WASTES
Wastes at the Wrigley Charcoal Site have been historically
discussed as coal-tar wastes from coking operations. These wastes
were also previously considered to be coal-tars by the EPA
Emergency Response and Removal Branch (ERRB) during an emergency
response effort in 1988. Approximately 130 cubic yards of tar
waste was transported and disposed at the Allied Signal Facility in
Detroit, Michigan. However, historical records indicate the
Wrigley Charcoal Site did not receive coal to be utilized in the
manufacture of coke to fuel the blast furnaces. The Wrigley
Charcoal Site retorted (or distilled) local hardwood trees from the
3,000-acre facility to produce charcoal for the pig-iron blast
furnace. This process generated what is referred to as "wood, tar".
Considering that the Site never formally maintained a coking
operation, it is reasonable to conclude that tar waste from the
Wrigley Charcoal Site can be referred to as "wood-tar" and not
"coal-tar". Present regulatory guidelines allow for specified
industries to recycle or utilize the wood-tar as a fuel. Coal-tar
from coking operations is designated K087 under the Resource
Conservation and Recovery Act (RCRA) and may be utilized or
recycled by active coking facilities.
Recent testing by the Tennessee Division of Superfund on the
Wrigley Site "wood tar" wastes indicates that it passes the
toxicity leaching tests in spite of high concentrations of phenols,
elevated PAHs, and high levels of tentatively identified compounds
which include hydrocarbons. Based upon the above information, the
EPA and the State of Tennessee consider this to be a RCRA non-
hazardous solid waste that may be recycled and Utilized as either
an industrial fuel in a boiler or as a fuel in a blast furnace at
a steel manufacturing facility. This cost effective method of
waste recycling will also eliminate the need for removing Site
wastes to landfills.
OTHER WASTE IDENTIFICATION ISSUES
EPA and State of Tennessee performed dioxin sampling as a
precautionary measure to ensure effective characterization of all
wastes. The findings of our sampling indicate that all levels of
dioxin/furan identified have been well below the action level of 1
part per billion (ppb). The State of Tennessee has reviewed this
data and has concluded that these trace levels of dioxins, furans,
and dibenzofurans do not present a problem for off-site transport
of this material and utilization as a fuel for an industrial
boiler. In the event the material is utilized in an industrial
boiler, the facility that receives the waste must modify their
State of Tennessee air pollution permit for the incineration of the
Wrigley tars as well as present a. compliance monitoring plan that
describes the regulatory limits that will be maintained during the
incineration of the tars. The subject incineration facility must
also submit an evaluation of ash handling and disposal procedures
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and perform a trial burn for the tars in order that the wastes and
the residual material are handled in accordance with State and
Federal regulatory guidelines.
SITE VANDALISM
Concerning Site fencing. Site vandalism has recently been on the
increase with warning signs (placards) shot or stolen, locks on
fences and wells shot or stolen, tarps for roll-off containers
stolen, garbage and appliances dumped, and sections of fencing and
gates damaged. At this time the EPA and State of Tennessee believe
that large sections of high quality fence & gates would be a viable
target for theft at the Wrigley Site. For these reasons it has now
been determined that short sections of fence adjacent to gates will
be utilized instead of perimeter fencing. Several of these areas
are remote and we do not believe that the lack of perimeter fencing
will pose a problem. Trespassers have been no tad to scale other
fences at the Primary Site and at the present time, we feel that
short sections of fence adjacent to gates will limit the amount of
vehicular traffic that may enter several specific Site areas under
remediation.
DESCRIPTION OF ORIGINAL SELECTED REMEDY AND NEW PROPOSED REMEDY
The alternatives that EPA has evaluated for the' Amended Interim
Action are described briefly below. EPA evaluated these options
using the nine evaluation criteria listed in Table . 1 (with the
exception of community acceptance). ~
Alternative 1: No Action
Present Worth (PW) Cost: $36,000
PW Capital Cost: $30,000 (institutional controls)
O&M Costs: $6,000 (Engineering controls & permitting fees)
Time to Implement: N/A
The EPA requires that this alternative be evaluated at every site
to serve as a baseline for comparison for all other alternatives
considered. Under this alternative, no remediation would take
place. The only reduction of contaminant levels that could
potentially occur would be via natural processes such as dispersion
or attenuation. The only associated costs with this alternative
would be administrative fees incurred by the State* of Tennessee for
the implementation of institutional and engineering controls.
