United States
Environmental Protection
Agency
Office of
Emergency and '
Remedial Response
EPA/ROD/R04-89/050
September 1989
Superfund
Record of Decision
Newsom Brothers/Old Reich hold,
MS
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R04-89/050
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Newsom Brothers/Old Reichhold, MS
kirst Remedial Action - Final
i«
5. Report Date
09/18/89
rAuttior(a)
8. Pertorming Organization Rept No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Gr»rrt(G) No.
(C)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The 81-acre Newsom Brothers/Old Reichhold site is in Marion County, Columbia,
Mississippi. The site is in a predominantly residential area and was used as a wood
processing facility under several owners from 1936 until 1977, when a fire and explosion
destroyed the facility. Site activities included producing tall oils, turpentine,
calcium and zinc resinates, and polymerized and rubber resins. Furthermore, PCP was
parently mixed with diesel oil and sold, and xylenes were used in a number of
cesses. A State investigation in 1976 revealed that wastewater containing phenols,
, and grease was discharging to a small creek. Further investigations resulted in
EPA performing an immediate removal action in 1984, which included the removal of over
600 surface drums from the site and excavating and draining two ponds, one of which was
subsequently filled with clean fill. Onsite buried drum areas were the target of
another EPA removal action conducted in 1987-88. Approximately 3,900 drums were
excavated and shredded, drum contents were disposed of offsite, and 1,920 tons of soil
were removed. In addition there is an extensive system of concrete drains that served
to collect and drain spilled wastes and rainwater that has an area of runoff of
approximately 300,000 square feet. There is an estimated 650 cubic yards of bulk
hazardous substances remaining onsite consisting of black tar-like waste material and a
resin material in three excavations and in the drainage (Continued on next page)
MS
17. Document Analysis a. Descriptors
Record of Decision - Newsom Brothers/Old Reichhold,
First Remedial Action - Final
Contaminated Media: soil, sediment, bulked wastes
Key Contaminants: VOCs (benzene, toluene, xylenes), other organics (PAHs, PCBs, PCP),
metals
b. Identifiers/Open-Ended Terms
c. COSATI Held/Group
liability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
81
22. Price
(See ANSI-Z39.1B)
See Instruction* on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
INSTRUCTIONS
Optional Form 272, Report Documentation Pag* la baaad on Guidelines for Format and Production of Scientific and Technical Reports,
ANSI Z39.18-1974 available from American National Standards Institute, 1430 Broadway, New York. New York 10018. Each separately
bound report—for example, each volume In a multivolume set—shall have Ita unique Report Documentation Page.
1. Report Number. Each individually bound report shall carry a unique alphanumeric designation assigned by the performing orga-
nization or provided by the sponsoring organization In accordance with American National Standard ANSI Z39.23-1974, Technical
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uppercase letters, Arabic numerals, slashes, and hyphena only, aa in the following examples: FASEB/NS-75/87 and FAA/
RD-75/09.
2. Leave blank.
3. Recipient's Accession Number. Reserved for uae by each report recipient
4. Title and Subtitle. Tine should Indicate dearly and briefly the subject coverage of the report, subordinate subtitle to the main
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data of laaue, date of approval, date of preparation, date published).
6. Sponsoring Agency Code. Leave blank.
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the performing organization.
8. Performing organization Report Number. Insert If performing organizaton wishes to assign this number.
9. Performing Organization Name and Mailing Address. Give naira, street, city, state, and ZIP code. Ust no more than two levels of
an organizational hlerachy. Display the name of the organization exactly as It should appear In Government Indexes such as
Government Reports Announcements & Index (GRA & I).
10. Project/Task/Work Unit Number. Use the project, task and work unit numbers under which the report was prepared.
11. Contract/Grant Number. Insert contract or grant number under which report was prepared.
12. Sponsoring Agency Name and Mailing Address. Include ZIP code. Cite main sponsors.
13. Type of Report and Period Covered. State Interim, final, etc., and, If applicable, Inclusive dates.
14. Performing Organization Code. Leave blank.
15. Supplementary Notes. Enter information not Included elsewhere but useful, such as: Prepared in cooperation with... Translation
of... Presented at conference of... To be published in... When a report Is revised, Include a statement whether the new
report supersedes or supplements the older report.
16. Abstract Include a brief (200 worda or less) factual summary of the moat significant Information contained in the report If the
report contains a significant bibliography or literature survey, mention It here.
17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
that Identify the major concept of the research and are sufficiently specific and precise to be used as Index entries for cataloging.
(b). identifiers and Open-Ended Terms. Use Identifiers for project names, code names, equipment designators, etc. Use open-
ended terms written in descriptor form for those subjects for which no descriptor exists.
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majority of documents are multidlsciplinary In nature, the primary Field/Group assignments) will be the specific discipline,
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18. Distribution Statement Denote public reieasabllity, for example "Release unlimited'', or limitation for reasons other than
security. Cite any availability to the public, with address, order number and price, If known.
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21. Number of pages. Insert the total number of pages, Including Introductory pages, but excluding distribution list, If any.
22. Price. Enter price In paper copy (PC) and/or microfiche (MF) If known.
A GPO: I983 0 - 381-526(8393) OPTIONAL FORM 272 BACK
(4-77)
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EPA/ROD/R04-89/050
Newsom Brothers/Old Reichhold, MS
16. Abstract (Continued)
I
ystem. The primary contaminants of concern in the soil, sediment, and bulked wastes are
organics including PAHs, PCBs, and PCP; and metals.
The selected remedial action for this site includes excavation and offsite disposal of
30,300 cubic yards of contaminated soil and 7,300 cubic yards of contaminated pond and
creek sediment; excavation and offsite incineration of 650 cubic yards of tar-like waste
material and any soil/sediment containing RCRA hazardous wastes, followed by offsite
disposal; draining, filling, and capping onsite ponds; recontouring the site; and ground
water monitoring for five years. The estimated present wo.rth cost for this remedial
action is $14,180,000, which includes an estimated present worth O&M cost of $520,225.
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SUPERFUND FACT SHEET
NEWSOM
OLD REICHHOLD COMPANY
COLUMBIA,
MARION COUNTY, MISSISSIPPI
December, 1989
INTRODUCTION
This fact sheet on the Newsom Brothers/Old Reichhold Co. Superfund site in Columbia,
Mississippi, has been prepared by the Region TV Office of the U.S. Environmental Protection
Agency (EPA). The purpose of this fact sheet is to update interested citizens and local officials
on the current status of the cleanup project
CURRENT STATUS - THE RECORD OF DECISION
The Record of Decision (ROD) for the Newsom Brothers site was signed by the EPA Region IV
Regional Administrator on September 18, 1989. Activities at the Newsom Brothers site will be
conducted under the Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA, or "Superfund"), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA).
EPA has begun making arrangements for the cleanup of the site. This is called the Remedial
Design/Remedial Action (RD/RA) phase of the project The intent of the RD/RA is to
implement the ROD.
Implementation of the ROD includes, off-site treatment and disposal of contaminated soil,
sediment and hazardous substances, at facilities approved under the Resource Conservation and
Recovery Act (RCRA). Soil and sediment will be excavated and taken to an off-site facility for
disposal. Hazardous substances will be treated at an off-site treatment unit prior to disposal.
Careful screening of the waste will be performed to insure that the materials meet requirements
for safe disposal. MONITORING WILL BE CONDUCTED DURING THE REMEDIAL
ACTION TO INSURE THE SAFETY OF RESIDENTS AND WORKERS ON AND
NEAR THE SITE.
CORRECTION TO ROD TABLE 4.5
The ROD as issued in September 1989 had a typographical error in Table 4.5. The new table
contains the correct soil cleanup levels for the carcinogens (potential cancer causing compounds)
benzene, chloroform, and pentachlorophenoL The error read micro-grams per kilogram (ug/kg)
which should have been milligrams per kilogram (mg/kg).
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
NEWSOM BROTHERS/REICHHOLD CHEMICAL COMPANY SITE
COLUMBIA, MISSISSIPPI
Prepared By
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Newsom Brothers/Reichhold Chemical Company
Columbia/ Marion County, Mississippi
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Newsom
Brothers site, Columbia, Mississippi, and is developed in accordance with
. 4i_*.
CERCLA, as amended by SARA, and to the extent practicable, the National
Contingency Plan. This decision is based on the administrative record fo|H
the site. The index identifies the items that comprise the administrative
record upon which the selection of the remedial action is based. The major
items that were used in the decision process were:
-Remedial Investigation Report, Phase I, Newsom Brothers site
-Remedial Investigation Report, Phase II, Newsom Brothers site
-Endangennent Assessment Report, Newsom Brothers site
-Feasibility Report, Newsom Brothers site
-Responsiveness Summary
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-State of Mississippi Recommendations
-Community Acceptance
-Staff Recommendations and Reviews
The State of Mississippi has concurred on the selected remedy.
DESCRIPTION OF THE REMEDY
This remedy is the final remedial action for the site. The function of
this remedy is to reduce the risks associated with exposure to contaminated
on-site soils/ sediments and waste materials.
The major components of the selected remedy include:
- No remedial action is planned for groundwater; monitoring will be
continued on-and off-site for five years
- Black tar-like waste material will be removed from the site and
rendered non hazardous through thermal destruction before
landfilling at an approved RCRA facility.
- Contaminated soils and sediments will be excavated and removed from
the site and disposed of at an approved facility.
- On-site ponds will be filled and capped and the site will be
recontoured to prevent runoff and ponding of water.
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DECLARATION
The selected remedy Is protective of human health and the
environment, attains requirements that are applicable or relevant and
appropriate, and is cost effective. This remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable for this site. However, because treatment of a
portion of the material was not found to be practicable for the site
this remedy does not satisfy the statutory preference for treatment
as a principal element of the remedy. Since no hazardous substances
will remain onsite above health-based levels, and no onsite disposal
will occur, the five year facility review will not apply to this
action.
UL ft
\
Date Greer C. Tidwell
Regional Administrator
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
NEWSOM BROTHERS/REICHHOLD CHEMICAL COMPANY SITE
COLUMBIA, MISSISSIPPI
Prepared By
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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TABLE OF CONTENTS
Section Page
1. 0 INTRODUCTION 1
1.1 Site Location and Description 1
1.2 Site History 4
1. 3 Site Activities 5
2 . 0 ENFORCEMENT ANALYSIS 7
3 . 0 CURRENT SITE STATUS 8
3 .1 Hydrogeologic Setting 8
3.2 Groundwater 8
3. 3 Surface Water 10
3.4 Sediment 12
3.5 Soil 12
3.6 Hazardous Substances 15
3.7 Site Risk/Endangerment Assessment 15
3.7.1 Human Exposure Pathways ^. 15
3.7.2 Human Health Risk Assessment 21
3.7.2.1 Quantitative Estimates of Risk 22
3.7.2.1.1 Estimates of Risks Under Current
Land-use Conditions 22
3.7.2.1.2 Estimates of Risk Under Hypothetical
Future Land-use conditions 23
3.7.3 Environmental Receptors 24
3.7.3.1 Endangered, Threatened and Rare Species 24
4 . 0 CLEANUP CRITERIA 29
4 .1 GROUNDWATER CLEANUP CRITERIA 29
4 .2 SURFACE WATER CLEANUP CRITERIA 31
4 . 3 SOIL CLEANUP CRITERIA 31
4 . 4 SEDIMENT CLEANUP CRITERIA 33
4 . 5 HAZARDOUS SUBSTANCES CLEANUP CRITERIA 33
4.6 ADDITIONAL HEALTH BASED CLEANUP CRITERIA 36
5 . 0 ALTERNATIVE EVALUATION 36
5.0.1 Alternative 1 - No Action Alternative 40
5.0.2 Alternative 2 - Offsite Disposal of Soil, Sediment,
and Hazardous Substances 40
5.0.3 Alternative 3 - Onsite Thermal Treatment of Soil, Sediment
and Hazardous Substances 42
5.0.4 Alternative 4 - Onsite Thermal Treatment of Soil
and Hazardous Substances; Capping
of Sediments 44
5.0.5 Alternative 5 - Capping of Soil and Sediment; Offsite
Disposal of Hazardous Substances 45
-i-
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TABLE OF CONTENTS
(continued)
5.0.6 Alternative 6 - Encapsulation of Soil? Capping of Sediment
Offsite Disposal of Hazardous Substances.... 46
5.0.7 Alternative 7 - Solidification/Stabilization of Soil
and Sediment; Offsite Disposal of Hazardous
Substances 46
5 .1 ALTERNATIVE COMPARISION 48
5.1.1 Reduction of Toxicity, Mobility, or Volume 49
5.1.2 Implementability 50
5.1.3 Cost 50
5.1.4 Compliance with ARARs 50
5.1.5 State Acceptance 51
5.1.6 Community Acceptance 51
6 . 0 RECOMMENDED ALTERNATIVE 51
6.0.1 Statutory Determination ^ 54
6.0.2 Protection of Human Health and the Environment 55
6.0.3 Compliance with ARARs
6.0.4 Cost Effectiveness
6.0.5 Utilization of Permanent Solutions and Alternative
Treatment Technologies The Maximum Extent Practicable 56
6 . 1 DESCRIPTION OF ALTERNATIVE 57
6 . 2 OPERATION AND MAINTENANCE 58
6 . 3 COST 60
6 . 4 SCHEDULE 60
6 . 5 FUTURE ACTION 60
7 . 0 COMMUNITY RELATIONS 60
APPENDIX A - RESPONSIVENESS SUMMARY
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LIST OF TABLES
Table Page
3-1 Sediment Sampling Data 13
3-2 Chemicals of Potential Concern for Soils
at the Site 16
3-3 Concentration of Chemicals In Waste Materials
Samples Based on EPA Removal Activities 17
3-4 Concentrations of Chemicals in Waste and Drum Materials
Samples Based on EPA CLP Analyses -..-... 18
3-5 Summary of Chemicals of Potential Concern
at the Newsom Brothers Site 20
3-6 Summary of Potential Risks Associated with Exposure to Newsom
Brothers Chemicals of Concern 25
4-1 Applicable or Relevant and Appropriate Requirements <,
for Groundwater 30
4-2 Applicable or Relevant and Appropriate Requirements
for Surface Water 32
4-4 Estimates of Sediment Volumes that Require
Remediation 35
4-5 Additional Sediment/Soil Cleanup Levels 37
<~
5-1 Results of Preliminary Screening of Remedial
Technologies 38
5-2 Cost Ranking of Remedial Action Alternatives 41
5-3 Applicable or Relevant and Appropriate Requirements
for Remedial Actions at Newsom Brothers Site 52
6-1 Detailed Cost Analysis of Proposed Remedial Action
at Newsom Brothers Site 61
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LIST OF FIGURES
Figure Page
1-1 Site Map 2
1-2 Site Features Map 3
3-1 Geologic Cross Section 9
3-2 Monitor Well Locations 11
3-3 Soil and Sediment Sample Locations 14
3-4 Hazardous Substance Remediation Areas 19
6-1 Soil Remediation Areas 59
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RECORD OP DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
NEWSOM BROTHERS/REICHHOLD CHEMICAL COMPANY SITE
COLUMBIA, MISSISSIPPI
1.0 Introduction
The Newsom Brothers/Reichhold Chemical Company site was proposed for
inclusion on the National Priorties List (NPL) in 1984. In 1986, the
Environmental Protection Agency (EPA) finalized the site's inclusion on the
NPL. The site has been the subject of a Remedial Investigation (RI) and
Feasibility Study (FS) performed for the EPA by its contractor Camp, Dresser
and McKee (CDM). Regulatory direction has been provided by Region IV
throughout the Remedial RI/FS. The RI report, which examines air, sediment,
soil, surface water and groundwater contamination at the site, was issued
November 21, 1988. The FS, which develops and examines alternatives for
remediation of the site was issued in draft form to the public January 24,
1989 and was finalized on March 30, 1989.
This Record of Decision has been prepared to summarize the remedial
alternative selection process and to present the recommended remedial
alternative.
1.1 Site Location And Description
The Newsom Brothers site is located in Marion County, Columbia, Mississippi
at coordinates 31"14'42" North latitude and 89*49'37" West longitude (Figure
1-1). The 81-acre site is bordered on the north by residences along Bullis,
Wade, and Pearl Streets, and on the east by residences along Chinaberry and
Park Avenues. The Illinois Central Gulf Railroad parallels most of the
site's southwestern border. Further to the southwest, across the railroad,
lies a moderately developed commercial area. Scattered : esidences are also
located to the south. A chain-link fence surrounds the entire facility.
