United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-89/043
December 1988
Superfund
Record of Decision
American Creosote Works, TN
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50272-101
REPORT DOCUMENTATION i. REPORT MO. i
PAGE EPA/ROD/R04-89/043
4. TMoendSuMM*
SUPERFUND RECORD OF DECISION
M*-ierican Creosote Works, TN
.rst Remedial Action
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U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
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EPA/ROD/R04-89/043
American Creosote Works, TN
First Remedial Action
(6. Abstract (Continued)
the remaining untreated oil/water mixture in empty tanks onsite, stabilizing the
contaminated soil and sludges remaining in the lagoon material, and covering two lagoons
with a clay cap. A second removal action was conducted in March 1986 after several
storage tanks were determined to be leaking. The plant process facilities, including
the treatment building, storage tanks, piping, ponds, and filters, are considered a
point source of contaminants due to leakage from these structures and adjacent pits.
Furthermore, several tanks and pipes are structurally unsound and open to precipitation,
posing a threat of overflow or sudden, major release of contaminants. This remedial
action will focus on reducing surface contamination resulting from degradation of the
tanks and site structures, and minimize the potential for increased contamination due to
flooding while further information is developed and analyzed. A subsequent remedial
action will address contaminated soil, gound water, and surface streams. The primary
contaminants of concern affecting the sludges, site structures, debris, and tanked
liquids are VOCs and other organics including PAHs and phenols.
The selected remedial action for this site includes consolidation and incineration of
sludges in the vicinity of the buildings and tanks; on- or offsite incineration of the
oils and sludges from the tanks; treatment of tanked process liquids onsite using a sand
filter, filter press, and carbon adsorption unit, followed by discharge to a surface
stream; decontamination and offsite disposal of site structures (e.g., buildings, tanks,
pipes) in RCRA Subtitle D facility; construction of a flood-protection dike; deed
restrictions and site fencing; and site stabilization including monitoring onsite water
levels behind the dikes and pumping, treating (as needed), and discharging impounded
fcater pending a final remedy. The estimated present worth cost for this remedial action
Ranges from $5 million to $6 million. Annual O&M costs were not provided.
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i
3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
34S COURTUANO STREET
ATLANTA. GEORGIA 303«S
MEMORANDUM
DATE, DEC 2 1 1988
SUBJECT: Declaration for the American Creosote Works, Tennessee
Record of Decision
FROM: Jon D. Johnston, Chief
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Thia operable unit includes: treatment of the water contained in the
incineration of the oils and aludgea from.the tanka; decontamination,
demolition and diapoaal of the tanka; and, conaolidation and incineration of
sludge* (spilled or leaked) in the immediate vicinity of the buildings and
tanka. Water from the tanka will be treated on-aite utilizing a aand filter,
filter pre»« and carbon adaorption unit. Treated water will be analyzed to
document treatment efficiency and discharged to the South Fork Forked Deer
River or Central Creek. The oil and aludgea from the aite will be incinerated
off-aite at a fixed facility or on-aite in a mobile incinerator if an off-aite
facility is unable to diapoae of the waste. The aite structures (buildings,
tanks), pipes) will be decontaminated and disposed off-site at a Subtitle 0
facility to be selected in consultation with the Tennessee Department of Health
and Environment. Uncontaminatad or decontaminated salvageable materials will
be sold if possible to a scrap dealer or recycler. Site stabilization pending
a final remedy will include monitoring water levels on-site behind the dikes
and pumping/ treatment (as needed) and discharge of impounded water.
Implementation of this operable unit will remove tanked sludges, process
liquids and process buildings which are major potential contamination sources.
Fencing all or part of the site will prevent accidental exposure to the near
surface contamination and limit the threat of dermal contact and ingestion.
This operable unit will prevent future adverse environmental effects that may
occur as a result of potential release* from the tanks but does not address
environmental threats from existing contamination of surface) streams.
Additionally/ this alternative does not address continued contaminant'migration
via the groundwater.
The selected remedy is protective) of human health and the environment, attaid
Federal and State requirements that ars> applicable or relevant and appropriate
for this remedial action, and is cost-effective. By authorizing the thermal
destruction of liquids and sludges, this remedy satisfies the statutory
preferences for remedies that employ treatment that reduces toxicity, mobility,
or volume as a principle element and utilites permanent solutions and
alternative treatment (or resource recovery) technologies to the m*»
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Decision Summary
American Creosote Works Site, Tennessee
Operable Unit One
I. Site Name. Location and Description
The American Creosote Works (ACW) site ie located in central Madison
County, Tennessee, on the Jackson South 7-1/2 minute quadrangle. The
site covers approximately 60 acres southwest of downtown Jackson/
Tennessee (Figure 1.1). The site is bounded on the south by the
Seaboard Railroad, on the southwest by the South Fork Forked Deer River,
on the west and north by Central Creek, a tributary to the South Fork
Forked Deer River, and on the east by a lumber mill. The general area
is characterized by a gently rolling topography with wide, marshy flood
plains. Maximum relief is on the order of 100 feet (elev 350 + ft MSL
to elev 450 + ft MSL), with relief on the plant: site of about 20 feet.
The surface topography of the site includes numerous, small swales, four
lagoons and other low lying areas. This low lying areas accumulate
contaminated surface water and sediments.
II. A. Site History
The American Creosote Works, Inc., began operation as a wood preserving
facility in 'the early 1930's and continued until December 1981. The
wood preserving operation used both creosote and pentachlorophenol
(PCP). Wastewater sludges from the creosote and PCP treatment of wood
products are listed as K001 waste under RCRA.
Untreated process wastewater and potentially contaminated storm water
run-off were discharged directly into Central Creek until 1973. The
major sources) of contaminated water were the treatment cylinder
condensate and surface water run-off over contaminated soils.
A levee was constructed in 1973 to retain surface water run-off from the
site and to reduce the potential for flood waters from the South Fork
Forked Dear River from inundating the site. The soil borrow pits used
for tha levesj construction subsequently hermsa sludge storage) lagoons.
Figur* 1-2 shows the general sit* facilities and historical lagoon
location*.
