&EPA
              United States
              Environmental Protection
              Agency
              Solid and Hazardous Waste
              Research Division MERL
              Cincinatti, Ohio 45268
Oil and Special Materials
Control Division WH 548
Washington, D.C. 20460
EPA 430/9-81-05 SW-910
              Water and Waste Management
                             January 1981
Remedial  Actions
at Hazardous Waste Sites:
Survey and Case Studies
 \



                         to
                                          t


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           REMEDIAL ACTIONS AT HAZARDOUS WASTE SITES

                    Survey and Case Studies
                               By

          N. Neelyf D. Gillespier F. Schauf, J. Walsh
                         SCS Engineers
                      Covington, Kentucky


This final report EPA-430-9-81-005 describes work performed for
      the Municipal Environmental Research Division of the
       U.S. EPA Office of Research and Development under
                    Contract No. 68-01-4885
       and is reproduced as received from the contractor


           D. Banning and S. James, Project Officers
          Solid and Hazardous Waste Research Division
          Municipal Environmental Research Laboratory
                   Cincinnati, Ohio    45268


  Published by the Oil and Special Materials Control Division
              U.S. Environmental Protection Agency
                   Washington, D.C.    20460


                         January, 1981

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                          DISCLAIMER
     This report has been reviewed by the Municipal  Environmental
Research Laboratory, U.S. Environmental  Protection Agency, and
approved for publication.  Approval  does not signify that the
contents necessarily reflect the views and policies  of the U.S.
Environmental Protection Agency, nor does mention of trade
names or commercial  products constitute  endorsement  or
recommendation for use.
                                ii

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                            FOREWORD
     The U.S.  Environmental  Protection  Agency  was  created
because of increasing public and government  concern  about  the
dangers of pollution to the  health  and  welfare of  the  American
people.  Noxious air, foul water, and spoiled  land are tragic
testimonies to the determioration of our natural environment.
The complexity of that environment  and  the  interplay of its
components require a concentrated and integrated attack on the
problem.

     Research  and development is that necessary first  step in
problem solution; it involves defining  the  problem,  measuring
its impact, and searching for solutions.  The  Municipal
Environmental  Research Laboratory develops  new and impoved
technology and systems to prevent,  treat, and  manage wastewater
and solid and  hazardous waste pollutant discharges from
municipal and  community sources, to preserve and  treat public
drinking water supplies, and to minimize the adverse economic,
social, health, and aesthetic effects of pollution.  This
publication is one of the products  of that  research  and provides
a most vital  communications  link between the researcher and the
user community.

     With the  passage of Superfund  legislation providing for the
clean-up of environmental hazards at uncontrolled  waste disposal
sites, information is needed on the types of remedial  actions
that have been implemented  to date, as  well  as their effective-
ness and cost.  This report  provides this information  by presenting
the results of a nationwide  survey of 169 such remedial action
sites.  More specific information on nine of these sites is
provided in the form of detailed case studies, also  contained
herein.
                                Francis T. Mayo, Director
                                Municipal  Environmental  Research
                                Laboratory
                               111

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                            ABSTRACT
     During the Summer of 1980,  a  nationwide  survey  was  conducted
to determine the status of remedial  actions  applied  at  uncontrolled
hazardous waste disposal  sites.   Over 130 individuals were
contacted to obtain information  on such  remedial  action  projects.
A total of 169 sites were subsequently identified as having
been subject to corrective measures.

     Remedial  actions were found to  have been implemented  at
many kinds of hazardous waste disposal facilities including
drum storage areas, incinerators,  and injection  wells,  but
most frequently landfill/dumps and surface impoundments.   At
the sites receiving such  remedial  actions, ground water  was
found to be the most commonly affected media, followed  closely
by surface water.

     Although several types of remedial  measures  were  identified,
remedial activities usually consisted of containment and/or
removal of the hazardous  wastes.  Sufficient  money was  often
not available for  complete environmental cleanup  (e.g.,
extraction and treatment).  The  survey determined that  a
lack of sufficient funds  and/or  selection of  improper techno-
logies was responsible for remedial  actions  having been  applied
effectively at only a portion of the uncontrolled hazardous
waste disposal sites.  Where they  had been applied,  remedial
actions were found to be  completely  effective only 16  percent
of the time.

     Nine sites were studied in  detail to document typical
pollution problems and remedial  actions  at uncontrolled
hazardous waste disposal  sites.   Of  these nine sites,  remedial
actions were completely effective  at two and  only partially
effective at the other seven.  Technologies  employed at  these
nine sites included (1) containment, (2) removal  of waste  for
incineration or secure burial, (3) institution of surface
water controls, and (4) institution  of ground water controls.

     The work upon which  this report is  based was performed
pursuant to Contract No.  68-01-4885, Directive of Work  No.  13,
with the U.S.  Environmental Protection Agency.  Work was
performed between  April and October  1980.
                               iv

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                             CONTENTS
Foreword	  i i i
Abstract	   iy
Figures	v i i i
Tables	    x

   1.   Summary	    1
         Introduction	    1
         Project Description	    2
         Survey Findings	    3
         Case Study Findings	    7
         Conclusions	    7
         Summary References and Bibliography	   10
         Appendix 1-1,  Remedial Action Hazardous  Waste
           Sites by State	   11
   2.   Site A, Olin Corporation,  Saltville,  Virginia	   21
         Introduction	   21
         Site Description	   21
         Site Operation and History	   26
         Pol lution	'.	   28
         Remedial Action	   33
         Concl usi on	   40
         Site A References  and  Bibliography	   42
         Appendix 2-1,  Site A  Photographs	   43
   3.   Site B, .Firestone  Tire  and Rubber Company,
           Pottstown, Pennsylvania	   47
         Introduction	   47
         Site Description	   47
         Site Operation and History	   48
         Pollution	   53
         Remedial Action	   54
         Conclusion	   55
         Site B References  and  Bibliography	   59
         Appendix 3-1,  Site B  Photography*	   60
   4.   Site C, Anonymous  Waste  Disposal  Company Dump Site,
           East-Central,  New York	   65
         Introduction	   65
         Site Description	   65
         Site Operation and History	   70
         Poll ution	   74
         Remedial Action	   75
         Conclusion	   83
         Site C References  and  Bibliography	   85
         Appendix 4-1,  Waste Disposal Company Sampling
           (1975-1979)  for  Site C	   86
         Appendix 4-2,  Site C  Photographs	   91

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CONTENTS (Continued)
   5.   Site D,  Destructo/Carolawn,  Kernersvi11e
           North  Carolina	   95
         Introduction	   95
         Site  Description	   96
         Site  Operation  and  History	   99
         Pollution	  100
         Remedial  Action	  104
         Conclusion	  109
         Site  D  References and  Bibliography	  Ill
         Appendix  5-1, Site  D  Newspaper  Articles	  112
         Appendix  5-2, Site  D  Photographs	  116
   6.   Site E, Whitmoyer Laboratories, Myerstown,
           Pennsylvania	  121
         Introduction	  121
         Site  Description	  121
         Site  Operation  and  History	  125
         Pollution  and Remedial  Action	  127
         Conclusion	  135
         Site  E  References and  Bibliography	  137
         Appendix  6-1, Site  E  Photographs	  138
   7.   Site F, Western Sand  and  Gravel,  Burrillville,
           Rhode  Island	  141
         Introduction	  141
         Site  Description	  141
         Site  Operation  and  History	  147
         Pol 1 uti on	  148
         Remedial  Action	  154
         Conclusion	  154
         Site  F  References and  Bibliography	  157
         Appendix  7-1, Multi-Probe  Well  Installation
           Details  for Site  F	  158
         Appendix  7-2, Site  F  Photographs	  162
   8.   Site G,  Ferguson  Property,  Rock Hill,  South  Carolina..  166
         Introduction	  166
         Site  Description	  166
         Site  Operation  and  History	  167
         Pollution	  169
         Remedial  Action	  171
         Conclusion	  176
         Site  G  References and  Bibliography	  177
         Appendix  8-1, Site  G  Photography	  178

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CONTENTS (Continued)
   9.   Site H,  3M Company,  Woodbury,  Minnesota	 182
         Introduction	 182
         Site Description	 182
         Site Operation and History	 186
         Pollution	 188
         Remedial Action	 190
         Conclusion	 197
         Site F References  and Bibliography	 198
         Appendix 9-1,  Site F Photographs	 199
  10.   Site I,  Whitehouse/Allied Petroleum,
           Jacksonville, Florida	 202
         Introduction	 202
         Site Description	 202
         Site History and Pollution	 203
         Remedial Action	 208
         Mo ni to ring	 215
         Conclusion	 222
         Site I References  and Bibliography	 224
         Appendix 10-1, Well Log for Site  1	 225
         Appendix 10-2, Site I Photographs	 227
                                 vii

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                             FIGURES
Number                                                        Page

 2-1      Aerial  Photograph  of 01 i n  Chemical  Complex	   22
 2-2      Site Layout  of Olin  Chemical  Complex	   23
 2-3      Generalized  Geologic Cross  Section	   25
 2-4      Upper Holston River  Watershed	   25
 2-5      Location  of  Former River  Bed  through  Waste
           Ponds 5 and 6	   27
 2-6      Process Flow Diagram for  Olin Alkali  Plant	   29
 2-7      Soda-Alkali  Production at  Olin Saltville Plant	   30
 2-8      Chlorine-Caustic  Production at Olin  Saltville  Plant..   30
 2-9      Erosion Control Measures  at Chlorine  Plant  Site	   35
 2-10    Construction Details for  Sealing North  Fork
           Riverbank	   36
 2-11    Mean Mercury Content of the Sediment  at the
           Control  and Affected Stations on  the  Holston
           River July 1978  and July  1979	   38
 2-12    Mean Mercury Content of the Fish at  the Control
           and Affected Stations On  the Holston  River
           July  1978  and July 1979	   39
 3-1      Partial Map  of the Firestone  Plant  Showing  Some
           Wells and  Pits  Used for  Remedial  Action	   49
 3-2      Location  Map of Firestone  Plant with  Remedial
           Action  Wells	   50
 3-3      Rough Geologic Cross Section  of the  Material
           Underlying the  Firestone  Plant	   51
 3-4      Location  and Partial Geologic Map for Firestone's
           Pottstown, Pennsylvania  Plant	   52
 3-5      Sulfate Concentration in  the  Ground  Water Before
           and After  the Use  of the  Recovery  Wells	   56
 3-6      Five Day  BOD in the  Ground  Water Before and After
           Use of  the Recovery Wells	   56
 3-7      Chlorine  Concentration in  the Ground  Water  Before
           and After  Use of the Recovery Wells	   57
 4-1      Site C  Location Map	   66
 4-2      Site Environs (1966  Before  Closure)	   67
 4-3      Facility  Layout in 1968 Before Closure	   69
 4-4      Generalized  Geologic Cross  Section  of Site  C in  1980.   71
 5-1      Site Layout  of Destructo/Carolawn,  Kernersvi11e,
           South Carolina	   97
 5-2      Drainage  Pattern  of  Destructo/Carolawn  Site	   98
 5-3      Tank Location and  Flow Direction of 1977 Spill
           at Destructo/Chemway	  102
                               VI 1 1

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FIGURES (Continued)


Number                                                        Page

 6-1      Location of Whitmoyer Laboratories	  122
 6-2      Detailed Site Location for  Whitmoyer  Laboratories....  124
 6-3      Ground Water Contour Map  of Whitmoyer Laboratories...  124
 6-4      Generalized Geologic Cross  Section  Drawn
           Perpendicular to  the Strike  Direction	  126
 6-5      Location of Wells  on the  Whitmoyer  Lab Property	  129
 6-6      Location of Sampling Stations  Established  by  the
           U.S. Army Corps  of Engineers	  134
 6-7      Arsenic Content at  Station  2 at  Whitmoyer  Labs	  134
 6-8      Cumulative  Graph of Arsenic Removed from  the
           Ground Water at  the Plant Site	  136
 7-1      Location of Western Sand  and Gravel  Site.	  142
 7-2      Site Environs and  Monitoring Well  Locations	  144
 7-3      Well and Pit Location Map	  145
 8-1      Location of Ferguson Site in Rock  Hill,
           South Carolina	  168
 8-2      Location of Drums  on Ferguson  Property	  172
 8-3      Site Layout After  Remedial  Action  at  the
           Ferguson  Property	  174
 9-1      Location of 3M Disposal  Site in  Woodbury,  Minnesota..  183
 9-2      Geological  Cross Section  of Area Beneath
           Woodbury  Disposal Site	  185
 9-3      Configuration of Waste Disposal  Pits  at
           3M Woodbury Site	  187
 9-4      Location of Contaminated  Schussler  Well
           and Barrier Wells	  189
 9-5      Sum of the  Concentration  of Isopropyl Either,
           Isopropanol, and  Dichloromethane  for Shall
           Well at Schussler Residence	  191
 9-6      Graphs of Isopropanol Ether Measurements
           for Barrier Well  Nos.  1 to 4	  195
10-1      Location of Whitehouse/Allied Petroleum Site	  204
10-2      Layout of Whitehouse Oil  Pits	  205
10-3      Layout of Whitehouse Oil  Pits and  Diversion  Ditches..  206
10-4      Carbon Adsorption  Treatment Plant  for PCB's	  212
10-5      Pit Profile After  Stabilization	  214
                                 i x

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                               TABLES
 Number                                                        Page

 1-1       Facility Type at Remedial  Action  Sites	    4
 1-2       Location of Remedial  Action  Sites	    5
 1-3       Affected Media at 169 Remedial  Action  Sites	    6
 1-4       Funding Sources  at 169 Remedial  Action  Sites	   6
 1-5       Pollution and Remedial  Action  Status  at 169  Sites....    7
 1-6       Case Study Site  Identification	    8
 1-7       Case Study Site  Background	   8
 4-1       Waste Disposal Company Sampling  (1966)	   76
 5-1       Storage of Waste Materials at  Destructo
            Chemway Corporation	  101
 5-2       Carolawn's Inventory  as of July  31,  1978	  105
 5-3       Bioassay Studies	  108
 6-1       Initial Arsenic  Concentrations from  Plant Wells	  130
 7-1       Pit Dimensions and Volumes	  146
 7-2       Summary of Field Permeability  Testing  Results	150
 7-3       Analytical Results for Pit Sampling  on  2/27/80	  151
 7-4       Analytical Results for Well  and  Stream  Sampling
            on February 7, 1980	  152
 7-5       Analytical Results for Well  Sampling  on May  1, 1980..  153
 7-6       Estimated Remedial Action  Costs	  155
 8-1       U.S. Environmental Protection  Agency  Drum
            and Soil Analysis	  170
 8-2       Cost of Containment Remedial  Measures  at
            Ferguson Property	  175
 9-1       Horsepower and Discharge of Barrier  Wells	  194
 9-2       3M Woodbury Wells Priority Pollutant
            Sampling Results	  194
10-1       Partial Remedial Action Costs  for First Phase	  216
10-2       Projected Remedial Action  Costs  for  Second Phase	  216
10-3       Depth of Monitoring and Private  Wells	  217
10-4       Water Quality in Wells	  218
10-5       Initial PCB Analysis  of Sludge Samples	  220
10-6       Quantitative Analysis of Oil  Sludge	  220
10-7       Analyses of Treatment System Removal  Efficiencies	  221

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                           SECTION  1

                            SUMMARY

INTRODUCTION

     Proper disposal and transport of hazardous substances is a
major concern of the U.S.  Environmental Protection Agency (EPA).
Past management of hazardous residues has generally been inade-
quate and unsound disposal practices have created adverse public
health and safety impacts.  It has been estimated that 90 percent
of all hazardous waste has been disposed of in an unsound manner.
Facilities comprising this 90 percent include surface impoundments
(48 percent), landfills  (30 percent), incinerators (10 percent),
and other practices  (2 percent).   [1-1]

     The two laws which  provide federal assistance for remedial
.actions at uncontrolled  hazardous  waste sites are the Clean
Water Act (CWA) and  the  Resource Conservation and Recovery Act
(RCRA).  Under Section 311 of CWA, a special contingency  fund
is available for emergency remedial action at sites where the
release of oil or hazardous materials threatens navigable waters.
However, land spills that  do not directly threaten surface
water are not covered under Section 311.

     RCRA dictates the manner in which  hazardous  material may
be transported, stored,  treated, and disposed.  The regulatory
thrust of RCRA is currently being  placed on  identification of
abandoned waste sites and  abatement of  pollution  at such  sites.
Section 7003 of RCRA authorizes  EPA to  bring suit against
legally responsible  parties to  remedy  conditions  at sites that
present "imminent and substantial  endangerment to health  or
the environment".

     The authorities under CWA  and RCRA enable EPA to  (1) supply
limited assistance  for enforcement related  investigations
 (e.g7, chemical analysis,  site  investigation,  technical  assis-
tance); (2)  take emergency remedial action  where  navigable
waters are  threatened; and (3)  take legal  action  in cases where
sites  pose  an  imminent hazard.   However, remedial actions at
sites  where  navigable waters  are  not  threatened  can only  be
initiated and  funded by  states,  local  governments, and
 responsible  parties. Usually  in  cases  where  Section  311  funds
are not used,  extensive  time  is  involved in  identifying  the
problem,  the  responsible party,  and the remedial  measure  which
 is  likely to  be  successful.   Even  more time is often  required
 in  getting  the  responsible party  to clean  up  such sites,  either
 voluntarily  or  through court  action.   The  Comprehensive  Environ-
 mental Response, Compensation and Liability Act  (Superfund) was
 passed and  signed into law in December 1980 in  order to better
 address these problems.

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PROJECT DESCRIPTION

     In an effort to determine the type and effectiveness of
past remedial actions at uncontrolled sites, a nationwide
survey of on-going and completed remedial  action projects was
conducted from May to October 1980.  The purpose of the survey
was to provide information and examples of applied remedial
action technologies.  Examples provided in the form of case
histories identify typical problems, effectiveness, and costs
related to implementing remedial action at such facilities.

     During the initial  phase of the survey, a list was compiled
of disposal sites where remedial actions had been or were being
implemented.  Remedial action sites were identified based upon
file and literature review and face-to-face discussions with
federal and state personnel.  The intent was to compile a list
of remedial action sites which (1) represented different remedial
action technologies; (2) were located in diverse geographical,
geological, and climatological regions; and (3) were fairly
effective in resolving the environmental hazard.

     In identifying remedial action sites, emphasis was placed
upon landfills, surface impoundments, drum storages, incinerators,
and deep well injection facilities.  If federal or state
personnel  identified a spill, that site was listed.  However,
spill  sites were not usually sought during the survey, since
much of this data is reported yearly in the proceedings from
the National Conference on Control of Hazardous Materials
Spills.

     For the purposes of this survey, a waste burial site was
designated as a "landfill" if it was permitted to receive
such waste.  It was designated a "dump" if it had not been
legally permitted.  Midnight dumping, roadside dumping, etc.,
were cited as "dumps", as well as land disposal sites located
on company property which had not been officially permitted.
Surface impoundments included pits, ponds, and lagoons used
for the storage, treatment, or disposal of wastewater or sludge.
Injection wells included subsurface disposal wells and for
purposes of the survey included such sites as old mine shafts.
Incinerators included facilities which dispose of wastes by
burning.  Spills included events such as liquid disposal into
sewers, pipeline spills, railway spills, and other transpor-
tation associated spills.

     After remedial action sites were identified, the sites
were prioritized to determine candidate sites on which detailed
case history investigations would be conducted.  Factors consi-
dered  in prioritizing these sites included consideration of
(1) legal  actions which would hamper in-depth investigation;
(2) the extent and nature of the environmental problem associated

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with the site; (3) the nature and  effectiveness  of  the applied
remedial action; and (4)  the availability  of  background  data.
Subsequently, after the top case history candidates were
selected, telephone contacts were  made  with  site owners/operators
to verify information and to request  permission  to  visit  the
site.  Permission for a site visit was  given  for nine of  the
19 sites for which permission was  requested.

