PB98-963123
EPA 541-R98-110
December 1998
EPA Superfund
Explanation of Significant Difference
for the Record of Decision:
Wrigley Charcoal Plant
Wrigley, TN
10/20/1997
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EXPLANATION OF SIGNIFICANT DIFFERENCES
WRIGLEY CHARCOAL SUPERFUND SITE
WRIGLEY, TENNESSEE
REGION 4
October 1997
INTRODUCTION
The U.S. Environmental Protection Agency (EPA)
is issuing this Explanation of Significant
Differences (ESD) for the Wrigley Charcoal
Superfund site ("the Site") in Wrigley, Hickman
County, Tenn. The purpose of this fact sheet is to
modify the Interim Action Record of Decision
(IAROD) issued on September 30, 1991, and to
inform the public of current site conditions and
future actions.
This fact sheet is being issued by the U.S.
Environmental Protection Agency (EPA) as part
of the public participation responsibilities under
Section H7(a) of the Comprehensive
Environmental Response, Compensation and
Liability Act (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act
of 1986 (SARA) and the National Oil and
Hazardous Substances Pollution Contingency Plan
(NCP), 40 C.F.R. Section 300.435 (c)(2)(l). An
ESD is published when the differences in a
remedial or enforcement action, settlement, or
consent decree significantly change but do not
fundamentally alter the remedy selected in the
Record of Decision (ROD) with respect to scope,
performance, or cost.
EPA and the State of Tennessee encourage the
public to review the Site documents that make up
the Administrative Record (AR) to better
understand the intent of this fact sheet. This ESD
and supporting documentation will become part of
the AR which is located in the following locations:
Hickman County Public Library
120 West Swan Street
Centerville, TN, 37033
Tel. (615) 729-5130.
Superfund Records Center
U.S. EPA Region 4
61 Forsyth Street, S.W.
Atlanta, GA 30303
Tel. (404) 562-8946
SUMMARY OF SITE HISTORY,
CONTAMINATION PROBLEMS, AND
SELECTED REMEDY
The Wrigley Charcoal site is located in Wrigley,
Hickman County, Tennessee, approximately 45
miles southwest of Nashville. It consists of four
distinct areas: 1) the 35-acre Primary Site, 2) the
three-acre Storage Basin located 1,400 feet west
of the Primary Site, 3) the 40-acre Irrigation Field
located 3,500 feet northeast of the Primary Site,
and 4) the three and one-half acre Athletic Field
located 800 feet southeast of the Primary Site in
the eastern portion of the Wrigley community.
The Primary Site 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 for the disposal of
contaminated Site wastewaters beginning in the
1940s and continuing until the mid-1960s. The
Athletic Field was constructed at the previous
location of a large ravine in the town of Wrigley.
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Slag and soils derived from the Primary Site were
utilized to fill this area from 1938 to 1950 when
the field was opened.
The Site was purchased in 1966 by the Tennessee
Farmers Cooperative (TFC). Portions of the
Primary Site were also used from 1978 to 1983 for
metals machining, storage of waste products
obtained from other local industries, and recovery
of copper from transformers.
Much of the waste at the Wrigley site was
disposed into the North Fork of Mill Creek. This
practice occurred until the mid-1940s when the
State of Tennessee requested that the Tennessee
Products and Chemical Company (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
poh/cyclic aromatic hydrocarbons (PAHs). These
attempts to reduce or impound contaminated
wastestreams inadvertently led to additional areas
of contamination.
In 1988, EPA conducted a response action aimed
at stabilizing the tar pits to prevent a major release
to the North Fork of Mill Creek. In 1989, the
State of Tennessee authorized the relocation of the
downstream Bon Aqua-Lyles Water District
primary water intake.
Based upon the results of the initial RI/FS, EPA
issued the IAROD in 1993. The State of
Tennessee Division of Superfund implemented the
Remedial Action for the contamination noted in
the IAROD and Explanation of Significant
Differences (October 1995). These activities are
described below.