During 1974 and 1975, a wastewater treatment system was installed which
operated through 1981. This system incorporated two oil/water
separators, six sand filters and a recirculation pond. The engineering
report for the treatment system reportedly states that 25,000 gallons of
groundwater per day entered the sump under the pressure treatment
cylinders. This report also indicated that there was an expected
accumulation of 5 tons of sludge per year in the sand filters at the
accumulation rate of 10.5 cubic feet par week. This would have required
a clean out every 3 month*. It ha* been reported that a "few" loads of
sand filter sludge were spread on the back road at the east end of the
property. In addition, the recirculation pond was reported to have
overflowed on more than .one occasion during its operation.
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FIGURE 1-1
.STEJ.OCAJ10N MAP
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LAGOON
\\\ ! V<—LAG
Mil \
— UNNAMED TKBUTA8Y
'._\.,.7.™_-V_-II~" '.'~L\ I.'—I—'--.'."" ~ ~" "'-'~''_*j
MONITOR WELLS SY TENNE^St-'.'£ :/i' :. i.'N
OF SOLID WASTE MANAGEMENT
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SAND FILTERS
T-6 ) OIL TANKS
o
SUMP AND
TREATMENT CYUNDERS
MAIN PROCESS
BUILDING
FIGURE ;-5
TANK LCCATiCK-
AMERICAN CSE:
JACKSCN. ">•.
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Tha American Creosote Works, Inc., ceased operations in December 1981.
(In May 1982, ACW filed for bankruptcy under Chapter 11 of the
Bankruptcy Law, see Enforcement Section.)
Response actions at the ACW sit* began immediately prior to the closing-
of the facility and continue to the present. Listed below in
chronological order are the actions identified.
-- November 1981; Tennessee Department of Health and Environment
(TDHE) installed four shallow groundwater monitor wells around the
property line.
— December 1981; National Pollution Discharge Elimination Systems
(NPDES) Permit ITN0001904 issued. ACW facility ceased operation.
— June 1982; TORE sampled the site. High concentrations of PCP and
creosote were present.
-- March 1983: Lagoons at the sit* overflowed.
— May 1983; Sampling at the ACW site by the EPA Environmental
Services Division (BSD) personnel indicated the sludge, surface
soils, lagoon waters and shallow groundwater south and southwest of
the lagoons were contaminated with organic compounds associated with
wood preserving using creosote and PCP. The EPA was authorized to
remove hazardous wastes at the site. Prom June 4 to June 22, 1983,
approximately 30,000,000 gallon* of wat*r were pumped from the site
to the South Pork Forked Deer River. Daily samples taken by EPA did
not exceed the PCP concentration of 100 part* per billion (ppb)
discharge criteria set by the Tennessee Division of Water Quality.
Treatable portion* of the lagoon water* were treated by filtration
and carbon absorption prior to discharge. The intratubal portion of
material in the lagoon* was stabilized with lime kiln dust in
'lagoon* 1 and 3, and covered with a clay cap.
— June 1984i EPA inspected the site.
)8St Repair work wa* authorized at the site to mitigate
effects of leaking tank*.
— November 198S; Analytical data from several old artesian wells
indicated results for the acid-extractable organics below detection
limits of 0.01 mg/1 (10 ppb).
— May 1986; Plans for the Remedial Investigation began between the
Corp* of Engineers and EPA.
— January 1987; Corps and EPA began field work for the RI/FS.
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II. B. Enforcement Hiatorv
In December 1981, American Creosote Works Tennessee, Inc., in Jackson,
Tennessee received its National Pollution Discharge Elimination Systems
(NPDES) Permit #TN0001904; however, shortly thereafter, the facility
ceased operation. On May 21, 1982, ACW filed for Chapter 11 Bankruptcy.
In June 1983, EPA approved $860,000.00 in CZHCLA emergency funds to
dewater the site, remove and bury sludge, and cap certain areas with
clay. On June 1, 1983, the Technical Assistance Team (TAT) took samples
at the site. On June 3, 1983, the Gulf Strike Team pumped water from
the site to the Forked Deer River. EPA consolidated the.sludge into a
control area and capped the area with clay. All on-site operations were
completed by August 13, 1983. Costs for the above described activities
totalled $735,399.61. In October 1984, the site was placed in Group IX
of the National Priorities List. On September 19, 1985, EPA approved an
Action Memorandum for a Remedial Investigation and Feasibility Study
(RI/FS) of the site in the amount of $306,000.00 and thru 1986 that cost
increased to $800,000.00.
On July 25, 1983, EPA filed a proof of claim for $3,500,000.00 in the
Chapter 11 Bankruptcy proceeding. Due to ACW's lack of adherence to the
court's procedures, on April 20, 1988, the U.S. Bankruptcy Court for the
Northern District of Florida, Pensacola Division, dismissed ACW's case.
Based upon this fact and the fact that the Tennessee Secretary of State
revoked ACW's charter of incorporation on April 9, 1985, ACW is no
longer in business and is not a viable party for cost recovery purposes.
III. Community Relations History
Community relations activities at the American Creosote Works site have
been handled with direct involvement from the U.S. XPA and TDHK. The
initial contact with the public took placet in Jackson, Tennessee in
1982. It was in the fora of interview* with representatives of the City
of Jackson with respect to the upcoming Superfund removal action of June
1983*- Two public meetings were held for the Jackson community. The
first meeting was held in December 1986 prior to initiating RI/FS field
activities. The second meeting was held on August 29, 1988 to disclose
the results of the RI/FS to the Jackson community. The remedial
alternatives from the FS were discussed as well as EPA's proposed plan
to address site contamination.
Public involvement and participation regarding the site have been
limited. Representatives of the City of Jackson have asked for greater
involvement in response planning and implementation. There is concern
regarding the potential impact on the Jackson well field located 1-2
miles northeast of the site, and the sewer interceptor line located near
the southern edge of the site. Also there is a strong interest from
these local bodies to facilitate development of the site and the
surrounding area (see Responsiveness Summary for further discussion).