SURVEY FINDINGS

     Initially 199 sites  were identified as  having  some  form  of
remedial action.  Thirty  of these  sites were  later  deleted  from
the list due to (1) lack  of sufficient  information,  (2)  insuf-
ficient progress on planned remedial  action,  and/or (3)  the use
of "low-technology" remedial actions.   "Low-technology"  actions
were defined to include measures such  as  (1)  merely filling a
lagoon with native soil without instituting  surface or  ground
water controls, (2) discontinuing  waste receipts at a landfill
without attempting to properly close  the  facility,  or  (3) clear-
ing a drum storage facility without regard to existing  soil
or water contamination.

     As summarized in Appendix 1-1 to  this report,  remedial
measures identified included a variety  of  technologies  such as
containment on-site, chemical treatment (neutralization  of
acids and bases, precipitation, etc.),  biological treatment
(land spreading, oxidation ponds,  and  underground enhancement
of native microbes using  fertilizer),  incineration, and
removal and burial in a secure landfill.

     The survey indicated that remedial measures usually
consisted of containment and/or removal of the hazardous waste.
Containment was often approved based  upon  cost and  the  concept
that it is better to deal with the problem in-place rather than
relocate the problem to another locality.   Cost was often the
prime determinant of the  type of technology applied.   As a
result, the primary remedial goal  has  been prevention  of
further contamination of the environment  rather than complete
cleanup.  Complete environmental cleanup  can require millions
of dollars, sophisticated technologies, and long periods of
time.

     When hazardous material was contained in its original
location, surface water controls were generally constructed
(e.g., grading, diversion ditches, revegetation, surface
sealing, etc.).  In most instances where  the ground water was
contaminated, a major portion of the  waste was removed  and sent
to a secure landfill or incinerated and surface water  controls
were constructed to secure the remaining  contaminants.   Imple-
mentation of controls for ground water cleanup is typically
more expensive and time-consuming than implementation  of surface

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water controls.  Accordingly, ground water remedial  measures
were implemented at only a few sites.   Ground water  pumping
was the most often applied ground water control  at disposal
sites while a remedial measure such as a bentonite slurry
trench or steel cutoff wall  was found  at some spill  sites.

     Tables 1-1 through 1-5 were compiled based  on information
gathered during the survey.   Over 130  individuals were contacted
to compile the data.  Some of the factors which  should be
considered in reviewing the data presented in the following
tables include:  (1) data was based solely upon  the  immediate
survey findings, as reported by individuals contacted;
(2) a potential threat was not included in the analysis;  and
(3) probable (but undocumented) contamination was taken as
a positive finding.

     Table 1-1 was compiled to indicate the types of disposal
facilities which experienced remedial  actions.  It should be
noted that the total number of facilities in Table 1-1 (204)
does not coincide with the number of identified  sites (169).
The higher number is the result of different types of facilities
being located on the same property.  For example, a  landfill,
drum storage, surface impoundment, and/or incinerator could all
be located at one site.  More surface  impoundments and landfills
were identified as experiencing remedial action  than other  types
of disposal facilities.  This would be anticipated since
surface impoundments and landfills are the most  used types  of
di sposal .


     TABLE 1-1.  FACILITY TYPE AT REMEDIAL ACTION SITES
Number of Facilities
Status
Facility Type
Landfill
Dump
Drum Storage
Surface Impoundment
Injection Well
Incinerator
Spill
Total
Active
16
0
11
18
1
1
0

Inactive
37
27
25
37
3
5
23

Total
Number
S3
27
36
55
4
6
23
204
     Table 1-2 was compiled to determine the geographical
location of sites which had undergone remedial  action.   During
conversations with federal  officials, it became apparent that
many factors affect the geographical  distribution.   For example,
industrial waste disposal  sites would typically predominate
in those states which have more industry.   The  possibility of
a larger number of uncontrolled sites needing remedial  measures
would increase with an increase in the number of industrial
disposal sites.  However,  the presence of more  uncontrolled

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sites needing remedial  measures  did  not  necessarily  mean
remedial  measures  were  being applied.
          TABLE 1-2.   LOCATION OF REMEDIAL  ACTION SITES
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
HI nnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin.
Wyoming
Total SO States
Number of
Sites
2
0
3
2
3
3
4
2
7
4
0
0
8
3
1
2
5
3
2
1
5
11
3
0
4
5
0
0
1
10
0
14
7
6
4
0
0
16
4
3
0
10
3
1
0
2
0
1
3
1
169
      Institution of  remedial measures was  dependent  upon time
 and  force exerted  by  public officials,  as  well as  the
 environmental  concern  of  the site's  owner/operator.  Public
 awareness and  environmental consciousness  were strong  factors
 in  implementation  of remedial  measures.   Pressure  exerted  by
 state  officials  sometimes  forced  companies and property  owners

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to implement corrective actions.  Since remedial action  is
generally a time-consuming endeavor, the number of  remedial
action sites was also dependent upon how long ago the  environ-
mental concerns were emphasized.  Legal action to identify
"responsible" persons for remedial actions generally took four
to nine years.  After this time, the identified responsible
party either instituted remedial actions at the site or  declared
bankruptcy (in the process refusing to remedy the situation).

     Table 1-3 was compiled to obtain an indication of the
type of pollution associated with sites which had undergone
remedial action.  Media affected at the 169 sites were found
to include ground water 65 percent of the time, surface  water
56 percent, soil 41 percent, air 29 percent, and food  chain
12 percent of the time.  Frequently a site affected more than
one media.
    TABLE 1-3.  AFFECTED MEDIA AT 169  REMEDIAL ACTION  SITES
                                  Number
                                   of
                     Affected Media  Occurrences

                   Ground Water        110
                   Surface Water        95
                   Air               49
                   Soil              69
                   Food Chain          20

                   Total            343
     Table 1-4 was compiled to identify funding  sources.
Generally the state, county, and/or municipality  attempted  to
persuade the owner/operator of an uncontrolled facility  to
voluntarily remedy the environmental hazards.  If this effort
failed, legal proceedings were instituted against the  responsible
party.  Depending on the degree of hazard posed  by the site,
various government agencies funded the remedial  activities
while legal responsibility was determined by  the  courts.   Federal
financial assistance for remedial measures  is largely  funded
under Section 311 of CWA.  As previously stated,  these funds
are available only for endangerment of navigable  waters.   Since
any one site might require millions of dollars,  total  funding
from state, county, or municipal sources is unlikely.  As  a
result of these high costs, more than one party  often  funded
the remedial activity.

    TABLE  1-4.   FUNDING  SOURCES  AT  169  REMEDIAL  ACTION SITES
Funding
Source
Federil
State
County
Municipal
Private
Total
Number of
44
62
11
22
103
242

-------
     Table 1-5 was compiled to determine the general  status of
improvement that occurred at sites which had undergone remedial
actions.  A total  of 180 separate remedial  action efforts were
initiated at the 169 sites.  The pollution  status was considered
unimproved when the implemented remedial measure did  not
correct the contamination problem.  Usually, lack of  improvement
was the result of inadequate funds or the type of action
instituted.  Improved refers to a remedial  measure which may
have partly corrected the problem, but some problems  are still
experienced at the site.  A remedied site was one at  which the
problem had been corrected; e.g., contaminated surface water
was returned to its natural state.  Based on these definitions,
the last column in Table 1-5 indicates that 46 percent of
corrective actions were not effective, 38 percent improved the
pollution problem, and 16 percent were completely effective.


 TABLE 1-5.  POLLUTION AND REMEDIAL ACTION STATUS AT  169 SITES
Pollution Status
Unimproved
Improved
Remedied
Total
Number of Remedial Actions
Planned On-Going Completed
Actions Actions Actions
16 49 17
12 36 21
0 3 26
28 88 64

Total
82
69
29
180*
            * A totil of 180 remedial activities were Identified at the 169 sites.
CASE STUDY FINDINGS

     Case study sites included in the report were selected
based on a desire to represent a wide range of facility types,
pollution type and media, and remedial action technology.
Tables 1-6 and 1-7 present an overview of the nine case
histories.  The nine sites include two remedied and seven
improved sites.  Remedial action applied at the seven improved
sites showed varying degrees of effectiveness.  The combination
of all nine sites covered contamination of all media including
ground water, surface water, soil, air, and the food chain.
Waste types involved included mercury, arsenic, solvents, oil,
tire wastes, inorganic and organic waste, and septic waste.
The types of facilities examined included surface impoundments,
landfills, drum storages, and incinerators.  The technology
employed consisted mainly of containment, removal of waste for
incineration or secure burial, and institution of surface water
and/or ground water controls.

CONCLUSION

     Remedial measures encountered during this survey were
usually confined to containment and/or removal of the hazardous

-------
TABLE 1-6.   CASE  STUDY  SITE  IDENTIFICATION
Site
No.
A
B
C
D
E
F
G
H
I
Name
01 in Corporation
Firestone Tire and
Rubber
Anonymous
Destructo/Carolawn
Whitmoyer
Laboratories
Western Sand and
Gravel
Ferguson Property
3M Company
Whitehouse/Allied
Petroleum
Location
Saltville, PA
Pottstown, PA
East Central, NY
Kernersville, NC
Myers town, PA
Burrillville, RI
Rock Hill, SC
Wood bury, MN
Jacksonville, FL
Waste Type
Mercury
Tires, SO. scrubber
waste, organic waste,
pigments, PVC sludge
Solvents, oils, paint
waste with PCB
Volatile/flammable waste
Arsenic compounds
Septic plus hazardous
wastes
Solvents, heavy metals
Spent solvents, acid
sludge
Oil. PCB
Remedial Action Technology
Graded and constructed erosion conrol structures. Removed
contaminants. Planning extensive remedial action ($23 million).
Recovery wells Intercepted polluted ground water and recycled
it through their plant. Expected to be 100 percent effective.
Lagoons filled and capped. Diversion ditches and test wells
installed.
Two Phases: 1. Waste removed, incinerated or landfilled.
Contaminated soil removed and landfilled.
2. Waste removed. Incinerated, landfilled, and deep
well Injected.
Removed arsenic waste from lagoon, treated and discharged. Waste
piles of arsenic placed in concrete vault. Ground water treated
using purging wells. Some contaminated soil remains.
Four lagoons pumped, dried, and contents stored off and on-site.
Monitoring wells installed. Future remedial action planned.
Two Phases: 1. Contained with polyethylene and clay cap.
Installed surface water diversion ditches and
vent pipes in contained area.
2. Since phase one ineffective, removed liquid.
Still some sludge and drums left.
Pits emptied and contents burned. Barrier wells Installed to
stop spread of contaminated ground water.
Mobile activated carbon unit dewatered pit, oil absorbed using
solid waste and earth. Future remedial action planned.
  TABLE 1-7.   CASE  STUDY  SITE  BACKGROUND





Facility Type


Site
No.
A
B
C
D
E
F
G
H
I


s-
•D
C
n
—i
X
X
X

X






II
o
i~ -M
« is>
V E
= 0



X


X


I

o o»
I =
o
U +•>
f-
LI C
X
X
X
X
X
X
X
X
X


Effected


Ground Water
X
X
X

X
X

X
X

I.
V
5
u
k. i.
X
X
X X
X X
X
X X


X
Po
llution
Media


5
X
X
X

X
X
X

X


c
i
o
•o
1


X
X




X
Status


Remedied

X





X



Unimproved











Improved
X

X
X
X
X
X

X


Federal



X

X
X

X
Remedial Action
Funding


State
County
Municipal





X


X X
Status


Private
X
X
X

X


X



Completed
X

X
X
X

X

X


at
c
3
8

X



X
X
X
X


Planned
x

X


X


X
L1t1ga


Current



X


X




£
X
X
X

X
X

X
X
tion


Expected










-------
wastes with a primary goal  being the prevention  of further
contamination of the environment rather than  complete  cleanup.
Complete environmental  cleanup of ground water or surface water
generally requires sophisticated technology,  additional  money,
and additional time.  Therefore, a responsible party with
sufficient funds and expertise must be located for complete
cleanup to occur.   In most  cases sufficient funds have not
been available for effective remedial  action.  The U.S.  EPA
is able to provide only limited funds  under Section 311  of the
CWA.  States and local  governments typically  cannot provide
sufficient money for total  cleanup, since any one site may
require millions of dollars to correct.

     Based on the  case studies and survey, the state-of-the-
practice in remedial action does not look favorable when one
considers that 46  percent of the time  the applied remedial
action was ineffective and  only a portion of  all uncontrolled
sites have received some form of remedial action.  In  addition,
remedial action applied at  a site experiencing problems was
found to be totally effective only 16  percent of the time.

     It should be  emphasized that the  numbers presented in
this section are based on assumptions  by the  persons performing
the survey and the opinions of those interviewed.  However,
the percentage numbers are  a fairly accurate  representation
of the state-of-the-practice in remedial actions.

-------
             SUMMARY REFERENCES AND BIBLIOGRAPHY
1-1   Connery,  Jan.   "Draft Report on Review of Uncontrolled
     Site Response,  Public Information Document".   Energy
     Resources Company,  Inc.   Cambridge,  Massachusetts.
     April  4,  1980.

-------
                  APPENDIX 1-1



REMEDIAL ACTION HAZARDOUS  WASTE SITES BY  STATE
                        11

-------
                                       Facility Type
<•)-
1
Name and Location ->
£>
IQ
i_
O
4J
to
§
a
Surface Ii
Injection
IncineratI
o.
VI
Waste Type
Remedial Action Technology
 Army  Redstone  Arsenal
 (011n Chemical  Plant)
 Huntsville,  AL

 Kevlar Waste Storage Site
 Anniston,  AL

 18-Acre Vacant  Lot
 Phoenix, AZ

 Tri-City Landfill
 Phoenix, AZ

 Mountain Home  View  Estates
 Slobe.  AZ

 Vertac  Chemical  Corporation
 Jacksonville,  AR
 Gurley  Refining  Company
 Edmondson, AR

 Koppers  Company,  Inc.
 Butte County,  CA

 Stringfellow Industiral
   Waste  Disposal  Site
 Riverside County, CA

 Holy Corporation
 Mountain Pass  Operations
 San Bernadtno  County, CA

Rocky Mountain Arsenal
Denver,  CO

Lowry Landfill
Denver,  CO

City of  Denver, CO

Fitzgerald Gasket Company
Torrlngton,  CT

Gallup Dump
Pla1nf1eld,  CT

Chemical Waste Removal
Bridgeport,  CT

Pioneer  Products
East Haddam,  CT

Diamond  Shamrock Corporation
Delaware City,  DE

Llangollen  (Army Ck) Landfill
Wilmington,  OE

Broward  Chemical  Company
Ft. Lauderdale, FL

North  Miami  Beach, FL
xx    xx
                                                                  PCB/DDT
                                Sulfurlc add,  spent dope
                                waste.

                                Arsenic.
                                Hazardous waste and heavy
                                metals.

                                Asbestos  dust.
                                Pesticides,  phenols,
                                herbicides,  dioxln.
                                PCB,  zinc,  heavy oil  sludge.


                                Creosote,  PCP


                                Organic  and inorganic  residues.



                                Lead  and zinc.



                                Pesticides,  herbicides.


                                Chemical waste.


                                Landfill gas.

                                Asbestos.


                                Acetate, organlcs, heavy
                                metals.

                                Chemical wastes.


                                Hydrocarbons.


                                Mercury wastes.


                                Heavy metals and  hazardous
                                wastes.

                                Calcium  hydroxide sludge.


                                Organosulfate
 Plant shut down 1n 1970, cleaned in 1979



 Drums removed, soil removed and treated with Hme.
 Site Hmed. Bern constructed to control runoff.

 Cleaned soil.


 Removed wastes.
Demolished mills, covered asbestos with dirt,
revegetated.

Built interceptor ditch and installed monitoring
wells. Building additional interceptor ditches and
will cap site.

Waste neutralized with Hrne.  Need to recycle waste
or cap site.

Triple lined lagoons.  Installed recovery wells.
Built dam to contain waste, leakage detected below
dam.  Waste and contaminated soil currently being
removed.

Installed a cement cut-off barrier and pumped
contaminated water.
Drainage corrected.  Recycling.  Containment of
ground water, lined impoundment, closure.

Monitor.  Cleanup initiated.
Monitoring.  Placed barriers.

Removed waste.


Cleanup included general containment.


Removed wastes.


Practices corrected.


Monitoring.  Removal of water.   Capped and seeded.


Capped.  Aquifer reclamation, aeration, monitoring.
Higher berms constructed.   Site regradlng to control
sludge planned.

Wells closed, system flushed, treated with
activated carbon.
                                                                       12

-------
                                      Facility Type


Name and Location
Gulf Coast Lead
Tampa, FL
WhUehouse Waste 011 Pits
3 Z S e S
= - 2 a, .2 2
>•- iq i/) u ** 4J
i*- en « o e p—
•o v E •*- « ••- •—
a ^ 2 3 c e S.
_, - o 1/1 « - 
-------
                                       Facility Type
                                      §•  g.  I  i   u
                                      S  E  S  =   2
    Name  and  Location
                                                                          Haste Type
                                                                                                              Remedial  Action Technology
UBounty Dump
Charles City, IA

Vulcan Materials Company
Wichita, Kansas
National Zinc Company
Montgomery County, KS

Goodyear Dump
Berea, KY

Raywlck Chemical Dump Site
(Allan Dump)
Raywlck, KY

Messingschlager Farm
Covington. KY

Lees Lane Landfill
Louisville. KY

Campground Landfill
Louisville, KY

Southeastern Chemical Corp.
Reserve, LA

Cl eve-Re ber
Sorrento, LA

Vulcan Materials Corporation
Darrow-Geismar, LA
Mr. 0'Conner's Junk Yard
Augusta, ME

McK1n Company
Gray, ME

NorHs Farm Landfill
Dundolk, MD

HJM Drum Company Chemical
  Waste Warehouses and
  Disposal Site
Dartmouth, HA

S1lres1m
Lowell, MA

MerHmac Chemical  Company
Woburn, MA

Bankrupt Waste Hauler
Dorchester, MA

Shad Factory Pond
Rebohoth, MA
Orthon1troanal1ne arsenic.


Chlorinated organics.



Heavy metals and sulfurlc
acid.

Asbestos, heavy metals.


Solvents



Solvents.


Combustible gas.


Combustible gas.
Chlorosulfonic acid,
hydrocarbons.

Corrosive waste and
volitlles.

HCB
PCB.


Waste oils.
Sjlfldes and organic wastes,
hydrogen sulfide.

Chloroform, organlcs, ketone,
toluene, etc.
Solvent waste oils, plating
wastes, toxic metals,

Solvents, tannery wastes.


Chemical wastes.
Toluene, trlchloroethylene,
ethyl acetatt.
Ground water monitoring system Installed.
Future remedial action planned.

Encapsulated landfill and (traded.  Purging  and
treating ground water, then Injecting Into
disposal wells.  Surface water treated.

Chemical treatment of land with lime and
precipitation of heavy metals.

Barrels removed.  Contaminated soil  removed.
Flammable material sent to Incinerators, non-
hazardous waste disposed In Lebanon Landfill.
Burial site reclaimed and revegetated.

Barrels removed.
Extraction system installed.
Extraction system installed.
Removed 2 trucks of liquid waste, assessment is
completed and future closure being planned.

Runoff controlled with dike - only in preliminary
stage of assessment.

Stopped previous practice and are burying waste
on-s1te. Ercisslons of HCB into the air have been
reduced. Have covered previously used landfills
which received HCB wastes with 4-6 ft soil and a
polyethylene film placed 2 ft below surface.
Storing HCB wastes underwater 1n a lagoon and
subsequently landfilllng utilizing above cover.