The site's main processing facilities were located in the west-central
portion of the site (Figure 1-2). Of significance are an extensive system
of concrete drains that apparently served to collect and drain spilled
wastes and rainwater, two 100,000-gallon storage tanks which reportedly
contained diesel oil, several smaller tanks and boilers, one incinerator,
and one boiler building used to heat "Dowtherm." The extent of the area of
runoff (Old Processing Area in Figure 1-2) drained by the concrete drainage
system is approximately 300,000 ft2.
North of the processing area is a 20-acre field sparsely covered with short
grass. The southeast quadrant of the site contains three ponds (North,
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10000 1000
SCALE IN FEET
::' • ,~?/H7 : r*SSS^s |i
* /; i! A x*'"'.; S 5 . B -^ T . J I
«rjL» , ; -!l4_ 7 —L---7' "4 —^ :p"
REM II
SITE MAP
NEWSOM BROTHERS SITE
COLUMBIA. MISSISSIPPI
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OOWTHBRM BOILER
BUILDING
REM II
SITE FEATURES MAP
NEWSOM BROTHERS SITE
COLUMBIA. MISSISSIPPI
-3-
FIGURE NO.
1--2
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East and Horseshoe), a pecan orchard, and the remnants of a wood chip pL
A fourth pond located in the extreme south was filled in 1984 during an Ibm
emergency response action.
Several areas of buried material were identified during the remedial
investigation of the site. Buried drums were found in the North Pond and
Pecan Orchard areas. EPA returned to the site in November 1987 to remove
these drums. During this removal action, additional areas of buried
materials were discovered and investigated through additional field work.
1.2 Site History
From the early 1930s until 1943, J. J. White Lumber Company operated a
sawmill on the Newsom Brothers Site. The Southern Naval Stores Company,
Limited, concurrently ran an operation called Naval Stores on various parcels
of the site, from 1936 to 1951. Naval Stores produced wood derivatives such
as resin, turpentine, pine oil, and tall oil. This company appears to have
been owned and operated by several people, but the plant consistently
produced the same wood-derived products. From the 1950s until 1965, the site
was owned and operated by Leach Brothers Inc. and the operation became known
as Southern Naval Stores, Division of Leach Brothers, Inc. Reasor Chemical
Corporation owned the site from 1965 to 1972, and Chem-Pro International Inc.
owned it from 1972 to 1974.
Southern Naval Stores Company, Limited, Reasor Chemical Corporation, and
Chem-Pro International, Inc. ran similar production processes. These
involved grinding pine stumps and digesting them with a boiling liquor or
sodium hydroxide and sodium sulfite. The products were tall oils, which are
35 to 40 percent resin and 50 to 60 percent fatty acids. Turpentine was alsc
extracted from the pine stumps using naptha. In addition, Reasor Chemical
Corporation specifically manufactured calcium and zinc resinates, polymerized
resin, and rubber resins.
In January 1975, Reichhold Chemicals, Inc. (Reichhold) took over ownership
and operations at the site. Details of operations are sketchy, but
pentachlorophenol (PCP) was apparently mixed vrith diesel oil, and sold. The
PCP and diesel oil were mixed and heated using Dowtherm as a heat transfer
medium. In other operations, boron trifluoride was mixed with phenol and
di-isobutylene to form octal phenol resin. Xylenes were also used in number
of processes. An unlined horseshoe shaped pond was used for cooling the
process discharge.
In April 1976, before Reichhold Chemicals abandoned operations at the site,-
the Mississippi Air and Water Pollution Control Commission investigated a
reported fish kill in a small creek downstream from the Reichhold Chemicals
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facility. Through the investigation, the state commission discovered that
the company had no discharge permit yet was discharging vastewater
containing phenols, oil/ and grease into a nearby stream.
Reichhold Chemicals continued operations at the property until March 1977,
when an explosion and fire in one of the boiler units destroyed most of the
processing facility. The Company subsequently abandoned the site.
Employees of the George Byrd Bulldozer Company have filed depositions
reporting that they used earth moving equipment to dig large holes in which
Reichhold Chemicals personnel buried many drums. In their deposition the
bulldozer company employees reported that this burial took place in five
separate areas on the Newsom Brothers Site. A geophysical survey conducted
by COM, November 1986 through January 1987, located two burial sites.
In 1980 and 1981, ownership of the 81-acre site transferred to R. R.
Newsom, Sr. and R. R. Newsom, Jr. (owners of the New-Cros Construction)
Company and Mr. William Earl Stogner (owner of Stogner Trucking Company).
The Newsoms' owned a total of 49 acres and Mr. Stogner owned 32 acres of the
site property Both Stogner and the Newsoms' had buildings on the property
from which they operated their respective trucking and construction
businesses. A furniture shop currently rents and operates from one of the
buildings owned by Mr. Stogner. Only a few of the original Reichhold
Chemicals buildings currently remain on the property; some were destroyed in
the March 1977 explosion and fire and others dismantled by Reichhold upon
leaving the site.
In November 1988 Mr. Stogner and the Newsoms' were awarded damages as a
result of a lawsuit against Reichhold Chemicals. Reichhold Chemicals
reassumed ownership of the property at that time.
1.3 Site Activities
In January 1984, the Mississippi Department of Natural Resources (MDNR)
Bureau of Pollution Control (BPC) received a letter from an area resident
who is a former federal Occupational Safety * nd Health Administration
inspector. In his letter, the former inspector warned of possible
contamination to the Columbia city water supply system (consisting of four
groundwater wells about 1,200 feet northeast of the site) he felt was
resulting from pollution at the Newsom Brothers Site. In February 1984, BPC
sampled two of the city's water supply wells, the city water distribution
system, and several locations at the Newsom Brothers Site (including sludge
from the old plant sump, water from the old treatment pond, soil in a drum
disposal area, and onsite well water). Concurrent with the BPC study, EPA's
Environmental Services Division (BSD) also sampled the city water supply
wells. EPA and BPC detected low levels of several volatile organic
chemicals, including benzene, acetone, methyl ethyl ketone, and chloroform
in the city water supply wells. Although the city'wells supply water to
almost all Columbia residents, EPA was able to locate 13 private wells in
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the south Columbia area. Following analysis of the results of the EPA aid
BPC studies, EPA conducted an additional sampling investigation of the a*
to determine the extent of the contamination problem. In March 1984, EPA'a
Field Investigation Team (FIT) collected samples from area private wells,
the Columbia city supply wells, and onsite soils, sediments, streams, and
other private wells in the area. BPC'8 sampling efforts revealed the
presence of dioxins (not the 2, 3, 7, 8-tetrachlorodibenzo-dioxin isomer) in
the soil at the former chemical plant site, but at levels that the Centers
for Disease Control considered not to pose a health threat to community
residents. EPA performed an immediate removal action that involved removing
over 600 surface drums and partial drums from the site and draining the
North and South ponds. EPA filled the South Pond with clay and graded it.
While EPA's immediate removal action was proceeding, the Mississippi BPC
received reports from local residents who had become ill after eating fish
caught in the Horseshoe Pond. After receiving these reports, fish tissue
samples were taken by the Mississippi BPC, no hazardous constituents were
revealed. After EPA completed its immediate removal action and left the
site in April 1984, several Columbia residents reported to the BPC that some
drums remained at the site. BPC investigated and arranged for the removal
and disposal of those drums.
Based on three sets of samples taken by the BPC in February 1984, the state
attempted to locate the source of volatile organic contamination detected in
the city wells. A comparison of the contaminants found in the city water
supply wells and the pollutants found on the Newsom Brothers Site led the
BPC to conclude that the Newsom Brothers Site was not the source of the
contamination. The groundwater flow, which runs east to west, or from the
direction of the wells toward the site, supported the BPC's tentative
conclusion. Further sampling and investigation in 1984 led the BPC to
believe that the city well contamination was caused by several leaking
underground gasoline storage tanks near the wells. The BPC removed several
tanks in 1984 and tested soil and groundwater near the tanks. Test results
revealed the presence of gasoline constituents, including benzene, which was
the contaminant of greatest concern in the two contaminated city wells.
Later in 1984, the Newsom Brothers Site was proposed by EPA for inclusion on
EPA's National Priorities List (NPL). In 1986, EPA finalized the site's
inclusion on the NPL.
In 1985, the BPC installed nine monitor wells in the area around the city's
water treatment plant. In June 1985, the BPC sampled those wells and found
significant quantities of the same chemicals originally found in the city
water supply in only one well.
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In early 1986, the current property owners (R. R. Newsom, Sr.,
R. R.. Newsom, Jr., and William Earl Stogner) filed and $100 million federal
lawsuit against Reichhold Chemicals, claiming that Reichhold knowingly sold
them contaminated land. To support the suit, the property owners hired a
chemical testing company to sample chemicals found in buried drums at the
site. The test results reported by the chemical testing company in the
summer of 1986 showed that the drums contained benzene, toluene, and zylene,
in addition to other pollutants.
Onsite drum burial areas identified during the Phase I RI were the target of
an EPA removal action conducted from November 2, 1987 through February 7,
1988. The Roy F. Waston. Inc. Technical Assistance Team (TAT) performed the
removal under contract with EPA. During the removal action, approximately
3,900 drums were excavated and shredded. Four major areas of drum burial
and an additional number of smaller drum burial pits were identified through
the geophysical surveys performed by TAT during the removal action.
An estimated 1,640 tons of contaminated soil were removed from the North
Pond Area and 280 tons of soil removed from the Wood Chip Area. During the
removal of drums from the North Pond Area, approximately 775 nearby
residents were relocated for two days to entirely eliminate any potential
hazard associated with the removal action. The drums were moved to a
central area of the site in the vicinity of the Wood Chip Area and
shredded. The waste contained in the drums was disposed in bulk .form at an
offsite location. Several other areas containing buried materials were
identified onsite, including two steel tanks in the North Field, chemical
jburial areas in the North Field, pecan orchard, and Wood Chip Areas, and
trash disposal areas in the Wood Chip Area.
2.0 Enforcement Analysis
The Newsom Brothers/Reichhold Chemicals site was placed on the NPL in June
1986. EPA determined that Southern Naval Stores, Inc., Leach Brothers,
Inc., Reasor Chemicals Co., Reichhold Chemical Co., R.R. Newsom and W.E.
Stogner were potentially reponsible parties (PRP) for the contamination of
the site. The PRP's were sent notice letters to allow them the opportunity
to conduct the site related remedial investigations and feasibility studies
(RI/FS). Since all PRP's declined to participate EPA assumed lead
responsibility for the site. With the recent completion of RI/FS activities
at the site EPA has begun negotiations with Reichhold Chemicals on a Consent
Decree for a Remedial Design/Remedial Action (RD/RA) for the site. If
agreement can be reached, the Consent Decree will be signed by the
participants shortly after approval of this Record of Decision and will be
submitted to the appropriate federal district court for entry.
-7-
-------
Additionally, EPA and the Department of Justice have entered into sett leal
negotiations with Reichhold Chemicals for recovery of site related costs
incurred by EPA. Reichhold has submitted a payment of $1 million to EPA for
partial reimbursement of expenses incurred to date. Notice letters will be*
sent to all identified PRP's to allow them the opportunity to participate in
the RD/RA stage of the cleanup.
3.0 Current Site Status
3 .1 Hvdroqeologic Setting
The Newsom Brothers site is located over the Pearl River alluvium, within
the Coastal Plain Province of Mississippi, a thick blanket of southwestward
sloping sediments. In Marion County, the sediments are greater than 30,000
feet thick. Near the base of the sediments, a thick deposit of salt (the
Louann Salt) is present, and in places has formed upward piercing diapirs.
These salt domes have been the target of oil and gas exploration throughout
southern Mississippi. Above the salt bed is a varying sequence of
sandstones, shales, clays and limestones, that extends upward to the
surface.
The occurrence of fresh groundwater in Marion County is limited tys the upper
1,500 feet. Below this depth the water is saline. The major aquifers
within the fresh water zone occur within Miocene and younger sediments.
The Columbia water supply wells produce groundwater from the alluvial
aquifer associated with the Pearl River. According to the electric logs of
two of the city supply wells, the alluvial deposit is approximately 146 feet
thick, and is underlain by clay, probably of the Graham Ferry and/or
Pascagoula Formation (Figure 3-1). One of the city wells, located 1,200
feet east of the site, encountered 100 feet of clay prior to termination.
The well did not completely penetrate the clay layer. Two electric logs of
the nearby Foxworth Community water supply wells show the clay underlying
the alluvial aquifer to be about 200 feet thick. Therefore, on the basis of
these limited data, the clay appears to be laterally consistent, and is
believed to confine and protect the underlying Miocene aquifer system.
Since the Columbia city well field is located approximately 1,200 feet to
the northeast of the site a series of aquifer performance tests were
performed to determine if groundwater from beneath the Newsom Brothers site
could be drawn into the city wells. The tests showed that the groundwater
beneath the site flows to the west and away from the city wells and would
not be drawn back into the city wells under the worst case scenario.
3.2 Groundwater
A total of 34 monitoring wells were installed on and off of the
-8-
-------
I
to
COLUMBIA
SSISS
NEWSOM BROTHERS SITE
REM II
GEOLOGIC CROSS SECTION
CO
I
0
-5
m
z
O
WEST
US
CITRONELlt FORMAHON
-BOO _ — —
AND
SAND
INTERMITTENT SAND AND CLAY
2000 0 20OO 4OOO
'-S^--- ~1 1
HORIZONTAL
SCALE IN FEET
• THE MIOCENE AQUIFER SYSTEM IS DIVIDED. FROM BOTTOM (OLDEST)
TO TOP (YOUNGEST) INTO THE CATAHOUIA SANDSTONE. THE
HAITIESBURG FORMATION. ANC THE PASCACOULA FORMATION.
-------
site (Figure 3-2) to sample groundwatar in the shallow and deep zones o*"t^6
alluvial aquifer. Some organic compounds were detected in samples from
few of the wells; however, most were detected at low estimated
concentrations near detection limits. No contaminant plume was identified..
Both temporary and permanent groundwater monitor wells were installed during
the Phase I RI at the Newsom Brothers Site. Sampling conducted at the
permanent monitor wells showed that no chemicals were detected above
National Primary Drinking Water Standards. One onsite temporary monitor
well contained concentrations of toluene which exceeded the proposed Maximum
Concentration Level Goals (MCLGa). Due to the observations in this
temporary monitor well, substantial additional groundwater monitor well
installation was proposed for the site during the Phase II RI.
Sampling and analysis of the new permanent groundwater monitor wells
installed during the Phase II RI showed concentrations of organic chemicals
in 3 of 27 sampled wells. The organics detected were benzene, ethyl
benzene, 1,1,1-trichloroethane, di-n-butylphthalate,
trimethylbicycloheptanone, and bis(2-ethyl hexyljphthalate. Contract
Laboratory Program (CLP) analyses detected benzene in monitor wells MW-01
(5 ug/1) and MW-17 (1 ug/1-estimated); Ethylbenzene (1 ug/1-estimated),
1,1,1-trichloroethane (3 ug/1-estimated), D-n-butyl pthalate (3
ug/1-estimated), and trimethylbicycloheptanone (700 ug/1 estimated) were
also detected in MW-17. Bis(2-ethylhexyl) pthalate (a common laboratory
contaminant) was detected in MW-01. A few other miscellaneous organic
compounds were tentatively detected at low estimated values.
The inorganic chemicals detected above background levels during sampling
the new wells were aluminum, barium, beryllium, calcium, copper, iron, lead,
magnesium, manganese, mercury, selenium, sodium, and vanadium. Lead was the
only inorganic contaminant detected above MCLs. Lead was detected in three
monitoring wells (MW-19 (120 ug/1), MW-23 (84 ug/1) and MW-27 (160 ug/1).
However, since the sampling of drilling muds used during well installation
revealed elevated lead levels, lead detected in well samples is not
considered to be an indication of lead contamination in groundwater but is a
result of residual lead contributed by the drilling muds.
3.3 Surface Water
The predominant surface water feature in proximity to the site is the Pearl .
River. The Pearl River and its tributaries drain about 6,630 square miles
of central and southern Mississippi. The river flows north to south along
the west side of the city of Columbia and empties into the Gulf of Mexico
near Bogalusa, Louisiana. From 1938 to 1968, the average discharge of the
Pearl River was approximately 8,693 cubic feet per second (cfs). Some
-10-
-------
m
o co
o
OD
>
z
CO
31
O
to 31
~~ CO
CO
m
O
3)
!»
m m
o
5
CO
c*>
I
c
m
z
O
MW-5
UMH6
200 0
M H g
200
SCAU M FEET
MW-24
MW-23
• MW-33
MW-29 BMW-2
MW-34 •
• MW-21
MW-22
LEGEND
• EXISTING MONITOR WELL
• NEW MONITOR MELL
MW-10
MW-9
UW-1J f
MW-14
-------
flooding is common, partly due to the relatively flat and low-lying
plains. On April 9, 1938, the river discharge reached 72,600 cfs. Duri
flooding events, large portions of the site may be underwater for an
extended period of time. Flooding occurs due to rising water levels in
nearby ^ow areas and-overflowing of local streams.