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IV. Scop* and Role of Operable Unit within Site Strategy
The remedial investigation identified general areas of contamination but
was not of sufficient scope to thoroughly define the extent of the
contamination in soil, groundwater or surface water. The fS identified
these three as the principal threats posed by the site but data gaps are
significant enough that a final remedy cannot b« selected without
additional study. As a result, this operable unit will reduce the
potential for direct exposure to surface contamination resulting from
degradation of the tanks and site structures and minimize potential for
increased spread of contamination due to flooding while additional
information is developed and analyzed. This action will dispose of
process liquids and sludges (estimated 500,000 gallons contaminated
water, 25,000 gallons oil and 115,000 gallons sludge) currently in
on-site containers, demolish and dispose of the process buildings and
storage tanks, isolate the site with fencing and construct flood
control. Implementation of this phased approach will minimize the
highest risk of human or environmental exposure through use of proven
technologies in a manner consistent with a permanent remedy.
V. Svwarv of Site Characteristics and Risks
The wood preserving operation at the site used both creosote and
pentachlorophenol Wastewater sludges from the creosote and PC?
treatment of wood products are listed as K001 wastes under RCRA. The
plant process facilities are considered a point source of contaminants.
These structures include the treatment building, pressure cylinders,
boiler room tank*, oil storage tanks, tank cars, piping, vacuum pond,
sand filters (and other water treatment-facilities) and associated
pipes, appurtenances and storage buildings. Leakage from these
structure* and adjacent pits are causing a constant discharge of
contaminants. Several of the tank* and pipes are structurally unsound,
posing thei threat of sudden, major release of contaminants. In
addition, many of the tanks are open-topped, allowing entry of
precipitation which increases the volume of contaminated liquids and
add*- to the threat of release. Surface water collecting behind the
facility dikes from upgradient poses a flooding hazard which may spread
contamination both on- and off-site.
The RI identified several classes of compounds of concern at the ACW
site. These were volatile organic compounds, polynuclear aromatic
hydrocarbons, and phenolic compounds. The m^»
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In the baseline risk assessment, indicator chemicals were chosen
according to the Superfund Public Health Evaluation Manual. This
process aids in the identification of chemicals which are believed to
represent the most toxic and carcinogenic members of each class of
chemicals. The indicator chemicals and the class of compounds each
represents are:
— benzo[a]pyrene and benz(a]anthracene - polynuclear aromatic
hydrocarbons
— tetrachlorophenol - phenolic compounds
Benzo[a]pyrene and benz[a]anthracene were detected in high
concentrations in soils and in tank wastes. In. tanks containing
creosote/ concentrations of these contaminants exceeded 1000 ppm.
Tetrachlorophenol was detected in a single near surface soil sample and
in two of the three ground water samples. Benz[a]anthracene is a
suspected human carcinogen. Tetrachlorophenol ia not known to be
carcinogenic to humans or animals.
The baseline risk assessment identified direct contact with contaminated
oils and inhalation of contaminated dust as primary routes of exposure.
Long-term or sudden release of contaminated liquids and sludges from
on-site structures will increase soil contamination and poses the risk
of surface water and groundwater contamination.
VI. Doc"rnentation of sionif ic*nt changes
CBRCLA Section 117(b) requires that this remedial action plan be:
[a]ccompanied by a discussion of any significant changes
(and the reasons for such changes) in the proposed plan
and a response to each of the significant comments,
criticisms and new data submitted [on the RI/FS report and
the Proposed Plan.]"
SPA did not receive any new or additional information from the public
hearing or public comment period. There were no significant commenta,
criticism* received after the August 29, 1988 Public Hearing and before
compilation of this ROD. However, the selected alternative described
below contains significant changes from the Proposed Plan and these
changes affect the scope, performance, and cost of the selected remedy.
These significant changes are a logical outgrowth of the information and
analysis presented to the public and could have been reasonably
anticipated by the public.
The selected alternative will be described in greater depth below. This
section will briefly describe the differences between the proposed plan
presented to the public on August 29, 1988 and the selected alternative
herein.
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From the FS alternatives evaluation, BPA selected the following
components as the proposed plan or preferred remediation at the public
hearing:
— groundwater monitoring
— deed restrictions limiting further use of the site
— construction of flood protection dike around the site
—- installation of a containment barrier around the non-aqueous phase
liquids (NAPL) plume of creosote and pentachlorophenol
— groundwater extraction and treatment of the subsurface contamination
to include soluble organics
— solidification of surface soils in place, or through excavation
solidification and replacement of soils on-aite which includes
remediation of tank sludges
stream sediment remediation
installation of security fencing around the site
The selected remedial action operable unit is a subset of the proposed
plan and includes:
* deed restrictions limiting further use of the site
* construction of flood protection dike around the site and site
stabilization
* removal and disposal of tanked liquids and sludges
* removal and disposal of site structures
* installation of security fencing around the site
As submitted these changes are significant as determined under CXRCLA
Section 117(b). The changes could be reasonably anticipated by the ,
public because it was emphasized in the RI/PS and at the public hearing
that there were data gaps concerning groundwater/ soils and stream
sediments and also that both the groundwater extraction treatment
technology and the practicability of installing a containment barrier
were uncertain. The SPA also stated at the public hearing that this
uncertainty could be dealt with during the i smsxll •! design phase. After
the public hearing and further consideration/ the SPA management and
project team decided that the most advisable and appropriate course of .
action would be to implement the operable unit clean-up measures only
and address the groundwater, soil and stream sediment questions in a
subsequent ROD. A citizen would be able to anticipate this change _n
scope because of the additional data gathering and technical
difficulties associated with groundwater extraction underscored at the
August 29, 1988 public hearing. This operable unit is a logical subset
of the proposed plan.
VII. The Selected Remedy
This operable unit will initiate action at the site while additional
information is developed and evaluated. The selected remedy includes:
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* deed restrictions limiting further use of the site
* construction of flood protection dike around the site and aite
stabilization
* removal and disposal of tanked liquids and sludges
* removal and disposal of site structures
* installation of security fencing around the site
This operable unit includes: treatment of the water contained in the
tanks; incineration of the oils and sludges from the tanks;
decontamination, demolition and disposal of the tanks; and,
consolidation and incineration of sludges (spilled or leaked) in the
immediate vicinity of the buildings and tanks. Water from the tanks
will be treated on-site utilizing a sand filter, filter press and carbon
adsorption unit. Treated water will be analyzed to document treatment
efficiency and discharged to the South Pork Forked Oeer River or Central
Creek. The oil and sludges from the site will be incinerated off-site
at a fixed facility or on-site in a mobile incinerator if an off-site
facility is unable to dispose of the waste. The site structures
(buildings, tanks, pipes) will be decontaminated and disposed off-site
at a Subtitle D facility to be selected in consultation with the
Tennessee Department of Health and Environment. Uncontaminated or
decontaminated salvageable materials will be sold if possible to a scrap
dealer or recycler.