Capped.
Wells capped. Mater supply extended to homes.
Cleanup completed.

Neutralization.  Covered and graded.


Criminal action.  Removed soil and chemicals.




Contained. Berms constructed. Monitoring.


Analysis.  Initial stage of cleanup.


Removed waste.


Cleanup Initiated.
                                                                      14

-------
                                       Facility Type
                                       i   g,   i  I
                                       3   C   £   c
     Name and Location
                                   g   £
                                           -Hi.
                                           i   t   S,
                                                                          Waste Type
                                                                        Remedial  Action Technology
 Chesapeake  1 Ohio  Railroad
   Derailment
 Pearl,  MI

 Chesapeake  & Ohio  Railroad
   Derailment
 Woodland Park, MI

 Anderson Development
 Adrian. MI

 Oakland County Dump Sites
 Oakland County, MI

 Bofars  Lakeway, Inc.
 Muskegon, MI

 Cordova Chemical Company
 Muskegon, MI
Hooker  Chemical Company
Montaque, MI
Wurtesmlth A1r  Force Base
Oscoda,  MI

Hedblom  Industries
Oscoda,  HI

Central  Landfill
Montcalm County, MI

Chemical Recovery
Wayne County, MI

Pollution Controls
Shakapee, MN

3M Company
Woodbury Village, MN

Rellly Tar & Chemicals Co./
Republic Creosotlng Company
St. Louis Park, MN

Verona, MO

Albert Harris Property
DUtmer, MO

St. Joseph, MO
Conservation Chemicals Company
Kansas City, MO

Montana Radiation
Butte, MT

Montana Radiation
Anaconda, MT
XXX
                           Styrene.
                            Phenol,  ethylene oxide,
                            vinyl1dene  chloride.
                            Curene  442.


                            Numerous  chemicals,


                            Amines, benzene,  toluene.
                            Pharmaceutical  Intermediates,
                            herbicides,  pesticides,
                            synthetic musks.

                            Brine,  asbestos,  fly  ash,
                            deadly  pesticides.
                            TCE.


                            TCE.


                            Metal plating waste  C-56.


                            Mixed chemicals.
                           Combustible  paint  sludges,
                           solvents, and waste oils.

                           Spent solvents, acid  sludge
                           (isoprophyl  ether).

                           Tars and creosote.
                           Dloxln.

                           011/PCB waste.


                           Alcohols, solvents,
                           chrome sludge.

                           Pickle liquor,  fly ash.


                           Radioactive  phosphate slag.


                           Radioactive  phosphate slag.
Slurry trench, aeration,  monitoring wells, and
purging wells Initiated.
Carbon filtration, aeration,  and ground water
prugtng Initiated.
Vacuum swept homes and streets.   Partial  cleanup
of site.

Some drums removed or containerized.


Purged ground water.


Drums being removed.  Ground water purged.
Wastes and contaminated soil will be placed In
a vault being constructed.  Ground water purging
will be continued for 50 years.

Leaky tank repaired. Ground water cleanup planned.
Public water supplied to residents.  Drums moved
to shed.

Excavated tanks and contaminated soil removed.
Approximately 5,000 drums removed. Intercept
trench built - failed - new one being built.

Hive removed some drums, will remove all drums
and dispose of contaminated soil.

Barrier wells Installed which continuously pump
water to stop continued spreading. Lagoons emptied.

Preliminary assignment of contamination.  Wells
capped and excavated material.
Excavated soil.

Excavated pit, pit sealed. Cleaned debris from
stream bed. Water treated using carbon absorption.

Drums removed and sent to a secure landfill.
Lagoons closed and stabilized, and will be
covered with asphalt.

Gamma monitoring.  Cleanup Initiated.


Gamma monitoring.  Cleanup Initiated.
                                                                      15

-------
Facility Type
4->
S
1 ..
Q. OJ O tl
E 01 0. X 1.
3 >a E o
<5 u — c *J
^- o o m
•«- (O t/l O +* fll
I*- CT (0 U C f—
•o at E •*- v •*- *—
C — § I- '0 0 —
Name and Location * « <=> «> •- ~ <«
Diamond Asphalt Company x
Chinook, MT
Kallspell Landfill x x
Kali spell, MT
Mouat Industlres x
Columbus, MT
Cross Road Landfill, NH x
Reich Chicken Farm x
Dover Township, NJ
Battery Operation x
Elizabeth, NJ
Sherwln Williams Company x x
Glbbsboro, NJ
Chemical Control Corporation x
Elizabeth, NJ
K1n-Buc Landfill x x
Scotch Plains, NJ
Martin Landfill x
Mlddletown Township, NJ
Jones Industrial Services x
Landfill
South Brunswick, NJ
Unknown Name x
Winslow. NJ
Ortho Pharmaceutical Company x
Brtdgewater Township, NJ
NFS (Nuclear Fuels Services) x x x x
West Valley, NY
General Electric Company x x
Hudson Falls & Ft. Edward, NY
FMC Corporation x x
Mlddleport, NY
Gas Storage Tanks x
Long Island, NY
Anonymous Landfill x x
East Central NY
Phelps -Dodge Refining Company x
New York City, NV
Necco Park Landfill x
Niagara Falls, NY
Love Canal Chemical Landfill x
Niagara Falls, NY
Hyde Park Landfill x
Niagara Falls, NY


Waste Type
011 compounds, sludge and
liquid.
PCB, polyester resin.
Toxic solids.
Phenols.
Petrochemicals, toxics,
flaimables.
Lead dust.
Lead, mercury.
Solvents, organics.
Inorganics.
Solvents, organics,
inorganics.
Petroleum wastes.
Petroleum wastes, chemical
wastes.
Phenols.
Volatile liquid organics.
Radioactive "low" and "high".
PCB.
Arsenic, ammonia.
Gasoline.
Solvents, oils, paint
waste, PCB.
Nickel and copper.
Barium organics.
Chemical (organic and
Inorganic)
Chemical (organic and
Inorganic)


Remedial Action Technology
Closed and contained.
Diked and removed.
Removed waste. Ongoing assessment.
Lime addition. Extentlon of public water
supply lines.
Removed drums and soil. New wells drilled.
Removed lead and lead contaminated soil.
Contained and removed.
Removal of waste.
degraded, discharge controlled. Monitoring.
Cleanup Initiated.
Closed. Removed or contained.
Emptied older lagoon and lined new lagoon.
Closed and removed.
Closed and Improved. Removed waste.
Removed soil and wastewater from impoundment.
Regraded and drained impoundment.
Removed waste. B1ostimulat1on instituted.
Filled lagoons, diversion ditches, and test
wells Installed. Capped.
Removed waste.
Drained, capped, seeded.
Drained. Assessment initiated.
Closed. Constructed leachate collection system
Removed soils, eliminated outer berm, berm com
                              ment,  drainage system,  removed waste, incorporated
                              cover.
16

-------
                                       Facility Type
                                                   all
                                                   2
                                                   tf  £  £
                                                  •^  O  —
     Name and Location
                                                                          Uaste Type
                                                                                                              Remedial  Action Technology
102nd Street Landfill             x
Niagara Falls, NY

Hudson Valley PCS Sites
1. Caputo RDA                     x

2. Ft. Edward Landfill            x
3. Klnsbury Landfill              x

4. Ft. Miller RDA - operating     x
5. Old Fort Edward RDA            x

Vanderhorst Co., Plant No. 1      x
Olean, NY

Allied Chemical
Onondoga County, NY

Pollution Abatement Services, Inc.
Oswego, NY

Destructo Chemway Corporation
(Carolawn Co., Inc.)
Kernersville, NC

"North Carolina Highway Spill"
Raleigh, NC

toppers Company, Inc.
Morrlsville, NC

Renroh Warehouse
Holly Ridge, NC

Summit Avenue
Charlotte, NC

Haywood County                    x
Clinton,  NC

Carolina  Task Cleaning Company
Greensboro, NC

Arsenic Disposal                   x
North Dakota

BelHeld-North Ashing Site        x
BelMeld, ND

Belfleld-South Ashing Site        x
Belfleld, NO

Husky Industries
Dlckenson, ND

Sodium Chromate
Dickenson, ND

North Dakota University at Fargo  x
Ml not, ND

Summit National Liquid Services
Pontege County, OH

Chem-Dyne Corporation
Hamilton, OH
Pesticides, phosphorous
chlorates.
PCB.

PCB.
PCB.

PCB.
PCB.

Chromium.


Mercury


PCB, chloroform, toluene, etc.
                                                                                                  Soil cover ussd 1n closure.
Runoff controlled,  regraded,  capped.   Removed
wastes.
Runoff leachate controlled and treated.  Capped.
Regraded, capped, grout-curtain wall,  well  point
system, leachate controls Installed.
Capped, reburied wastes.
Removed wastes.

Removed wastes.
Cleaned up lake.
Fuel oil, toluene, xylene,
dlchloroethane, tHchlorethene.
PCB.


Pentachlorophenol (PCP).


2-4 dlnitrophenol.


Waste chemicals, solvents,
plating wastes.

Petroleum based cleaning
fluid.

Solvent rinses.


Arsenic.


Radloactives and heavy metals.


Radloactives and heavy metals.


Organic residues.


Chromium.


Toxics, radfoactlves,
flamnables.

Chemical waste oils, acetone,


Solvents, organlcs, inorganics.
Constructed dike and trench for leachate control,
removed wastes, filled Impoundment.

One-third of waste chemicals removed. 32,000 ft
contaminated soil removed.  New drinking water
supply system constructed.

Sprayed activated carbon and covered the area
with asphalt.

Contaminated soil/waste removed.  Still some
contaminated soil on site.

Removed drums.
Removed drums.


Surface skinning of water.


EEB cleanup of waterway.  Pit cleaned up.


Collected and recycled waste.


Preliminary study. Cleanup Initiated.


Preliminary study.  Cleanup Initiated.


Preliminary study.  Cleanup Initiated.


Monitoring.  Cleanup Initiated.


Monitoring.  Cleanup Initiated.
Containment, drainage Instituted, redrummed,
and removed wastes.

Removing wastes and site cleanup.
                                                                     17

-------
                                        Facility Type
                                               S
                                               I   _
                                           s,  §.   s
                                           25   =
                                           2   „   .2
     Name and Location
                                                   Jj   =   ~
                                                   I—   t-i   1/1
                                                                          Waste Type
                                             Remedial  Action Technology
 Chemicals  I Minerals  Relcamatlon
 Cleveland,  OH

 Pristine,  Inc.
 Reading, OH

 Ambler Water Company
 (New Jersey Zinc)
 Ambler, PA

 Kawecki Berylco  Industries,  Inc.
 (KBI)
 Ha2le  Township,  PA

 National Wood Preservers
 Haverford,  PA

 Nease  Chemical Company
 State  College
 College Township, PA

 Transformer Sales
 Youngsvllle, PA
 Revere Chemical  Corporation
 Nackamlxon,  PA

 Tobyhanna  Army Depot              x
 Coolbaugh  Township, PA

 Firestone  T1re 1 Rubber Company   x
 Pottstown, PA

 Mill Service,  Yukon Plant
 Southington  township, PA

 ABM Company  -  Wade Site           x
 Chester, PA
Elkland Tannery Site
Elkland, PA

ftohm-Haas Company
(Whltmoyer Labs)
Myerstown. PA
Environmental Aids
New Beaver Burrow, PA

Ohio River Park
Neville Island
PHtsburg, PA

"1977 Flood"
Johnstown, PA

Foote-Mlneral
Exton Corporation
Whiteland, PA
 Solvents, organic and Inorganic. Removed drums.


 Mixed  hazardous chemicals        Some drum removal and site cleanup.
Gasoline spill.



Beryllium sludge.



PCP, oil.


Heavy metals,  kepone, mlrex.



PCB, organlcs.



Adds, heavy metals.


Electroplating (cyanide
hexavalent chromium)

Refinery, S02 scrubber wastes,
organic waste.

Pickle liquor sludge.
Volatile organlcs hydro-
chloric add, PCB, cyanide,
benzene.

Sulfurk add, tannlc add,
line and sodium hydroxide.

Arsenic compounds.
Pickle liquor, organic
sludge.

Upgrading to landfill  led
to release of noxious  fumes.
011, organlcs.


Lithium.
Aquifer recycling.  Added phosphate as fertilizer
to ground to accelerate blodegradatlon.
Treating collected ground water, site capped.
Impoundment filled and graded.
Initial cleanup created a kepone problem which
Is ongoing.
PCB material placed 1n new drums. Building has new
roof and concrete floor pad. Berm constructed
around building.  Soil being evacuated.

Waste neutralized, removed, sent to sea. Lagoons
backfilled. Soil at site still contaminated.

Closed, regraded, changed pre-landf1H1ng technique.
Contaminated ground water redrculated and used 1n
plant processes.

Practice corrected, closure plans being developed.
Determined extent of problem.  Materials disposed
above natural grade. Hot spots removed. Runoff
discharge prevented.

Material removed, lagoon backfilled.
Removed arsenic waste from lagoon, treated and
discharged. Waste piles of arsenic placed 1n
concrete vault. Ground water treated using purging
wells. Some contaminated soil remains.

Removed waste and chemically treated.  Limed pond.
Revegetated.

Closed park off. Monitoring gas and ground water.
Material removed.
Containment. Activated carbon for water treatment.
                                 Lagoons lined.   Activated carbon for water treatment
                                                                     18

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                                        Facility  Type


Name and Location
-

I
a
n
I
O
l/t O
1 1
O i/1
c
O
4-»
,S
4-1
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                                       Facility Type
                                               S
                                               •I
                                   r-   «—   *J   Ot   T-
     Name and Location
                                                   _
                                                   QJ   -^-  >—
                                                   1—   t-4   t/>
                                                                          Waste Type
                                                                                                              Remedial Action  Technology
Bio-Ecology Systems, Inc.
Grand Praire, TX

Little Mountain Salvage Yard
Ogden, UT

Spill
Plains, VA

011n Plant
Saltvllle, VA

Train Derailment - Spill
WilHamstown, WV

Welseter Construction
Calumet County, MI

Ansul Company
Marlnette, HI

Tecumseh Products Company
sneboygan Falls, MI

Amoco Refinery Plant
Casper, HY
Arsenic, chromium, copper,
lead, zinc, nickel, etc.

011s.


Pesticide.
Mercury and alkalide
products.

Hydrochloric add, mother
liquor, formaldehyde.

Demolition wastes, PCB's,
mercury, lead, cadmium.

Arsenic salts.
PCB's.


011s.
Removed drums. Drained lagoons. Filled and
graded.

Removed, treated and redisposed of wastes. Site
was capped and graded.

Recycled and treated waste.
Graded, constructed erosion controls. Removed
contaminants.

Contained and removed.


Contaminated soil being removed.


Treated and removed wastes.


Contaminated soil stored in warehouse.
                                 Closed.  Contamination removed and monitoring
                                 1s ongoing.
                                                                     20

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                          SECTION  2

                            SITE A
                       OLIN  CORPORATION
                     SALTVILLE,  VIRGINIA
INTRODUCTION

     A chemical  production complex  located  in  Saltville,  Virginia
was established  in 1895 and operated  continuously  until  its
closure in 1970  by the final  owner/operator,  Olin  Corporation.
Major product streams generated by  the facility  over  its
operational  life included soda alkali, chlorine,  hydrazine,  and
dry ice.

     Operation of the now-closed chemical  complex  resulted  in
total dissolved  solids (TDS)  and mercury pollution in the
nearby North Fork of the Holston River.  The  TDS pollution  has
been traced  to several ponds  on the property  used  by  plant  owners
for disposal of  their manufacturing wastes.  The mercury
pollution has been traced to an old chlorine  plant on the
complex (since demolished) and one  of the  above-cited ponds.

     Mercury is  the pollution problem of chief concern.   Although
plant officials  and regulatory authorities had been aware of
the mercury  problem for many years, the problem was not
seriously addressed until 1976 when it became obvious that
mercury in the North Fork bottom sediments was not decreasing
through natural  dispersive processes.

     Subsequently, environmental engineering studies  indicated
that soil erosion from the chlorine plant area represented  a
major pathway of mercury to the North  Fork.  Accordingly,
erosion control  measures at the old plant site were implemented
by Olin Corporation.  These measures were apparently effective
in controlling further mercury discharges from the chlorine
plant site.   However, TDS and mercury  discharges are continuing
from the  ponds,  and measures  to control these discharges are
now  being considered.  Even after  all  further mercury and TDS
discharges  from the chemical  complex  site are controlled, some
remedial  actions will have to be performed to control settled
mercury in  riverbed sediments downstream.

SITE DESCRIPTION

     The  Olin Chemical complex  is  located  in the  Saltville  Valley
in southwestern Virginia.  The  plant  location is  shown  in an
aerial photograph  included as  Figure  2-1;  the layout of  facilities
at the complex  is  shown  in Figure  2-2.
                               21

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                 Chlorine Plant
                 •"PMC
Figure 2-1.   Aerial  photograph of Olin
      Chemical complex. [2-1]
                22

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         0  J  OMLES
                                        PRESSURE WELLS-*
                                        MUCK PONDS -u»—•
                                        GRAVITY FLOW LINES-
                                                            CONTROL.^
Figure 2-2.    Site  layout  of  Olin  Chemical complex.  [2-2]
                               23

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     The average annual rainfall in the area is 109 cm (43 in.)
and average annual snowfall is 38 cm (15 in.).  The average daily
high temperature is 13°C (55°F) with the highest daily maximum
in July at 29°C (85°F) and the lowest in January at -4°C (25°F).

     The small town of Saltville lies in the belt of the faulted
and folded Appalacian Mountains.  Saltville and the former Olin
plant site lie in the flood plain of the North Fork of the Holston
River.  Underlying the site is the MacCrady Formation, a shaley
limestone of Mississippian Age.  The MacCrady Formation contains
evaporite deposits of high quality halite (rock salt) and occupies
a narrow bank less than 300 m (1,000 ft) wide.  This Formation
supplied salt to the brine wells located on the plant property.

     East of the former chlorine plant site, the MacCrady Formation
thickens to about 600 m (2,000 ft) as a result of flowage of the
evaporites during thrust faulting.  The strike of the MacCrady
is 55° NE with a dip ranging from 45° to 60° SE.  The North Fork
flows to the southwest following the bedrock strike and is
underlain by the MacCrady Formation.

     The Little Valley Formation, resistant limestone of Missis-
sippian Age, overlies the MacCrady Formation.   This limestone
outcrops and forms the cliff and ridge between the former plant
site and the Town of Saltville, southeast of the North Fork.
Northwest of the river valley is Little Mountain formed by the
resistant Price Sandstone of Mississippian Age, which underlies
the MacGrady Formation.  In the river valley,  alluvium overlies
the bedrock and consists mostly of sandstone boulders in silty
and sandy clay.

     Figure 2-3 displays a generalized geological  cross section
of the area in which the plant was located.   The alluvial
material may have been removed from some areas of the plant
grounds during initial  site preparation.  Presently, most of
the former chlorine plant site is underlain by loose fine
grained fill consisting of clayey silt and sand and some pieces
of building materials.

     The North Fork is  located on the southeast side of the
Olin property and separates the former plant site from Saltville;
it originates from springs and streams near the town of Nebo,
Virginia about 64 km (40 mi) northeast of Saltville.  As shown in
Figure 2-4, it flows southwest for about 209 km (130 mi) to
Kingsport,  Tennessee where it joins the South  Fork of the Holston
River to form the Holston River.   The Holston  River flows about
80 km (50 mi) to the Cherokee Reservoir, and thence an additional
160 km (100 mi) to the Tennessee River.

     The North Fork of the Holston River is a  mountain stream
with an unregulated flow ranging from 0 to 467 m^/sec (0 to
                               24

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               NW
                 UTTLE MOUNTAIN
                                                     I
                                                SALTVILLE
           Figure 2-3.  Generalized geologic cross  section*.