Alternative 2: Original Remedy - Thirteen remedial items as
presented in the ROD. All are small-scale
activities except for Spillway reconstruction.
Activities address Primary Site imminent
concerns, access restrictions at the Primary
Site and Storage Basin.
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The original remedial measures were designed to reduce and
eliminate some of the most imminent and substantial dangers present
at the Primary Site and reduce risks associated with dermal contact
at the Storage Basin through access restrictions. This alternative
includes implementation of institutional controls that prevent the
future use of ground water at the Primary Site. This alternative
reduces the risks associated with various contaminants at the
Primary Site but does not eliminate Storage Basin wastes.
Present Worth Cost: .... $984,998
PW Capital Cost: . . . . . $787,810
PW O & M Cost: ..... $3,500
Time to Implement: 6 months
Alternative 3: New Proposed Remedy - Eliminates on-site
consolidation area, provides off-site disposal
of wastes, remediates and eliminates wood tar
wastes at the Storage Basin.
This alternative addresses remediation of the Storage Basin where
wastes are located at the top of a hill adjacent to the North Fork
of Mill Creek. Medium-viscosity tars reside under approximately 2-
3 feet of water and 3 inches of silt and clay. Prior to mid-1994,
the wastes did not present the appearance of being exposed.
However, at this time dermal contact with these wastes is probable
in the event person(s) enter the basin. Although the berms
presently appear intact, slumping during times of heavy
precipitation has been noted following the flood of 1991. The
basin is also located in karst terrain and in the event the tamped-
clay bottom of the basin was compromised, wastes t.ould likely enter
the karst network and future waste remediation of these wastes
would be impossible. Remediation of the Storage Basin would
essentially eliminate risks at this location. The State of
Tennessee and EPA have investigated several options for Storage
Basin wood tar disposal. Treatability studies performed during
1994 indicate that raw wood tars are not effectively bioremediated.
Wood tars with low levels of contaminants may respond to
biotreatment but significant amounts of time are required making
this a non-feasible option. The State of Tennessee conducted a
treatability study to utilize this material as a fuel in an
industrial boiler. The study indicated that the wood tars make an
efficient fuel for industrial boilers. Also, data from this study
indicates that utilization of this wood tar meets regulatory
retirements. Any potential impact to the groundwater/air or from
transport of wastes during remedial activities will be monitored in
order to insure that these activities have no adverse impact to
human health and the environment.
Present Worth Cost: .... $900,000 - $1,200,000 ,
PW Capital Cost: $897,000 - $1,197,000
PW O & M Cost: $3,000
Time to Implement: 8 months
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^^
TABLE 1
BPA CRITERIA FOR EVALUATING
CLEANUP ALTERNATIVES
Overall Protection of Public Health and Bnviron«>Tit ; Degree to
which each alternative eliminates, reduces, or controls threats
to public health and environment through treatment, engineering
methods, or institutional controls (e.g., deed, land use or other
restrictions) .
Compliance with State and Federal Requirements; Degree to which
each alternative meets environmental regulations determined to
be applicable or relevant and appropriate to Site conditions.
Short-Term Effectiveness; Length of time needed to implement each
alternative and the risks posed to workers and nearby residents
during implementation.
Long-Term Effectiveness: Ability to maintain reliable protection
after implementation.
Reduction of Toxicity, Mobility, and Volume; Degree to which
alternative reduces (1) ability of contaminants to move through
the environment, (2) harmful nature of contaminants, and (3)
amount of contamination. ~
Implementability; Technical feasibility (difficulty of
constructing, operating, or maintaining) and administrative ease
(e.g., amount of coordination with other governmental agencies
or relocation or residents) of implementing remedy, including
availability of goods or services.
Cost; Benefits of alternative weighed against cost.
State Acceptance; EPA requests State comments on the Proposed
Plan and concurrence on final remedy selection.
Acceptance; EPA holds a public comment period to get
input from the affected community and considers and responds to
all comments received prior to the final selection of a remedial
(long-term cleanup) action.
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&->ii^<-;^3eiS:5b£^ifcS^
EVALUATION OF ALTERNATIVES
This section provides the basis for determining which alternative:
1) meets the threshold for overall protection of human health and
the environment and compliance with Applicable or Relevant and
Appropriate Requirements (ARARs), 2) provides the "best balance"
between effectiveness and reduction of toxicity, mobility, or
volume through treatment, implementability, and cost, and 3)
demonstrates State acceptance. Community acceptance is also an
important consideration and will be evaluated throughout this
process.