Phase II of this remediation is intended to remediate more areas of the
site by constructing a fence around the site boundary to deter access to
casual visitors and construct flood-protection diking. This option may
be implemented concurrent with or subsequent to Phase I. Removal of
non-process area structures and other incidental construction is not
planned during either phase, but will be addressed as part of the final
remedy. Site stabilization pending a final remedy will include
monitoring water levels on-site behind the dikes and pumping, treatment
(as needed) and discharge of impounded water.
iiation of the surface soil* is not planned during either phase
since bench- or pilot-scale testing is needed to verify that the
technologies discussed in the FS report are applicable to site
conditions.
VIZI. Statutory Determinations
The U.S. BPA and TDHE believe that this remedy will satisfy the
statutory requirements of providing protection of human health and the
environment, attaining applicable or relevant and appropriate
requirements of other environmental statutes, will be cost-effective,
and will utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent
practicable.
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IX. Protection of Human Health
The selected remedy provide* adequate protection of human health and the
environment by eliminating the direct exposure threat through dermal
contact with surface soils and tank sludges.
There are no unacceptable short-term risks or cross-media impacts
anticipated by implementation of the Operable Unit.
Implementation of this alternative would remove tanked sludges and
process liquids, and the process buildings which are a potential major
contamination source. Fencing the site would isolate the casual visitor
from the near surface contamination and limit the threat of dermal
contact and ingestion. Implementation of this alternative would also
remediate future environmental effects that may occur as a result of a
major release from the tanks, but would not address environmental harm
that may be occurring as a result of existing contamination in the
surface streams. Additionally, since this alternative does not address
groundwater contamination by the aqueous or NAPL plume, it has no impact
on continued off-site contaminant migration via the groundwater route.
X. Attainment of ARARs
This Operable Unit will comply with the applicable or relevant and
appropriate requirements listed in Table 1.
XI. Cost Effectiveness
This alternative affords a higher degree of overall effectiveness in not
only protecting the public against direct exposure to surface soils but
also in removing the threat of sudden release of contaminated liquids.
The ^present worth of this alternative) ranges from $5 million to $6
million dollar* (Attachment 1. Action Memorandum). This remedy Im a
proven technology, and it is a straightforward cleanup remedy which e&n
be implemented year round.
Thie alternative uses technologies that are proven for isolation
(fencing), remediation of tanked liquids and sludges (incineration),
remediation of process buildings (decontamination and off-site disposal)
and flood protection (earthen dike construction or reinforcement).
Stabilization of the site conditions through use of the proven
technologies would allow time to do the testing needed to validate the
less proven technologies that may be appropriate for the final remedy.
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XII. Dtilization of Permanent Solutions and Alternative Treatment
Technologies or Reaourcea Recovery Technologies to the Maximum gxtent
Practicable and Preference for Treatment as a Principal Element
U.S. EPA believes this remedy is the moat appropriate solution for
initiating an appropriate operable unit at the ACW site and for
providing the best balance among the evaluation criteria for the
alternatives evaluated. This remedy provides effective protection in
both the short- and long-term to potential human and environmental
receptors, is readily implemented, is cost effective and is consistent
with future response actions that may be undertaken at the site.
Thermal destruction of liquids and sludges represents a permanent
reduction (through treatment) of toxicity, mobility and volume.
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Table 1.
Applicable or Relevant and Appropriate Requirement3
Action
Discharge of treatment system effluent
Protection of flood plains
Fish and Wildlife Coordination Act
(16 USC 661 et sag.)
Dike stabilization
Solid waste disposal
Off-site transport of hazardous wastes
On-aita incineration of hazardous wastes
On-site incineration of hazardous wastes
(in addition to the above)
Citation
40 CFR 122.44(a)
40 CFR 122.44
Water Quality Act, Tennessee Code
Annotated (T.C.A.) Section
69-3-101 et aec. Rule Chapter
1200-4-3
40 CFR 131
40 CFR 6, Appendix A
40 CFR 6.302
40 CFR 264.221
Solid Waste Disposal Control Act,
T.C.A. Section 68-31-101 et see.
Rule Chapter 1200-1-7
Hazardous Waste Management Act.
Part 1 T.C.A. Section 68-46-101
at see. Rule Chapter 1200-1-11,
12 and 13. Part II T.C.A.
Section 68-46-201 et aeq. Rule
Chapter 1200-1-11-14
40 CFR 264
Air Pollution Control Act. T.C.A.
Section 68-25-101 et sea. Rule
Rule Chapter 1200-3-1
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Final Responsiveness Summary
The U.S. Environmental Protection Agency (EPA) established a public comment
period from August 30, 1988 through September 20, 1988 for interested parties
to comment on EPA's Proposed Remedial Action Plan (PRAP) for the first operable
unit of the ACW site.
EPA held a public hearing on August 20, 1988 in Jackson' to describe the
remedial alternatives developed and present EPA'a preferred remedial
alternative for the ACW site.
A responsiveness summary is required by Superfund policy for the purpose of
providing EPA and the public with a summary of citizen comments and concerns
about the site, as raised during, the public comment period, and EPA's responses
to those concerns. All of the comments summarized in this document have been
factored into EPA's final decision of the preferred alternative for cleanup of
the ACW site.
This responsiveness summary for the American Creosote Works site is divided
into the following sections:
I. Background on Co"""unitv Involvement and Concerns. This
section provides a brief history of community interest and
concerns regarding the American Creosote Works site.
IX • S'immarv of Ma'I or Questions and C/v*rnents Received During
the Public Comment Period and EPA Responses. This section
presents both oral and written comments submitted to EPA
during the public comment period, and provides BPA's
responses to these comments.