* The cross  section is perpendicular to the strike direction and
  the vertical  exageration  is  approximately 2.5  times the
  horizontal  distance.
               i I    ir. I.™..,,.. ,.„„   ,


                         
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 16,500 ft3/sec).  Typical stream flow at Saltville is about
 80 m^/sec (300 ft^/sec).  Extensive pool and ripple areas are
 located in the river, and the riverbed is primarily composed of
 boulders and cobbles with submerged rock ledges.  Figure 2-5
 shows that the riverbed has been altered in the area which now
 houses two ponds used for disposal  of Olin's liquid wastes.
 The River now flows to the southeast of Ponds 5 and 6 rather
 than through the area in which these waste ponds are located.

     The two plant site areas causing environmental concern are
 the old chlorine plant site and Ponds 5 and 6.   Since corrective
 action has only been implemented at the old chlorine plant site,
 this area will be emphasized.

     Hydrogeological studies indicate that most of the ground
 water underlying the former chlorine plant area is the result
 of infiltration of precipitation.   However, the western part of
 the chlorine plant area derives some ground water from the
 Robertson Branch Creek and some from precipitation falling on
 higher surfaces.  Ground water has  been found at the old
 chlorine plant site at depths from  4 to 6.4 m (13 to 21 ft).
 Hydraulic connections occur horizontally and vertically between
 the rock, alluvium, and fill. [2-4]  The drinking water for the
 Town of Saltville is supplied by mountain springs located at
 higher elevations north of the plant site.   These springs are
 capable of supplying 0.07 m^/sec (1.5 mgd).

 SITE OPERATION AND HISTORY

     In 1748, saline brines were discovered in  the vicinity of
 Saltville.   Although salt production began in 1788, production
was sporadic until  the Mathieson Alkali Works acquired the
 property in  Saltville in 1892.  The first alkali product was
 produced in  1895 by Mathieson.

     To capitalize on the raw materials of the  area (e.g., rock
 salt and limestone deposits, as well  as coal fields), Mathieson
 began to broaden their chemical product capability.  A dry ice
 plant, the largest of its kind, was constructed in 1931.  In
 1951, the electrolytic chlorine and caustic soda plant was
constructed  by the Company, then called Mathieson Chemical
 Corporation.   Mathieson merged with Olin Corporation in 1954,
constructed  a hydrazine plant, and  began production of rocket
 fuel.  The hydrazine plant, operated for the U.S. Air Force,
was the last major addition to the  Olin complex.

     Due to  economic and technical  factors, Olin Corporation
began closing their facility in Saltville in 1970 and completed
the process  by 1972.  Olin had owned 3,000 ha (7,300 ac) in
 Smyth and Washington Counties and was the only  major industry
 in the area.   About 1,400 ha (3,500 ac) was donated to the State
                              26

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                 WASTE POND No I


                  WASTE POND NO 2


            WASTE POND No 5


               HENRYTOWN
Figure  2-5.  Location of  former  river bed  through
          Waste  Ponds 5  and 6.  [2-3]
                        27

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of Virginia as a game and timber reserve.   About 1,400 ha
(3,500 ac) within the corporate limits of  Saltville  were
donated to the Town, including the plant site,  building,  and
surrounding farm lands.   In addition,  mineral  rights plus
some money was awarded to the Town.

     From July 4, 1895 until June 20,  1972, Olin Corporation
and its predecessors (Mathieson Chemical Corporation and
Mathieson Alkali Works)  operated a chemical complex  at
Saltville.  A list of principal products and manufacturing
processes utilized by Olin at the Saltville complex  is
displayed in Figure 2-6.   As shown in  Figure 2-7, raw materials
were converted to soda-alkali compounds via the Solvay process.
Chlorine and caustic soda were produced by electrolysis
from salt(see Figure 2-8).  The Solvay process  and chlorine-
caustic process produced  significant quantities of wastes.
The Solvay process produced sodium chloride, calcium chloride,
calcium carbonate, calcium hydroxide,  and  other solids as
wastes.  The chlorine-caustic process  produced  caustic soda,
salt, and mercury as wastes.  The dry  ice, liquid carbon
dioxide, and hydrazine processes did not produce wastewater
with any significant contaminants.

     The Saltville facility produced 0.1 m3/sec (2 mgd) of
waste containing 910,000  to 1,360,000  kg (1,000 to 1,500  tons)
per day of calcium and sodium chlorides (salt), plus much
smaller amounts of caustic agents, mercury, and other
contaminants.  The wastewater was discharged to large disposal
ponds where the solids were settled  and supernatant  discharged
to the North Fork.  During the plant's operation, a  total of
six such ponds were used.  Ponds 1 and 2 have since  been
filled and residences are located atop Pond 1.   Ponds 3 and
4 were only temporary holding lagoons, and Ponds 5 and 6
exist to this day, although they are now dry.

POLLUTION

     As a result of preparation of alkali  and chlorine
products, the North Fork  has elevated  levels of total
dissolved solids (TDS)  and mercury.   During the
                              28

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 SODA ASH
 PRODUCTION
(AMMONIA SODA)
                    1001 OF WASTE CHLORIDES
                    FROM SODA ASH (AMMONIA
                    SODA), BRINE PORTION OF
                    CHLORINE PLANT AND
                    HYDRAZINE PLANT
        PURIFICATION
                               TOTAL LIME
                               SODA AND
                               ELECTROLYTIC
                               CAUSTIC SALES
    Figure  2-6.    Process flow  diagram  for  Olin
                  alkali  plant.    [2-2]
                                29

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       RAW MATERIALS
                                                                PRODUCTS
                                                                SODA ASH

                                                              ^•BICARBONATE OF SODA

                                                              ^CAUSTIC SODA

                                                                AMMONIA —
                                                            •RECYCLE-*-
                                     WASTEWATER
DISPOSAL
PONDS -
(SOLIDS
REMOVED)
1
CALCIUM CHLORIDE '
SODIUM CHLORIDE /
CALCIUM CARBONATE \
LIME >
OTHER SOLIDS '
) IN SOLUTION
> AS SETTLEABLE SOLIDS
        CALCIUM AND SODIUM CHLORIDE SOLUTION TO RIVER
             Figure  2-7.   Soda-alkali  production  at  Olin
                          Saltville  plant.    [2-2]
       SALT - NaCl
    (SODIUM CHLORIDE)
1_ _
    _+  O.C.	
     VOLTAGE
           Figure  2-8.
Chiorine-caustic
Saltvil1e plant.
production
 [2-2]
at  Olin
                                    30

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plant's operation prior to  1969-70,  the  State  Water  Control  Board
regulated the chloride discharges  and  gave  little  attention  to the
amount of mercury discharged.   Since the plant's closure,  the
500 mg/1  IDS standard for the  North  Fork is  exceeded  60  percent
of the time.  However, no real  health  hazard is  experienced  from
TDS loading and resident fish  appear to  have acclimated.   Also,
the river water is too brackish for  use  as  a water supply  and
there is  no demand for its  use since ground  water  supplies are
adequate.

     Approximately 10 percent  of the TDS concentration  (as salt)
in the North Fork is estimated to  be the natural background  level.
Salt leakage from the brinefield is  believed to  have occurred
for many  centuries and could be considered  to be a natural
condition since the present Saltville  flat  was once  a salt lake
around which Pleistocene mammals gathered.   It is probable
that the  mining operations  of  Olin and its  predecessor  aggravated
the situation.  However, saline flows  could probably not be  stopped
since the near-surface geological  formations are fragmented.  The
brinewell field contribution to TDS  is not  considered to be
easily remedied.  The TDS loading  due  to Ponds 5 and 6  is  con-
sidered to be at least partially abateable.

     In 1969, the Swedish scientists Jensen and Jernelov published
the first findings on methylation and subsequent bio-accumulation  of
inorganic mercury in the environment.   Their discovery focused
attention upon the amount of mercury being discharged as waste.
Virginia  State Water Control Board water analysis  of the North
Fork indicated that the stream was seriously contaminated with
mercury.

     Beginning in 1951, Olin Corporation used mercury in  an
electrolytic chlorine process.  The mercury-contaminated  waste-
water and process wastewater were recycled, disposed in the
ponds, and/or discharged to the river.  In  1970,  tighter
restrictions were placed on chlorine plants, as a  result  of
Jensen and  Jernelov's discovery of mercury  methylation.   Before
regulation  (1950  to 1970) an estimated  45 kg/day  (100 Ib/day)
of mercury  discharged to the North  Fork via spills,  runoff,
and other pathways.   After  regulations  were developed (1970  to
1972), Olin  reduced losses  to  about 0.1 kg/day  (0.25 Ib/day)
by recycling and  tightening plant operations.

     Olin officials had  planned to  redesign the plant and to
further  reduce mercury  discharge  to a minimum.  However,  Olin
later  decided  to  abandon the Saltville  plant  since the cost of
repair and  restoration  was  prohibitive.  Olin closed the  plant
and donated  its  land  to  the State of Virginia and the Town  of
Saltville in 1972.
                                31

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     A 0.5 mg/kg (ppm) mercury level  in fish was  established  by
the Food and Drug Administration in Spring 1970.   Since  September
1970, the North Fork of the Holston River has been closed  to
fishing for eating purposes as a result of the mercury content
in the fish.  Game fishing is now allowed.  The Virginia State
Water Control  Board annually monitors the mercury content  in  the
fish and river sediment.

     When it became evident that the natural dispersive  processes
would not eliminate the mercury problem and return the River
to an acceptable quality, the State and Olin began to consider
clean-up actions.  A mass balance study of mercury input to  the
river conducted by Olin from October 1978 until November 1979
indicated an average mercury input of 45 g/day (0.10  Ib/day).
State samples  taken during the same period indicated  an  input
of 40 to 60 g/day (0.10 to 0.13 Ib/day). [2-5]  Mercury's  physical
property complicates the  contamination process.  Because of  its
weight mercury has the tendency to settle out and water  does  not
act as a driving force.  The higher than water density of  mercury
resulted in accumulative  deposits of mercury in the riverbed
from long-term, historical discharges.  Abatement of  mercury
contamination  of the river  will thus require dredge  removal  or
fixation of the riverbed  mercury.

     Even with a mercury  input to the North Fork  of 60 g/day  or
22 kg/year (0.13 Ib/day or 10 Ib/year), the concentration  of  mercury
in the flowing river probably never exceeds 1 ug/1 (1 ppb) and
rarely exceeds 0.2 ug/1 (0.2 ppb).  The mercury criterion  for
domestic water supply is  2.0 ppb and this level would probably
never be exceeded.  As further health protection, there  are  no
public water supply intakes in the North Fork below Saltville,
nor is there a need for public water intakes on the river.  Thus,
apart from human consumption of fish caught in the river,  the
mercury level  in the water was not seen as presenting a  health
hazard.

     The two site areas containing residual contamination  and
discharging mercury have  been identified as Pond  5 and the old
chlorine plant site.  The only pollution source which has  been
assessed and which has received corrective actions is the  chlorine
plant site.  Therefore, for purposes of clarity,  the  mercury
contamination  as associated with the chlorine plant will be
discussed more than the problem associated with Pbnd  5.

     Pond 5 was recently  assessed by a consultant for Olin.   The
report revealed that 92 percent of the mercury, approximately
38,600 kg (85,000 Ibs), in the pond was confined  to the  top  5.3  m
(17.5 ft) of the solids comprising 612,000 m3 (800,000 yd3).   The
average concentration in  the top 5.3 m (17.5 ft)  of soils   was
about 13 mg/kg (13 ppm).   Olin estimates that it  will cost
$25,000,000 to $30,000,000 to remove this material and dispose
of it in a secure landfill.  A water balance conducted on  Ponds
                               32

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5 and 6 indicated that 60  percent  of  the  total  water  results  from
direct rainfall  onto .the pond.   Ground  water  contributions are
insignificant.

     Approximately 100,000 kg  (220,000  Ib)  of mercury has  been
estimated to be  at the surface  and subsurface of  the  demolished
former chlorine  plant  site.   The fill material  contains  the
highest concentration  of mercury and  the  alluvium contains the
lowest concentration.   Generally,  soils in  the  western half  of
the building site contain  the  highest concentrations  of  mercury.
Mercury beads, up to 1.5 mm (0.1  in.)  in diameter, have been
visible on the  top surface of  concrete  structures.   Mercury
concentrations  in the  soil above and  below  the  concrete  were
found to be less.  Most of the  mercury  present  at the site
entered the subsurface during  the  years that  the  chlorine  plant
was in operation.

     It appears  that  mercury percolated downward  via  gravity
through pore spaces in the fill  and alluvial  materials at  the
chlorine plant  site and along  open bedding  planes and joints  in
rock.  It then  collected in high concentrations in the subsurface
where relatively tight materials such as  concrete and tight
rock formed barriers  to further downward  migration.   Because of
gravity and ground water movement,' mercury  could  have spread
laterally for short distances.   However,  it is believed that the
lateral movement of elemental  mercury at  the  site in the ground
water is slight.

REMEDIAL ACTION

     When it was determined that the natural  dispersion of
mercury would be slow, with centuries elapsing before the  river
ecosystem recovered completely, Olin Corporation  and the State of
Virginia began  taking the first steps to  correct  the problem.

     A Saltville Task Force was established to study the level  of
mercury, evaluate the problem,  and advise Olin on acceptable
measures to remedy the problem.  Members  of the Task Force
represent the U.S. Environmental Protection Agency, State  of
Virginia Water Control Board,  the State of Tennessee Department
of Public Health, and the Tennessee Valley Authority.

     The former chlorine plant site continued to  discharge
mercury into the. river after its closure  in 1972  through residual
materials and deposits at the plant site.  Olin's consultants
studied the movement of elemental  mercury at the  chlorine  plant
site (1) through the soil  and rock, (2) in the ground water, and
(3) by soil movement through erosion.

     The potential for mercury pollution of the  river through
erosion was deemed to be greater than through ground water
seepage from the area to the river.  The fill material at the
                                33

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former plant site has higher mercury concentrations than the
ground water.  This mercury could be deposited in the river by
sheet flow runoff, especially from the steep river banks at times
of heavy rainfall.  A flood in April 1977 undercut the river bank
in front of the former chlorine plant site.   The amount of mercury
deposited into the river by erosion and movement of particulate
matter is believed to have been significant.  It is also probable
that stream bank erosion at the site during  high river flows
in the mid-1970's carried more mercury into  the River and
contributed to the noticed increase in mercury contents in fish
and sediment.

     The corrective action completed in 1979 included implementa-
tion of erosion control  measures along the river bank to prevent
further discharge of mercury.   This was the  first corrective
project Olin undertook in conjunction with the Task Force.  Olin
Corporation contracted W-L Construction of Chilhowie, Virginia
to implement the erosion control project.  The U.S. Army Corps
of Engineers and the Virginia  Water Control  Board reviewed the
plans for the project.  The detailed engineering work was done
by a consulting firm from Chicago, Illinois.

     Approximately $400,000 in costs were incurred by Olin to
prevent erosion of the river bank in the area of the chlorine
plant.   The project (see Figure 2-9) began in October 1978 and
was completed by April 1979.   The corrective measures to reduce
mercury concentrations in the  North Fork included the following:

     1.   Drainage diversion measures.   Revisions to prevent the
         possibility of  Robertson Branch Creek overflowing onto
         the chlorine plant site consisted of the following:
         a.   The road across the Branch Creek serving Tri-Cities
             Dry Ice was modified to include a 7.6 m (25 ft) wide
             by 3 m (10  ft) high arch structure to allow higher
             flows to pass.
         b.   An earthen  berm was constructed from the above
             mentioned road along the chlorine plant site to
             the double-barreled culvert.
         c.   An overflow channel was constructed on top of the
             double barreled culvert.   A 2:1 slope was maintained
             in the overflow channel by removing previous railroad
             tracks, and by applying sand, filter material, and
             riprap on the slope.

     2.   Sealing off the plant site from the North Fork (see
         Figure 2-10).  The slope of the chlorine plant site
         facing the river was  regraded to a  2:1  incline.  Soil
         and debris which noticeably contained mercury deposits
         were removed from the slope and placed back away from
         the North Fork  on the former chlorine plant site.  Sand
                               34

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..
                                                                                                Concrete plug
                                                                                                for pipes
                                                     ....*..  ..I..
                                         ' •-o^-	. tajirijoiH^' m
Slop* protection
from concrete
bridge to railroad
bridge
                    Figure 2-9.   Erosion  control  measures  at  chlorine plant  site.   [2-6]

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  rroSr-
  iroo
       / Slops to drain
  K95
  I6X>
iq tees
  /eao-
                 •f* fop soil plus sefc//ntj
             f.tftr
                                        Seal* 0
            Figure 2-10.   Construction details  for  sealing
                       North  Fork  riverbank.   [2-6]
                                     36

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         was  applied  to  the  slope,  at  a  thickness of from
         5 cm to  15  cm (2  to  6  in.).   A  0.8 mm  (30 mil)
         polyvinylchloride (PVC)  mesh  filter was applied
         over the sand to  hold  it in place.  Finally, riprap
         was  applied  on  the  slope.

     3.   Removal  and  plugging of  drainage  pipes  from the area.
         Two  drain pipes and  a  rectangular concrete drain
         were located during  the  excavation and  regraded.
         These drain  structures were moved back  a distance
         from the North  Fork  and  plugged.

     4.   Prevention  of precipitation infiltration.  A 10 cm
         (4 in.)  layer of  topsoil was  used as  cover material
         for  the  chlorine  plant site.   The area  was then
         seeded.

     The above measures  were  implemented as erosion control
measures and  are  considered  effective  to that  end.  It  is  hoped
that these measures  will prevent  the migration of mercury  from
the chlorine  plant area  during  flooding  and high stre-am flows.
Entrance of water due to surface  runoff  from  the nearby hills
and overflow  of Robertson  Branch  Creek,  likewise should be
prevented by  the  surface diversion measures  installed.

     It is difficult to  accurately determine  the extent of
mercury contamination at the site and  in the  river  and  fish.
Fish data taken since plant  closure appear random  since
statistically the change in  mercury concentration  over  time  can
be equally represented by  a  line  with  a  positive,  negative,  or
flat slope. [2-5]

     Figures  2-11 and 2-12 present  mercury  concentrations of
fish and sediment before and after the erosion control  activity
was implemented at the chlorine plant  site.   The sampling  station
identification number increases with  distance downstream from
the site.  Sampling Station Bl  is located 8  km (5  mi)  downstream
from the former Olin plant site.   Sampling Station  B6  is 119 km
(74 mi) downstream of the Olin  site.   Figure  2-11  illustrates
the mean mercury content of fish  in July 1978 (prior  to remedial
action) and July 1979 (after remedial  action).  Likewise,  Figure
2-12 indicates the mean mercury content of the sediment in the
North Fork in July 1978 and July  1979.  From  viewing  Figures 2-11
and 2-12, it is difficult to determine if further discharge  of
mercury has been prevented.   Because  of the  behavior  of mercury,
lodgement of mercury on the river floor may  be creating a  random
data appearance.   Time will  permit the collection of  a  larger
data base for mercury concentrations  in fish  and sediment.
Perhaps then, a site-specific accurate assessment of mercury
mobility and transport mechanisms can be made, as well  as a
determination of whether  further mercury  discharges from the
chlorine plant site  are continuing.
                                 37

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    5.0-1
UJ
UJ
 UJ
    4.0-
    3.0-
    2.0-
    1.0 '
    0.0
         n
RIVER     ^8

MILE   CONTROL
                                                                 1979
                                                                 1978
 82  77  72
OLIN  Bl   82
36
B4
22
85
8
B6
                                    STATION
        Figure  2-11.  Mean  mercury content  of the  sediment at
           the  control and  affected stations on the  Holston
                 River, July 1978 and July 1979.  [2-7]
                                    3ft

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  3.01
  2.0-
O
o



I
o
tc
u
  1.0
                    I
                                                      QI979



                                                      • 1978
                         n
   0.0

RIVER    98
MILE    CONTROL
                 82  77  72

                 OLIN Bl  B2
                               STATION
      Figure 2-12.   Mean  mercury content of the fish  at the

       control and affected stations  on  the Holston  River

                 July  1978 and July  1979.   [2-7]
                                 39

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     Concurrently,  Olin's  consultants  have  been  collecting  data
and investigating methods  of  corrective  action  at  the  disposal
ponds.   The six ponds constructed  over the  years  by  the  site
operators were operated in accordance  with  standard  operating
practices of the day.  While  four  of the six  have  reverted  to  a
natural  state, two  of the  ponds  remain active  pollution  sources.
Ponds 5 and 6 are sources  of  total  dissolved  solids  (mainly
calcium and sodium  chloride)  pollution;  Pond  5  is  also a  source
of mercury pollution.