Surface water was sampled both onsite (concrete drainage system and onsite
ponds) and offsite (unnamed tributary and Jingling Creek) during the Phase I
RI. Mercury detected at both onsite and off site locations, was the only
contaminant exceeding the Mississippi Ambient Water Quality Criteria (MAWQC)
of 0.2 ug/1. However, only one sampling point, in Jingling Creek, contained
mercury at a concentration (2.3 ug/1) exceeding the 2 ug/1. All other
detected mercury values ranged from 0.1 ug/1 to 0.5 ug/1, and all values
were reported as estimated and with only presumptive evidence of the
material. Therefore, no clear indication of surface water contamination
could be drawn from these samples.
3.4 Sediment
Indicator chemicals were identified in the Phase I RI during sampling of
onsite sediments. Copper, phenols, ethyl benzene and total xylenes were
detected in sediment samples taken from the concrete drainage system.
Sediment in the North Pond, the drainage ditch Immediately upgradient from
the North Pond, and the East Pond contained elevated levels of a variety of
organic chemicals. The North and East Ponds were sampled again during tha
Phase II RI to confirm the results of Phase I. Sediment samples collected
from Jingling Creek upstream and downstream from the site did not contain
detectable levels of contaminants of concern. Results of sediment sampling
are presented in Table 3-1.
3.5 Soil
Over 300 soil samples have been taken at various depths across the site
(Figure 3.3). The samples were taken at one foot, five feet, and some at 10
feet. A variety of soil contaminants were detected at scattered locations
at the site during the Phase I RI, conducted in late 1986 to early 1987.
The inorganic chemicals most frequently detected in the soil were beryllium,
cobalt, and nickel. The organic chemicals frequently detected were,
xylenes, Arochlor 1254 and polycyclic aromatic hydrocarbons (PAHs). Based
on these results, a soil sampling and analysis program was included in the
Phase II RI conducted in 1988.
Soil sampling at the Newsom Brothers Site during the Phase II RI indicated a
wide variety of organic and inorganic chemicals present at various areas of
the site. These chemicals were generally found in isolated samples, rather
than at consistent locations throughout the site. The major organic
-12-
-------
TABLE 3-1
SAMPLING DAXA
HEHSOH BMOTHEKS SITE
COUMIA, MISSISSIPPI
ChMical
Coapouod
FtMnol
P«at*chloroph«tol
Toluww
Xyl«o*s
pea
Ethyl B«M«M
PlouranthMM
2 M.tmri-pth.i.0.
•orth Pond
S3&
«2
117
122
•0.000
10.000
7.700
^^~
f»»\: Pood
.aa,
RD
HD
HD
HD
HD
RD
31,500
200,000
Coocr*t« DralD*9«
Hor»««bo« Pond Sy«t«B
-a^a a^
RD
HD 9.000
HD
RD 1,300.000
HD
RD 210.000
1«,300
— T
^, RD - ibis compound MMlyy««d for but not d>t«ct«d.
GJ
510/31
-------
LEGEND
• SOB. SAMPIC LOCATION
• SOXMCNT SAMPLE LOCATION
REM II
SOIL AND SEDIMENT SAMPLE LOCATIONS
NEWSOM BROTHERS SITE
COLUMBIA, MISSISSIPPI
FIGURE N^
3-3
-14-
-------
chemicals detected in soils were toluene, ethyl benzene, phenol,
pentachlorophenol , and xylenes. The major inorganic chemicals were barium,
chromium, copper, nickel, and vanadium. The frequency of detection and
concentrations of chemicals of concern in soil samples collected at the site
are presented in Table 3.2
3.6 Hazardous Substances
Hazardous substances were identified onsite and sampled during the RI .
Materials observed in drums and onsite storage tanks were removed during the
EPA expedited removal action. The estimated 650 cubic yards of bulk
hazardous substances remaining onsite consists of black tar-like waste
material and a resin material which is found in three locations onsite and
in the concrete drainage system (Figure 3-4). This material was sampled
both during the Phase I and Phase II RI and was found to contain high levels
of a variety of organic compounds . The concentrations of chemicals found in
the drummed material and waste material is listed in Tables 3-3 and 3-4.
3.7 Site Risk/Endanoerment Assessment
An endangerment assessment (EA) was performed for the Newsom Brothers site
to evaluate potential impacts on human health and the environment in the
absence of further remedial action. The analytical results of the samples
collected from the various media at the site were reviewed to determine
which of the chemicals detected are potentially site related and of
potential concern at the site. Chemicals detected frequently and present at
concentrations above those considered to occur naturally (background) were
chosen as chemicals of potential concern for the site and were assessed for
overall threat to human health and the environment. These chemicals are
listed in Table 3-5.
3.7.1 Htiman, Exposure Pathways
Potential pathwiys by which human populations could be exposed to chemicals
of potential concern currently and in the future were identified and
selected for evaluation. Identification and selection of pathways was based
primarily on considerations of chemical migration and current or
hypothetical future land use conditions of the site and surrounding area.
The exposure pathways selected for evaluation under current land use
conditions are the following:
- direct contact (incidental ingestion and dermal absorption) with
contaminated soil by workers and trespassers (children) at the site;
- inhalation by on-site workers and residents bordering the site, of
vapors emitted from the soil
- direct contact with wastes (incidental ingestion and dermal
absorption) by workers and trespassers (children) onsite;
-15-
-------
TABLE 3-2
CHEMICALS OF POTENTIAL CONCERN
IN CUE-FOOT SOIL SAMPLES FROM WHOLE SITE
NEWSOM BROTHERS SITE
COLUMBIA, MISSISSIPPI
/•Mt,
Frequency of Geometric
Chemical Detection Mean
ORGAN! CS
Noncarcinogenic PAHs
Benzo(g,h,i)perylene
Naphthalene
2-methylnaphthalene
Acenapthene
Fluoranthene
Pyrene
Anthracene
Phenanthcene
Total:
Carcinogenic PAHs
Indeno ( 1 , 2 , 3 , cd ) pyrene
Chrysene
Benzo( a ) anthracene
Benzo(b and/or k)
fluoranthene
Benzo(a)pyrene
Dibenz ( a , h ) anthracene
Total:
Toluene
Ethylbenzene
Benzoic Acid
Pentachlorophenol
INORGANICS
Barium
Calcium
Copper
Lead
Manganese
Zinc
3/68
4/68
3/37
2/68
4/68
6/68
2/68
3/68
10/68
3/68
4/68
3/67
2/68
3/68
1/68
5/68
39/131
9/132
13/31
12/132
35/36
28/36
19/36
32/35
36/36
18/36
0.020
0.019
0.42
0.018
0.019
0.022
0.018
0.019
0.54
0.020
0.019
0.020
0.02
0.020
0.018
0.12
0.054
0.025
2.7
0.25
37
1,100
8.5
16
120
19
CENTRATION
Maximum
12
1
3.2
0.22
4.7
3.5
0.30
1.3
26
2.3
3.1
2.2
5.0
1.4
0.37
14
34
40
140
64
640
8,800
91
320
1,600
540
/ wm*m A* *m \
Background
<0.33
<0.33
<0.33
<0.33
<0.33
<0.33
~<0.33
<0.33
—
<0.33
<0.33
<0.33
<0.33
<0.33
<0.33
—
<0.005
<0.005
<1.6
<1.6
32-160
<1, 000-3, 600
4-<5
6-26
240-1,400
11-140
-16-
510A/2
-------
TABLE 3-3
or CHEMICALS in WWTE MATERIALS SAMPLES BASKD on
EVA RBOTXL ACTTTXTZES
NEN5OH aKCTHCTS SITE
COLUMBIA, MISSISSIPPI
All Concent ration* in
Cheaucr 1
Cone . R*no;e in
Old Proeeeiino;
Area Waate* (•)
Cone. Range in
North Field
(b)
Cone. Rang* in
Pecan Orchard
and Woodchip
Are* Matt** to
Concentration
Range in
Background Soil (c)
Acetone
Bentene
Butylbentyl-
phthaiat*
Chloroform
OEHP
Di-n-butyl-
phtnalate
Ethylbencene
Methylbensene iaoaier*
!Uphthal«n*
Pentaehlorophenol
Ph*nantbr*n*
Pt)*nel
1.1.2.2-
T»trachloro«th«n»
Tolu*n«
Total Xyl*n*»
Trichloro*th*n*
Inorganic*
TO
0.47-94.2
341 - 1.500
111
0.45-1.8
0.13-1.5
7.5-91.5
ND
TO
0.68-«43
HO
ND
0.27
10.4-119
27.2-3,080
0.50
ND
279
ND
103
0.29-28
2.0-17.6
0.26-13,500
3.7
1.3
ND
NO
7.7
ND
0.58-12,870
0.63-8,280
ND
ND
0.74-950
ND
3.5-10.4
0.18-4.7
0.85-15
0.26-23.800
26.8-90.7
ND
ND
ND
0.15-2.97
ND
0.11-8,300
181-54,300
ND
<0.005
-------
TABLC 3-4
•aa or OOWZCALS IN MUTK AMD own KxrtniAt SAMPLM
BA5tP Off BPACLP AHM.rStS
HtMSOH BXOTHBIS JITS
COLUMBIA, MISSISSIPPI
Cheaic«la
Concentration
la Drum
Material
On-Oround
geometric Mean
On-around
*•«* Material
Maximum
Organic*
Ac*ton«
ethylbcniMio
P«ntachloroph«nol
Phananthrm*
Fhonol
Tolu«fi«
Total Xyl«n*(
Inora,a«iei
Ar««nic
Qiromaua
Cobalt
Copper
Iron
Titan! u»
140
130
1,200
ND
1,800
17
640
ND
0.12
NO
0.03S
1.7
ND
ND
HD
IU
3,200
2,035
NA
ID
3,000
NA
NA
NA
1.71
251
71
•A
ND
970
3,200
3,200
40
ND
3.000
0.012
0.042
0.02
36
730
78
0.23
T«ntativ«ly Identified Coapounda
A-pinene
A-Terpineol
Borneol
C4-,C8-, and C9-alkylphenol
Caapnene
Cajapher
Cycanol
Dihydrodihydroxyphenylbencopyranone
Endopomeol
Hexadeeanoic acid
Iioborneol
Liawnene
nethoicypropenylbensene
Methylapiete
Methyl»ethylcyelohexaneMthMol
Nethylaethylethylidenecyclohexene
Phenylethylphenol
OctahydrodiaethylphenanthrenecarboKylic acid
Terpin hydrate
Tet rachio rophenol
Tet raawthylbutylpiMnel
TetraaethylpheaanthreiM
TriaethylbicyelolMpeaaol
Trinethylbicyeloaeptaaeae)
Tri«etnylcyclohe«en«awth«nol
—
—
—
1E-08
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
^^
4,000
4,000
1,000
4,300
700
600
300
5,000
900
1,000
400
1,000
800
2,000
— 0
400
300
5,000
2,500
200
2,000
400
800
400
2,000
_ . ^
4.000
4,000
1,000
4,300
700
600
300
5,000
900
1,000
400
1,000
800
2,000
—
400
300
5,000
3,000
200
2,000
400
800
400
2,000
ND • Not Detected
— • Data not available or coejpound not observed In particular ea«ple.
NA • Not applicable. Chemical wa« detected infrequently, aad the use of one-half the detection
limit in calculating a geometric mean reeult* in a mean concentration that exceed* the
maximum. Therefore, a mean will not be reported.
-18-
510A/4
-------
LEGEND
HAZARDOUS SUBSTANCES
AREA CODE NUMBER
REM II
HAZARDOUS SUBSTANCES REMEDIATION AREAS
NEWSOM BROTHERS SITE
COLUMBIA. MISSISSIPPI
-19-
PIGURE NO
3-4
-------
TABLE 1-3
SIMM? Or OOMXCALS OF FOTBirXAL
RIM5GH BMOTfUXS SXTI
COLUMBIA, MISSISSIPPI
Old Froceaaing Area
Soil*
Pecan Orchard and
Moodchip ACM
Soil*
Berth Field
Soila
Horieahoe Peed
Surface Mater/
laat Pond
Sediment*
Barium
Bciweie acid
Calelta
Copper
Ctftylb«ns«n«
PAH*
PCOM/KBF*
P«nt>ehloropeh«nol
Tolu«n«
Zinc
Benseic acid
Cepp«r
Bthylbww«n«
PAHs
Barium
Baase(b)fluerM
Copp«r
tthylt»n»«n«
P*ntaehloropto«nel
Telu«tM
Iron
zyl«n«*
P«nt«ehloroph«nol
ToluwM
Alluvial Aquifer
Ground Mater
Drainc^e Ar*««
and Cr*«kt
Surface Mktar/Sediaent
Concrete Oraiae
Surface Water/S*diaent
North Pond
Surface Nfeter/Sedlaent
Beryllium
Bi* ( 2-ethylhe*yl Iphthalate
Copper
Iron
Lead
Sodium
1,1, 1-trichloroethane
Trichloroethene
Benaoic acid*
Beryllium"
Calcium
Carbon, diiulfide
Cobalt*
Copper* 'D
Di-n-octylph£halate
tthylbentaite
Magneaium .
Hethvl butyl ketone
PAH* .
Petaaaium
Sodiu.%
Toluene
Total xylene*
vanadium"
Antimony*
Beryllium
carbon-diaulfide
Cobalt b
copper*'
Bthylbenaene '"
2-«*thylphenol"
4-«ethylphenol*'D
'**• a b
Pentachlorophenol '
Total xylene* '"
Trichloroethene
b
Aluminum .
Arochlor 1254°
BariuJ5 -
Bi* ( 2-tthy ih««yl )phthala£a^
Calcium b
Chloroform
Chromium
Copper
Cthylbeniene '
Iro«b
*-*m w
Ha9>e*ium b
Pentachlorophenol
Phenol0
Total ivlene*
Toluane
Cine
Mater
Sedimenta or aoila
c Chemicala detected in more than 5% of aamplea and preaeat at concentration* eaceediaq twice the maximum
background concentration.
-20-
-------
- direct contact with pond sediments (dermal absorption only) by
trespassers while wading.
The above-mentioned potential exposure pathways would also apply in the
future. Additional hypothetical human exposure pathways that were selected
for evaluation and may be relevant for the future if the site were developed.
for residential use or if groundwater from the alluvial aquifer at the site
were used-for drinking, are the following:
- direct contact with wastes, soils/ and pond sediments placed on
ground surface (incidental ingestion and dermal absorption) by
future residents of the site; and
- ingestion of groundwater from the alluvial aquifer by future onsite
residents.
3.7.2 HUMAN HEALTH RISK ASSESSMENT
Risks from the exposures identifed above were evaluated first by comparing
concentrations of chemicals of potential concern at points of potential
exposure with ARARs. ARARs are not available for all chemicals in all media
and therefore risks were quantitatively assessed for human exposures to
these chemicals of potential concern at the site. ^
Quantitative risk assessment involves estimating chronic daily intakes
(GDIs) by potentially exposed populations based on the assumed exposure
scenario. Chronic daily intakes are expressed as the amount of a substance
taken into the body per unit body weight per unit time, or mg/kg bw/day. A
GDI is averacred over a lifetime for a carcinogen and over the period of
exposure for a nonearcinogen. These intakes are then combined with
reference doses (RfDs) or cancer potency factors to derive estimates of
noncarcinogenic hazard or excess lifetime cancer risks, respectively, to the
potentially exposed populations For nonearcinogens, results are presented
as the ratio of the intake of each chemical to its RfD, and as the hazard
index, which is the sum of the ratios of the intake of each chemical to its
Rfd. A hazard index exceeding one indicates that a health hazard might
result from such exposures. For carcinogens the excess lifetime cancer risk
was estimated. EPA recommends that the total carcinogenic risk to
individuals resulting from exposure at a Superfund site be reduced to zero
where possible. However, according to agency policy, the target total
individual carcinogenic risk resulting from exposures may range between
10 to 10 (i.e., one excess cancer in every 10,000 and 10,000,000
individuals, respectively, exposed throughout their lifetime).