Overall Protection of Human Health and the Environment
Considering the extent of contamination at the Wrigley Charcoal
Site, Alternative 1 would not be protective of human health and the
environment and will not be considered further in this Proposed
Plan. Alternative 2 is protective of human health and the
environment to the extent discussed within the IAROD. Alternative
3 provides more protection since it addresses and eliminates the
Storage Basin, a major area of Site contamination. In addition,
alternative 3 adds additional monitoring in order to fully assess
any potential impact of remedial activities. Alternative 3 is
protective of human health and the environment since it reduces or
controls significant, immediate, and potential threats from direct
exposure to hazardous contaminants at the Primary Wrigley Charcoal
Site and the Storage Basin. Institutional controls such as deed
restrictions will limit future use of these locations which will
reduce risks associated with these contaminated areas.
Alternatives 2 and 3 also provide the basis for future action with
the distinction between the two alternatives being that Alternative
3 will eliminate the need for significant future actions at the
Storage Basin. Therefore, concerning overall protection of human
health and the environment, Alternative 3 provides significant
advantages over Alternative 2.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Alternative 2 fully meets ARARs identified in the IAROD. Alter-
native 3 will also meet these ARARs. While neither Alternative is
considered to be the final Site remedy, Alternative 3 is considered
to be more protective because this action fulfills, for the Storage
Basin, the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal element.
Subsequent actions are planned to address fully the threats posed
by the conditions at the Wrigley Site. Alternative 3 also totally
eliminates much of this Site debris through off-site disposal
instead of storing wastes in an on-site consolidation area. This
prevents these wastes from either being on or adjacent to the flood
plain of the North Fork of Mill Creek or from potentially being
vandalized in the on-site consolidation area (refer to IAROD for
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details on the originally proposed and select-ad consolidation
area).
Since wastes such as tar-cubes will not be moved within to an on-
site consolidation area, the Resource Conservation and Recovery Act
(RCRA) Land Disposal Restrictions (LDRs) will not be triggered.
Therefore, as was stated in the original IAROD, the RCRA storage
ARARs do not need to be waived (previously discussed in Section 9.2
of the IAROD). Concerning off-site transport and disposal of tar
wastes, contaminated soil, and site debris, RCRA Subtitle C
requirements are applicable when excavating and transporting the
soil or other contaminated media that does not pass TCLP. Safety
precautions as specified by RCRA must be followed which include
standards and' requirements for owners and operators of treatment,
storage, and disposal (TSD) facilities.
The final Site cleanup levels are not addressed in the original
IAROD or in the IAROD Amendment (in preparation) because such goals
are beyond the scope of an interim action. The final cleanup
levels for the Site will be addressed by the final remedial action
ROD.
Long-Term Effectiveness
As discussed in Alternative 3, excavation, transportation off-site,
ctnd incineration of Storage Basin tars with appropriate disposal of
the residual ash will permanently eliminate wastes at this
location. The same scenario is applicable for process tank and
still house sump wastes at the Primary Site. However, all the
interim measures will not provide any degree of long term
effectiveness for other highly contaminated areas at the Wrigley
Site. Primary Site areas such as the retort area, tar pits, and
still house are proposed for remediation during the next operable
unit. Concerning these Site areas, the EPA will continue to
evaluate long-term effectiveness and permanence as part of the
development of the final action for the Site.
Reduction of Toxicity, Mobility or Volume
Alternative 3 reduces toxicity, mobility, and volume of several
Primary Site wastes and eliminates wastes at the Storage Basin.
These actions will significantly reduce the potential for dermal
contact, migration, or bioac cumulation of Site waste streams
addressed through this Interim Remedial Action. Activities for
this Interim Action are intended to reduce present risks associated
with the most imminent and substantial dangers t-^ human health and
the environment wnile preparing several of the Site waste locations
for future remedial activities that will eliminate the wastes.
Alternative 2 satisfies this requirement concerning small-scale
activities at the Primary Site. However, Alternative 3 satisfies
this requirement concerning both Primary Site Interim Action
Activities as well as the elimination of wastes at the Storage
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Basin.
X
Short-Term Effectiveness
Significant short-term effectiveness will result from the
previously mentioned activities. The IRA 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 effects are expected during
interim remedial activities that could impact human health or the
environment. Any short-term risk to workers involved in Storage
Basin excavation, transportation or construction activities would
be reduced through evaluations performed during the Phase II
Remedial Design, and the Phase II Health and Safety Plan.