III. Remaining Concerns. This section discusses community
concerns that EPA should be aware of as it prepares to
design and implement the first operable unit, and plan the
necessary steps to address the second operable unit for
the ACW site.
XV. Correspondence. This section serves •• an attachment for
rrespondence received and responded to during the public
at period.
I. Background on Community Involvement and Concern
The Jackson community has been aware of the contamination problem at the
ACW site for several years. In response to complaints received between
1980 and 1983, TDH3 began investigating the site for surface water and
groundwater contamination. Then in June 1983, the U.S. EPA Region IV
conducted the first of two removal actions at the site to stabilize the
contamination and protect the nearby residents from any contamination
spreading off-site into potable drinking water supplies. The second
response action took place in the latter part of 1985 when the on-site
tanks which contained sludges were repaired to prevent any leaking. Both
of those responses included EPA interviews with both Jackson officials and
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community residents. Before with the public hearing on August 29, 1988,
SPA conducted a public meeting in December 1986 at the beginning of the
Remedial Investigation of ACW. At both of these meetings, the key issues
and concerns identified were:
u
Financial Concerns Both officials and merchants were concerned with the
negative impact a Superfund site would have on land value and business
development in the area.
Coordination with Local Officials Officials expressed a desire to be
kept informed about activities and developments at the ACW site. Health
officials were concerned about the possible effect of the groundwater
contamination on the nearby Jackson well field and the wastewater
treatment lines that run tangential to the southwest boundary of the
site. Officials did express dissatisfaction with the EPA'a effort of
keeping the Jackson community well informed over the last three to four
years.
II. Summary of Malor Questions and Comments Received During the Public
Hearing and Co^^ent Period *nd EPA Respons
At the public hearing, the community residents expressed concern about tJ
extensive surface soil and groundwater problem, the wastewater lines
running near the site, time frame to clean the site completely and ways to
restrict access to the site to prevent people from trespassing on the site
and being exposed to hazardous waste.
Also SPA received two letters from Kenneth Martin who is manager of the
Water Department of the Jackson Utility Division. His August 23rd and
August 29th letters are addressed specifically as part of this
Responsiveness Summary. This section will briefly summarize the BPA
responses to both (See Section IV below) letters and the concerns at the
public hearing commentst
Concerns, rnmasnts and views of the) Jackson cosnunity were similar in
nature) to those) of Kenneth Martin's correspondence; in fact, Mr.
Martin's concerns elaborated on the statements and views expressed at
the) bearing. There was the comment that the RI/TS study performed for
ACW did not adequately address the extensive groundwater contamination
at the site, its effects on the Jackson well field and the need to
collect more data about the subsurface contamination. The EPA
completely agrees with Mr. Martin regarding the inadequacy of the
groundwater data accumulated thus far and therefore the SPA plans to
perform additional investigation of the groundwater condition below the
site, off-site, re-evaluate the direction of the groundwater gradient
and establish definitive results regarding the relationship between tha
ACW contaminated aquifer and that of Jackson's well field.
When this additional investigation is completed, the EPA will issue another
proposed plan to remediate the groundwater and will conduct a public
hearing regarding this plan. The damage done to the aquifer below the ACW
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•ita ia severe and will require a long time to clean up. The EPA will use
the moat practicable technology to clean up the aquifer and at the game
time protect the Jackson well field aquifer from being contaminated.
Another major concern was the forty eight inch (48") sewer interceptor line
running near the site. This line is off-site and does not run under the
property of the ACW site as Mr. Martin contends in his correspondence.
These lines were placed near the southwest boundary of the site at
approximately the same time the ACW company ceased operation. The SPA will
coordinate with Mr. Martin's staff when performing field work in that
particular area. The EPA does not have authority to finance repair work
for the sewer line since EPA's jurisdiction only extends to the
contamination directly caused by the ACW contamination. Finally SPA
recognizes the dangers and risks associated with exposure to surface soil
contamination and is presently making plans to relieve this threat to any
people passing or venturing on the site.
III. Remaining Concerns .
HPA's field work during the remedial design phase and remedial action
pursuant to this ROD will be concerned with cleaning up the surface soil
contaminants and the tank process area. Additional field work and further
investigation will be in conformance with this action and compatible with
the final ROD in ?Y 89 that will address the groundwater contamination.
IV. Correspondence
Note attachments and EPA responses.
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Jackson Utility Division
'CST C"'CE 3C* ;J JAC^SOS "S'NESSEE j83C2-C05£ ~E-E = -CN£ 9C'
KENNETH W. MARTIN k __ .;,_«,
MANAGER AuaUSt 23, i988
WATER DEPARTMENT
Mr. Greer C. Tidwell,.
Regional Administrator
U.S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 3C265
Re: American Creosote Works Superfund Site
Jackson, Tennessee
Dear Mr. Tidwell:
Jackson Utility Division (JUD) recommends that additional groundwater and
contaminant studies should be performed for the above-referenced site in
order to determine the extent of contamination and to determine if this
contamination could have an effect on Jackson's drinking water supply.
JUD has recently reviewed the draft remedial investigation report and the
draft feasibility study for the American Creosote Works Superfund site.
JUD's conclusions are:
1. The purpose of a remedial investigation is to determine the extent of
contamination, the rate the contamination is moving, and which
contaminants are present. This information is needed so that the best
alternatives for cleanup may be determined in the feasibility study.
2. The remedial investigation report states that the extent of both
horizontal and vertical contamination has not b««n defined.
* . t
3. The direction of groundwater flow at the site i« presently assumed to be
from the northeast to the southwest toward the Forked Deer River.
4. The city of Jackson's water supply is from groundwater. The city's wells
are north and southeast of the site.
. t i*
5. Taking into consideration the minute gradient-(0.0031 feet per foot) and
the fact that groundwater investigations have been performed during a
drought, it is conceivable that the direction of groundwater flow could
reverse after periods of long, intense rainfall.
6. A groundwater flow reversal could mean a possible effect on the city's
water supply from site contamination.
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Mr. Greer C. Ticwell
August 22, 193.2
Page 2
'?. The wastewater system lir.es rur. through t.-e site. This was r.z: addressed
in the remedial investigation or the feasibility study. These would
certainly be affected during remedial activities. I.-f iltraticr. c:
contamination into the wastewater system will likely occur. The U.S.