ARARs were available only for certain chemicals in groundwater. Only
maximum concentrations of lead exceed the MCL of 0.05 mg/L. It should be
noted, however that lead was also detected in water samples collected from
sampling/drilling equipment and may be more indicative of equipment
-21-
-------
contamination than groundwater contamination. Although no standards or
criteria were identified for chemicals in soils or sediments, guidance
levels for PCDDs/PCDPs and PCBs (which although not standards or criteria,
may be considered relevant and appropriate requirements), were identified.•
The toxicity equivalent (i.e., equivalent to the carcinogenic toxicity of 2,
3, 7, 9-TCDD) concentration of PCDDs/PCOPs detected in the soils at the site
were below the Centers of Disease Control (CDC) recommended level of 1 ug/Jog
for residential areas. The PCB concentrations at the site (in the North
Pond sediments) were below the EPA TSCA guidance level 10 mg/kg for
unrestricted access areas.
3.7.2.1 QUANTITATIVE ESTIMATES OF RISK
Because ARARs are not available for all chemicals in all media, risks also
were quantitatively assessed for all potential exposure pathways outlined
previously. The results of this assessment are discussed below.
3.7.2.1.1 Estimates of Risks under Current Land-use Conditions
In the direct contact with contaminated surface soil pathways, current
exposure was evaluated for workers in the old processing area, North Field
and in the pecan orehard/woodchip area, and for trespassers (older children)
in these site areas« For the exposure of workers to soils, an upperbound
excess cancer risk of approximately 10"5 was indicated under the
conditions and assumptions of the plausible maximum scenario, primarily due
to exposure to cPAHs in the old processing area. For the exposure of
trespassing children to soils under maximum conditions, an upperbound exq
cancer risk of 10"b was estimated again due to the presence of cPAHs in
the old processing area. Estimated cancer risks of PCDD/PCDFs under these
exposure scenarios did not signficantly contribute to the total estimated
upperbound cancer risk estimates. Average scenarios for exposure of both
workers and children yielded upperbound cancer risks less than or equal to
10". The hazard index was greater than 1 for these current soil exposure
scenarios only under the maximum exposure conditions, with the dominant
chemical of concern being total PCDDs/PCDFs in the old processing area
evaluated as nonearcinogens. Inhalation of toluene volatilizing from the
surface soils resulted in exposure intakes less than the risk reference dose
and therefore are not likely to result in health effects to potentially
exposed populations.
Current exposure pathways involving direct contact with wastes by
trespassers and workers did not involve potential carcinogens, and
noncarcinogenic hazard indices were less than one under both average and
maximum exposure conditions. It should be noted, however, that due to the
lack of quantitative toxicological information on tentatively identified
compounds (TICs) found in the various wastes on site, the risk evaluation of
the wastes did not consider the potential health effects of exposure to the
TICs by individuals. TICs as a mixture may augment the toxic effects of
each chemical individually. These toxic effects may include adverse effects
on behavior, the central nervous system, effects on gestation, other
systematic effects, and potential neoplastic effects. TIC areas are
associated with the tar-like waste material which will be removed from the
site.
-22-
-------
The exposure scenario involving children currently wading in either North
Pond, Horseshoe Pond, or East Pond and dermal IY absorbing sediment
contaminants yielded carcinogenic risks of 10~* only under maximum
exposure conditions, primarily due to cPAHs in the Bast Pond Horseshoe Pond
and PCBs in North Pond. Noncarcinogenic hazard indices for this exposure
pathway were less than one for all on-site ponds.
3.7.2.1.2 ggt-^At^es of Risk under Hypothetical
For future lifetime residential exposures, direct contact with surface
soils, wastes, and pond sediments spread on the site surface, were
evaluated. Cancer risks estimated using average exposure conditions for all
of these future direct contact pathways were less than or equal to 10~ .
For direct contact future pathways involving soils, only the maximum
exposure conditions yielded risks on the the order of 10~5, primarily due
to the presence of cPAHs in the old processing area. Average exposure
conditions for this scenario yielded cancer risks of approximately 10".
For direct contact with sediments, maximum cancer risks of 10~5 were
estimated for North Pond due to PCBs . The maximum cancer risk estimates
calculated for direct contact with sediments in East Pond and Horseshoe Pond
were approximately 10~ , with cPAHs as the significant chemicals of
concern. No carcinogenic chemicals of concern were identified in the
wastes. However, as noted above, although risks cannot be quantitatively
evaluated, the TICs found in the wastes may produce adverse health impacts
on exposed future residents.
The only future direct contact pathway yielding a hazard index greater that
one was the possible maximum soil pathway involving direct contact by future
lifetime residents, with total PCDO/PCDFs evaluated as noncarcinogens being
the significant chemicals of concern. Hazard indices for direct contact
with wastes or sediments by future lifetime residents under average and
maximum exposure conditions were less than one.
Corns umpt ion of groundwater from the alluvial aquifer from beneath the site
was evaluated under a potential future use scenario. Cancer risks were
10~5 and 10" J under average and maximum exposure conditions, -•
respectively. Maximum lead concentrations yielded- a. noncarcinogenic hazard
index greater than one. It has been determined however^ that the lead found
was residual contamination from drilling muds.
The great majority of the human health excess lifetime cancer risks
calculated for current and future exposure to the chemicals of concern at
the Newsom Brothers site discussed above are well within or lower than the
target risk range of 10~4 to 10 that EPA has used under Superfund. It
should be noted that PAHs and PCDO/PCDF compounds, detected at low levels
primarily in the old processing area of the site, are likely to have been
formed in the explosion which occurred at the site. PAHs are ubiquitous in
the environment and the levels of cPAHs observed in the site soils are
within their range of urban background levels although above those levels
thought to represent rural background. It should also be noted that most of
the PAHs in the old processing area and other site study areas were detected
-23-
-------
in less than 8% of the samples collected and analyzed. This low frequed
of detection may not be representative of actual site conditions.
Furthermore/ the risks associated with exposure to the carcinogenic PAHs are
probably overestimated due to the application of the potency factor for
benzo(a)pyrene to other PAHs which may be less potent.
Table 3.6 summarizes the risks determined under the exposure pathways and
conditions presented.
3.7.3 Environmental Receptors
Potential environmental impacts of the chemicals of potential concern at the
Newsom Brothers site also were evaluated. Plant and animal species
potentially exposed to the chemicals of potential concern at the site were
identified based on a knowledge of the site and surrounding habitat.
Individual species or communities were selected as indicators of potential
impacts at the Newsom Brothers site, and exposure of these receptors was
quantified. Receptors for which exposure was quantified were terrestrial
plants, small mammals, birds, and aquatic life. The available toxicological
literature was reviewed to identify exposure concentrations or doses
potentially associated with adverse effects in plants and wildlife.
Toxicity values derived for terrestrial plants and animals from the
available literature and Ambient Water Quality Criteria (AWQC) developed by
EPA for the environmental impacts at the Newsom Brothers site.
*jk
Risks were assessed by comparing the reported environmental concentratio^fcr
the estimated dose with the selected toxicity value. Absolute conclusid
regarding the potential environmental impacts of the Newsom Brothers site
cannot be made because there are many uncertainties surrounding the
estimates of toxicity and exposure. However, given the available data and
limitations, several general conclusions regarding the potential for
environmental impacts are presented below.
The maximum concentration of copper and zinc in the soils of the site exceed
levels that are known to be phytotoxic in at least some species. Small
mammals and birds that potentially use the surface water of the site as a
drinking water source do not appear to be at .increased risk of adverse
impacts, as the estimated intakes are well below those estimated to be
associated with toxic effects. Toxic effects to some species of aquatic
life may be occuring in some of the surface waters on site as a result of
exposure to pentachorophenol and copper found in the surface waters and PAHs
and PCBs in the sediments. These contaminants do not appear to be moving
downstream to any extent, and are apparently not impacting the waters of the
lower portions of Jingling Creek.
3.7.3.1 Endangered. Threatened and Rare Species
Two species classified by the state as threatened and by the Federal
governmental as endangered are known to occur in Marion County. These are
the Ringed Sawback Turtle fGraptemys oculifera) and the Gopher Tortoise
(Gooherus Polyphemus). U.S. Fish and Wildlife Service has stated that
species are not likely to extend into the site and no sightings have bee
reported.
-24-
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TABLE 3-6
SUMMARY OF POTENTIAL RISKS ASSOCIATED WITH
EXPOSURE TO CHEMICALS OF CONCERN1 * '
NEWSOM BROTHERS SITE
COLUMBIA, MISSISSIPPI
CDI:RfD Index for Lifetime Excess
Noncarcinogenic Cancer Risk
Effects (Upperbound)
Pathway/Chemical Average Maximum Average Maximum
Current Direct Contact
with Soils by Workers
PCDDS/PCDFS 5x10"J 8x10° 1x10"' 1x10"s
CPAHS NQ NQ 4x10"' 2x10"*
Total: 5xlO"1(
-------
TABLE 3-6
(Continued)
CDIrRfD index for Lifetime Excess
Noncarcinogenie Cancer Risk
Effects (Upperbound)
Pathway/Chemical Average Maximum Average Maximum
Current Direct Contact with
Drum Wastes by Workers
Pentachlorophenol 1x1O"2 3x10"? NQ NQ
Phenol 1x10 4x10 NQ NQ
Total: 3x10" 2«1) 7x10" «1) NQ NQ
Current Direct Contact With
On-Ground Wastes by Workers
Pentachlorophenol 3x10"2 8x10"2 NQ NQ
Lead 4x10 8x10" NQ NQ
Total: 8xlO"2«l) 2xlO"1«l) NQ NQ
Current Dermal Contact with
Pond Sediments By
Children While Wading
North Pond;
PCBlNQ NQ 4x10"lo 2x10"*
Phenol 7x10"' 2x10"4 NQ NQ
DEHP 5x10 1x10 NQ NQ
Chloroform 3x10"* 1x10"4 NQ NQ
Total: 8x10" *«1) 5x10" 4«1) NQ NQ
Horseshoe Pond;
cPAHs NQ NQ 5x10"lo 2x10
East Pond; ,. .
cPAHlNQ NQ 3xlO"l° 4x10"*
Future Direct Contact
with Soils by
Lifetime Residents
Old Processing Area; t .
CPAHS NQ , NQ 3x10". 7x10"
PCDDs/PCDFs 7x10"4 8x10° 1x10"' 4x10"*
Total: 7x10"4«1) 8x10° (>1) 2x10"8 7x10"
510A/6
-26-
-------
TABLE 3-6
(Continued)
CDI:RfD Index for Lifetime Excess
Noncarcinogenic Cancer Risk
Effects (Upperbound)
Pathway/Chemical Average Maximum Average Maximum
Pecan Orchard/Woodchip Area;
CPAHS NQ NQ 2x10" 1x10"5
PCDDs/PCDFs 5x10" 2x10 2x10" 2x10"'
Total: 5xlO"4«l) 2x10-1 «1) 2x10" 1x10"5
North Field;
Barium 1x10 «1) 9x10 ~«1) NQ NQ
Future Direct Contact with
On-Ground Wastes by Lifetime
Residents
Pentachlorophenol 5x10"3 9x10"2 NQ NQ
Lead 6x10"; 9x10" 2«1) NQ NQ
Total: lxlO"a«l) 2xlO"1(
-------
TABLE 3-6
(Continued)
CDIsRfD Index for Lifetime Excess
Noncarcinogenie Cancer Risk
Effects (Upperbound)
Pathway/Chemical Average Maximum Average Maximum
Horseshoe Pond;
CPAHS NQ NQ 5x10"' 2x10" *
Consumption of Ground Water
from Alluvial Aquifer
Bis(2-ethylhexyl)
phthalate 9x10°3 4x10° 3x10"' 1x10"J
Trichloroethene NQ NQ 6x10" 6x10"7
Lead 5x10", «1) 8x10° (>1) NQ NQ
Total: 5x10"*(1) 3xlO"s 1x10"J
1 *' The chemicals presented in this table are those that significantly
contribute to the overall carcinogenic and noncarcinogenic risk for a
particular pathway,
NQ - Not Quantified.
-28- 510A/6
-------
4.0 Cleanup Criteria
Cleanup objectives at the Newsom Brothers Site are based on protection of
public health and the environment and are consistent with Section 300.68 of
the NCP, Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) as amended by SARA, EPA guidance, and state local regulations.
The cleanup levels for each contaminant of concern at the Newsom Brothers
Site have been developed based on the following objectives:
- The protection of the public health and environment (i.e.,
terrestrial and aquatic wildlife) from exposure to contaminated soil,
pond sediment, and hazardous substances through reasonably expected
current and future exposure scenarios
- The protection of onsite workers from inhalation of dust and vapore
through current exposure scenarios
- The prevention of the spread of contaminants identified onsite
- The reduction of the potential for future contamination of ground
and surface water
The soil and sediment cleanup goals were based on an increased potential
cancer risk of 10", which is consistent with guidance under SARA. EPA
generally considers increased potential cancer risks of 10~4 to 1£ in
developing cleanup goals at Superfund sites. A risk level of 10~6 was
selected by EPA to develop cleanup goals for chemicals at the site to ensure
a high level of protection of public health at the site. In addition,
exposure scenarios considered in the EA are very conservative in that the
scenarios are not likely to occur at this site, but have been included to
provide added protection of public health for naaaible future events.
4.1 Groundwater Cleanup Criteria
ARARs that apply to contaminants found in the groundwater at the Newsom
Brothers Site are given in Table 4-1. Requirements were obtained from the
Safe Drinking Water Act (SDWA) in the form of SDWA MCLs and SDWA MCLGs. In
cases where an MCL or an MCLG has not been established, Federal Ambient
Water Quality Criteria (AWQC) adjusted for drinking water, were used to
establish cleanup goals.
-29-
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TABLE 4-1
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR GWOUND WATER
NEMSOM BROTHERS SITE
COLUMBIA, MISSISSIPPI
CHEMICALS
Inorganic
Arsenic
ChroBiu* (he»valent)
Lead
Mercury
Nickel
1 Organic
1 *> ™' '
\JiJ
O
Benzene
ethyl Bencene
Toluene
Pentachlorophenol
Polynuclear Aromatic
Hydrocarbons (PAHsl
Phenol
SDMA MAXIMUM
CONTAMINANT
LEVEL (HCL)
SO
50
50
2
13.4
5
NA
NA
• ft
0.1
NA
NA
GROUP) HATER
SDMA MAXIMUM
CONTAMINANT
LEVEL
GOALS (HCLG)
NA
120*
A
20
a
3
NA
NA
A
680
2,000*
A
220
NA
NA
CLEANUP GOAL (ug/1)-
FEDERAL AMBIENT
WATER QUALITY
CRITERIA ADJUSTED
FOR DUNKING
HATER
0 (0.025)
50
5,200
10
15.4
0 10.67)
2,400
15,000
1.010
0 (O.OOJ1)
3.500
GOALS SELECTED
FOR SITE
REMEDIATION
50
50
20
2
13.4
5
680
2,000
0.1
tt * 6
10
1,500
NA = Not available/applicable.
k
= Proposed value as of October 1986.
=. Proposed value «3 of May 22, 1989
• * •
= Pi»cti<:al Qualification Unit based on B«nzo(bl t luoianlhene f
»
I) - The criterion vain* tur all csicinoijens i •-. /.«m. Tt>« . »i>. ent i jl ion value .|iven in
iisk of 10" .
tui an incieased canc«
blO/41
-------
Groundwater sampling conducted during the Phase II RI indicated the presence
of miscellaneous organic compounds (tentatively detected) at low estimated
levels. Of the inorganic compounds, lead was the only compound detected at
levels above the MCL. The MCL for lead is 0.05 mg/1. Lead was detected in
three wells on the site at 0.160, 0.120, and 0.084 mg/1, but lead was also a
contaminant of the drilling mud used at the site. Due to the low
concentration of the contaminants, no groundwater remediation is recommended
at this time. However, groundwater monitoring should be continued in the
future to confirm that contamination is not present in the groundwater.
A monitoring program with periodic sampling of a select number of wells
would be appropriate for this purpose. The initiation of such a monitoring
program should take place after the three contaminated wells have been
redeveloped using a surge technique in order to remove any remaining
drilling mud.
4.2 Surface Water Cleanup Criteria
Surface water was sampled to determine the potential for offsite migration
of contaminants. ARARs for the contaminants detected in surface waters at
the Newsom Brothers site are presented in Table 4-2. Because surface water
is not a direct source of potable water, but should be safe for recreation
and ingestion by aquatic organisms, site remediation goals were selected
from Mississippi's AWQC. However, if the detection level is higHer than the
goal, the detection level is chosen as the standard for cleanup. In
addition, if the AWQC was not available for a contaminant of concern, the
applicable SDWA goal was selected.
No surface water remediation is required at the site because onsite sampling
results yielded values below the appropriate ARAR. One offsite sample taken
during the Phase I RI showed estimated mercury values above the ARAR;
however, this sample does not appear to have been representative of site
conditions and the result is tentative.