Implementability
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 either Alternative 2 or 3
since only standard construction or recycling techniques will be
utilized.
Cost
Tentative cost estimates provided by the State_ of Tennessee
indicate that Alternative 3 which includes remediation of the
Storage Basin will have a present worth cost of approximately
$900,000 - $1,200,000. The cost estimate presented in the original
Interim Action ROD was $984,998. Any additional costs concerning
Alternative 3 would be due almost entirely to Storage Basin
. remediation. A comparison of the cost for Alternatives 2 & 3
reveals that a large number of activities are included for each and
the total cost is relatively low considering several early final
activities are included. However, Alternative'1 includes early
final remediation of the Storage Basin tars which will completely
eliminate risks at this location. Storage Basin remediation is a
large-scale task and the associated costs are relatively low in
comparison to the magnitude of the cleanup. Additional areas of
contamination that are not addressed during Phases I or II of this
Interim Action are proposed for later cleanup and the associated
costs of these activities will be determined after additional
information is obtained.
State Acceptance
While EPA is the lead agency for the Wrigley Charcoal fund-lead
Site, the State of Tennessee has taken the lead for the Interim
Remedial Action. EPA and the State of Tennessee have reviewed all
of the proposed modifications to these activities and concur on
this information as presented within this Proposed Plan.
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''t'Sfynrur** . ..-....- ,-;-.-.-^-- - --.-_um__-_ -.--j-.- -.---- ^*--»-.--.*
Comnrunity Acceptance
Community acceptance of the Amended Interim Remedial Action will be
evaluated after the public comment period and wiX*. be described in
the Amendment, to the Interim Action Record of Decision for the
Site.
The public is asked to comment on the proposed modifications to the
Interim Remedial Action during the Public Comment Period, which is
from October 7, 1994 through November 7, 1994.
Community response to the alternatives will be presented within the
responsiveness summary within the Amendment to the Interim Remedial
Action ROD.
COMMUNITY RELATIONS
A wide variety of community relations activities have been
performed for the Wrigley Charcoal Site. The following Public
Meet ings/Availability Sessions have been held at the East
Elementary School near Wrigley: 1) October 24, 1988 to provide
information and also to answer citizens' questions concerning
removal activities at the Wrigley Site, 2), October 29, 1989 to
inform citizens and other interested parties of the beginning of
the RI/FS, and 3) .July 25, 1991 to present the Proposed Plan for
Interim Action activities. Between public meetings and
availability sessions, numerous site visits have_been made and
members of the local community have periodically met with the EPA
project manager to discuss the Site cleanup activities. EPA Fact
Sheets have been distributed prior to RI/FS activities, before the
1991 Public Meeting, and prior to RD/RA activities.
A Community Relations Plan had been updated for the Site which
contains a list of contacts and interested parties throughout
government and the local community that establish communication
pathways to ensure timely dissemination of pertinent information.
This document along with the RI/FS, Interim Action Record of
Decision, RD/RA and other associated documents, are available in
both the Administrative Record at the information repository
maintained at the Hickman County Memorial Library and at the EPA
Records Center in Atlanta, Georgia.
During public meetings and availability sessions the local
community voiced their opinions and concerns about the site. The
majority of community responses supported EPA and State of
Tennessee cleanup activities at the site. As the EPA and the State
of Tennessee progress on site cleanup activities, they will
continue to keep the community informed through px\blic meetings and
fact sheets.
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SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The preferred alternative for the remediation of the Wrigley
Charcoal Site is Alternative 3. This alternative appears to
represent the overall best interim remedy for the Site.
Alternative 1 does not meet the CERCLA statutory preference for
treatment of wastes and is not protective of human health or the
environment. While Alternative 2 achieves the CERCLA statutory
preference (NCP Requirement) for reduction of toxicity, mobility,
or volume through treatment, Alternative 3 includes additional
large-scale activities that provide an additional margin of
effectiveness concerning long-term site clean-up (especially at the
Storage Basin).