Environmental Protection Agency (EPA) las not obtained any information
from JUD concerning our treatment capabilities.
8. An adequate remediation plan cannot be developed until the problem is
better defined (i.e.. How can anyone clean up the problem if no one knows
what the actual problem is?).
9. JUD has discussed with the United States Geological Survey (U.S.G.S.) the
possibility of performing a groundwater study in the Jackson area because
JUD - feels the remedial investigation has not defined groundwater
conditions adequately.
10. The remedial investigation appears to be inadequate, due to the factors
discussed above.
Therefore, JUD believes EPA should perform further groundwater and
contaminant investigations which would fill in the gaps of the remedial
investigation before, a remedial action is chosen (i.e., the investigation
should better define groundwater conditions in the area and define the extent
of contamination).- JUD believes this study should also determine any
possible effects of contamination of the city of Jackson's water supply, i
Perhaps EPA would consider a U.S.G.S. study as part of the remedial
investigation.
JUD believes that a remedial option should be decided as soon as possible so
that remedial activity can begin, but if the problem has not been properly
defined then a proper alternative cannot be chosen. >
JUD would appreciate a response to this letter as socr? AS possible. Thank
you for your time and consideration.
Sincerely,
JACKSON UTILITY DIVISION
Cenneth W. Martin
Manager, Hater Department
KWM/pdc
cc Joe Exum, JUD
Robert Conger, Mayor, City of Jackson
Dennis Manganiello, EPA Project Manager
Danny Lester, JUD
Richard Holland, Jackson Basin Office, TDHZ
Lauren HeffeLman, UT MTAS
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Jackson Utility Division
POST OFFICE 9OX 68 JACKSON TENNESSEE 38302-0068 TELEPHONE 1901)
KENNETH W. MARTIN
MANAGER
WATER OCPANTMCNT
Mr. Donnas Manganiello
Remedial'Project Manager
Superfund Branch
U.S. E.P.A., Region IV :
345 Courtland Street, N.E.
Atlanta, Georgia 30365
RE: IT. 5. Environmental Protection Agency, Region IV
f.uperfund Public Information Meeting for the American Creosote Site
Dear Mr. Manganiello:
Jackson Utility Division has concerns about the hazardous waste at the
American Creosote site and the impact it could have on the water and 'waste-
water systems which serve more than 60,000 people within the City of_Jackson
and Madison County, Tennessee. Some of these concerns are listed as follows:
1. The protection of all groundwater within the City of Jackson and Madison
County from contamination of hazardous waste from the American Creosote
site.
—-.
?. Full development of the Jackson Utility Division's well fields to meet
the future water demands could completely reverse the hydraulic gradient
in the aquifer creating a condition for withdrawal and/or inflow from the
'/icinity of the American Creosote site.
3. Jackson Utility Division has a forty-eight (48) inch interceptor and a
ten (10) inch outfall wastewater line crossing the American Creosote
site, and infiltration and/or inflow of the hazardous waste into these
lines will likely occur.
4. The time frame it will take to clean up the aquifer from the potential
- contamination from the American Creosote site.
The Jackson Utility Division would like these concerns and the attached
letter to Mr. Greer C. Tidwell, Regional Administrator, Region IV, USEPA,
dated August 23, 1988, to be entered into the record of this Public Hearing.
Very truly yours,
JACKSON UTILITY DIVISION
Kenneth W. Martin, Manager
Water Department
JWV vv.
Attachment
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Mr. Kenneth W. Martin
Jackson Utility Division
P.O. Box 68
Jackson, TN 38302-0068
Dear Mr. Martin:
The purpose of this letter is to respond to your Correspondence
dated August 23, 1988 and August 29, 1988. Your letters and this
response are part of the ROD for the American Creosote Works Site,
Jackson, TN.
The following statements are responses to your August 23rd letter
to Mr. Tidwell:
Response to //I
Response to if2
Response to #3
Response to #4
Response to #5 .
Response to #6.
Response to t7
The purpose of the
determine not only
the contamination.
is accurate.
remedial investigation is to
the extent but the nature of
The remainder of your commeni
To be more specific, the RI and the FS state that
the horizontal and vertical contamination of the
aqueous or dissolved contaminant plume is not
fully defined by the RI data.
This flow is not assumed but calculated from wel^
testing and the flow is characterized as a radi
vector and its direction varies or radiates from
the dominant flow northeast to southwest.
This statement
noted.
Is correct and your comment is
Groundwater flow would not be reversed following a
long Intense rainfall. If anything the rainfall
would intensify the hydraulic gradient and the
flow would continue to the southwest toward the
Forked Deer liver. .
Not necessarily since the contaminants are highly
Insoluble and adhere to unconsolidated alluvial
deposits rather than dissolve to any appreciable
extent. However this comment Is premised on f5
which Is erroneous.
Your first statement is inaccurate. The
wasttwater lines 48 Inch interceptor and 10 inch
outfall do not cross the cite where the heaviest
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cone en £rations are found. The 10 inch outfall
crosses the northwest corner where low levels of
contaminants are found. The 48 inch interceptor
crosses the southwest corner and is assumed to be
above the area of highest contamination. However
inflow and infiltration cannot be ruled out. The
US EPA's jurisdiction is the ACW site and any
off-site areas directly affected by the ACW
contamination. There is no direct evidence that
contaminants from the ACW site have found their
way into the 48 inch line and therefore are of no
consequence to JUD's treatment capabilities.
Response to #8. An adequate plan can be developed for the surface
soils. However the groundwater problem will need
additional investigation.
Response to #9. Comment noted .
Response to #10. The remedial investigation is inadequate in
addressing the groundwater, surface water &
sediment problem.
August 29th letter to Dennis Manganiello:
Response to /'I: The EPA and State of Tennessee have the same
concerns and are of the highest priority.
Response to #2: See Response to #5 above. Based on the
information developed as part of the RI and JUO
water usage, reversal in the hydraulic gradient is
not likely.
Response to .#3: This statement is inaccurate, note response to 07
above.