     Pond 5, which  covers  29  ha  (72 ac)  contains  5 million  m3
(7 million yd3) of  waste.   No final decision  has  been  made  on
abating the mercury problem associated with this  pond.   The
soil  under the pond consists  of  sandy, cobbled  material,  and
thus  containment of  leachate  from  the  bottom  of this pond would
be difficult. As an alternative  surface  sealing has  been  proposed
to prevent further  intrusion  of  rainwater.   Such  sealing  would be
less  expensive to install  and although it would not  prevent  any
further leaching, it would minimize the  amount  of  future  leachate
discharges.

CONCLUSION

     When the chlorine plant at the Olin complex  ceased operation
and was demolished,  it was anticipated that the environmental
problem associated with mercury contamination of the fish in the
North Fork of the Holston  River would  gradually diminish.  However,
mercury concentrations in  fish have fluctuated and actually appear
to have increased in 1977.  This increase correlated with a
reduction in dissolved solids and  chlorides in the North Fork.
Likewise, river sediment values fluctuated and a linear  decrease
was not noted for some 80  km (50 mi) downstream.  It was
theorized that the increases in mercury content in the fish was
the result of changes in the stream's  chemistry after the plant
closure.  This increase has since   subsided, but some mercury
discharge has continued and the  stream remains  contaminated.
No reduction in mercury concentrations has been substantiated in
the eight years since closure.

     In mid-1976, the State of Virginia and Olin Corporation began
studying the problem.  The State of Tennessee also became involved
with the assessment  since the North Fork of the Holston  River
empties into the Tennessee River.   There is evidence that the
contamination extends down the river to the TVA Cherokee Reservoir,
161 km  (100 mi) from Saltville, Virginia.

     Delay  in correcting the mercury contamination problem has
been the result of several factors, one of which would be the
time consuming environmental and engineering studies to
rationally analyze the problem and to formulate cost effective
corrective measures  that would have a reasonable chance  of success.
                               40

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Presently, only a small  part of the environmental  problems
associated with the previous operations at the chemical  complex
has been corrected.  The completed corrective action includes
erosion control measures implemented at the former chlorine
plant site.  These measures appear to be successful  in limiting
further mercury contamination from the chlorine plant site  from
entering the North Fork, according to representatives from  both
the Virginia State Water Control  Board and 01 in Corporation.

     Olin believes the largest potential source of mercury  dis-
charge to the river has  been corrected.  They maintain that
current discharges of TDS and mercury are between  0 and 20
percent of levels discharged during the years immediately before
and after plant closure.  Thus, Olin officials believe a large
portion of the overall environmental problems associated with
the chemical complex were mitigated by the plant closure and
subsequent remedial actions. [2-5]  Although a significant
amount of effort and money has been expended, the  U.S. EPA  and
Virginia State Water Control Board believe that correction  of
environmental problems from the site is onl-y beginning.
                                41

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              SITE A  REFERENCES AND BIBLIOGRAPHY
2-1  Aerial photographs, Virginia Department of Transportation,
     Richmond, Virginia.

2-2  Personal  communication and file review with Larry K.  Owens,
     H.V. Arnold, and Dallas Sizemore of Virginia State Water
     Control Board, Southwest Regional  Office,  Abingdon,  Virginia.
     June 6-9, 1980

2-3  Investigation of Ground Water and  Surface  Water Conditions
     Related to Quality of Water in the North Fork of the  Holston
     River near Saltville, Virginia. Dames and  Moore, Lexington,
     Kentucky.  1976.

2-4  Kleiner,  D.E.  Investigation of Mercury Occurrence,  Former
     Chlorine  Plant Site,  Saltville, Virginia.   Harza Engineering
     Company,  Chicago,  Illinois.  1976.

2-5  Personal  communication with and memorandum from J.C.  Brown,
     Olin Chemicals Group.  Charleston, Tennessee.  June  6,  1980.

2-6  Topographic Survey for Olin Corporation by Hart and  Bell.
     August 1977.

2-7  Turner, C.S.  Draft,  Mercury in Fish and Sediment of  the
     North Fork of the  Holston River, 1978 and  1979.  Virginia
     State Water Quality Board, Bureau  of Surveillance and Field
     Studies,  Division  of  Ecological Studies.  1980.

2-8  Olin Corporation,  Saltville Works, Study of Stability at
     Waste Pond No. 6.   Harza Engineering Company, Chicago,
     Illinois.  1971.

2-9  Olin Corporation,  Saltville Works, Stability of Waste Pond  Nos.
     5 and 6.  Harza Engineering Company, Chicago, Illinois.  1976.

2-10 Elimore,  G.R. Investigation of Mercury Occurrence at  Waste
     Pond 5, Saltville, Virginia.  Harza Engineering Company,
     Chicago,  Illinois.  1976.

2-11 Milligan, J.D. and R.J. Ruane.  Analysis of Mercury  Data
     Collected from the North Fork of the Holston River.   Division
     of Environmental Planning, Tennessee Valley Authority,
     Chattanooga, Tennessee.  1978.

2-12 Personal  communication with C.C. Norris, Olin Chemicals Group.
     Saltville, Virginia.   June 6, 1980.

2-13 Personal  communication with Frank  E. Lewis, Mayor of  Saltville,
     Saltville, Virginia.   June 6, 1980.


                               42

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   APPENDIX 2-1



SITE A PHOTOGRAPHS
        43

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View of Olin Corporation at Saltville while
it was still oerpational.   Plant facilities
are located in the upper right corner.   Pond
5 is in the center and left portions  of photo.
The North Fork of Holston  River borders the  pond


Overview of Olin Corporation  at  Saltville.   Town
of Saltville in upper right corner  of  photo.
Olin plant facilities with  Ponds  5  and 6  are
located in the central  portion  of the  photo.
                    44

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Appearance of river  bank  bordering  chlorine  plant  site
before and after sloping  and  sand  application.
     Application of plastic liner and riprap
     to resloped, sanded embankment of chlorine
     plant site.
                        45

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Appearance of chlorine plant site  after
remedial  action.
                    46

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                           SECTION 3

                             SITE B
                FIRESTONE TIRE AND RUBBER COMPANY
                     POTTSTOWN, PENNSYLVANIA
INTRODUCTION

     In 1942 Jacobs Aircraft and Engine Company  operated  a
machine shop for the production of aircraft engines  in  Pottstown,
Pennsylvania.   During this time, they disposed  of  cutting oils
and metal  filings in lagoons on their site.  Firestone  Tire
and Rubber Company purchased the Jacobs site in  Pottstown in
1945.   Since that time,  they have landfilled tires,  inert cloth
and rubber, pigments, zinc oxide, sulfur dioxide scrubber wastes,
rubber flashing, and PVC sludge resins at the site.   Iron,
manganese, aluminum, sulfates,  and chlorides originating  from
the landfill and lagoons on the site have polluted the  ground
and surface water in the area.

     To remedy these water quality problems, Firestone  has
established a  ground water recovery system of wells  which purge
the ground water near the lagoons and landfill  so  that  no
off-site migration of the contaminants occurs.   The  amounts  of
contaminants in the ground water and surface water are  now
within health  standards  as the  Company continues to  monitor
the water quality in the area.

SITE DESCRIPTION

     The Pottstown Plant of Firestone Tire and Rubber Company is
located in southeastern  Pennsylvania approximately 50 km  (30  mi)
northeast of Philadelphia in Montgomery County.   The site
occupies 106 ha (263 ac) within a meander loop of the Schuylkill
River which eventually flows to the Delaware River.   Pottstown,
a community of over 20,000 people, lies a few kilometers  (miles)
upstream from  the Firestone Plant.  Residents in the area use
the ground water for drinking water.

     Pottstown receives  about 110 cm (43 in.) of precipitation
and 81 cm (32  in.) of snow per  year.  No frost can be expected
from early April to late October.  The winds average 15 km/hr
(9.3 mph) from the west.  The temperature averages about  10°C
(51°F) year round with a summer average of about 22°C (72°F)
and a winter average of about -3°C (26°F).

     Firestone's old landfill area is located 45 to  90  m
(150 to 300 ft) from the Schuylkill River.  Both the new  landfill
                                47

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area and the new lagoons lie about 200 m  (600 ft)  from the
Schuylkill River (see Figures 3-1  and 3-2).   The Schuylkill
River is 0.6 to  1.2 m (2 to 4 ft) deep and  15 to 30 m (50 to
100 ft) wide (depending on seasonal  variations) at  the Firestone
site.  The river is 33 m (110 ft)  above sea  level and the
landfill is 9 m (30 ft) deep.  The river's 100 year frequency
flood raises its level 9 m (30 ft) which would flood the bottom
of the landfill.  This has occurred three times in  recent years.
The site is fairly flat''with a small  valley  that will be filled
in with the expansion of the old landfill.  The old landfill
itself is flat across the top with steeply sloped sides.

     The subsurface consists of two distinct materials.  Alluvium,
6 to 7.5 m (20 to 25 ft) thick, lies  at the  surface and consists
of thin layers of silt, sand, and  gravel.  The water table levels
in this material correlate closely with river stages.  There  is
little hydraulic gradient in this, the upper, or shallow flow
system.  The landfill and lagoons  lie in this material.  Under-
lying the alluvium are the Lockatong  Formation, a mudstone and
shale, and the Brunswick Formation,  a shale, siltstone, and
sandstone.  The bedrock is not horizontal but dips  approximately
30 degrees to the southeast (see Figure 3-3  and 3-4).  Ground
water in this, the lower or deep flow system, occurs along
joints and bedding planes of the Brunswick Formation.  The deep
wells used for process water and potable water extend down into
this system.  There is some communication or recharge from the
shallow to the deep ground water.   Therefore, the Schuylkill
River, the alluvium aquifer, and the  bedrock aquifer are not
independent of one another.

     The area around the Firestone site is hilly and well drained.
Elevations range from 33 m (110 ft)  to over  90 m (300 ft) as
seen in Figure 3-4.  The vegetation at the Firestone site consists
of grasses and some hardwood trees.   The trees grow along the
river banks and in the small valley.   Native grasses have been
planted on the landfill and other  disturbed  areas.

SITE OPERATION  AND HISTORY

     In 1942, Jacobs Aircraft Engine  Company operated a machine
shop and defense plant for the production of aircraft engines  as
part of the war effort.  Cutting oils, metal filings, and other
wastes were placed in an open dump on the site.  Firestone Tire
and Rubber Company bought the plant in 1945  and began tire
production soon afterwards.  They  continued  the use of the
open dump through the early 1960's converting it to a landfill
accepting vinyl resins, factory trash, and rubber tires.  The
landfill was originally 5.3 ha (13 ac) in size.  Six earthen
lagoons were also used for PVC wastes.  Six  deep wells were
used in the early 1960's to supply water for process uses.
                              48

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                                                THIS AREA BOTTOM LAND

                                                SCATTERED TREES S THICK BRUIH
                                                       \
                                                              OKI

                                                     ZOO	400FT
                                            OUTS
                                                     • O PLANT WATER
                                                        WELL

                                                     M I • LANDFILL MONITOR!*
                                                        WELL (SHALLOW)

                                                     OW2 • OBERVKTIOfl WCLL

                                                          (DEEP)
Figure  3-1.   Partial  map of  the  Firestone  plant  showing
  some  wells  and pits  used  for  remedial  action.  [3-1]
                                  49

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_.._..:>
    .3
              I KM
                                    PLANT WELLS


                                    INVESTIGATION WELLS


                                    LANDFILL


                                    FIRESTONE PLANT
  0   IOOO  ZOOOFT
Figure 3-2.   Location map  of  Firestone plant
            with  remedial action  wells.
                          50

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                                                        SE
                            FIRESTONE PLANT
                        ALLUVIUM
                     THIN SAND, SILT OR GRAVEL LAYERS
On


3m

10 m
                                                             20m
        BRUNSWICK FM
Figure  3-3.   Rough   geologic  cross  section  of the  material
              underlying  the Firestone  plant.
                                51

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     IFENNSYLWWU /
     i     ;>
                                   LANDFILL
LOCKATONG FORMATION
(MUDSTDNE AND SHALE)
        _5	I KM
Figure  3-4.   Location  and partial geologic  map for
  Firestone's  Pottstown, Pennsylvania  plant.  [3-2]
                            52

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     Currently, Firestone operates a tire manufacturing  plant,
a chemical  plant, and a sheeting plant which  produces  plastic
resins, film, and sheeting products.  They have  proceeded  with
plans to close their tire plant.  However, the chemical  plants
will remain in operation.  Before the tire plant was  closed,
Firestone employed nearly 2,400 people, and produced  450,000  kg
(1 million Ibs) of finished tires per day.  Both the  number of
employees and the amount of tires produced declined as closure
activities continued.  The chemical plant employs 450  people  and
the film and sheeting plant 250 people.

     Both the tire and the chemical plants contributed to  the
landfill.  In early 1971, an average of 30 metric tons (33 tons)
of waste was landfilled per day; the majority of which was
factory trash and paper.  The following is a list of typical
landfill refuse:
     •   Tires
     •   Paper
     t   Carbon black
     •   Polyethylene
     t   Wastewater treatment
           siudge
     •   Metal banding and
           strappings
     •   Wooden pallets
     t   Coagulated butadiene/
           styrene latex
           wastes
     •   Miscellaneous
           compounding agents
           or dust from- clean-
           up  activities
           (including sulfur
           and zinc oxides)
Inert cloth and rubber
Rubber flashing
Oily rags
Polyvinyl chloride (PVC) film
Clay
Talc
Boiler fly ash
Synthetic polymer fabric
Oil/water emulsions
Sulfur dioxide sludge
Floor and roadway sweepings
Fiber drums
Lagoon wastes  (including
  calcium carbonate,
  calcium hydroxide, and
  PVC resin)
Two lagoons are now used by the chemical
lined and used only during emergencies.
material added to the  lagoon.

POLLUTION
      plant.  Both are rubber-
      Wastewater is the only
      Initially,  the  landfill  and  lagoon operations were considered
environmentally  adequate  by  the  Pennsylvania  Department of
Environmental  Resources.   However,  subsequent  monitoring of wells
and  the  Schuylkill River  indicated  contamination.  Contaminants
detected  in  the  ground water in  1972  from  monitoring  wells
placed around  the  landfill included iron  (185  ppm), manganese
(20  ppm),  aluminum (10 ppm),  and  sulfates  (140 ppm).   Because
of the interconnection of the two aquifers  as  well as the
Schuylkill  River,  all three  water bodies  were  threatened by
the  pollution.
                               53

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     The landfill was accepting nearly 27 metric tons  (30  tons)
of refuse per day in 1970 when Firestone applied for a new
permit to operate a sanitary landfill.  The permit was approved
in July 1971, but not actually issued until  August 1973 due  to
permit infractions and revisions.   It was the first industrial
land disposal permit issued by the State's Division of Solid
Waste Management.

     Firestone received a variance for a pilot plant process to
remove sulfur dioxide and fly ash  from their boiler stacks.
They also received permission to landfill the wastes from  the
sulfur dioxide scrubber system in  late 1973.  Wastes from  the
scrubber process included calcium  sulfite dihydrate, lime
residues, fly ash, and sodium sulfate.  The sludge was mixed
with dirt and landfilled.  Use of  the scrubber system began  in
February 1975 as an experimental one-year operation in cooperation
with the State.   A permit for continued operation of the
scrubber processing and disposal facility was granted in
September 1977.

REMEDIAL ACTION

     In early 1974, the Pennsylvania Bureau of Water Quality
Management ordered that use of the six lagoons be discontinued.
Two of the lagoons were excavated  and one lined lagoon was
installed in their combined locations.  A second lined lagoon
was installed alongside in virgin  ground:.  These new lagoons
were lined with multi-1ayered rubber liners developed by
Firestone.  The other four lagoons were filled during this time
and a solids removal system was constructed upstream.   The
four lagoons were then discontinued.  Currently, solids which
are removed upstream go directly to the landfill and the lined
lagoons are used only in emergencies.  The new lagoons lie in a
one-hundred year flood area but otherwise there is no discharge
and, therefore,  they do not affect the ground water.

     In 1974 Firestone sought permission to expand their existing
landfill, but were first required  to install a leachate control
system since lining the expanded landfill to isolate it from the
ground water flow system was determined to be more expensive
than flow manipulation.  Also, it  would be impractical to
attempt to line the existing landfill.  Therefore, Firestone
began a ground watering recovery system consisting of 14 wells
located as shown in Figures 3-1 and 3-2.  Some of the extracted
water would be used for processing and potable uses.

     Three wells, used for potable water, draw a total of
0.01 m3/sec (150 gal/minute) and are 60 m to 120 m (200 to
400 ft) deep.  Five wells are used for process water which is
deionized previous to use in the polymerization process.  These
wells draw 0.006 to 0.01 m3/sec (100 to 200 gal/minute) each.
The five wells form a large zone of depression beneath the
                              54

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seepage lagoons and the  landfill.   Recharge  from  the alluvium
aquifer is  drawn to this large  zone of  depression.  Therefore,
the pollutants entering  the  shallow flow  system  (alluvium
aquifer) are similarly drawn down  and do  not flow to the
Schuylkill  River.   Water from the  Schuylkill  River enters  the
alluvium aquifer as recharge.   Flow manipulation  has altered
the original flow pattern of the alluvium aquifer which recharges
both the bedrock (deep flow  system) and the  Schuylkill  River.
Four wells  are used for  monitoring.  This recovery system  has
been effective in controlling off-site  migration  of pollutants.

     The data presented  on the  graphs contained  in Figures 3-5
through 3-8 illustrates  the  problems of the  pollution  to  the
ground water as well  as  the  effectiveness of the  use of the
recovery wells.  No graphs illustrating iron, phosphate,  or
manganese contamination  are  included.   Early sampling  for  iron
was affected by contamination by the iron casings in the  wells.
Phosphate and manganese  results are too vague to indicate
consistent  contamination or  trends.

     Firestone has discontinued their tire manufacturing  plant
so less material is now  being landfilled.  Their chemical  plant
will continue use of the seepage lagoons and landfill.
Therefore,  the recovery  system should be adequate to  control  the
water flow  system and the migration of  pollutants.  Monitoring
will continue on a quarterly basis.

     Firestone paid $40,000  for a hydrogeologic  study  to  deter-
mine the best means of leachate control and for  the placement
of the recovery and monitoring wells.   Another $210,000 was
used for revisions to the permit application and revisions
necessary to complete the landfill expansion.

CONCLUSION

     Firestone has attempted, through several types of remedial
action, to  control leachate migration from their Pottstown
facility.  There has been a threat of contamination to the
ground water  (a two aquifer system) and to the surface water
(Schuylkill River).

     Firestone converted their open dump to a landfill in the
early 1960's.  This helped  control surface conditions  (blowing
litter, etc.).  No data  is  available to  determine whether this
influenced  the leachate  entering  the ground water, soil,   or
the Schuylkil1 River.