1-HiS PREFERRED ALTERNATIVE
Based upon consideration of the requirements of CERCLA which
includes the detailed analysis of the alternatives, EPA has
determined that the activities as presented in Alternative 3
constitute an appropriate interim Site remedy until a final action
for the Site is determined. The major components of the EPA
preferred (Amended) Interim Remedial Action include:
The original 13 Interim Remedial cleanup activities that have
already been performed during Phase I plus new activities to be
added as Phase II of the Interim Action. Phase I included the
Spillway reconstruction that prevents additional erosion or
mobilization of Site wastes into the North Fork of "Hill Creek that
is part of the Duck River Drainage Basin. The rebuilt Spillway has
been designed to accommodate flood waters that frequent this
location. The EPA and State of Tennessee are proposing to expand
the Interim Action by adding Phase II which will consist of:
STORAGE BASIN ACTIVITIES
1) Removal, treatment (if necessary), and disposal of waters at the
Storage Basin. The approximate volume is estimated at 50,000
gallons;
2) Removal off-site of Storage Basin wood-tars and associated
contaminated soils, appropriate disposal and/or treatment, or
utilization of these wastes as fuel. The volvme of raw sludge
is estimated at 300-400 cubic yards;
3) Associated wood tar contaminated soils at or below the tar/soil
interface will be removed for disposal in a RCRA Subtitle D
landfill. The volume of this material is estimated at 200 cubic
yards;
4) A minor amount of wood tar contaminated soil will be removed
from the Overflow Basin. This material is expected to be less
than 60 cubic yards and will be disposed in a RCRA Subtitle D
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facility;
5) The existing Storage Basin clay berms will t»e used for clay
cover material once the tar and associated soil has been
removed. Since the Storage Basin is perched on top of a hill
the finished upper surface can be contoured to conform with the
existing topography. An upper dome configuration to enhance
drainage is required to prevent infiltration of water. The
Overflow Basin will also be contoured to prevent water from
accumulating;
6) Air monitoring will be performed at the Storage Basin during
excavation and removal of wood tars;
7) At the conclusion of Storage Basin Activities, the road to this
area will need to be removed. This will prevent unauthorized
access to this area and help to reduce vandalism.
PRIMARY SITE ACTIVITIES
1) The Primary Site Smoke Stack and Retort areas will require
further removal of metallic or other debris and excessive
vegetation to aid in future sampling prior to cleanup. The
total amount of materials removed from these locations are
estimated at approximately 200 cubic yards. This debris
(including many empty drums) may be placed into an on-site
building or decontaminated (if necessary) and transported from
the Site to a recycling facility; ~
2) A small earthen dam will be eliminated by removing the lower
concrete wall. This activity is required since waters
accumulating at this location are likely entering an hidden
underground conduit and exiting a 16 inch pipe at the Still
House area. It is estimated that 10 cubic yards of non-
hazardous debris will be removed from this location. This may
be staged with other concrete adjacent to this location or
disposed at a RCRA Subtitle D facility.
Air monitoring data was recently acquired for the Site following
Phase I remedial activities. This monitoring was conducted to
assess the impact, if any, of these cleanup activities. The
results of this study are expected to be submitted to EPA by the
end of 1994. If this information suggests further activities are
warranted, appropriate measures will be taken.
A minor investigative effort is also planned to follow Phase II
remedial efforts. During this effort, additional monitoring wells
and soil borings will be placed downgradient of che Storage Basin
and Still House foundation sump. These monitoring points will
serve to assess the impact, if any, of the Phase I remedial
activities at these locations.
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The major goal of the entire IRA is to reduce risks at the Primary
Site and the Storage Basin by eliminating, or controlling the most
imminent and substantial threats to human health and the
environment.
It should be noted that some of the actions may be modified
following this ROD Amendment, specifically during the Phase II
RD/RA. These changes may reflect modifications resulting from the
engineering design process.
STATUTORY REQUIREMENTS
The U.S. EPA and the State of Tennessee believe that the activities
included in the IRA 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.
TECHNICAL ASSISTANCE GRANTS
EPA has been authorized by Congress to provide communities affected
by Superfund Sites the opportunity to apply for Technical
Assistance Grants (TAGS). Grants range up to $50,000 per site and
are designed to enable community groups to hire technical advisors
or consultants to help them interpret EPA findings and specifica-
tions for cleanup activities. The community must provide a 20%
match to the amount provided by EPA and only one TAG is awarded per
site. Interested persons or community groups may contact the
Region IV Grants Specialist listed below. ~
Sharon Chandler
Technical Assistance Grant Specialist
U.S. EPA, Region IV
345 Courtland Street., N.E.
Atlanta, GA 30365
(404) 347-2234
THE NEXT STEP: THE COMMUNITY'S ROLE IN THE SELECTION PROCESS
EPA solicits input from the community on the cleanup methods
proposed for each superfund response action. EPA has set a
public comment period from October 7, 1994 to November 7, 1994,
to encourage public participation in the selection process.