Surface water may be removed from onsite ponds to allow sediment
remediation; however, this water is not considered hazardous and could be
safely discharged to nearby surface waters. Nevertheless, the water must be
analyzed, and bioassays performed, before discharge to ensure that water
quality criteria are not exceeded and it is non-toxic to aquatic life.
4.3 Soil Cleanup Criteria
Considering each of the previously discussed exposure scenarios, cleanup
goals were developed. The EA identified carcinogenic polyaromatic
hydrocarbons (cPAH) as the only contaminants present in the soils of the
site at concentrations that could possibly cause adverse human health
impacts. However, the cleanup levels for carcinogenic polyaromatic
hydrocarbon (cPAH) compounds in soil calculated at maximum exposure for the
10~° risk level were substantially below expected background
-31-
-------
TABLE 4-2
APPLICABLE OR RELEVANT AHD APPROPRIATE REQUIREMEnTS
rO« SURFACE HATER
HCM50H BROTHERS SITE
OOLUHBIA. MISSISSIPPI
I
U>
K>
Chemicals
Inorganic
Arsenic
Lead
Mercury
Organic
Etbylbemene
Pentachlorophenol
Toluene
SDNA Maximum
SOMA Maximum Contaminant
Contaminant Level
Level Goal
50 HA
M 20*
2 1
HA 610*
HA 220*
HA 2,000*
In eTlMIP fVkftf fun /I 1 .
Mississippi
Ambient
Mater Quality
Criteria
41
• *
1.2
0.012 (0.21
HA
*•
11
HA.
Goals Selected
for Site
••mediation
41
1.2
0.2
MO
11
2.000
•A - Rot available/applicable.
* ,
• Proposed value as of October 19IC.
• pH dependent, for acute toilcity of pentachloropiienol: |PCP| • ,1-005 'P* ~ 5-
() - Current detection Unit recognised by EPA is given in parentheses. If the detection limit is higher
criterion, the detection limit is the standard unless it is lowered.
then the established
510/U
-------
concentrations of these compounds, a soil cleanup level of 10 mg/kg was
selected for cPAHs by EPA. This cleanup level is based on natural
background concentrations and risk values of the average exposure scenarios
and is consistent with actions at other Superfund sites.
Several areas at the Newsom Brothers site were disturbed during the EPA
removal action conducted in late 1987 through early 1988. During this
removal action, buried hazardous materials were excavated and disposed of at
an offsite location. In certain disturbed areas, potentially contaminated
soil was used to fill the excavations. These areas are considered to
require further soil remediation and removal volumes have been calculated
for these areas. These volumes are presented in Table 4-3. Assumptions of
the amount of soil to be removed from burial areas are included in this
table, and are generally made based on information obtained from personnel
involved with the EPA removal action. Inclusion of these areas in
calculation of the remedial volume for the site is conservative in that no
clear contamination has been identified. During the remedial action, these
areas should be sampled and analyzed to refine the estimated remedial
volume. Possible contaminants have been identified and health based cleanup
levels are presented in Section 4.6.
4.4 Sedinient Cleanup Criteria
Cleanup goals for pond sediments were developed during the exposure scenario
previously described. For a scenario of future direct contact with North
iPond sediments by lifetime residents, the cleanup goal for Arochlor-1254 is
calculated to be 0.12 mg/kg at 10~6 risk. All sediments removed which
contain PCBs will be treated as PCB waste in accordance with 40 C.F.R.
761.65. All other chemicals detected in the North Pond sedvmftni- present a
lower than 10~b risk. The cleanup goal for the sediments in the creek
upgradient of the North Pond, North Pond sediments, East Pond sediments, and
the Horseshoe Pond is based on cPAHs at the cleanup level of 10 mg/kg as
selected EPA. This cleanup goal was selected after consideration of
reasonably expected background levels for these chemicals and average
exposure scenarios.
Table 4-4 contains estimates of the volume of sediment to be removed and the
assumptions regarding the dimensions of the removal areas.
4.5 Hazardous Substances Cleanup Criteria
Hazardous substances were observed in the form of two separate types of
waste material, tar-like waste material and a resin-type waste material.
These materials were sampled during both the Phase I and Phase II RI and
-33-
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TABU 4-1
ESTIMATES or SOIL VOLUMES THAT UQUIBC REMEDIATION
H06QH mOTHERS SITE
COLUMBIA, MISSISSIPPI
ATM Cod* EatlMated
Location Buatoer Area
(ft2)
•octb Pond ATM 1 (.160
Mbod Chip/South Pood ATM 2 6,670
1 7,160
4 3,120
S 2.640
< 660
7 2.000
HaXlBUB
Depth
(ft)
40
25
25
15
20
15
10
Naiiaui
••tiMted
VolUM
(ftJ»
126,400
166.750
195,500
46.100
52,100
• ,900
20,000
Mat.ri.l Hajor
Ovacription CoatuUauit
Soil-OniB cfMta
Burial Area
Soil-Oro cTAta
Buri*d Rubbl*
Ar»«
Soll-DruB cfAfla
Buried OMaUcal
Ar«a
Soil-Dl99iit9«/ cPABa
Traah Pil*
Soil-Traeh Pil* c»Alc
Soil-Oabria/ c»Ala
Di (colored Soil
Area
Soil-Trendi Area cPAMa
Cleanup
Objective
(•9A9)
10
10
10
10
10
10
10
TOTAL VOLUME - BIS.150 Ct'
• 10,102 yd
510/14
-------
TABLE 4-4
or SEDtmrr VOLUMES IHAT uguiu nmoiAnoa
•EMSGH BBOTHEXS SITE
COLUMBIA, MISSISSIPPI
u>
V
HaiiauB
ACM O»d* latinatad Nulaua Eatlaatad
Location mmbut ACM Depth Voluna
(ft2J JftJ
-------
found to contain a wide variety of organic compounds. The hazardous
substances presented difficulties in performing laboratory analysis, and
presence of high concentrations of unidentified chemicals was indicated. Due
to the presence of these unidentified contaminants, removal and thermal
destruction of these .hazardous substances is recommended. An estimated 650
cubic yards of these materials are present on the site.
4.6 Additional Health Based Cleanup Criteria
Some compounds associated with the drummed waste and other waste material
removed from the site during the removal activities may be present in North
Pond sediments, drainage system sediments, and in the areas where soils were
returned to the excavation areas. These compounds were present in high
concentrations in the waste materials. Therefore, health based cleanup level
have been calculated for these compounds using the previously described
exposure scenarios and protection levels. The cleanup levels for these
compounds are presented in Table 4-5. Soil in the burial areas and sediments
should be carefully analyzed to determine if the compounds are present at
levels that require soil or sediment removal.
5.0 Alternatives Evaluation
The purpose of the remedial action at the Newsom Brothers site if to mitigate
and minimize potential risks to public health, welfare, and the environment
posed by contaminated site soils, sediments, and hazardous substances.
initial screening of a wide range of applicable technologies was performe^Pto
identify those which best meet the criteria of section 300.68 of the National
Contingency Plan (NCP) . Following the initial screening of technologies,
potential remedial action alternatives were identified and analyzed. Table
5-1 summarizes the technology screening process. Each of the remaining
alternatives for site remediation was evaluated based on cost, technical
feasibility, implementability and reliability, attainment of institutional
requirements, and degree of protection of public health, welfare, and the
environment. The following seven remedial action alternatives were
considered:
1. No action
2. Off-site disposal of soil and sediment, and off-site thermal
destruction of hazardous substances at facilities approved under RCRA
3. On-site incineration of soil, sediment, and hazardous substances
4. On-site incineration of soil and hazardous substances; on-site
capping of sediment
5. On-site capping of soil and sediment; off-site incineration of
hazardous substances
6. On-site encapsulation of soil and capping of sediment; off-site
incineration of hazardous substances at a RCRA-approved facility
7. Solidification/Stabilization of soil and sediment; off site disposal
of hazardous substances.
-36-
-------
TABLE 4-5
ADDITIONAL SEDIMENT/SOIL CLEANUP LEVELS
NEW50M BROTHERS SITE
COLUMBIA, MISSISSIPPI
SEDIMENT/SOIL CLEANUP CONCENTRATICKS (uq/Vq)
Lifetime
Contaminant Residents
Benzene (a) 41
Chloroform (a) 197
-Toluene 3.6 x 10*
Xylenes 2.4 x 10
Phenol 4.8 x 10*
Naphthalene 6.3 x 10
, Di-N-butyl Phthalate 1.1 x 10*
•_Ethyl Benzene 1.2 x 10
Pentachlorophenol (a,b) 1.2
a - These chemicals are carcinogens and soil cleanup levels represent a
10"s risk level.
b - Pentachlorophenol has recently been reclassified by the Agency as a
B2 Carcinogen. A cancer potency has not yet been determined. The
information that we have is that it will most likely fall between
0.2-1.0. The more conservative value of 1.0 was used as the potency
factor for determining soil cleanup levels.
510/36
-------
UULE 5-1
RESULTS or nteuiaiiART souconm or RQBDIAL TCOIRDLOGIES
HCHSOH BROTHERS SITE
COLUMBIA, MISSISSIPPI
Possible Technologies
Screened Out (SI
or
Ratalnad (R)
If Scraanad Out, Raaaon foi Doing So
00
A. Complete or Partial Removal of Contaminated Madia
1. Excavation and Offait* Disposal
o Soil
o Sediment
o Baiardoua Substances
2. Excavation and Onsita Disposal
o Soil
o Sediment
o Baiardoua Substances
B. Treatment of Contaminated Madia
1. Extraction (Fluahing/Me.ahing)
o All media
2. Immobilisation
Solidification/Stabilisation
o Soil
o Sediment
o Hasardoua Substances
Vitrification (crystallisation)
o All madia
1. Biological Treatment
- Land farming
o All e»dla
R/3
B/S
S
R
R
S
(Of (sit* dlapoaal to landfill)
(Offalta diapoaal to landfill)
(Offsita diapoaal to incinaration plant)
(Ratalnad aa part of cappinq and •ncapaulatioa)
(Ratainad as part of capping)
•ot appllcabla to wast* characteristics - organic contaot too oioji
Difficult to apply for contaminants with low aolublllty
(Ratainad in conjunction with capping and v*9*tatlwe cover)
(Ratainad in conjunction with capping and vegetative covar)
Rot applicable to waata characteristics - organic content too high
Mot applicable to Meat* characteristics/unknown reliability
and effectiveness, water table too high
Hot applicable to vast* characteristlcs/Xnknown reliability
and effectiveness
-------
TABU 5-1
(continuod)
toaaibU T*chnolwji«a
Scromod Out (S)
or
pitalnad (•)
1C Scraaood Out, ftMaon for Doing So
I
f
C.
Activated Sludga
o All a»dia
CoBpoating
o All Badla
«. tttacml Traataant
Ctoalta daaorptlon
o Soil
o Sodlaant
o Macardoua Sub«t«nc«*
ContainMot of ContoiMtod Itodla
1. Oqpiao;
o Soil
o
o
2.
o Soil
•/S
Sutetancos
Bot applicabl* to wait* ch«r«ct*riitic*/V>ifcaoMa roliablllty
•ad offOCtiVMMBS
•ot applicBbl* to wacto ct>»f»ct»rlftic*/\mttnm*t roliability
and •ff«ctiv«Ma«
too u»ll but foulbla if u>«d with ooil)
(VolUM tOO M«ll bUt fOMlbl* if UMd With Mil)
(tetaioad In coo junction with aicavation, onait* dlapoaal,
and v*9atativ« cov*r)
(totainad in conjunction with filling tha pond* aw*.
v*9«tativ« covar)
•ot applicablo to waato characteristic*
in conjunction with aicavatlon and onait* dlapoaal,
and vogatatlva covor)
Hot applicabla to waat* charactarlatica
Hot appllcabl* to waato charactariatlc*
510/11
-------
Costs of the seven remedial alternatives are presented in Table 5-2.
All alternatives are designed to isolate or treat the volumes of soils,
sediments, and waste material described in Section 3.0. These volumes of
material are based on the cleanup levels for the various media as described
in Section 4.0. At the completion of all remedial action alternatives the
health risks posed by direct contact with contaminated media at the site
would be no greater than 1 x 10"*° under the exposure scenarios described
in the endangennent assessment.
5.0.1 ALTERNATIVE 1 - NO ACTION ALTERNATIVE
The National Oil and Hazardous Substances Contingency Plan requires that the
no action alternative be considered during the feasibility study. The no
action alternative was evaluated in the Endangerment Assessment to determine
the associated health risks.
Under the no action alternative, soil, sediment and hazardous substances
would remain contaminated with toxic substances regulated by local, state,
and federal laws. Potential impacts of no remediation might include
occupational or public exposure, decline in property values, expenditures
for legal services depressed area growth, expenditures for laboratory
analyses and monitoring, restricted access to the site, and environmental
impacts.
Approximately four months would be required for the execution of
administrative activities, selection of a contractor to provide continued
maintenance at the site, and the preparation of contracts. The only capital
costs associated with the no action alternative would be the placement of
warning signs. Operation and maintenance costs would include periodic
groundwater monitoring, analysis costs, and upkeep of the fence and ground
maintenance. The following is a summary of the estimated costs associated
with the no action alternative:
Present Worth Operation
and Maintenance (O&M) Cost! S 1.005.852
Total Present Worth Cost: $ 1,005,852
5.0.2 ALTERNATIVE 2 - OFFSITE DISPOSAL OF SOIL AND SEDIMENT. AND
THERMAL DESTRUCTION OF HAZARDOUS SUBSTANCES
This alternative involves excavation and offsite disposal of contaminated
soil, sediment and hazardous substances. All materials will be transported
to an approved RCRA disposal facility. Due to the high levels of organic
materials present in samples of the hazardous substances, this material will
be subjected to thermal destruction at an offsite facility.
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TABLE 5-2
COST BANKING OP REMEDIAL ACTION ALTERNATIVES
NEWSOM BROTHERS SITE
COLUMBIA, MISSISSIPPI
Number
1
5
Alternative
No Action
Capping of Soil and Sediment;
Estimated Cost
$ 1,005,852
$ 8,220,717
Rank
1
2
Offsite Disposal of Hazardous
Substances
Encapsulation of Soil; Capping
of Sediment; Offsite Disposal
of Hazardous Substances
Solidification/Stabilization of Soil
and Sediment; Offsite Disposal of
Hazardous Substances
Onsite Thermal Treatment of Soil
and Hazardous Substances;
Capping of Sediment
$ 8,757,249
$10,094,345
$13,688,438
2
3
Off site Disposal of Soil, Sediment,
and Hazardous Siih«t-_anr*a
Onsite Thermal Treatment of Soil,
Sediment, and Hazardous Substances
$14,180,249
$15,452,473
6
7
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510/38
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Excavation of onsite sediments will require dewatering the North Pond, Ea|
Pond, Horseshoe Pond and the concrete drainage system. This water will bl
contained onsite by pumping to the Horseshoe Pond. The water will be
analyzed and bioassays performed before discharge, to be sure that no water
quality criteria are.exceeded and it is non-toxic to aquatic life.
After excavation, the contaminated soil, sediment, and hazardous substances
will be hauled to a RCRA. approved facility. The excavated soils and
sediments will be representatively analyzed to determine if they are RCRA
hazardous wastes. If RCRA hazardous waste is found it will be treated prior
to land disposal or a treatability variance will be sought. EP toxicity
test and TCLP will be performed. Removal will be conducted in compliance
with CERCLA off-site policies.
Approximately four months would be required for excavation design,
contractor selection, and approval by the offsite disposal facility. This
alternative could be implemented rapidly after contractor selection, and the
complete remedial action should take less than six months. Groundwater
monitoring would be conducted for five years following the remedial action
to ensure no groundwater contamination is present at the site.
Ambient air monitoring should be conducted during excavation activities.
The monitoring would be conducted at the site perimeter to ensure that
nearby residents were not exposed to hazardous vapors. In addition,
continuous monitoring would be conducted during excavation to provide
protection of onsite workers.
The following is a summary of the estimated costs associated with this
alternative:
Total Contraction Cost: $ 13,660,024
Present Worth O&M Cost: 520.225
Total Present Worth Cost: $ 14,180,249
5.0.3 ALTERNATIVE 3 - ONSITE THERMAL TREATMENT OF SOIL. SEDIMENT
AND HAZARDOUS SUBSTANCES
This alternative allows source control for the contaminated media at the
Newsom Brothers site. Surface water removed during excavation of sediments
would be treated in the manner described in Alternative 2. The total volume
of contaminated material to be treated is approximately 33,500 cubic yards.