     In 1974  and 1975,  Firestone  closed  their earthen lagoons
and built two  new  lined  lagoons.   They also  initiated a ground
water recovery system which manipulated  the  flow  of ground water
                                55

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  200
i100
                              Ul
                              CK
      1972 11973  11974   11975  I 1976  I 1977 11978  ' 1979  ' 1980 I



  Figure  3-5.   Sulfate concentrations  in the ground water
      before and after the use  of the  recovery wells.
  40
  30
  20
   10
                         •    o
                              o
                              LU
                                        •


                                     • •   •
      1972  11973  11974  I 1975 I 1976  I 1977  I 1978  11979  11980 '


  Figure  3-6.   Five day BOD  in  the  ground water  before and

               after the use  of  recovery wells.
                               56

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   200
UJ
o
re
p
100
                            §
                               a
                               UJ


                               UJ
            	

       1972  I 1973 '  1974  ' 1975 I I97B  ' 1977  I 1978 ' 1979  ' 1980  '



      Figure 3-7.  Chloride  concentrations  in  the ground water

             before and after the use of  recovery wells.
  1,000
   500
                               <

                               s

                               3
                               QC
       1972  11973  I 1974  ' I975M976 M977  '1978  ' 1979  ' I9&0 '



   Figure  3-8.   Concentration of total solids  in the ground  water

           before and after  the use of the  recovery wells.
                                  57

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to prevent off-site migration of pollutants.   These  two  actions
occurred close enough in time and location to make  it  necessary
to assess their effectiveness simultaneously.  Both  the  supporting
data and persons with the Pennsylvania Department of Environmental
Resources indicate that no off-site migration of pollutants  is
occurring now.  It is predicted that the threat of  contamination
to the ground water and to the Schuylkill  River will lessen  with
the closure of the tire manufacturing plant.   The cost of the
hydrogeologic study and the recovery wells ($250,000)  as a
preventive measure is much less than the cost of extensive
cleanup of migrating pollutants which could have appeared in the
ground water  and in the Schuylkill  River.
                              58

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            SITE B REFERENCES AND BIBLIOGRAPHY
3-1   Martin and Martin,  Inc., and Todd Giddings and Associates.
     Report to Department of Environmental  Resources on
     Hydrogeology of the Existing Landfill, Proposed Landfill,
     and Sludge Lagoons:  The Firestone Tire and Rubber Company,
     Pottstown, Pennsylvania.  1975.

3-2  Pennsylvania Geological Survey,  Pennsylvania Geological
     Survey Report W-22.
                               59

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   APPENDIX 3-1



SITE B PHOTOGRAPHS
          60

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View of part of the old landfill.  Note access  road
trees (which border the river)  in  the background.
Ponded  water is the result of  a recent rainfall.
and
                         61

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View of the edge of the old  lagoon.   The  final  cover
and vegetation were quickly  established.
                        62

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View from the old lagoon  looking  toward the  proposed
area for the new lagoon.
                         63

-------
View of the old lagoon's  final  cover and  vegetation,
Numerous deer tracks  were seen.
                         64

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                          SECTION 4

                            SITE C

           ANONYMOUS WASTE DISPOSAL COMPANY DUMP SITE
                      EAST-CENTRAL NEW YORK
INTRODUCTION

     Since 1958, the discharge of hazardous wastes from a  dump  site
in east-central New York has been of concern to local  residents  and
to the State and County Health Departments.  Despite warnings  from
the State and County and complaints from local  residents,  the  Company
continued to accept wastes from local  industries for disposal.   In
1964, the Company tried to contain the pollution by building a  dam
across the site outlet,in the process  forming a waste lagoon.
However, the dam was ineffective and waste continued to escape  from
the dump site.

     In 1966, the State ordered the Company to stop dumping.   Dumping
continued, however, fish kills occurred, and the State Attorney
General initiated court action.  In 1968, the Courts ordered  the
Company to refrain from further discharges of wastes into  nearby
streams, to cease dumping at the site  immediately, and to  remove
the wastes already there.  The Company complied with the cease-
dumping order.   However, area residents complained again in
Spring 1970, when heavy rains sent wastewater over the dam.  The
site was finally cleaned up by the Company between 1970 and 1974.
The area was capped with soil and a ditch constructed to divert
surface water around the site.

     Concern over the effectiveness of remedial action developed
several years later.  Noticeable chemical and oil contamination of
area streams was traced to ground water seeps at the site.  Further,
water, sediment, and fish samples from a downstream lake revealed
the presence of polychlorinated biphenyls  (PCB's), and these  too
were traced to the dump site.  Additional remedial action, including
the construction of a slurry wall, is  now being considered.

SITE DESCRIPTION

     The waste disposal site is located in a rural area approximately
24 km (15 mi) southeast of a large city, 6 km (4 mi) northeast  of
a small community, and 5 km {3 mi) from a lake in east central  New
York.  Area residents and vacationers  use the Lake for fishing  and
other recreational activities.  The land is partly wooded  and  partly
pasture land used for grazing.  Several residents live in  the
vicinity of the dump site (see Figures 4-1 and 4-2).

     When the waste disposal Company terminated its dumping
operations in 1968 as a result of legal action by the State of


                               65

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Figure 4-1.   Site  C location  map.
             66

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Figure 4-2.   Site  environs  (1966  before  closure).
                        67

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New York, the operations included two wastewater lagoons,  one
oil pit, four above ground storage tanks, a storage shed,  and  a
drum burial area on the south and eastern perimeter of the dump
site.  The lagoons, referred to as the lower and upper lagoons,
were approximately 0.4 ha (1 ac) and 2 ha (5 ac) in size respec-
tively, and were separated by an earthen dike.   The dimensions
of the earthen dam across the outlet of the lower lagoon were
estimated at 14 m (45 ft) long and 3 m (10 ft)  wide.   The  oil
pit on the site was approximately 2 m (6 ft) deep and had  an
approximate area of 8 m (25 ft) by 46 m (150 ft).  Four large
steel oblong storage tanks, each having a capacity of 114  m3
(30,000 gal), the storage shed, and the drum burial area are
located on the eastern and souther sections of  the site.  The
entire dump site was 4 to 6 ha (10 to 15 ac).   Figure 4-3  shows
the waste disposal dump site as it appeared in  1968.

     The climate of New York State is representative of the humid
continental type which prevails in the Northeastern U.S.  The
average annual temperature at the site is 14°C  (58°F) and  the  average
annual precipitation is 84 cm (33 in.).  There  are an average  of
155 days between late September and early May with minimum
temperature of 0°C (32°F) or less and 137 days  with precipitation
of 0.03 cm (0.01 in.) or more.  The average annual snowfall is
168 cm (66 in.).

     The dump site is the low point of a 40 ha  (100 ac) watershed.
Drainage from the dump site is through a small  0.8 km (0.5 mi)
tributary stream to the upper reaches of a perennial  stream.   The
perennial stream is approximately 3.2 km (2 mi) long and empties
into the Lake north of the community, southwest of the dump site.
Currently no surface water enters the site.  Drainage ditches  have
been constructed around the dump site to divert all runoff.
Originally, the waste disposal dump site was a  flat,  wet marshy
area about 600 m.,(2,000 ft) long and averaging  75 m (250 ft) wide.
The terrain sloped upward into a wooded-area from the marsh.

     Glacial  deposits left during the Quaternary period
mantle the entire  region except for small isolated rock outcrops
and recent alluvium.  These glacial deposits differ considerably
from one another in lithology and thickness, and may be divided
into till,  kames, and outwash.  Till is a heterogeneous mixture
of largely unsorted material ranging in size from clay to  boulders,
and topographically it forms the tops of the nearby hills.  Owing
to the lack of sorting and the presence of much fine material, the
till has a low permeability and yields only small to moderate
quantities of ground water.  Overlying the till in most of the
stream valleys are kames forming terraces and  knobs of sand,
gravel, and boulders.  Meltwater along the edges of the glacier
stripped the  till  and kame deposits pYoviding the source for the
accumulation of outwash (stratified stream deposits formed by
glacial meltwater) in the deglaciated tributary and perennial
                               68

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                                                    DRUM BUNM.
                                                      AREA
 • MONITORNO VCLLS
Figure  4-3.   Facility layout  in 1968  before closure.
                           69

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 stream valleys to the south.  Ground water yields in the outwash
 average about 0.5 m^/min (140 gpm).  Thickness of the outwash
 material below the dump site is approximately 9 m (30 ft).
 Clays and silt alluvium cover the outwash.  The thickest alluvium
 lies in the perennial stream near the Lake.  A geologic cross
 section through the dump site showing bedrock, glacial  deposits,
 alluvium, and the water level at the site is presented  in
 Figure 4-4.

 SITE OPERATION AND HISTORY

     The Company operated as a private scavenger service collecting
 and disposing of waste chemicals and oils of various chemical
 and industrial plants in east-central New York.  Hazardous  waste
 materials were collected in 0.2 m^ (55 gal) drums and transported
 to the dump site.   The contents of reuseable drums  were dumped
 into the pit or into the upper lagoon.  Unuseable drums were  dumped
 either on the perimeter of the upper lagoon or in the drum  burial
 area.  Drums were later covered with soil using a medium size
 bulldozer.   The pit was used to store and separate recyclable
 oily wastes.  The non-recyclable contents were pumped into  the
 lagoon or onto the ground surface.

     The Company currently has a scavenger waste permit and is
 allowed to store oil  in the four oil tanks.  The oil tanks  operate
 as a backup storage and transfer station for oily wastes which
 are disposed of at a New Jersey site.  There are no longer  any
 lagoons or pits to dispose wastes,  including water from oil
 tank trucks.  However, hundreds of drums remain at the  site,
 many of them unburied.  Some waste still remains in the drums
 and has dried to a tar-like consistency; most of the drums  have
 leaked onto the ground.

     During the period of active dumping from 1955 to 1968, large
 amounts of oils and chemicals were dumped at the site.   Industrial
wastes dumped in the area included toluene, silicone, benzene,
xylene, phenols, polychlorinated biphenyls (PCB's), isopropanol,
acetone,  methanol, butanol, trichloroethylene, methylchloride,
oils, and paints.   Portions of the waste oil were from  cutting
and cooling operations and contained impurities, such as metal
grindings,  filings, and silicone.

     During 1965,  one industry disposed of 3,340 m3 (883,000  gal)
of silicone-contaminated wastes through contract with the Company.
The industry estimates the total  quantity of waste material taken
by the Company in  the 1960's at approximately 13,617 metric tons
 (15,000 tons), much of it liquid solvents or water solvent  mixtures.
A substantial  quantity of filter cake and other solids, often
saturated with solvents, was also  removed.
                               70

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   10-
Figure 4-4.   Generalized geologic cross section
               of Site C in 1980.
                        71

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     Another industry disposed of 3,460 m  (914,000 gal)  and
17 metric tons (19 tons) of wastes from April  1,  1965 to  April  1,
1966.  For seven years, from 38 to 57 m3 (10,000  to 15,000 gal)
of wastes were received from a third company.

     In August 1953 the owner of the Company acquired the property
for industrial waste disposal activities.  The property was in
an undeveloped area of east-central  New York and  at the time
seemed to be an ideal location for waste disposal  operations.
At the smae time, area residents were informed what the property
was to be used for, but there were no objections  to the purchase.

     During the summer of 1955, the Company initiated their
scavenger service for the collection and disposal  of wastes,
chemicals, and oils from various industrial establishments.  In
late October 1958 the County Health Department received a complaint
from a property owner adjacent to the dump site.   The owner
reported that the Company's dumping had contaminated his  pond  and
well.  As a result, the property owner was forced to obtain water
from another source for domestic use.  A County Health Department
inspection was the first indication that a serious water  pollution
problem existed.

     A year later, in October 1959, the County Health Department
received additional complaints that waste oil  products were
seeping from the property and damaging livestock  and private  wate
supplies.  The Company was advised of the continued complaints
and was again instructed to confine their waste discharges.  Steps
were undertaken by the Company to regrade the  property so that
drainage of oil from the dump site was minimized.   The Company
stated that in the future, oil received would  be  promptly burned
and not permitted to accumulate.  However, the complaints
persisted, and follow-up inspections by the Health Department  were
conducted.  Each inspection reached the same conclusion:

     1.  Conditions at the dump site were not  improving.

     2.  Freshly dumped oil and chemical wastes were found at
         the dump at each visit.

     3.  Oil and chemicals were observed in the tributary
         and on farm ponds.

     4.  Strong chemical odors pervaded the area  and some
         discharges were found in the Lake

     In March 1963, inspections indicated evidence of repeated
oil and chemical discharges.  At various points along the
tributary and perennial stream to the Lake, evidence of No. 2
fuel oil and silicone odors was evident.
                               72

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     Warned by the  State  and  County  Health  Departments about further
discharges, the Company constructed  dikes and  diversion ditches
around the disposal  area  to  contain  the  waste  chemicals and oils.
However, the dike and diversion  ditches  were only temporarily
effective.  In September  1963, residents prepared a petition
requesting that further dumping  and  burning of wastes at the dump
site be discontinued.  In May 1964,  the  Company constructed an
earthen dam across  the outlet of the swamp  to  pond the wastes in
a lagoon.   This measure was  largely  ineffective in controlling
discharges; sludge  still  leaked  from the dam and entered the
stream as  before.

     On July 31, 1964 the County Health  Department recommended
that surface disposal of  waste be eliminated,  and scum, sludges,
and other  deposits  collected  and enclosed  in  impervious containers
as soon as possible.   In  order to discharge,  the Company would
need a permit to comply with  the law.   Because voluntary pollution
abatement  was not successful, and because  open dumping  and  burning
of wastes  continued,  causing  a serious  public  health  hazard,  legal
action against the  Company was initiated in September 1964.   The
Company continued to act  in  violation of water standards adopted
by the State and to discharge -wastes without  a permit.

     In April 1965, drums of contaminated  gasoline,  spilled by
a bulldozer, caught fire  and  spread  to  the  lagoon.   Complaints
of burning at the dump were  received.   Dense  smoke  and  odors  were
prevalent  in the area.  Fire spread  to  the  wooded  area  surrounding
the dump.   Several  months later  in July 1965,  another serious  fire
broke out  when chemicals  stored  at the  site ignited  spontaneously
while attempts were made  to  cover the drums.

     In 1965, amendments  to  the  Public  Health Law  allowed  the
State Health Department to take  more effective measures against
polluters  of the State's  waters.  An administrative  hearing was
convened by the State Commissioner of Health  during  September 1966,
at which time an order was issued directing the Company to  stop
dumping its wastes by the end of October 1966, and  to remove the
remaining wastes from the site by April  1,  1967.

     Despite the Commissioner's  order,  dumping operations  were  not
halted.  Numerous field inspections  by the Health  Department
revealed that chemical wastes were being dumped into the  lagoon
and the lagoon outlet was leaching to the tributary.   Deposits  of
a yellow-orange colored substance covered the tributary's  bottom
soil and rocks, and  oil slicks were observed  in one location.
Inspections  in 1967  revealed hundreds of drums were still  being
dumped at the site.   In October 1967, a 15 cm  (6 in.) diameter
valve outlet pipe to  the tributary was  inserted in the edge of
the lagoon providing  a direct outlet for the  waste.   The outlet
and additional construction, including  a dike  dividing the lagoon
into upper and lower  lagoons, violated  the Public Health Law
                                73

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which required permits for such activities.   These actions  were
responsible for fish kills and pollution of  the perennial  stream.

     To enforce the Commissioner's  order and to prevent the
Company from further endangering the public  health,  the case  was
formally referred to the New York State Attorney General's  Office
on May 31, 1967.   Court action was  initiated on August  8,  1967,
ordering the Company to cease disposal  of wastes at  the site.
Dumping was finally terminated in 1968.

POLLUTION

     During the period of active dumping between 1955 and  1968,
large amounts of  oils and chemicals were dumped into the lagoons
and oil pit.  Hundreds of drums containing chemical  wastes  were
also scattered along the perimeter  of the property,  in  the  lagoon,
and buried in the dump site.  Many  drums ruptured or were  opened,
their contents spilling onto the ground surface and/or  into the
lagoons.  Waste leached into subsurface soils from buried  leaking
drums.  With each rainfall, waste washed or  leached  into the
lagoons.  The lagoons and oil pit were often heavily coated with
oil and sludge floating on the surface.  Strong chemical odors
were emitted from the site.  Spontaneous and intentional fires
were common and heavy clouds of acrid smoke  drifted  over the
adjoining countryside.

     Some oils and chemicals leached from the drum burial  site  and
lagoons into a swampy area north of the dump site.  At  the  outlet
of the lagoon, oils, chemicals, and sludge frequently leaked  into
the tributary through holes breeched in the  dam  by  runoff.

     Numerous documentations were made concerning chemical  wastes
and oils entering the tributary, perennial stream, and  Lake.   The
tributary flowed  through several farm pastures used  as  grazing  land
for cattle.  Cattle illnesses and deaths were reported.  A pond
in the tributary  accumulated a 7.6cm (3 in.) layer of oil,  often
killing ducks, herons, and other wildlife or preventing them  from
remaining there.   Several fish kills occurred in the perennial
stream.  In 1963  water in the perennial stream 515 m (1,700 ft)
downstream from its confluence with the tributary was contaminated
with trichloroethylene and toluene  and was fatal to  test fish
within 12 minutes.  In 1966 the water in the tributary  about  1.8 m
(6 ft) above its  confluence with the perennial stream diluted with
an equal volume of water was fatal  to test brown trout  within four
hours.  The fish  kill and absence of aquatic fauna was  a result
of high phenol concentrations.  Water samples taken  in  1965 and
1966 above and below the confluence of the tributary and perennial
stream and in the tributary showed  conclusively that the source
of phenols was the dump site.  The  perennial stream above the
tributary contained phenols at 5 ppb.  The tributary varied in
phenols content from 29 ppm to 99 ppm.   The  perennial stream below
the tributary  varied in phenol content from 86 ppb  to  774 ppb.
                               74

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     Residential  wells  were  contaminated  during  the time of the
fish kills.   In some  cases  it  was  felt  that  the  contamination was
not necessarily due to  ground  water  influence, but due to surface
waters intruding  into the wells  from the  tributary which flows
alongside the wells.   However, it  was believed that contaminated
surface water had slowly percolated  to  the  ground water table and
that neighboring  wells  located in  the direction  of ground water
flow had become contaminated.   Table 4-1  presents data from water
samples taken in  March  and April  1966 in  the tributary, perennial
stream, wells, and springs.

REMEDIAL ACTION

     In the  spring of 1970,  a  large  quantity of  waste  products was
discharged from the lagoon with surface runoff and swept downstream
into the Lake, leaving  a film  coating on  the surface.  State  and
County health officials recognized the need for  further  action.
In a final effort to purge the lagoon of  its pollutants, health
officials issued  a burning permit to the  operator.   The  object
was to "burn off  the top" of the lagoon,  destroying  as much  as
possible of  the floating wastes.   Whatever wastes  remained  were
to be  "skimmed off" by  the operator and placed  in  sealed drums.

     Because of the weather conditions and the  serious air  pollution
problem and  fire  hazard that would be created from  the burning,
State  and County  officials re-examined the situation and  suspended
the burning  permit.  There were many dead trees  surrounding the
lagoons and  it was believed that if the lagoons  were set on fire
the dead trees would probably  catch fire also.   In  addition,  any
type of burning was ruled out  because of the concern of  the
toxicity of the combustible products and the large  number  of
unknown chemicals in the lagoons.

     Other alternatives considered included skimming the wastes
from the lagoons and burning  them at another site or applying
straw  or wood chips on the lagoon to induce "accelerated bacterial
decomposition".  Another alternative considered  was  filling the
lagoons, constructing a ditch to divert the stream,  and  regrading
the site.  A  final alternative considered was pumping the  lagoon
contents into open sand beds  to filter out the wastes, filling
the lagoon,  and removing remaining wastes to a sanitary  landfill
or other burial site.