Comments will be summarized and responses provided in the
Responsiveness Summary section of the Amendment to the
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Interim Remedial Action ROD. The public can send written
comments to or obtain further information from:
Douglas A. Bell
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, 6A 30365
(404) 347-7791
1-800-435-9233
MORE INFORMATION
EPA has established two information Repositories to allow public
access to information about the Wrigley Charcoal Superfund Site.
Documents are currently available at the repositories (listed
below) include the Administrative Record File, which contains all
public documents used by EPA that were utilized in the development
of EPA cleanup methods for the Site, fact sheets, and RI/FS
documents.
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)
EPA Records Center
345 Courtland St., N.E,
Atlanta, GA 30365
(404) 347-0506
LIST OF CONTACTS
Douglas A. Bell
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-3555 (x3410)
Tim Stewart
Tennessee Department of Environment and Conservation
Environmental Field Office
537 Brick Church Park Drive
Nashville, Tennessee 37243
(615) 741-5940
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Suzanne Durham
Community Relations Coordinator
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-3555 (x4136)
GLOSSARY
Administrative 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 CERCLA. 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
regional EPA and/or state office.
ARARs: Applicable or Relevant and Appropriate Requirements. Refers
to the Federal and State requirements that a remedy that EPA
selects must attain. These requirements may vary from site to
site.
Baseline Risk Assessment: An assessment whr.ch provides an
evaluation of the potential threat to human health and the
environment in the absence of remedial action.
Comprehensive Environmental Response, Compensation, anri Liability
Act (CERCLA) : A Federal law passed in 1980 and modified in 1986 by
the Superfund Amendments and Reauthorization Act. The Acts created
a special tax that goes into a trust fund, commonly known as
Superfund, 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.
Hazardous Substances: Any material that poses a threat to public
health and/or the environment. Typical hazardous substances are
materials that are toxic, corrosive, ignitabj.a, explosive or
chemically active.
Information Repository: A file containing current information,
technical reports and reference documents regarding a Superfund NPL
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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.
Interim Action Record of Decision: A public document that presents
information concerning an expedited cleanup alternative that has
been selected to reduce or eliminate problems at a National
Priorities List site prior to implementation of the Final Remedy.
This document also explains the reasons for choosing that cleanup
alternative over other possibilities.
Interim Remedial Actions: Usually short-term cleanup activities
selected to reduce risks at a Superfund site while investigations
continue. Once additional information is obtained'from studies and
also from the Interim Remedial Action, then the Final Remedy is
proposed for the Site.
Monitoring: The continued collection of information about the
environment that helps gauge the effectiveness of a cleanup action.
National Priority List: A list of the nation's hazardous waste
sites that are eligible for cleanup under Superfund (1980) and SARA
(1986).
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. This alternative was selected
from a list of the most technologically feasible; alternatives for
a remedial strategy.
Proposed Plan: A fact sheet summarizing EPA's preferred cleanup
strategy for an NPL site, the rationale for the preference and
reviews of the alternatives presented in the detailed analysis of
the remedial investigation/feasibility study.
Resource Conservation and Recovery Act (RCRA) : A Federal law that
established a. regulatory 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: A public document written by EPA that presents
information concerning . the Final Remedy selected to reduce or
eliminate problems at a National Priorities List site. This
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document also explains the reasons for choosing that cleanup
alternative over other possibilities.
Remedial Action: The EPA selected action for an NPL site.
Remedial Alternative: A potential cleanup option for a Superfund
site.
Remedial Design: A set of specifications, plans, and procedures
that describe how the remedial action will proceed.
Remedial Investigation arid Feasibility Study (RI/FS): 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 Summary: A summary of oral and/or written public
comments received by EPA during a comment period.
Superfund Amendments and Reauthorization Act (SARA) : Modifications
to CERCLA Enacted on October 17, 1986.
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EPA MAILING LIST ADDITIONS
If you know of others that wish to be placed on the mailing list
to receive information on the Wrigley Charcoal Site, please
request that they fill out and mail this form to:
WRIGLEY CHARCOAL SITE
Suzanne Durham, Community Relations Coordinator
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-3555 (x4136) or 1-800-435-9233
Name:
Address:
Affiliation:,
Telephone:
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APPENDIX B
Information Concerning Information Repositories
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)
EPA Records Center
345 Courtland St.,
Atlanta, GA 30365
(404) 347-0506
N.E.
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