Response to #4: The alternatives for groundwater remediation
presented in the FS require a significant
timefraae for cleanup of the aquifer. There 'are
ao knovn coat effective alternatives for "quick"
groundwater remediation at the preaeat time.
This initial operable ROD will address surface soils, taak sludges,
flood and access control. During the remedial design phase the EPA
will investigate further the grouadwater problem. If you wish to
coordinate with us in this effort in regards to any effects the
sewer lines or well fields please do not hesitate to contact
Richard Green or myself at the above address. Please be advised the
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o - a -. v
U.S. Government does not have any authority to spend tnonev u.- A - v
aunicipal wastewater treatment facility or components in the"
v.iciaity of a hazardous waste site, that is the C'-v o-"*I-
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n
RAFT
ACTION MEMORANDUM
DATE:
SUBJECT: Request for $2 Million at the American Creosote Works
Site, Jackson, Tennessee
FROM: Greer C. Tidvell
Regional Administrator
TO: J. Winston Porter
Assistant Administrator
ATTN: Timothy Fields Jr., Director
Emergency Response Division
I. ISSUE:
Immediate response actions are estimated to exceed the $2
million at the American Creosote Works Site in Jackson,
Tennessee. Further response actions can not be initiated unless
an exemption pursuant to Section 104(c)(l) of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), is approved. This action
meets the removal criteria of Section 300.65 of the National
Contingency Plan (NCP) and is consistent with both CERCLA as
amended by SARA/ and the National Contingency Plan. This
Jequest will allow for a total project ceiling of $6.4
illion. The previous project ceiling for work completed in
1983, 1985, and 1988 was $942,000. This action will be
consistent with the Record of Decision (ROD) and completely
funded by the remedial program for the $5 million needed for
this project. The purpose of this action memorandum is to
request your approval of this proposed removal action.
II. BACKGROUND
The American Creosote Works began operation as a wood preserving
facility in the early 1930's and continued until December,
1981. The plant process area and tanJcs included the physical
structures on tne site; tne treatment building, pressure
cylinders, boiler room tanks, oil storage tanks, tank cars,
piping, vacuum pond and sand filters.
In May, 1983, SPA conducted an immediate removal at the
facility. At that time, five unlined surface impoundments were
overflowing at the site. Each contained creosote and
pentachlorophenol (PCP) sludge and water. SPA contractors
pumped 30,000,000 gallons of water from flooded areas of the
site and treated and discharged it to the South Fork Forked Deer
River. When the water level approached the top of the sludge
deposits, the water became highly emulsified. This untreatable
prtion of oil/water mixture was placed in the empty tanks on
Whe site. Dewatering the site revealed contaminated material
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far in excess of the original estimate, making the allocated
funds inadequate for complete site cleanup. Plans were approved
for the on site containment of the contaminated sludges and
soils by stabilizing with lime kiln dust, partially covering
lagoon 1, and totally covering lagoons 3 and 4 with a clay cap.
Approximately $736,000 was expended in this removal action.
A. Incident/Response History
1. Location:
The American Creosote Works (ACW) site is located in central
Madison County, Tennessee, on the Jackson South 7-112 minute
quadrangle. The site is vest of by-pass 45 south. The site
covers approximately 60 acres in a predominantly industrial/urban
or undeveloped area immediately southwest o-f downtown Jackson,
Tennessee. The site is bounded on the south by the Seaboard
Railroad and the southwest by South Fork Forked Deer River. The
west and north are bounded by Central Creek, a tributary to South
Fork Forked Deer River, and the east by an adjacent industry.
2. History:
During the time that the American Creosote Works site was ranked
on the NPL and the Remedial Investigation and Feasibility Study
(RIFS) was completed, vandalism and deterioration of the tanks
continued.
In May, 1985, the Tennessee Department of Health and the
Environment contracted for a site assessment. The assessment
included sampling, inventory, and analysis of the wastes stored in
the tanks and pits on site. The inventory of the fifteen (15)
remaining tanks, nine (9) sand pits, and one (1) sump identified
the quantities and concentrations of liquids and solids
remaining. The tanks and pits contained over 115,000 gallons of
creosote and PCP sludge, 25,000 gallons of contaminated oil, and
500,000 gallons of contaminated water. Moat of the tanks and pits
were exposed to atoospneric precipitation, posing a potential risk
of overflow and spillage. Three pita and at least one tank were
full and even a slight precipitation caused overflow of the top
oil layer. At least two tanks were found with leaking bottom
nozzles.
In March, 1986, several leaks had developed in the storage tanks.
A removal action was initiated at ACW at this time consisting of
treating the contaminated water in the storage tanks and the old
treatment system, consolidating all the oil in the storage tanks
into one secure tank, and constructing covers for the treatment
system and open storage tanks. The sludges remaining in the
storage tanks were not addressed in this action as their was a
lack of available funds. Approximately $81,000 was expended for
this removal action.
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fl. Site Conditions
EPA was notified of the deteriorating tank conditions and leaking
contaminants at the site again in September, 1988. Discharges
vere observed during a site visit by the EPA OSC oh September 27,
1988 from the leaking tanks. To prevent further vandalism and
restrict site access, EPA in October, 1988, installed a security
fence around the tank farm area and a large portion of the site.
Approximately $30,000 was expended for this removal action. The
State of Tennessee temporarily repaired the damaged leaking tanks,
but overflow conditions still exist.
1. NPL Status
This is an NPL site.
The American Creosote Works Site was added to the NPL in Group IX
in 1984.
C. Quantity and Types of Substances Present
1. Hazardous Substances Present
The process of wood treatment used at the ACW site included the
use of creosote and pentachlorophenol. Creosote (a coal tar
derivative) is a complex mixture of hydrocarbons consisting of
approximately 85 to 95 percent polynuclear aromatic hydrocarbons
(PAHs) and 5 to 15 percent phenolics.
The concentration of PAHs and phenolics at the site are as high
as:
Location PAHs Phenolica
Tanka 340,000 ppm 19,000 ppm
Pita 105,000 ppm 5,800 ppm
Soil 11,530 ppm 1,700 ppm
The estimated volumes of water, oil, and sludge contaminated
vith PAHa and phenolica remaining in the tanka and sand filter
pita are aa follow*:
Water 500,000 gallons
Oil 25,000 gallons
Sludge 115,000 gallons
Waatewater sludges from the creosote and pentachlorophenol (PCP)
treatment of wood products are listed aa K001 waate under RCPA.