     Discussions between State and County representatives  in a
June 1970 meeting resulted in an agreement  that the Company should
undertake immediate steps that would serve  to abate the
problem.  To  guarantee the Company would take the necessary actions,
a  schedule for immediate and  long term measures to cleanup the
lagoon was developed,  including the  following tasks and deadlines:
                                75

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TABLE 4-1.   WASTE DISPOSAL  COMPANY  SAMPLING (1966)
 Date
               Sampling Location/Source
                                              Phenols (ppb)
_p_H_
3/25/66
3/25/66
3/29/66
3/29/66
3/29/66
3/29/66
3/29/66
3/29/66
3/29/66
4/5/66
4/5/66
4/5/66
4/5/66
Lagoon - 30 m (100 ft) from discharge
Discharge from lagoon
Lagoon - northwest end
Pond overflow
Tributary
Perennial stream - below
Perennial stream - above
Dug wel 1 - Residence A
Spring supply - kitchen
Dug wel 1 - Residence C
Dug well - Residence D
Dug wel 1 *1 - Residence
Dug well 12 - Residence




tributary
tributary

tap - Residence B


E
£
148,000
134,000
140,000
14.600
8.600
86
<5
11.2
<5
293
6.2
<5
10.4

~ ~
5.0
6.5
7.2
7.3
7.1
6.3
6.8
6.3
6.9
6.5
6.5
1  m • 3.3 ft
                               76

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     1.   A competent water pollution  abatement  engineer was to
         be retained by the Company  by  July  15,  1970.

     2.   A report addressing the  extent of pollution,  the nature
         of the  wastes, and proposals  for pollution  abatement
         was to  be completed by  October 30,  1970.

     3.   A satisfactory and stable  dam  was to be completed to
         contain the polluted waters  in the  two  lagoons at the
         site,  and the outlet pipe  was  to be removed by July
         31, 1970.

     4.   A ditch was to be completed  diverting  the  influent stream,
         and necessary grading was  to  be completed  to assure  that
         no further runoff would  enter  the lagoons  by July 31,  1970.

     5.   All floating pollutants  were  to be  removed  from  the
         lagoons and disposed of in  an  acceptable manner  by
         August  31, 1970.

     In  complying with the schedule,  the Company encountered
problems, particularly because they elected  to  fill  in the lagoons
rather than building a satisfactory and stable  dam.   Described
below for each  of the tasks in the  schedule  is  a description  of
some of  the problems encountered and the effectiveness of each
task in  abating  the pollution:

     1.   Retain  a Competent Water Abatement  Engineer by July  15,
         1970.   In early July 1970,  initial  contact was made  with
         a local professional engineering and surveying firm
         acceptable to the State and County  Health Departments.
         In early August 1970, the  Company  retained the engineering
         services of that firm.

     2.   Submit an Engineering Report by October 30, 1970.   The
         report was submitted on schedule.   Portions of the
         report have been incorporated in the following section.

     3.   Build  a Satisfactory and Stable Dam and Remove the  Outlet
         Pipe from the Dam by July  31,  1970.  In July 1970,  the
         outlet pipe in the dam  was removed.  Instead of building
         a dam,  the Company chose to fill  the lagoons with
         material from the adjacent hill in  an  apparent attempt
         to permanently solve the pollution  problem.  State  and
         County officials gave informal approval to the proposed
         filling operations.

         In filling in the lagoons  the initial  plan was to section
         off the lagoons with dikes and then pump out the wastes
         into tanks.  The filling operations began  during July
         1970.   The initial earth-moving operation was directed
                               77

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towards creating a dike 0.6 to  1  m (2  to  3 ft)  in
height atop the dam for the purpose of preventing  any
further spills from the lagoons.   A Company bulldozer
created the'dike and the Company  then  proceeded to fill
in the lower lagoon which was about 0.4 ha (1  ac)  in
size.  By mid-August 1970, the  lower lagoon had been
substantially filled.

In the ensuing months,  filling  operations  in the upper
lagoon were slow.   The  plan was to section off the upper
lagoon area into two smaller lagoons with  the construction
of a new dike.  The lagoon was  to continue to be
sectioned until filling operations were completed.  The
major reason for the slow progress was that it was much
deeper than expected,  in addition to having a much larger
surface area.  As  a result most of the fill was saturated
below the water level  of the lagoon and was unstable,
making it difficult for the bulldozer to  pass over the
fill.  In the interests of securing firmer footing, the
Company decided to await freezing weather  before continuing
the fill  operations.

Subsequently, filling  operations  were conducted throughout
the winter.  As with the preceeding months, progress  was
very slow.  By June 1971, only  about five  percent  of  the
upper lagoon area  remained to be  covered.   Further effort
to fill and grade  the  former lagoon diminished by  summer's
end even though ponding of surface water was apparent,
particularly in substantial depressions in the eastern
part of the site farthest away  from the lagoons.  Limited
filling and grading was done in 1972,  1973, and 1974.
In 1973, the old oil pit was filled.  The  last filling
and grading at the site was in  October 1974.  Additional
fill material was  brought in on the southeastern end  of
the upper lagoon.   The  number of depressions had been
minimized and the  regrading was essentially adequate.
However, considerable  ponding of water was noted in
other areas near the old lagoons.  No further effort
has been made by the Company to complete the filling
and grading operations  since 1974 and the  appearance  of
the site has remained  relatively unchanged since that
time.  Some areas  have  been completely or  partially
overgrown by swamp vegetation and weeds.  Otherwise, the
fill material is exposed at the surface.   The Company
has made no effort to  revegetate the site.

Construction of Diversion Ditch by July 31, 1970.   Due
to the Company's decision to completely fill the lagoons,
the July 31 deadline could not  be met.  Construction
of the diversion ditch  was in conflict with the earth
moving operations  conducted at  the site to cover the
                      78

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   existing lagoons,  since the diversion ditch_was
   continuously crossed by heavy equipment obtaining
   additional fill material.  As a result, the Company
   requested and received a time extension from the  State
   and County health departments.

   Once the lower lagoon was filled, work proceeded  with
   the construction of the diversion ditch on the west side
   of the lower lagoon.  The plan developed by the State
   and County Health Departments and the consulting
   engineer was to maintain a minimum separation of  9 m
   (30 ft) to prevent seepage from the drum burial site
   and the former lagoon.  The  ditch was to be constructed
   in tight clay soil and a transit was to be used to assure
   that the diversion ditch had  the necessary grade.  Final
   sloping of the ditch was expected to be a  relatively
   simple matter.  When completed, the diversion ditch was
   to completely encircle the waste disposal  site.

   During the filling of the upper lagoon, attempts were
   made to build temporary  diversion ditches.  The  diversion
   ditches were constructed with  a sweep  by a bulldozer
   blade.  In addition, during  filling operations,  the
   ditches were frequently  blocked with  fill  material.   As
   a  result  they were not effective in diverting  the  surface
   water of  the influent stream around the  lagoons.   Surface
   water from the influent  stream  running  through the  lagoons
   was a constant problem.  However, the  diversion  ditches
   were effective in  intercepting  runoff  from the hill
   where fill material was  being taken  to  fill the  lagoons.

   Another major  problem was that  leachate  was frequently
   found in  the diversion  ditches,  mostly because the
   ditches were constructed too close  to  the  lagoons.   As
   a  result,  some chemicals seeped  from  the  lagoons and
   drum burial  site  into  the ditches.   One  case  occurred
   in  June 1971 where  leachate  from the  former lower  lagoon
   area had  seeped  into  a  ditch constructed  adjacent  to  the
   former  lower lagoon.   The Company was  immediately
   instructed  to  fill  the  ditch and construct a  new ditch
   further away  from the  former lagoon.   This action  was
   completed the  same  day.

   The  diversion  ditches  were  completed  in 1973.  They
   were  excavated with  a  rented backhoe  and graded  to permit
   proper  drainage.   Since  their completion,  they have
   been  effective in diverting  considerable amounts of water
   around  the former dump  site  area.

5.   Removing  All  Floating Pollutants from the Lagoons and
    Disposal  in  an Acceptable  Manner by August 31, 1970.
                          79

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         The Company removed the floating pollutants at the
         same time the lagoons were being filled.   The liquids
         displaced by the filling operations had been pumped
         to a tank truck for salvage use.  The largest portion
         of the surface skimmings consisted of waste oil,  and  this
         was used to spray dirt roads in the nearby towns  in
         which the Company had contracts.  Most of the floating
         pollutants that were in the lagoons were  removed  by
         December 1970.

         Despite the skimming operation, pollutants at the site
         continued to be a major problem.  This was predominantly
         due to surface water running into the lagoons, lagoons
         overflowing into the ditches and ground water seeping
         from the north bank of the upper lagoon.   Leachate
         accumulated in the depressions  of the filled portions
         of the lagoons where it had not been graded properly,
         forming small  shallow ponds with floating chemicals and
         oils.  Runoff or seepage of leachate into the diversion
         ditches was a constant problem.  In addition, underground
         leaching from the lagoons and diversion ditches was also
         observed on the north side of the road in the swampy  area
         opposite the dump site giving it a red-orange color and
         chemical-oily odor.

         Completion of the diversion ditch in 1973 diverted
         considerable amounts of water around the  dump site, thus
         reducing, but not preventing, leaching from the site.
         Ultimately, however, the leaching problem increased
         with time.  Ground water continued to seep through  the
         drum burial area and emerge from the north bank of  the
         upper lagoon contaminated with  chemicals  and oils.   To
         compound the problem, chemicals and oils  began to surface
         from the drum burial site and lagoons, predominantly
         from chemicals and oils stored  in leaking, deteriorating
         drums.  Many buried steel drums have corroded and are
         now collapsing causing sinks in the cover of the  site.
         In addition, it is believed that the severe winters in
         the late 1970's have had some effect in loosening the
         fill and allowing waste to percolate up through the soil.
         Heavy black oil and chemical seeps have been observed
         from the north bank of the old  lagoon area.  Ponding  of
         pollutants and strong odors are becoming  more prevalent
         and the marsh and tributary are becoming  discolored.

     Surface and ground water monitoring of the site has essentially
been in two phases.  In the first phase, two monitoring wells  were
installed approximately 90 m (300 ft) apart on the Company side
of the road with one well located about  15 m (50 ft) from  the
watercourse, culvert under the road (see  Figure 4-2).  Each well
was placed about 1.8 m (6 ft) deep with  0.2 m (0.6 ft) diameter
                                80

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perforated bituminous   fiber  pipe  as  casing.   In  addition, an
existing shallow well  about  0.4  km (0.2  mi)  downstream from the
Company's property was used  as a  third monitoring well.  This
well served as a domestic  water  supply and  had  been contaminated
earlier by discharges  from the dump  site.

     Installation of the two  monitoring  wells  on  the  Company's
property took place in February  1973.  Although analytical
results showed contamination, they were  not considered satisfactory.
Wells were not properly sealed and the water in them  was believed
to be contaminated with surface  runoff or  overflow of high waters
in the stream.  Thus,  the  results  were considered inconclusive.

     Surface water monitoring at the site  was  very  limited during
cleanup.  Grab sample  analysis of lagoon wastewater,  the marsh
opposite the dump site, and the  tributary  by the  consulting
engineer using infra-red analysis  techniques indicated the
presence of hydrocarbon groups,  such as  petroleum residues,  sul-
fur oxide, organic compounds, and substituted aromatic organic
compounds.

     The second phase  of surface and ground water monitoring
began in 1977 after indications  of a redeveloping pollution
problem.  Ground water contaminated with oils and chemicals
continued to seep from the north bank of the former lagoon  and
collect in  pools where the fill had not been properly graded.
Seepage into the marsh opposite  the road and probable contamination
of the tributary led to renewed  monitoring of the dump site.   The
dump site was ordered by State and County officials to be  placed
on a regular monitoring and inspection schedule to determine  the
degree of contamination of the tributary and perennial stream.

     Results of samples taken in 1977 and 1978 show low  levels
of contamination to the surface  water although the tributary
contained an orange color during warm periods of the year.
Several ground water samples likewise showed low levels  of
contamination.  Chemicals found in the water samples included
those disposed of at the dump site, including  xylene and benzene.
In addition, polychlorobiphenol  (PCB), a chemical used as  an
electrical insulator and a suspected cancer agent, was found
in  low concentrations  escaping from the site.

     Following additional sampling in the stream, it was decided
that sediment samples  from the Lake should  be  collected since
PCB's were more apt to  be detected  in the  sediments  rather than
in  the water.  Analysis of these  samples showed  PCB's (Aroclor 1260)
in  the  Lake although  not at  extremely high  levels.   It was also
decided   that fish  samples would  be analyzed.

     In  the  spring  of  1979 fish samples were collected in the
Lake.   These  samples  showed  levels  of 19.23 mg/kg of  PCB's in
Large Mouth  Bass  and  63 mg/kg in  samples of American  Eel.  Samples
                                81

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from a lake 10 km (6 mi)  downstream showed  the  Large  Mouth  Bass
to be less than 5 mg/kg.   American  Eel  samples  showed PCB levels
of 6 mg/kg.  In comparison,  the PCB level  guideline set  by  the
U.S. Food and Drug Administration (FDA)  is  5  mg/kg.   As  a result
of the PCB levels found in the samples,  the State  Health Depart-
ment warned residents against consuming  fish  in  the Lake during
November 1979 (a written  advisory was  not  issued until May  1980).

     Although the high levels of PCB's  in  the Lake were  a good
indication that the dump  site was the  probable  source, the  origin
could not conclusively be determined without  further  investigation.
Plans developed in November  1979 were  to take additional surface
and ground water samples  from the tributary and  perennial stream
because officials thought the PCB's could  be  related  to  old
leakage rather than new leakage.  In addition,  other  sources  of
pollution could be involved  including  waste oil  spreading
activities on roads.  Plans  also called  for the  gathering of
contaminated fish samples, as well  as  additional samples of
sediment and the invertebrates which dwell  on the  Lake bottom.
It was felt that sampling should be done in the  quiescent areas
of the Lake to determine  how widespread  the PCB's  were on the
Lake bottom.

     In November 1979, hundreds of  samples  were  taken from  the  Lake,
the perennial stream, the tributary pond,  and the  swamp  next  to
the dump site.  Water samples from  the  swamp  showed  extremely
high levels of PCB's.  However, fish from  the perennial  stream
and Lake had lower concentrations than  those  taken in April 1979.
Fish taken from the perennial stream,  regardless of  species,  had
a PCB concentration in excess of 5  mg/kg and  most  fish from the
Lake had PCB concentrations  between 2  mg/kg and  5  mg/kg. The
reason may be due to periodic flushing  of  the swamp.   During
periods of low flow such  as  the Fall,  PCB's accumulate in the swamp.
Then in the Spring or at  other times of high  runoff,  PCB's  are
flushed out of the swamp  into the tributary and  perennial stream
down to the Lake.  Results of the April  and November  samplings
are given in Appendix 4-1.

     After the discovery  of PCB's in fish,  ground water  from  15
wells was tested, including wells near the Lake  and  in the  higher
elevations near the dump  site.  Benzene, toluene,  and xylene
were found in a 19.5 m (65 ft) deep drilled well located along
the road 180 m (600 ft) west of the dump site.   Tests indicated
the presence of 15 to 20  ppb benzene,  versus  the ground  water
standard of 5 ppb.  This  was the first indication  that the  wastes
at the dump site were entering the  ground  water.  The other 14
wells did not show excessive benzene levels.

     To allow additional  ground water  monitoring in  the  immediate
vicinity of the site, four monitoring  wells were proposed in
December 1979.  The wells were installed in February 1980.
                               82

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Preliminary analysis indicates  that Wells  B-2,  B-3,  and  B-4
down-gradient from the dump site show ground  water  contamination.
Monitoring Well  B-l  up-gradient from the  dump site  shows  no
ground water contamination indicating that the  dump  site  is
the probable source of the ground water contamination.

CONCLUSION

     Although problems at first were minimal, conditions  at  the
site are growing steadily worse.  The primary reason is  that
ground water is  seeping through the very  permeable  fill  material
and is being contaminated by waste leaking from corroded  drums.
In addition, the severe winters in the late 1970's  have  aggravated
the situation.   It is evident that the remedial action was  not
effective and should not have been permitted.  A more positive
approach would have been to remove all pollutants,  including
buried drums  and contaminated  soil and water from  the dump  site
to an approved landfill.

     From laboratory analyses and the background history of  the
dump site, the following can be concluded about the recent
problem of pollution in the Lake and streams:  (1)  the  PCB
problem in the Lake has developed over a  period of  several
years and the most recent data  indicates  that a relatively  small
periodic discharge of waste is  occurring  from the dump  site; and
(2) PCB analyses of the various samples indicate the PCB's  in
the Lake originated from the dump site.

     Based on the evidence of ground and  surface water pollution
and also the deteriorating site conditions, State and County
officials have concluded further investigation will be necessary
to conclusively determine what course of remedial action will be
necessary to abate the pollution problem.  To further identify
the hydrogeologic condition of the site,  field checks including
geophysical studies and a more extensive drilling program have
been suggested to substantiate existing data.  This data will
give additional  insight into what types of remedial action
should be undertaken.  Remedial actions considered  for the
future have included the following:

     1.  Capping the lagoon with an impervious layer of  fill
         and improving the grading of the existing  fill  to
         prevent seepage.

     2.  Installing impervious cutoff walls around  the dump
         site through 6 to 9 m  (20 to 30 ft) of gravel  to a
         layer of glacial till  below to prevent runoff and
         leachate from reaching the watershed.