A mobile thermal treatment unit is used in the economic evaluations. Low
temperature thermal treatment may be used at the site to desorb the
contaminants in a primary chamber and destroy them in a secondary
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combustion chamber. The organic contaminants are thermally destroyed and
the soil is left essentially the same.
A startup period of approximately 75 working days is to be allotted to this
operation. During this time, the equipment will be tested to confirm its
safety, and operating parameters will be generated for the process. Up to
150 tons of soil per day can be incinerated depending upon the condition of
the soil prior to its introduction into the furnace. This implies that at
best, with a least 25 percent down-time for maintenance and repairs, the
around-the-clock operation would require about 540 working days. More
realistically, 1.5 years should be allotted for the total incineration
procedure of 50,000 tons of contaminated soils, sediment and hazardous
substances. Additionally, approximately 100 days will be required for
mobilization, equipment orders, and installation. No long lead equipment
(exceeding 10 weeks delivery) is anticipated.
Preconstruction activities, including conceptual and final designs,
specifications, and preparation of contract documents for bidding, are
estimated at about 180 working days (8-1/2 months). Therefore, the overall
project duration is estimated to be approximately 830 working days for the
initial design phase to the completion of construction.
Monitoring concerns specific to the incineration operation are scrubber
effluent composition, levels of contamination in the incinerated soil,
contaminants in the stack gas, PGP content of the incoming soils,/system
pressure and temperature, and combustion air and scrubber water flow rates.
These factors are preeminent concerns for the incineration alternative and
considerable process control must be exercised due to the toxicity of
materials present.
previously installed groundwater monitor wells to determine and maintain
records of the groundwater quality at the site. The monitoring schedule for
the groundwater phase is the same as that outlined in Alternative 2.
The following is a summary of the estimated cost associated with this
alternative:
Total Construction Cost $ 14,932,248
Present Worth O&M Cost 520.225
Total Present Worth Cost $ 15,452,473
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5.0.4
SUBSTANCES; CAPPING OP SEDIMENTS
This alternative allows source control for the soil and hazardous substances
at the Newsom Brothers Site and containment of sediments. The ponds would
be dewatared in the manner outlined in Alternative 2. Capping of the North-,
East, and Horseshoe Ponds would be done by filling these ponds with a low
permeability material such as clay, and covering with a multi-component RCRA
cap. Thermal treatment would be conducted as described in Alternative 3. A
startup period of approximately 75 working days is to be allotted to this
operation. During this time, the equipment will be tested to confirm its
safety/ and operating parameters will be generated for the process. up to
4.2 tons of soil per hour can be incinerated depending upon the condition of
the soil prior to its introduction into the furnance. This implies that at
best, with at least 25 percent down time for maintenance and repairs, the
around-the-clock operation would require about 540 working days. More
realistically, 1.5 years should be allotted for the total incineration
procedure of 40,000 tons of contaminated soils and hazardous substances.
Additionally, approximately 100 days will be required for mobilization,
equipment orders, and installation. No long lead equipment delivery
(exceeding 10 weeks) delivery is anticipated.
Preconstruction activities, including conceptual and final designs,
specifications, and preparation of contract document for
bidding, are estimated at about 180 working days (8-1/2 months). Therefoca
the overall project duration is estimated to be approximately 830 working
days from the initial design phase to the completion of construction.
Monitoring for the capping of sediments includes regular inspection of the
cap for signs of erosion, settlements, deterioration, or invasion of the cap
by deep rooted vegetation or burrowing animals.
Monitoring concerns specific to the incineration operation are discussed in
Alternative 3. In addition, this remedy requires continued use of
previously installed groundwater monitor wells to determine and maintain
records of the groundwater quality at the site. The monitoring schedule for
the groundwater phase is to collect samples quarterly for one year and
semi-annually for 29 years thereafter.
The following is a summary of the estimated cost associated with this
alternative:
Total Construction Cost: $ 12,880,846
Present Worth O&M Cost: 807.592
Total Present Worth Cost: $ 13,688,438
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5.0.5 ALTERNATIVE 5 - CAPPING OP SOIL AND SEDIMENT; QPFSITB DISPOSAI,
HAZARDOUS SUBSTANCES
Surface capping of the contaminated soil involves constructing a three
layered cap according to RCRA guidelines. The onsite ponds would be
dewatered in a manner described in Alternative 2. The installation of a
surface cap will inhibit infiltration through the contaminated soil thereby
reducing the migration of pollutants to the groundvater. The cap would be
installed over the area of contaminated soil which encompasses approximately
3/4 acre. Sediment capping consists of filling the North and East Ponds
with clay. Hazardous substances would be disposed of at an offaite
facility.
Soil capping would first include the placement of a two foot clay layer
compacted in six inch lifts. A twenty mil thick synthetic liner would then
be placed over the clay. Next, a one foot thick drainage layer of gravel
would be spread and a filter fabric placed on top of the gravel. The filter
fabric would help to stabilize a final layer of eighteen inches of topsoil.
The topsoil would be vegetated to prevent erosion. Also, the cap would have
a minimum slope of two percent generally toward the southeast. Drainage
would be assigned to direct surface runoff toward the present natural
drainage channels. The capping of the sediments is identical in detail to
Alternative 4, and the hazardous substances will be incinerated in a thermal
treatment facility. —
Approximately six months would be required for design and contractor
selection. Assuming that weather conditions do not cause extreme delays,
this alternative could be implemented in approximately one year. It is
important to note that construction must be scheduled to allow for the site
to be adequately vegetated immediately following final grading. The total
time to excavate and cap the contaminated soil is approximately 14 months.
The excavation and truck loading of the contaminated sediment and hazardous
substances can be accomplished at a rate of 200 cubic yards per day (10
truckloads). At this rate, these cleanup activities will take about 20
working days. Monitoring for the capping of sediments and soils includes
regular inspection of the cap for signs of erosion, settlement,
deterioration, or invasion of the cap by deep rooted vegetation or burrowing
animals . Groundwater monitoring would be required in conjunction with this
alternative. Monitoring would involve continued use of the existing monitor
wells to determine whether contaminants are leaching or migrating from the
capped area. For the first year, quarterly monitoring will be required.
After the first year, and depending on results from the initial monitoring
period, the monitoring will be limited to twice per year for the 29 year
post-closure period.
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The following is a summary of the estimated costs associated with this
alternatives
Total Construction Cost
Present Worth O&M Cost
Total Present Worth Cost
$ 6,276,192
1.944.525
$ 8,220,717
5.0.6 ALTI
The contaminated soil will excavated and placed in a lined, onsite
landfill. The landfill will be covered with a multi-component cover system
to provide complete encapsulation of the soil. The onsite ponds would be
dewatered in a manner described in Alternative 2. The contaminated sediment
will be capped as in Alternative 4 and hazardous substances will be sent to
an offsite facility as described in Alternative 2. Excavation of soil,
sediment and hazardous substances could be achieved in 100 working days.
Mobilization, equipment procurement, and equipment installation will require
approximately 60 working days. Preconstruction activities such as design
and contractor selection will add about 180 working days to the schedule.
The total project time is estimated at about 340 working days.
-A J*
Monitoring of the integrity of the cap will be required as described in
previous alternatives. Currently installed groundwater monitor wells wi|
be used to ensure that contaminants are not leaching or migrating from tn^
containment area. For the first year, quarterly sampling will be required.
After the first year, and depending on the results from the initial
monitoring period, sampling will be reduced to twice per year for 29 years.
The following is a summary of the estimated cost associated with this
alternative:
Total Construction Cost
Present Worth O&M Cost
Total Present Worth Cost
$ 6,812,724
1.944.525
$ 8,757,249
5.0.7 ALTERNATIVE
7 - SOLIDIFICATION/STABILIZATION OF SOIL AND SEDIMENT;
OFFSITE DISPOSAL OF HAZARDOUS SUBSTANCES
This alternative involves the use ot source controls to reduce leaching and
migration of contaminants to the groundwater. The onsite ponds would be
dewatered in the manner described in Alternative 2. Solidification
/stabilization techniques would be applied to the contaminated soils and
sediments, and hazardous substances would be sent to an offsite facility for
disposal.
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The solidification of the hazardous waste area, which could be accomplished
by several methods, would involve a cementacious fixation of the
contaminated soil enabling it to be permanently stored at the site. One of
the most common solidification methods is to excavate the contaminated soil,
transport it to an onsite cement batch plant, mix the wastes directly with
Portland cement and other aggregates, and deposit the mixture back into the
excavation for permanent solidification. This method would include
excavation of all material and solidification/stabilization of 37,611 cy. of
soil and sediment. Likewise, bulk solids found onsite would also be
combined with soils during solidification and replaced onsite. This would
be accomplished by creating mixtures of soil and sediment to be treated in
the solidification process. The exact mixture of soil, sediment, cement and
other aggregates to be used would be developed through treatability studies
to be conducted prior to the remedial action.
Approximately six months would be required for contractor selection and
mobilization. The solidification/stabilization activities would have a
duration of approximately five months. The construction should be scheduled
to allow for vegetation to immediately follow final grading in the late
summer or early fall. The total time to implement this alternative would be
approximately 18 months.
The stabilized area should be inspected on a regular basis for signs of
erosion, settlement, or subsidence. It is recommended that inspections be
conducted frequently in the first 6 months when problems are most"*likely to
appear. Any signs of unexpected settling or subsidence should be addressed
immediately by removing the overburden and inspecting and repairing the
affected areas.
Groundwater monitoring would be required in conjunction with this
alternative. Monitoring would involve continued use of existing monitor
wells to determine whether contaminants are leaching or migrating from the
solidified mass or the capped area. For the first year, quarterly
monitoring will be required. After the first year, and depending on results
from the initial monitoring period, the monitoring period, the monitoring
will be limited to twice per year for 29 years.
Air monitoring during construction will be necessary to ensure that a safe
working environment is maintained and that no threat to the public health or
the environment is created by air emissions or dust from the site.
The following is a summary of the estimated costs associated with this
alternative:
Total Construction Cost $ 8,525,802
Present Worth O&M Cost 1.568.543
Total Present Worth Cost $10,094,345
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5.1 Alternative Comparison
Prior to selection of the preferred alternative all alternatives were
evaluated based on the following criteria:
- Overall protectiveness of human health and the environment
- Compliance with applicable or relevant and appropriate
requirements (ARAR's)
- Long-term effectiveness and permanence
- Reduction of toxicity, mobility, or volume
• Implementability
- Short-term effectiveness
- Cost
- State acceptance
- Community acceptance
A summary of this evaluation follows.
Long-term and short-term effectiveness and overall protectiveness of human
health and the environment.
Each of the alternatives evaluated, with the exception of no action,
provides for protection of human health and the environment by removing the
potential for exposure to contaminants at the site. Onsite incineration of
the contaminated material is the most protective alternative since the
contaminants are reduced to non-harmful compounds. Therefore, the long-term
effectiveness of this alternative is excellent. The shprt-term
effectiveness of the remedy is also good. However, some local impacts may
exist due to the start up of the equipment and operation. Slight risks may
be incurred by residents due to partially incinerated compounds. However,
risks associated with incinerators are considered to be less than a 10~°
level. Time for cleanup completion is 2.4 years and is the longest of the
alternatives.
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.Offsite disposal of the contaminated material at a RCRA approved facility
'reduces the potential for exposure of human and environmental receptors by
placement and isolation of the materials at a location that is known to be
safe for disposal and containment due to favorable geologic conditions and
strict adherence to best management practices. The short-term effectiveness
of this remedy is good since the remedy relies on established earth moving
techniques and duration of the cleanup is one year. Short-term risks due to
transporation of the wastes offsite are incurred. Under Alternative 2, the
most contaminated portion of the waste will be incinerated thereby
permanently rendering the waste non-hazardous. Since the remainder of the
contaminated material will be removed from the site, the alternative will
provide a high degree of long-term protection for the receptors at the
site. Alternative 7 (solidification/fixation) relies on a technology which
is unproven for long term containment of the type of organic wastes found at
the site. However, tests conducted on the short term effectiveness of the
technology in containing organic wastes have indicated that it can be
effective if applied properly. Unfortunately, the overall effectiveness of
this remedy to protect human health and the environment is currently
unknown. The alternatives that rely on onsite containment by way of capping
or encapsulation of the wastes (Alternatives 4, 5, 6) would isolate
contaminants into one area and reduce the potential for human exposure;
however, due to the potential for site flooding and the shallow groundwater
at the site the ability of the action to isolate the waste from the
environment is limited. Short term effectiveness may be good, however,
longer term effectiveness of these containment remedies would not~be
reliable.
k
5.1.1 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
Thermal treatment of contaminants uses heat under controlled conditions to
break down organic wastes into gases, water vapor, and ash. This technology
effectively reduces the mobility, toxicity, and volume of the contaminants
by destruction of the compounds. The ash from the process can be landfilled
as non-hazardous material. Waste gas emissions are trapped by control
devices before nhey can be released to the air. Effluent from the control
equipment may require further treatment before disposal. Alternative 3
relies on thermal treatment of all contaminated media at the site. Other
treatment alternatives use thermal destruction to destroy the heavily
contaminated tar-like waste material. Alternative 4 uses thermal treatment
of contaminated soil to eliminate the toxicity, mobility, and volume of the
waste. The offsite disposal alternative does destroy most contaminated
portion of the waste through thermal treatment but the majority of the soil
and sediment would be landfilled without treatment.
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If the solidication technology of Alternative 7 was successfully implemen]
the mobility of the waste would be greatly reduced since the contaminants
would be bound in a solid mass and thus eliminate the production of
leachate. In addition some of the contaminants may be chemically bonded to
the matrix and thereby reduce the toxicity. The volume of the contaminants
would be unchanged.
5.1.2 IMPLEMENTABILITY
The implementability .of all the alternatives were carefully evaluated during
the Feasibility Study (FS). The timeframes for implementation of each of
the alternatives are presented in Table 5-1. Alternatives 4, 5, and 6 rely
primarily on disposal practices that are well established and use common
earth moving and landfill equipment and materials, and are easily
implemented. Alternative 2 also uses earth moving technology to prepare the
contaminated material for offsite disposal. The additional step of
transporting the material to the final disposal site is required. On-site
thermal treatment is also established technology using commercially
available mobile incinerators. The implementation time for this action is
the longest of all the final alternatives. The success of the
solidification/fixation technology on organic compounds at the present time
is not presently proven. Long-term treatability tests would be necessary to
determine the effectiveness of the implementation of this alternative.
5.1.3 COST
A comparison of the estimated costs of the remedial alternatives are
included in Table 5-2.
5.1.4 COMPLIANCE WITH ARARs
A list of the State/ Federal, and Local ARARs that apply to the
-50-
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remedial action at this site are presented in Table 5-3. The various
remedial action alternatives would be performed to comply with these
requirements and necessary permits must be acquired before remedial action
activities begin. Some problems may exist in complying with the ARARs. For
example, for onsite landfilling activities in Alternatives 4, 5, 6, and 7,
FEMA and RCRA floodplain criterion may preclude landfilling on major
portions of the site. RCRA requirements and restrictions on landfilling
certain types of contaminants may require pretreatment of certain material
to reduce contaminant concentration prior to offsite disposal.
5.1.5 STATE ACCEPTANCE
Consultations with the State of Mississippi were held during the development
of the remedial alternatives and the proposed plan. Mississippi officals
stated a preference for the offsite disposal alternative. On-site
incineration was not supported due to the location of the site in the center
of Columbia/ the close proximity of many residents, and the potential for
operational problems with the mobile incinerator. Alternatives that
utilized on-site disposal were not favored due to the shallow groundwater
(10-15 ft) and the potential for flooding of the site.
Solidification/fixation of the contaminated material was not favored since
the effectiveness of the technology on organic wastes is unknown and may not
be protective.
5.1.6 COMMUNITY ACCEPTANCE
Discussion were held with the community leaders, elected officals, and
citizens of Columbia during the alternative selection process. During these
discussions a very strong preference was expressed fur a fexuedy that would
be completed quickly and permanently remove the contaminated material from
the site. Opposition was expressed for any alternative that would allow
untreated contaminants to remain on the site. Opposition to onsite
incineration was expressed due to fears over possible accidents and
incinerator emissions harming the nearby residents. The solidification
alternati/e was opposed since the technology is unproven. The preferred
alternative was to remove the contaminated material from the site and treat
-he waste as required for offsite disposal.