• Phase I of the remedial action included:
disposal of transformer carcasses and transformers
filled with non-PCB containing tar; removal of
waste debris from the flood plain; removal of
metallic waste material from the maintenance
building's burn-pit; removal of 44 cubic yards (cy)
of process tank waste sludges; excavation and
recycling as fuel of approximately 45 cy of
contaminated soil from the Still House
foundation's sump; removal and disposal of visibly
friable asbestos corrugated roofing material from
the small building in front of the Maintenance
Building; disposal of exposed wastes located in the
spillway; disposal of wastes in 14 deteriorating
drums and of drums; repair of the spillway;
disposal of tar-cubes and other materials
containing low levels of contaminants; recycling of
wood tar wastes as fuels; excavation and removal
of waste debris piles containing predominantly tar-
cube chips and/or tar contaminated soils; and,
removal of metallic and loose surficial debris from
an area around the smoke stack northeast to the
access road down to the North Fork of Mill Creek.
• Phase II of remedial activities included:
removal, aeration, and discharge of water in the
Storage Basin and Overflow Basin to Hollow
Creek; removal of a discrete layer of fluid-like tar
material on the bottom of the Storage Basin,
blending and use as a fuel blend; removal and
disposal of 2,172 tons of visible contaminated soil
at the tar/soil interface of the Storage Basin;
removal and disposal of a small amount of material
consisting of tar residues from the Overflow Basin:
removal of the small earthen dam to aid in Site
drainage near the former retort area; and, removal
and disposal of 3,113 tons of contaminated
material from the former on-site tar pits.
DESCRIPTION OF SIGNIFICANT
DIFFERENCES AND BASES FOR THE
DIFFERENCES
The IAROD identified the bum-pit remediation
and the elimination of process tank waste sludges
as early final actions. The burn-pit was to be
cleaned up to acceptable soil concentrations
(ASCs), then backfilled with clean fill. During
Phase I of the remedial action, all metallic waste
material was removed from the concrete-lined
bum pit (trench) and disposed off-site. The burn
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pit was backfilled with clean fill as a safety
measure. Therefore, no sampling was necessary at
the bum-pit to confirm that the cleanup levels
were attained because of complete removal of
waste material down to the concrete bottom of the
pit. The process tank waste tar was removed,
placed in roll-off containers, and utilized in a
treatabilhy study at a later date. The waste tar that
spilled during the tank removal was collected,
transported off-site, and stabilized in an approved
facility. Spill remediation continued until all
visible black tar was removed. The area was then
graded, seeded, and mulched with rip-rap being
placed on the creek bank to prevent erosion. Both
the metallic wastes and waste tar were classified
as non-hazardous solid waste.
CURRENT SITE CONDITIONS
All remedial activities specified in the IAROD and
subsequent amendments have been completed.
The risks of exposure through direct contact and
inhalation have been substantially reduced at the
Primary Site and Storage Basin by removing,
treating and/or disposing of contaminated
materials. Sampling of residential wells and
springs conducted after completion of Phase II
confirm that there are no impacts from the
remedial activities conducted.
A final inspection conducted by EPA and the State
of Tennessee Division of Superrund on May 30,
1996, revealed hot spots of liquid tar in a localized
area at the Primary site. The hot spots were
mostly dry but some liquid was evident. This area
will be monitored, evaluated, and if needed,
excavated, treated and/or disposed at an approved
landfill.
FUTURE ACTIONS
The aquifers at the Wrigley Charcoal site have not
been fully defined or characterized. The ground
water investigation for the RJ focused on the
shallow aquifer with only one round of sampling
conducted. From this sampling event, various
contaminants were identified above Drinking
Water Standards. Additional data will be needed
to fully characterize the ground water at this Site.
The data will be evaluated, and a risk assessment
prepared to determine if further action is needed.
The decision will then be documented in the final
Record of Decision for the Wrigley Charcoal site.
PUBLIC PARTICIPATION
This fact sheet provides public notice of the ESD,
including the reasons for such differences.
Supporting information is included in the
Administrative Record and is available for public
review. Comments or questions on this ESD
should be mailed to Liza I. Montalvo at the
address shown below.
U.S. Environmental Protection Agency
Region 4
North Site Management Branch
61 Forsyth St., S.W.
Atlanta, GA 30303
>. Green
irector
lanagement Division
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MAILING LIST ADDITIONS/CORRECTIONS
If you or someone you know would like to be placed on the Wrigley Charcoal site mailing list, please fill out
and mail this form to:
Cindy Gibson
Community Relations Coordinator
U.S. Environmental Protection Agency
61 Forsyth Street, S.W.
Atlanta, Georgia 30303
Name:
Address:
Affiliation: Phone:
• United States Environmental Protection Agency
| Region 4, North Site Management Branch
61 Forsyth Street, S.W.
Atlanta, Georgia 30303
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