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Polynuclear aromatic hydrocarbons (PAHs)f phenolic compounds,
metals and volatile organic compounds have been identified as
the predominant contaminants on site. Recently, the EPA
Carcinogen Assessment Group (CAG) has added. PCP on a list of B2
class carcinogena (probable human carcinogen) .
D. State and Local Authority's Roles
1. State and Local Action to Date
In November, 1981, four shallow monitoring wells were installed by the
Tennessee Division of Solid Waste Management (TNDSWM) around the ACW
property line.
TNDSWM conducted several site inspections during 1982-1983 and collected
samples on June 21, 1982. The results of the laboratory analysis showed
the presence of high concentrations of pentachlorophenol (PCP) in the
process storage tanks as well as in the plant's waste treatment
facilities. The plant closed in 1982 and the waters in the lagoons r-ose.
EPA conducted an emergency removal in 1983.
In February, 1985, TNDSWM authorized and funded the repair of a leaking
tank containing PCP contaminated water.
In June 1985, a state funded contractor submitted a Remedial Action Plan
for the ACW site to the State of Tennessee. The report was limited to tbft
15 tanks, 9 pits and sump area, but did not evaluate the soil '
contamination areas and lagoons. The plan was never implemented.
Jn February, 1986, TNDSWM funded a report entitled "Evaluation of
Alternatives for Spill Prevention and Control at the American Creosote
Works Site". This report was primarily concerned with the site security,
spill response planning and secondary containment. The report concluded
that the preferred method of securing the ACW site included a combination
of locking tank valves and piping, installing a security fence,
implementing a spill response plan and constructing a secondary
containment system. None of these recommended actions were implemented.
2. Potential for Continued State and Local Response
TNDSWM has agreed to sign a state contract for a 10% cost sharing for the
proposed response action.
III. EXEMPTION FROM STATUTORY LIMITS
A. Continued Response Actions are Otherwise Appropriate and Consistent
with the Remedial Action to be Taken
In order to obtain an exemption from the $2 million limit, the removal
action must meet the criteria set forth in CSRCLA Section 104 (c) as
amended by SARA. This exemption request is based on the "Consistency
Waiver,* which allows removal actions to exceed the statutory limits if
continued response action is otherwise appropriate and consistent
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vith the remedial action to to be taken.
••he selected remedy in the Record of Decision (ROD) is identified as
Operable Unit One. The Remedial Investigation (RI) identified general
areas of contamination, but was not of sufficient scope to thoroughly
define the extent of contamination in soil, groundwater or surface water.
The RI identified the general site hydrogeologic conditions and areas of
high contamination including process liquids and sludges, and near-surface
soils. Since there is a lack of information on the high levels of
contaminants, the extent of contamination, and a difficult hydrogeology, &
final remedy cannot be selected at this time. Operable Unit One was
developed to implement early action items that are consistent with any
final remedy and to address the principal threats posed by the site.
These actions include:
* deed restrictions limiting further use of the site
* construction of flood protection dike around the site
* removal and disposal of tanked liquids and sludges
* removal and disposal of site structures
* installation of security fencing around the site.
Implementation of this operable unit will remove tanked sludges, process
liquids and process buildings which are major potential contamination
sources. This operable unit will prevent future environmental effects
that may occur as a result of potential releases from the tanks. This
remedy is protective of human health and the environment, attains Federal
and State requirements that are applicable or relevant and appropriate for
this removal action, and is cost-effective. This action is consistent
With the ROD.
IV. PROPOSED ACTIONS
This remedy includes treatment of the water contained in the tanJcs,
incineration of the oils and sludges from the tanks, decontamination,
demolition, and disposal of the tanks and consolidation and incineration
of sludges spilled or leaked in the immediate vicinity of the process
buildings and tanks.
The oil and sludges frost the site will be incinerated off-site at a fixed
. facility or on-site in a mobile incinerator if an off-site facility is
unable to dispose of the vaste.
- 1. Proposed Schedule
The OSC will initiate a Delivery Order for the ERCS contractor as soon as
the project is approved. If on site incineration is necessary, a site
specific contract for incineration will be awarded. The total project is
expected to be completed by November 1989.
V. ENFORCEMENT
See *Enforcement Sensitive' Attachment
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VI. SUMMARY OF COSTS
Extramural Costs Current Ceiling Proposed Ceiling
Cleanup Contractor
(includes ERCS, Regional ERCS,
Subcontractors, Letter Contracts,
Site Specific Contracts) $821,000 $4,821,000
(10% Contingency) 482,000
TAT Costs 96,000 170,000
Subtotal Extramural Cost $917,000 $ 5,473,000
15% Contingency of above costs 820,950
TOTAL EXTRAMURAL COST $917,000 • $6,293,950
Intramural Costs
Intramural Direct $9,000 $24,000
($30 x 500 Labor Hours, 400-Region, 100 HQ)
Intramural Indirect Cost
($54 x 400 Regional Hours) $16,000 $37,600
TOTAL INTRAMURAL COST $25,000 $61,600
*TOTAL COST (ESTIMATED) $942,000 $6,355,550
*This coat estimate assumes that incineration costs will be performed off
site at an estimated cost of $0.50/lb. If on site incineration is
necessary, the estimated coat will be $350 per ton. Region IV has had
several site specific contracts for incineration and found that the
average cost is between $250-$450 per ton.
Alternative Actions
See ROD for alternatives.
VII. Recommendation
Because conditions* at this site meet the National Contingency
Plant Section 300.65(b)(2) and CBRCLA 104(c)(l)(c) criteria for
removal action, I recommend your approval of this proposed action
and $2 million exemption. The estimated total project cost for
this action is $5.14 million of which $5.18 million is for
extramural cleanup contractor cost. Previous actions at this
site total $942,000 which brings the proposed ceiling to $6.4
million.
You may indicate your approval or disapproval by signing below.
Approved fiate
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Disapproved •_ Date
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ENFORCEMENT SENSITIVE
'* f£t!:-*nc'' ce
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