6.0 Recommended Alternative And Statutory Determination
Based on consideration of the requirements of CERCLA, the detailed
evaluation of the alternatives, and public comments, both EPA and the State
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TABL* 5-3
APPLICABLE OR RELEVANT AMD APPROPRIATE REQUIROKfTS TOR REMEDIAL ACTIOHS
REMSGH BROTHERS SITE
OOLUHBIA, MISSISSIPPI
Require
Applicable Criteria
federal
Toxic Subatancee Control Act (T3CA)
Occupational Safety and Health
Adaunistratlon (OSHA) (29 era 1910.120)
Resource Conservation and Recovery Act (RCRA)
and the Haaardoua and Solid Nbata AawjodMnta
of 19«4
KJ
I
Coavrehanaive Environmental Response and Liability
Act (CEBCLA) (19*0) and Superfund AnendBenta and
Reautboriiatlon Act (SARA) (19*6)
U.S. Dapartaant of Tranaportation and
Hiaaiaaippi Public Sorvic* Coamiaaioa Raqulationa
(40 cnt261, 45 PR1274), 45 rmJJISl. 45 FM5022,
45 PM690I, 45 PBI697J and 41 PR14153)
Podaral Nhtor Quality Criteria
Elapowara EPA to taha necaetary step* to Unit tha Banufactura, proc»s«lnq,
diatribution, uaa and dlspoaal of a chaaical •ubatanca that My pratant an
unraaaonabla riak or injury to health or to tha anvironaant.
Raqulataa aBplayaaa' aafaty and haalth at haiardoua waata oparatlona and
durin9 aawrgancy raaponaa to nasardoua subitaoca incidanta.
Rvgulataa tha treatawnt and diapoaal o( haaardoua waata in land treatment
unite (40 CTR Part 264).
Relevant and appropriate Cor:
- cap deaign and onaito landfill deaign for RCRA haiardoua waatea.
- ground water Monitoring and poat cloaure care for all alternatiwea
leaving waatea onaite.
- aolidificatlon/atabilisation technologiea with regard to
decharacterisation of haiardoua waatea.
- diapoaal of the hasardoua waatea at an offaite ROA landfill.
Applicable to tha •election of a reawdy aa well aa all other activities
aaaociated with the remedial inveatlgation and feasibility atudy. Require*
reaaaeaaaant of the aite every five yeara for reaedlea selected that retain
hasardoua waatea onalta.
Regulafea tranaportation of hacardoua Materials for diapoaal at
an offaite facility.
Seta criteria for water quality baaed on the kind and eitent of all
identifiable effects on health and welfare by pollutants in any body of water,
including ground water.
Applicable to wastawater discharges fro* dredging, dewataring, and
cfecont»ination activities, iBpleawntstion of s iea»dy for the ooaite ponds,
and gtound^ water atonitoring.
510/JS
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TABU S-3
(Continued)
Applicable Criteria
tn
Clean Air Act
State
Niaslsslppi Ambient Water Quality Criteria (MQC)
Mississippi Air Pollution Control Regulations
Mississippi Pollution Control Permit Board
Regulations on Landfills
Local
PDA Modulation* and BOA Ploodplalm Criterion
(44 cm farta St-77 and 40 en 2«4.1l(b)|
Relevant and appropriate (or preventing, abating, and controlling air
pollution caused by air contanlnante being discharged into the atanaphere s
partlculatea, snoke, fly ash, solvent, and other chemicala or coefcioetions
thereof.
Similar to Federal Mkter Quality Criteria (NQC). However, if Nlaslsslppl
Aabient MQC are acre stringent, they are selected over the Federal MQC.
Similar to Clean Air Act. However, if Mississippi Air Pollution Control
Regulations are nore stringent, they are selected over Clean Air Act
standards.
Relevant and appropriate for siting of landfill.
Relevant and appropriate for consideration of onsite landfill and
capping alternatives.
410/19
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of Mississippi have determined that alternative 2; offsite disposal of
contaminated soils and sediments with offsite incineration of waste
material, is the most approptiate remedy for the Newsom Brothers site in
Columbia, Mississippi. The action is completely described in Section 6.1.
The response objectives for this remedial action are to control exposure of
contact with soils, sediments, and waste material to an acceptable 10^
level. In determining an acceptable cleanup level, the ARARs of
environmental laws and the exposure levels calculated in the endangerment
assessment were reviewed and assessed.
Both Federal and State ARARs were reviewed to determine if there were any
standards indicating acceptable levels of contaminants in soils. The
results of this review indicate that no Federal or State legal standards
exist for the contaminants in soil or sediments at this site. Therefore,
soil and sediment cleanup levels were determined using site specific
analysis based on potential human health and environmental effects. The
cleanup levels for each media are presented in Section 4.0. The volumes of
materials to be excavated from the site are discussed in Section 6.1.
The potential ARARs and health based cleanup criteria were analyzed during
the RI/FS to determine volumes of soil and sediments to be excavated and
removed from the site. Because this alternative involves the excavation and
placement of hazardous substances (soil, sediments, and waste), the RCRA
land disposal restrictions could be potential ARARs. Pentachlorophenol,
toluene, and xylenes are known to occur on the site. Pentachlorophenol was
detected in the tar-like waste material present on the site. This materijd
is to be incinerated prior to land disposal. Xylenes and toluenes are
present on site in certain areas, however, these compounds may not be
present at concentrations that will require further cleanup. Future soil
and sediment screening will determine the levels that exist on the site. If
levels that require cleanup are detected, treatment of the material to
reduce concentrations of these contaminants may be necessary prior to land
disposal, in order to comply with land disposal restrictions. The PAHs
present on the site are not RCRA listed waste and land disposal restrictions
do not apply to this contaminant at the present time.
6.0.1 Statutory Determinations
Under its legal authorities, EPA's primary responsibility at Superfund sites
is to undertake remedial actions that achieve adequate protection of human
health and the environment. In addition, section 121 of CERCLA establishes
several other statutory requirements and preferences. These specify that
when complete, the selected remedial action for this site must comply with
applicable or relevant and appropriate environmental standards established
under Federal and State environmental laws unless a statutory waiver is
justified. The selected remedy also must be cost-effective and utilize
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permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. Finally, the
statute included a preference for remedies that employ treatment that
permanently and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following sections discuss
how the selected remedy meets these statuatory requirements:
6.0.2 Protection Of Human Health And The Environment
The selected remedy protects human health through destruction of the heavily
contaminated tar-like waste material by offsite thermal destruction and
deposition of the residual in a RCRA approved landfill. The remainder of
the contaminated soils and sediments will be isolated from environmental and
human contact by excavation and removal from the site and placement in a
RCRA approved secure landfill. Materials that pose a health risk in excess
of the 1 x 10"5 level will be removed from the site. There are no known
short-term threats associates with the remedy that cannot be readily
controlled.
6.0.3 Compliance With ARARs
The selected remedy will attain all applicable or relevant and appropriate
chemical, action and location specific requirement. The ARARs are presented
below:
For Transportation of Hazardous Wastes:
U.S. Department of Transportation
Mississippi Public Service Commission Regulation
(40 CFR 263, 45 FR 12743, 45 FR 33151, 45 FR 85022, 45 FR 86908
45 FR 86973, 48 FR 14153)
For Offsite Thermal Destruction:
Federal Clean Air Act
State Air Pollution Control Regulations
For Dwatering Ponds:
Federal and State Water Quality Criteria
National Pollution Discharge Elimination System (NPDES)
For Offsite Disposal:
Resource Conservation and Recovery Act
Hazardous and Solid waste Amendments
Land Disposal Restrictions
Waste Acceptance at the Treatment, Storage and Disposal Facility
CERCLA offsite disposal policy
Cleanup Criteria:
Toxic Substances Control Act
PCB Spill Policy
-55-
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6.0.4 Coat Effectiveness
The selected remedy is coat effective because it has been determined to
provide overall effectiveness proportional to its costs. The net present
worth is estimated at a cost of $14,180,000. The estimated cost are within
an order of magnitude of the other potential alternatives. The alternatives
that rely on onsite disposal are less expensive, however the site is not
suitable for onsite disposal due to shallow groundwater and potential for
surface water flooding. Therefore, onsite disposal does not offer a safe
remedy for containment of the wastes and is not cost effective. Onsite
incineration, which has similar but higher cost, would be a cost effective
remedy that destroys the hazardous constituents present on the site but
implementation would be difficult due to the uncertain!ty over the volume of
the material to be treated and the lack of acceptance of this alternative by
the State and community. Additionally the chosen alternative has the
potential for further reduction of costs through careful screening of the
various media prior to transportation of material to the disposal site.
This screening could significantly reduce the volumes of materials to be
removed from the site. The solidification/stabilization alternative is
innovative technology and is less expensive, however its effectiveness is
unproven for the type of wastes present at the site. Investment of funds
for use of this technology may prove to be ineffecient if the alternative
fails.
«*
6.0.5 Utilization Of Permanent Solutions And Alternative Treatment
Technologies To The Maximum Extent Practicable
EPA and the State of Mississippi have determined that the selected remedy
represents the maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost effective manner for final source
control at the Newsom Brothers site. Of those alternatives that are
protective of human health and the environment and comply with ARARs, EPA
and the State have determined that this selected remedy provides the best
balance of tradeoffs in terms of long-term effectiveness and permanence,
reduction in toxicity, mobility, or volume achieved through treatment, short.
term effectiveness, implementability cost, and State and community
acceptance.
While the selected remedy does not offer as high a degree of long term
effectiveness and permanence as the onsite incineration it will
significantly reduce the hazards posed by the contaminated soils at the site
through disposal at a secure containment facility with offsite incineration
of the heavily contaminated tar-like waste material. The remaining
contaminants can be managed with a high degree of certainity over the long
term. Since the State and community would not accept onsite incineration
and the effectiveness of other alternatives is questionable the selected
remedy is the only practicable alternative available. Offsite incineration
of the total volume of contaminated material was initially considered but
was not found to be cost effective because of the large volumes of materials
that potentially would be treated. The implementation time of the selected,
remedy is approximately six months compared to an estimated two and
-56-
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one-half years for onaite incineration.
The selection of incineration of the contaminated black tar-like waste
material is consistent with program expectations that indicated potentially
highly zoxic wastes are a priority for treatment and often necessary to
ensure long term effectiveness of a remedy. The less contaminated material
can be effectively contained in an approved facility. The only alternatives
offering treatment for all of the contaminated material is onsite
incineration. This remedy was rejected for the reasons discussed above.
The selected remedy can be implemented quickly and with less difficulty than
the other alternatives while offering a high degree of protection of human
health and the environment, is approved of by the State and local community,
and is therefore determined to be most appropriate for use at the Newsom
Brothers site.
6.1 Description Of Alternative
The recommended alternative, Alternative 2, for remediation of contamination
at the Newsom Brothers site includes the following components:
- Groundwater monitoring.
- Draining of onsite ponds.
- Excavation of contaminated pond and creek sediments
(estimated 7,309 cu. yards) for offsite
disposal at an approved facility.
- Filling of onsite ponds with clean fill material.
- Excavation of contaminated soils (estimated 30,302 cu. yards) for
offsite disposal at an approved facility.
- Excavation of remaining tar-like waste material (estimated 650 cu.
yards) for offsite thermal destruction and disposal at an
approved facility.
- Recontouring land surface to prevent erodable material from
reaching area surface water.
All components of the proposed remedy must be included in the remedial
action in order to reduce potential human health risks from the contaminants
at the site to the proposed 10~6 protection level. This protection level
was established as an added measure of protection due to the density of
residential housing adjacent to the site and due to the location of the site
near the central business district of Columbia, Mississippi.
Removal of all of the black tar-like waste material from the locations on
-57-
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the site, shown in Figure 6-1, is necessary due to the contaminant
the material. Since small amounts of this material are scattered across
site surface, a careful survey of the entire site will be necessary to
ensure that all of the material is located and removed. The underground and
surface drainage system must also be surveyed for this material. Due to the
high levels of organic substances present in samples of this material it
will be subjected to thermal destruction off site at a RCRA approved
facility. The residual material from the thermal treatment will be
landfilled at an offsite RCRA approved facility. The contaminated sediments
from the three onsite ponds and drainage areas must be removed from the
site. The sediments must be screened for the presence of contaminants in
excess of the cleanup standards listed in Section 4.0. The ponds and
sediments must be dewatered prior to the sediment removal. All water must
be analyzed before discharge to ensure water quality criteria are met and no
toxic substances are discharged in toxic amounts. Treatment of the
discharge water will be required if necessary. Since discharge will occur
onsite, no NPDES permit will be required. The primary contaminants
identified in the pond sediments are polyaromatic hydrocarbons (PAH's) at a
maximum concentration of 37.5 ppm in the East Pond, and Polychlorinated
biphenyls (PCBs) in the North Pond at a maximum concentration of 10 ppm.
Additional analytical results indicated that PCBs may be present up to 110
ppm in North Pond sediments . The contaminated soils are located in the
areas shown in Figure 6-1. Careful analytical screening of the soil in
these areas must be completed prior to removal of the contaminated soil for
offsite disposal at an approved facility. The screening will identify areas
that are contaminated above the cleanup criteria detailed in Table 4-5.
Following the excavation activities, the areas must be backfilled to
ponding of water. The site must be recontoured and seeded and mulched to
prevent the transport of erodable material to offsite areas and area
streams .
6 .2 Operation And Maintenance
A three to four-man crew will be required to conduct the excavation
activities. These personnel will ensure that the materials sent offsite
mt?t all requirements for shipment and disposal of hazardous substances .
The contractor is expected to maintain equipment and materials as needed to
conduct the excavation and packaging for offsite disposal. This includes
maintenance personnel, parts, materials, etc. Routine maintenance
activities to be conducted are:
* Periodic testing of personnel protective equipment and
monitoring devices
* Maintaining and repairing equipment
* Maintaining logs of data collected
-58-
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LEGEND
AREA NOT REQUIRING
FURTHER REMEDIATION
AREA REQUIRING
FURTHER REMEDIATION
AREA CODE NUMBER
REM II
SOIL REMEDIATION AREAS
NEWSOM BROTHERS SITE
COLUMBIA, MISSISSIPPI
FIGURE NO.
6-1
-59-
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* Coordination for proper replacement backfilling with clean soilj
* Dust control
Ambient air monitoring should be conducted during excavation activities.
The monitoring would be conducted at the site perimeter to ensure that
nearby resident were not exposed to hazardous vapors. In addition/
continuous monitoring would be conducted during excavation to provide
protection of onsite workers. Groundwater monitoring would be conducted at
selected wells for five years to ensure no groundwater contamination was
present at the site.
6.3 Cost
The summary of the estimated costs associated with the completion of the
remedy is presented in Table 6-1.
6.4 Schedule
Approximately four months would be required for excavation design,
contractor selection, and approval by the offsite disposal facility. This
alternative could be implemented rapidly after contractor selection, and the
complete remedial action should take less than six months. Groundwater
monitoring would be conducted for five years following the remedial actioil
6.5 Future Action
Since all contaminated media will be removed from the site future activities
will be limited to groundwater monitoring at existing monitoring wells. The
monitoring will continue for five years at selected wells.
7.0 Community Relations
The local community has been very interested and involved in the
site status during the RI/FS and removal actions related to this site.
Therefore, community relations activities have remained an important aspect ,
throughout the RI/FS process. A public meeting was held in Columbia,
Mississippi on August 6, 1986, to inform concerned citizens and receive
comments on the proposed RI/FS Work Plan. After completion of the first
phase of the RI another public meeting was held on September 22, 1987. The
purpose of this meeting was to discuss the findings of the RI, announce
plans of an immediate drum removal activity, and to solicit community input
for the removal activity. The meeting was attended by several hundred local
citizens and many comments were received on the drum removal proposal. Many
-60-
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TABLE 6-1
DETAILED COST ANALYSIS (PRESENT MGRTH COST)
OF PROPOSED REKDIAL ACTION AT DC
NEW» KOTOS SITE
ITEM DESCRIPTION
nOBILIZATION
Transport EquipMnt 1 Staff
TMporary Facilitits
LAND b SITE DEVELOPMENT - Soil and
Stdivnt
Sitt Preparation
Excavation b Oust Control
Backfill b Placing
Load b Off sitt Hauling
Pond Fill Rattrial
Pilling Ponds b Dust CQntrol
RECOVERY I DISCHARGE OF SURFACE tMTER
LAND b SITE DEVELOPMENT - Hazardous
Substancts
Sitt Prtparation
Excavation, Oust Control b Hauling
to Thtrtal Trtatunt Plant
Backfill b Placing
QFfSITE INCINERATION - Hazardous
Substancts
EBJIPffNT b MATERIALS
Health b Saftty EquipMnt
SAILING b TESTINB
AIR QUALITY nONITORINS
CONTRACTOR'S SUPERVISION
UNITS
M
ta
acrt
cy
cy
cy
cy
cy
lujp iua
acrt
cy
cy
cy
ta
day
Mtk
M
gUANTITY
1
1
6
37,611
37,611
37,611
33 216
33,216
1
0.5
650
650
650
1
100
20
1
UNIT PRICE
DOLLARS
MO, 000. 00
MO, 000. 00
(3,000.00
120.00
S12.50
1185.00
112.50
130.00
<100,000.00
<3.000.00
1200.00
112.50
1800.00
120,000.00
$700.00
11,000.00
5.01
SUBTOTAL - Capital Cost
LESAL FEES, LICENSES b PERMIT COSTS ( 21 of Capital Co*t )
ENSIFCERING b AONINISTRATIVE COSTS ( 101 of Capital Cost )
SUBTOTAL
CONTINGENCY ( 101 of Subtotal )
TOTAL CONSTRUCTION COST
PRESENT NORTH Obfl COST
TOTAL PRESENT WORTH COST
TOTAL COST
DOLLARS
MO, 000
MO, 000
118,000
1732,220
M70,138
fcb. 758,033
MIS, 200
$996,480
$100,000
$1,500
$130,000
$8,125
$520,000
$20,000
$70,000
$20,000
$527,985
$11,087,682
$221,754
$1,108,768
$12,418,204
$1,241,820
$13,660,025
$520,225
$14,180,249
A-2.MK1
-61-
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ITCT DESCRIrTIOH
-ORT TERM WNITORIN6
Personnel
Supplies
Quarterly Hell Sampling t Laboratory
Testing (20 wlls)
LONG TERH NONITQRINB
Personnel
Supplies
Semiannual Meli Sailing i Laboratory
Testing (20 wlls)
OBTOTAL
CONTINGENCY - Cost Based on 10Z of Subtotal
UNITS
, QUflMTITY
ffunits/yr)
«279,000
127,900
«06,900
NORTH
hr«
ea
ea
hrt
ea
ea
200
12
80
100
12
40
ISO
« 1,000
<2,000
ISO
» 1,000
«2,000
110,000
<12,000
» 160, 000
«s,ooo
» 12, 000
•80,000
1
1
1
4
4
4
«9,09:
*IO,90«
«143,4S
81S,S49
f 38, 036
8253,389
-62-
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informational meetings were held with local community leaders and elected
officials during the removal activity. In November 1988, EPA established an
Administrative Record for the Newsom Brothers site at the South Mississippi
Regional Library, in Columbia, Mississippi. By January 24, 1989, the RI,
draft PS, and final Bndangerment Assessment reports were submitted to the
repository in Columbia, Mississippi. A public meeting was held at Columbia
High School in January 24, 1989, to present the findings of the RI/FS,
Endangerment Assessment, and EPA's preferred remedial alternative. Public
comment on the proposed plan and study findings was solicited at this time.
Prior to the public meeting EPA had issued press releases, Public Notices,
Fact Sheets, and the Proposed Plan to keep the public informed of the
activities at the site. Following the January 24, 1989, public meeting a 30
day public comment period was opened and the comment period ended February
24, 1989. A discussion of the comments received is included in the
responsiveness summary in the Appendix.
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APPENDIX A
RESPONSIVENESS SUMMARY
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NEWSOM BROTHERS SITE
RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION PLAN
TABLE OF CONTENTS
Section I.
Section II.
Section III
Section IV.
Addendum
Overview
Background on Citizen
Involvement and Concerns
Summary of Major Comments Received
During the Public comment Period and
the EPA Responses to the Comments
A. Implementation of Remedy
B. Health Concerns
C. Off-Site Contamination
D. Miscellaneous
Remaining Concerns
Response to Reichold's Comments
Page
1
2
2-
4
4
5
5
6
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RESPONSIVENESS SUMMARY
NEWSOM BROTHERS SUPERFUND SITE
This community relations responsiveness summary is divided
into the following sections:
Section I
Section II
Section III
Section IV
Overview. This section discusses EPA's preferred
alternative for remedial action, and public
reaction to this alternative.
Background on Community Involvement and Concerns.
This section provides a brief history of community
interest and concerns raised* during remedial
planning activities at the Newsom Brothers site.
Summary of Mai or Comments Received Purina the
Public Comment Period and the EPA Responses to the
Comments. Both written and oral comments are
categorized by relevant topics. EPA responses to
these major comments are also provided.
Remaining Concerns. This section describes
remaining community concerns that EPA and the
State of Mississippi should be aware of in
conducting the remedial design and remedial action
at the Newsom Brothers site.
I.
OVERVIEW
The remedy proposed by EPA for the Newsom Brothers site was
total excavation and off-site removal of contaminated soil. The
State of Mississippi concurred with this proposed alternative.
The strong consensus from the community was also support for this
alternative. They did express concerns, however, regarding its
implementation, particularly in regard to dust control.
Questions were also raised regarding other potential sources of
contamination in the community and the health study currently
underway. Voluminous comments and questions were received from
Reichhold Chemical Company, a potentially responsible party.
Their comments focused on (to be provided by David Melgaard).
II. BACKGROUND ON CITIZEN INVOLVEMENT AND CONCERNS
This site started as a removal action in 1984. Because the
site is situated in the center of town, community interest in the
site has been strong. One community group, Stop Toxic On-site
Pollution (STOP) has taken the lead in expressing the concerns of
the community to EPA and the State of Mississippi. Community
-------
relations at the site was extensive, with EPA making many
contacts with local officials and scheduling several meetings
with citizens.
To get public input on the proposed remedy, EPA held a 30-
day public comment period from January 24 to February 24, 1989.
Jl?A's community relations efforts included a fact sheet that was
sent to interested citizens in January 1989, a public meeting
notice that appeared in the Hattiesburer American on January 22,
1989, and the Columbia Progress on January 19 and 22, 1989, and a
public meeting that was held January 24, 1989. Approximately 250
citizens attended the meeting. Site repositories contain the
RI/FS and other relevant documents. EPA also had many contacts
with local officials and citizens' groups throughout the remedy
selection process.
III. SUMMARY OF MAJOR COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND THE EPA RESPONSES TO THE COMMENTS
Concerns and questions on the proposed remedy for the Newsom
Brothers site received at the public meeting January 24, 1989 and
during the public comment period can be grouped into four
categories:
A. Implementation of Remedy
B. Health Concerns
C. Off-site Contamination
D. Miscellaneous
A summary of the comments and EPA's responses to them is provided
below.
A. IMPLEMENTATION OF REMEDY
Overall, citizens are pleased with the chosen remedy.
They have major concerns, however, about the dust that
may rise during clean-up activities.
EPA Response; The dust problem will be addressed in
the remedial design and common dust control measures,
such as sprinkling water or spreading dust suppresant
materials, will be taken to control the dust during
remedial action.
Many citizens had questions about the amount of soil
that will be removed.
-------
EPA Response; This issue will also be addressed during the
remedial design phase. According to reports from the
removal, digging may be 30-35 feet deep in some areas and
15-20 feet in others. Tests will be conducted and excava-
tion will continue as long as contamination is found.
citizens asked if the soil that is removed will be
replaced with new soil.
EPA Response; EPA does not want to lower any water
levels for areas that might be flood prone, so bringing
soil in to refill excavated areas will be considered.
Final site restoration is part of the proposed remedy.
Citizens questioned the safety of the fumes that may be
emitted during the excavation -
EPA Response: Fumes that are at any levels of concern
are not anticipated. During the removal operation, the
tests conducted did not indicate any large
concentrations of fumes of any concern.
One citizen asked why there were no plans for
evacuating area residents, as was done during the
removal.
EPA Response: Most of the material has already been
removed. There are no drums remaining that could
explode so the precaution is not necessary.
The STOP representative stated that the community would
like to see a safety plan in place before any remedial
activity begins at the site.
EPA Response; The health and safety plan is an
integral part of all remedial actions. Site security,
dust control, and vapor monitoring are all considered
during the feasibility study. Safety plans will be
included in all of the design documents, which will be
available to the public at the information
repositories.
Citizens were interested in acquiring someone to
perform independent oversight of the remedial
activities.
EPA Response; EPA offers Technical Assistance Grants
(TAGs) to communities that qualify to hire a consultant
to monitor the project. Information on TAGs is
available in the information repositories.
-------
B. HEALTH CONCERNS
Citizens questioned the methodologies being used for
the health study.
EPA Response; The Agency for Toxic Substances and
Disease Registry (ATSDR) is conducting, the health study
and is determining the methodologies.
• • One citizen asked if there was a correlation between
the chemicals at the site and the number of children in
the community who have been sick.
EPA Response; The health assessment being conducted by
ATSDR is currently underway and should be completed
within the next two months.
Several citizens said that their animals died after
being in contact with flood water that had run off the
site. Others stated that the crops growing in their
gardens are inedible. One citizen said that his
grandson has an incurable disease that his doctor
attributes to the contamination.
EPA Response; EPA must rely on what studies have shown
and the evaluation of the situation is that when the "'
cleanup is complete, the site will not pose a
significant health risk to anyone who lives near the
site. The Mississippi State Department of Health
offered to investigate the child's disease.
C. OFF-SITE CONTAMINATION
Many citizens expressed concern about contamination
they are aware of off-site. Citizens attested to drums
buried under construction sites and placed ir an old
garbage dump.
EPA Response; The State of Mississippi, Department of
Natural Resources, Bureau of Pollution Control has
stated that it will look at these sites to determine if
there are environmental problems. The off-site testing
that EPA has conducted to date show no indication of
chemicals off-site at levels of concern.
Several citizens asked if EPA had tested areas around
the site for contamination.
-------
EPA Response: EPA has performed tests on the soil. No
contaminated soil has been detected in the off-site
areas adjacent to the site.
One citizen has drums behind her house which, she says,
EPA promised to remove but never has.
EPA Response; EPA will look into the problem.
D. MISCELLANEOUS
Citizens asked for a commitment from EPA that the site
will be restored to what the citizens consider to be a
livable environment; they want every piece of
contamination removed.
EPA Response: EPA is committed to making the site area
livable which is done by reducing the contamination to
a level that is acceptable for both environmental and
public health concerns.
Citizens expressed concern over the amount of input the
potentially responsible party (PRP) will have regarding
clean-up activities.
EPA Response: By law, the PRPs must have the
opportunity to participate in the cleanup. •*
IV. REMAINING CONCERNS
Local residents expressed several remaining concerns in
regard to remedial operations at the Newsom site. They remain
concerned about the dust that will rise during the clean-up,
about off-site contamination, and about the results of the ATSOR
health study. EPA will continue to coordinate with the other
agencies involved and to get site information to the citizens.
-------
Addendum
Responses to Reichhold's Comments Submitted
On the RI/FS and Proposed Plan
Malcolm Pirnie, Inc. and ENVIRON Corporation were asked to
review the Endangerment Assessment (EA) conducted by ICF-Clement
Associates and a Feasibility Study conducted by Camp Dresser and
McKee, and submit public comments on behalf of Reichhold Chemicals,
Inc. (Reichhold) which has been identified as a potentially
responsible party at the site.
The PRP's. concerns over USEPA's proposed remedial action for
the site are summarized and EPA's responses follow.
[1]
COMMENT - The Remedial Investigation for the Site does not provide
compelling or in many cases any evidence of chemical contamination
in the areas that are targeted for excavation in the USEPA remedy.
RESPONSE - Several areas listed as requiring soil remediation are
areas that contained buried drums and/or chemicals. These areas
were excavated and the contaminated material and drums were removed
and transported offsite for disposal during the 1987-1988 removal
activity. Soil that was not obviously contaminated yet surrounded
the excavated contaminated material was returned to the burial
areas after these burial areas were lined with plastic. Through
association with the contaminated drums and/or chemicals the soil
may also have become contaminated. The limited sampling conducted
during the remedial investigation did not detect the presence of
materials contaminated in excess of cleanup standards in some of
the burial areas. A complete screening of the soils in these areas
will be necessary to determine the total amount of contaminated
materials that will have to be remediated.
[2]
COMMENT - As documented in the Endangerment Assessment (EA) for the
site, the average levels of chemicals of concern in soils and
sediments do not pose significant health risks, even if lifetime
human exposure is postulated. In fact, the average risks claimed
in the EA are overstated.
RESPONSE - In order to ensure a high level of protection, the
Endangerment Assessment (EA) used conservative current and future
use scenarios to assess the potential threat to human health and
the environment posed by the site if no cleanup occurred. Both
average and maximum exposure scenarios were considered in the
establishment of cleanup standards. The EA utilized the most
accurate and current information available to establish the risks
-------
levels for the chemicals that were detected in the contaminated
media at the site.
[3]
COMMENT - USEPA's proposed soil cleanup goal for carcinogenic
polynuclear aromatic hydrocarbons (cPAHs) is roughly equivalent to
the amount of cPAH's .consumed by someone eating an 8 oz. charcoal
broiled steak every two years for a lifetime. This is a prospect
that few people would consider excessively risky.
RESPONSE - The soil cleanup levels for carcinogenic PAH'a have
been reassessed based on available literature on normal background
concentrations present in the region and known health effects of
the compounds. Urban background levels range from zero to 22 ppm.
The cleanup criteria has been revised to an action level of 10 ppm
in soil. This number is based concentrations known to occur
naturally in urban areas and the health based cleanup criteria for
average exposure scenarios established in the EA to provide
protection to the 10"& level.
[4]
COMMENT - Cleanup levels estimated for the site are inappropriately
stringent/ in that they are based upon exposure scenarios thatr-are
unrealistic. Use of more realistic/ yet still conservative/
exposure scenarios would have yielded substantially higher cleanup
targets/ even if the residual risk level is kept as low as 10-6
(i.e., a one-in-a-million chance of developing cancer through
lifetime exposure at the site.)
RESPONSE - The cleanup levels are based on scenarios that are
considered by EPA to be realistic and appropriate for the area
under study.
[5]
COMMENT - The USEPA remedy incurs but does not evaluate risks of
transportation related fatalities that are substantial relative to
the health risks estimated in the Bndangerment Assessment for
lifetime exposure at the site. While excavation and off-site
transportation of some material may be cost-justified/ the amount
of material to be moved off-site should be limited to the extent
feasible given the transportation risk.
RESPONSE - EPA does realize the risks associated with highway
transportation. We will implement stringent safety requirements
for offsite transport of material. These safety requirements will
-------
be implemented to protect citizens from highway incurred dangers
during transport and eliminate the potential exposure to
contaminated material from the site by thorough decontamination and
inspection procedures. These safety requirements will be included
in the health and safety plan for the site and will become an
integral part of the cleanup operation. To further ensure the
safety of the citizens of the area, transportation routes and
safety procedures will be coordinated closely with City of Columbia
and Marion-County officials, as well as state Departments of
Transportation.
[6]
COMMENT - The USEPA remedy is inconsistent with the intent of
Congress as expressed in the Superfund Amendments and
Reauthorization Act of 1986. Remedies that offered permanent
solutions were clearly favored and Congress clearly indicated its
desire to minimize movement of waste material to different landfill
sites around the United States.
RESPONSE - This remedy will utilize permanent solutions to the
maximum extent practical for this site. The remedy calls for
offsite thermal destruction and disposal of the most heavily
contaminated portion of the material. The remainder of the
material will be transported to an approved secure landfill that is
permitted to receive material that is within the 10~4 to 1O~°
risk range for permanent disposal. Some additional pretreatment
may be necessary prior to disposal of the waste.
[7]
COMMENT - Remedies are available and feasible for this site that
utilize on-site permanent solutions such as bioremediation, and
limit the amount of soil sent off-site to material which is not
amenable to on-site treatment. Such an approach reduces
transportation risks and provides lower exposure and risk for
citizens of the communities involved.
The Feasibility Study (PS) has eliminated technologies during the
screening process which should have been retained. Furthermore, in
developing remedial actions, the FS has inappropriately evaluated
them against the nine criteria identified in the USEPA guidance on
conducting Feasibility Studies.
RESPONSE - Section 5.0 of the ROD lists the various technologies
that were considered for use at this site. The entire list of
technologies was carefully evaluated based on the criteria listed
in the Feasibility Study (FS). The method used to screen the
8
-------
various alternatives closely follows EPA guidance. The complete
method used to screen the various technologies is presented in the
?S. Bioremediation was eliminated from consideration for use due
to the unproven ability of the technology to reduce the targeted
compound to cleanup levels. Encapsulation/ vegetative cover, and
capping received a thorough consideration for use at the site.
Section 5.0 of the ROD evaluates these alternatives. A full
discussion of technologies considered is included in the PS and
further discussions of the alternative selection process are in the"*
ROD. •
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