     3.  Lowering the flow of ground water into the tributary
         by installing a subdrain or French drain.
                                83

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     Concern over the cost of investigative studies and remedial
actions is a problem.  Possible recovery of these cost through
enforcement action and assessment of appropriate civil penalties
are among the suggestions.  The original court order issued to
the Company to close the site can probably be used to order the
necessary corrective action.   In addition, the industries
disposing of their wastes at  this site may be requested to pay
for a proportionate share of  the site cleanup or face possible
legal action.  If these fail, a special  remedial action fund
available at the Governor's direction could be used to finance
the cleanup.
                               84

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              SITE C REFERENCES AND BIBLIOGRAPHY
4-1   Personal  communication and file review with David Knowles,
     Department of Conservation, Albany, New York.   June 1980.
                                85

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          APPENDIX 4-1

WASTE DISPOSAL COMPANY  SAMPLING
    (1975-1979) FOR SITE C
                86

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            WASTE  DISPOSAL  COMPANY  SAMPLING
 DATE
TYPt OF SAMPLE
                                             PARAMETER
RESULTS
South Side  Drainage from Dump Site (Retching late)
11/20/79   Aquatic  Organisms
Haste Disposal  Company  Dump Site

3/B/79     Water  (Leachate)
           Center of  Fill Area


Dunp Site - Outlet from Site

9/26/75    Water


6/9/77     water  (Leachate)

6/10/77    Hater  (Leachate)
4/17/78    Water
6/29/79    Water


Swamp - North  Side of Road at Dump Site

11/20/79   Aquatic Organisms
                                        HydropMUd  bettle  (22)
                                        PCS 1016
                                        PCS 1254
                                        PCB 1260

                                        Fingernail clam
                                        (Approximately 100)
                                        PCB 1016
                                        PCB 1254
                                        PCB 1260

                                        Caddlsfly  larvae  (35)
                                        PCB 1016
                                        PCB 1254
                                        PCB 1260
                        Benzene
                        Toluene
                        Xylene
                        PCB 1016
                        PCB 1254

                        Phenols
                        Toluene
                        Xylene
                        Benzene
                        I.l,1-Tr1chloroethane
                        Trfchloroethylene
                        Tetrachloroethylene
                        Chloroform
                        Carbon tetrachlorlde
                        Bromodlchloromethane
                        PCB 1254
                        PCB 1221

                        I.l,l-Tr1chloroethane
                        Carbon tetrachlorlde
                        Bromodlchloromethane
                        Chloroform
                        TMchloroethylene
                        Tetrachloroethylene
                        COD
                        Arsenic
                        Silver
                        Cadmium
                        Chromium
                        Copper
                        Lead
                        Mercury
                        Z1nc

                        PCB 1016
                        PCB 1254
                                        Dytlsdde  bettle (15)
                                        PCB  1016
                                        PCB  1254
                                        PCB  1260

                                        Giant water bug (5)
                                        PCB  1016
                                        PCB  1254
                                        PCB  1260

                                        Caddlsfly  larvae
                                        (Approximately 25)
                                        PCB  1016
                                        PCB  1254
                                        PCB  1260
                                                 ND
                                                 NO
                                                 2.43 mcg/g
                                                 ND
                                                 ND
                                                 0.20 mcg/g


                                                 ND
                                                 NO
                                                 0.78 mcg/g
  >1,000  mcg/1
  >750 mcg/1
  >750 mcg/1
 < 0.25 mcg/1
 < 0.25 mcg/1
0.046 mg/1

 < 10 mcg/1
ND
 < 10 mcg/1
 < 5 rocg/1
 < 5 mcg/1
 < 2.5 mcg/1
 < 5 mcg/1
  <5 meg/1
  <5 mcg/1
1.5 mcg/1
  <0.02 mcg/1

  <5 mcg/1
  <5 mcg/1
  <5 mcg/1
  <5 mcg/1
  <5 mcg/1
  <2.S mcg/1
1* mg/1
  <0.02 mg/1
  <0.02 mg/1
  <0.02 mg/1
  <0.1 mg/1
0.05 mg/1
  <0.0004  mg/1
  <0.05 mg/1

  <0.25 me 9/1
  < 0.25 mcg/1
                                                ND
                                                ND
                                                186.64 mcg/g


                                                ND
                                                ND
                                                10.76 mcg/g
                                                NO
                                                ND
                                                £5.64
                                    87

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WASTE  DISPOSAL  COMPANY SAMPLING  (continued)
DATE TYPE OF SAMPLE PARAMETER
RESULTS
60 m (200 ft) West of Dump Site
11/7/79 Water
Benzene
Toluene
Xylene
< 1
< 1
< 1
mcg/1
mcg/1
tncg/1
          Perennial Stream and Tributary Junction

          11/7/79   Fish
         11/20/79
         Pond

         11/21/79   Aquatic Organisms




         I1/2V/79   Aquatic organisms
                                              Gasoline, kerosene,
                                               lubricating oi1,
                                               fuel  oil
Isopods (Apx.100)
PCB  1016
PCB  1254
PCB  1260

Cranefly larvae (23)
PCB  1016
PCB  1254
PCB  1260
                                                                    ND
Wite Sucker (3)
PCB 1260
Blacknose dace (4)
PCB 1260
Tesselated darter (1)
PCB 1260
Longnose dace (2)
PCB 1260
Creek chub (8)
PCB 1260
Creek chub (1)
PCB 1260
Creek chub (4)
PCB 1260
Fallfish (2)
PCB 1260
Fallfish (2)
PCB 1260
White sucker (6)
PCB 1260
White sucker (4)
PCB 1260
White sucker (2)
PCB 1260
White sucker (2)
PCB 1260
Crayfish (O.limosus 2)
PCB 1016
PCB 1254
PCB 1260
Dragonfly nymph (6)
PCB 1016
PCB 1254
PCB 1260
Caddisfly larvae (36)
PCB 1016
PCB 1254
PCB 1260

10.89 mcg/g

23. 55 mcg/g

30. 26 mcg/g

28.97 mcg/g

5. 22 mcg/g

14.1 mcg/g

5.35 mcg/g

9.43 mcg/g

8.92 mcg/g

19.10 mcg/g

1 5. 34 mcg/g

16.67 mcg/g

16.71 mcg/g

ND
ND
2. 54 mcg/g

ND
ND
1 . 98 mcg/g

ND
ND
0.93 mcg/g
0.63 mcg/g
1.23 mcg/g
ND
                                                                    0.34 mcg/g
                                                                    0.84 mcg/g
                                                                    ND
                                           88

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WASTE DISPOSAL COMPANY SAMPLING (continued)
DATE TYPE OF SAMPLE
Perennial Str«« - Between Like and
11/7/79 F1sh
















11/20/79 Aqmtlc Orginlsns







Perennial Stream
11/19/79 Domestic -Duck
11/20/79 Aquatic OrginJsms











Inlet to Lake
11/20/79 Aquatic Organisms







fait Side of Lake
11/14/79 Hater


ll/M/79 Hater


11/16/79 Water


Vest S-tde of Like
11/16/79 Hater


PARAMETER
Tributary
Brown Trout (2)
PCB 1260
PCS 1260
White sucker (4)
PCB 1260
White sucker (7)
PCB 1260
White sucher (3)
PCB 1260
White sucker (1)
PCB 1260
Famish (1)
PCB 1260
Fallflsh (7)
PCB 12CO
Pumklnseed (1)
PCB 1260
Caddlsfly larvae
PCB 1016
PCB 1254
PCB 1260
Cranefly larvae
PCB 1016
PCB 1254
PCB 1260

PCB
Crayfish (0, Hnrosus}<4 J
PCB 1016
PCB 1254
PCB 1260
Crsnefly larvae (13}
PCB 1016
PCB 1254
PCB 1260
Helgramnlte larvae (8)
PCB 1016
PCB 1254
PCB 1260

Crayfish (0. Hmosus) (1}
PCB 1016
PCB 1254
PCB 1260
Cranefly larvae (10)
PCB 1016
PCB 12S4
PCB 1260

Benzene
Toluene
Xytene
Benzene
Toluene
Xylene
PCB
Ml rex


PCS
Him

RESULTS


10.85 mcg/g
0.31 ncg/g

2.63 Ricg/g

2.4 ncg/g

7.01 mcg/g

0. 25 mcg/g

3,87 mcg/g

7.39 mcg/g

0.66 ncg/g

ND
ND
ND

ND
ND
1 .96 mcg/g

Awaiting Results

ND
NO
0.34 mcg/g

ND
ND
0. 98 mcg/g

ND
ND
1. 93 mcg/g


ND
ND
3.72 ncg/g

ND
ND
10.69 mcg/g

<1 mcg/1
<1 mcg/1
<1 mcg/t
<1 mcg/1
<1 ncg/1
<1 BIC9/1
0.5 mcg/1
Resample
1/80 Neg.

0.4 ncg/1
Resample
1/BO Neg.
                                89

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WASTE DISPOSAL COMPANY  SAMPLING (continued)
DATE TY*E OF SAMPLE
Lake
2/8/79 Sediment
61 m (200 ft) from Inlet
Sediment
122 m (400 ft) from Inlet)
Sediment
183 m (600 ft) from Inlet
Sediment
61 m (200 ft) behind Dame
at Outlet
4/24/79 Fish

PARAMETER

PCB 1221
PCB 1016
PCB 1254
PCB 1260
Mlrex
PCB 1221
PCB 1016
PCB 1254
PCB 1260
Mlrex
PCB 1221
PCB 1016
PCB 1254
PCB 1260
Mlrex
PCB 1221
PCB 1016
PCB 1254
PCB 1260
Hi rex
Largemouth bass(2)
PCB
DDT
American Eel (20
PCB - Average
(Range)
DDT - Average
(Range)
RESULTS

< 0.01 mcg/g
0. 02 mcg/g
< 0.01 mcg/g
0.3 mcg/g
<0.01 mcg/g
<0.01 mcg/g
0.02 mcg/g
<0.01 mcg/g
0.5 mcg/g
<0.01 mcg/g
<0.01 mcg/g
0.01 mcg/g
<0.01 mcg/g
0.4 mcq/g
'<0.01 mcg/g
< 0.001 mcg/g
< 0. 001 mcg/g
<0.001 mcg/g
0.01 mcg/g
<0.01 mcg/g
19.23 ppm
0.11 ppm
45.27 ppm
33.57 to 62.82 ppm
0.29 ppm
D.19 to 0.35 ppm
       ND - not detectable
                                 90

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   APPENDIX 4-2



SITE C PHOTOGRAPHS
        91

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Aerial  photograph of the dump site  (1966)
       The waste oil  pit (1966).
                   92

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Overview of the drum burial  area (1966).
      Bank of the lagoon (1966).
                     93

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      Overview of the site in June 1981)

Ground water seep from the bank of the former
lagoon (1980).
                      94

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                           SECTION  5

                             SITE D
                       DESTRUCTO/CAROLAWN
                  KERNERSVILLE,  NORTH  CAROLINA
INTRODUCTION

     The Destructo Chemway Corporation and Carolawn  Company,  Inc.
incinerator and drum storage site is  located  near the  Town  of
Kernersville in North Carolina.   In June 1977,  while the  facility
was managed by Destructo, a chemical  spill from the  site  contami-
nated Kernersville Lake/Reservoir which had served as  the primary
drinking water source for the Town of Kernersvi.il e.

     Ninety to 99 percent of the fish in the  20.2 ha (50  ac)
Reservoir were killed and over 200 people were  forced to  temporarily
evacuate their homes.  Fuel oil, toluene, ally! ether, xylene,
dichloroethane, trichloroethane, and 2-methyl-l, 3-diallyloxy
propane were later identified in the Reservoir's water.  Since
that time, Kernersville Lake has not been used  as a drinking
water supply, although analyses  of water samples have indicated
that toxic chemicals are no longer present in the Reservoir.   The
State of North Carolina has refused to approve  the use of the water
as long as a chemical disposal facility remains located within  the
Reservoir's watershed.

     Carolawn began using the site after  Destructo went  bankrupt
in 1978.  Carolawn operated as a waste storage and transfer
facility rather than a treatment/incinerator facility.   In late
1979, the Town of Kernersville succeeded  in forcing Carolawn to
vacate the site.  However, about 273 m3  (72,000  gal) of  chemicals
were left behind when Carolawn vacated the facility.

     Emergency cleanup measures  initiated after  the Destructo
spill included (1) deploying  a boom on a  tributary to the
reservoir, (2) placing sorbent material  in the ditch  from the
Destructo/Carolawn site  to the above  tributary,  (3) use  of an
underdrain spillway,  (4)  excavation of contaminated soil,
(5)  removal of dead  fish,  (6) placement  of contaminated  Cleanup
material in a  lined  pit  on the  property,  and (7)  installation  of
dikes around  the  tanks.   This emergency  cleanup  activity was
jointly funded by the U.5. Environmental  Protection Agency (EPA),
the  Town of Kernersville,  and the  State  of North  Carolina.

     Subsequent  remedial  activities associated with the  Carolawn
operation were funded by the  property  owner: Brenner  Shredder,
Inc./United Metal Recyclers.  When  Carolawn  abandoned  the  leased
property  in early 1980,  Brenner  contracted Browning-Ferris,  Inc.
                                95

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 (BFI) to remove the waste and r'egrade the s.ite.  Presently, the
 State believes the site has been improved to a reasonable degree,
 although some soil contamination remains on-site.  State approval
 of future use of Kernersvil1e Lake as a drinking water source will
 be based upon surface water and ground water monitoring to be
 performed in the future.

 SITE DESCRIPTION

     As shown in Figure 5-1, the Destructo/Carolawn site is located
 in north-central North Carolina to the west of the Town of
 Kernersville.  The annual precipitation in the area is 118 cm
 (46.6 in.) and the annual snowfall is 148 cm (58 in.).  The
 average wind speed is 12 kph (7.6 mph).  The average daily
 high temperature is 15°C (55°F) with the highest daily maximum
 occurring in July at 31°C (88°F), and lowest in January at
 -1.7°C (29°F).

     Little detail is known about the geology of the site due to a
 lack of sufficient boring logs.  No rock outcrops appear within
 the general  vicinity of the site.  The site is located atop
 granite gneiss and schist bedrock of the Charolette Belt and
 the soils are estimated to be 3.0 to 4.6 m (10 to 15 ft) deep.
 The soil  is a fine sand and loam with a high  permeability of 5
 to 15 cm/hr (2 to 6 in./hr).  Starting from the ground surface
 the soil  stratification is as follows:  silt, clay, silt, and
 sandy silt.

     The  site lies on two terraces.  The upper terrace is to the
 south of  the property, next to Highway 66.  The pit excavated by
 the U.S.  EPA during the spill lies in the southeast corner of
 the propery in the upper terrace.  This pit area would tend to
 drain toward the south, away from the Kernersville Lake.  The
 lower terrace housed the old incinerator, two storage tanks, and
 0.21  m3 (55 gal) drums.  The lower terrace to the north of the
 property   and part of the upper terrace drains toward Kernserville
 Lake (see Figure 5-2).

     The  seasonal  high water table is estimated to be between
 1.8 to 10.4 m (6 to 34 ft) deep.  Springs appear at a lower
elevation northwest of the site, and these and other springs
 feed Kernserville Reservoir.

     Kernersville Reservoir has a 435,275 m3 (115,000,000 gal)
capacity  and was used as the primary drinking water source for
the Town  of Kernersville prior to the spill  of 1977.  Drainage
from the  Destructo/Carolawn facility enters an unnamed tributary
about 2.5 km (1.5 mi) above the Reservoir and drains northward to
the Reservoir.   Kernersville Reservoir is man-made and has an
earthen and concrete dam with a spillway at the southeastern end.
Two surface streams and three undergound springs feed the
                               96

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Figure 5-1.   Site layout  of Destructo/Carolawn  site.  [5-1]
                           97

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                               'KERNERSVILLE LAKE
                                        .•jr....

                                   DESTRUCTO/CAROLAWN
Figure 5-2.
Drainage  pattern of Destructo/Carolawn
      site.   [5-2]
                           98

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Reservoir.   The Town  of Kernersville  requires  about  0.06 m3/sec
(1.3 mgd) of water.

SITE OPERATION  AND  HISTORY

     Destructo Chemway, Inc.  began  operating  an  industrial waste
incinerator in 1974  under an  air quality  permit  issued  by
Forsyth County.  Approximately 1.6  ha (4  ac)  belonging  to  Brenner
Shredder, Inc./United Metal  Recyclers was leased by  Destructo
to  house their facility.   Brenner operates a  metal recycling
operation on the property immediately adjacent and northeast
of  the Destructo site (see Figure 5-1).

     During the site's active years,  liquid wastes suitable for
incineration were transported to the  Destructo facility by truck
from industrial customers.  A tank  truck  of approximately  5.7  m3
(1,500 gal) capacity  was  used to transport the liquid  waste to
the Destructo site.   Once the waste had  been  transported to the
site, the liquid waste was segregated according  to its  BTU value
in  five large storage tanks.   The waste  was then transported
via PVC pipe to two  tanks adjacent  to the incinerator.   The
storage tanks had capacities  of 11  and 64 m3  (3,000  to  17,000
gal).  Small quantities of commercial  fuels were used  to
start up the incinerator.  There were no  dikes around  the
storage tanks, nor was there  any form of  secondary containment
to  contain  spills.  Likewise, the valves  on the tanks could be
opened by pulling a  lever, since no locks had been  installed.

     According to the Destructo Plant Manager, the  plant had
originally  been set  up by Chemwaste Corporation  (a  division  of
Brenner) and had operated since 1974 without  incident.   When
Destructo purchased  the equipment from Chemwaste, it was  agreed
that the equipment would  be  moved to a more suitable location
(outside the watershed),  and  that the new installation  would  be
properly engineered  with containment dikes around all  tanks.  [5-3]
Neither of  these conditions  were met during Destructo  operations.

     After  the spill  of June  3, 1977, Destructo  went bankrupt
and Carolawn Company, Inc. took over the  operation  of  the  site
in  early 1978.  Although company officials claimed  that Carolawn
was a different company,  the  State of North Carolina questioned
the non-association,  since Carolawn retained  some of Destructo's
officers.  In early  1980, Carolawn vacated the site, leaving  behind
chemicals in corroded 0.2  m3 (55 gal) metal  drums.   It is now
believed that during Carolawn's active days,  the facility  was
used more for storage and transfer than  treatment,  and that  wastes
were usually received in 0.2  m3 (55 gal)  drums,  rather than  in
bulk tankers.  Little is known concerning the actual operation of
Carolawn since books (which were reportedly kept) could not  be
located.  Thus, the  type, quantity, and  source of the  wastes  is
not known.   About 91  metric tons (100 tons) is reported to have
                               99

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 been  processed at this site through 1978.  It is believed the
 Company operated with limited capital and that once the State
 prohibited further waste receipts, the Company had insufficient
 funds with which to perform cleanup activities.

      When Brenner and the Town of Kernersville requested that
 Carolawn discontinue waste receipts and cleanup the site, Carolawn
 showed an initial interest in complying with the requests, but
 later abandoned the site.  During this initial interest period,
 Carolawn was constructing a waste disposal plant in Fort Lawn,
 South Carolina about 72 km (45 mi) southwest of Charlotte, North
 Carolina.  Approximately 80 drums had been transferred to South
 Carolina from the Kernersville site, when South Carolina prohibited
 further transfer of wastes to the Fort Lawn site.  Carolawn had
 proposed to establish an incinerator in Fort Lawn to incinerate the
 wastes. However, when the State of South Carolina became aware of
 their poorly managed/supervised operations at Kernersville, it
 began regulating their Fort Lawn operations more closely.
 Carolawn subsequently abandoned the Fort Lawn site, leaving behind
 thousands of gallons of waste.

 POLLUTION

      Problems associated with the Destructo-Carol awn site generally
 have occurred in two phases.  The first phase consisted of actual
 pollution of the Reservoir by the chemical spill of June 1977.  The
 second phase consisted of a threat of surface water pollution due
 to the Carolawn waste storage and transfer operation.

     On June 3, 1977, between 9 and 11 p.m.,  vandals entered the
 facility grounds and opened the valves on six storage  tanks.  The
 released chemicals flowed down a slope in a culvert, then through
 a dry ditch for about 0.4 km (0.25 mi), thence into an unnamed
 tributary, before entering the Kernersville Reservoir.

     Table 5-1  provides general information on storage capacity
and waste material  housed in the tanks associated with the spill.
 Figure 5-3 displays  Destructo's layout and the northwest flow
direction of spilled liquid wastes.   According to the  officials
of Destructo, Tanks  33 and 101 contained water contaminated with
small  amounts of alcohol, ketone, and toluene from Xylo Graphics
Company.   Tank  34 contained a mixture of ally! ether and water
reportedly from Proctor Chemical  Company.   Tank 91  contained allyl
ether (from which most of the water had been removed)  reportedly
from Gravely-Roberts Company, Tot Screen II,  and Proctor Chemical.

     A strong chemical  odor (possibly ether)  was present during
the spill.   DUe to the unknown nature of the  spill  and the unusual
odor,  approximately  200 people were evacuated from the immediate
area of the spill.   During the excavation of the contaminated
debris and soil  and  reservoir cleanup, 23 men were hospitalized
with eye  irritations.


                              100

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   TABLE  5-1.   STORAGE OF WASTE MATERIALS AT DESTRUCTO
                CHEMWAY CORPORATION  [5-4]
Tank
No.
33
34
81
91
101
171
Total
Available
Capacity
(m3)
11
11
30
34
42
64
192

Oily Water
(m3)
10.1
3.3
18.3
40.7
72.4
Quantity
Oil
(m3)
18.6
18.6
Discharged
Ether
(m3)
3.1
0.3
6.7
12.4
22.5

Total
(m3)
10.1
6.4
0.3
25.0
40.7
31.0
113.5
m
3 = 264.2 gal
                            101

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                     TO KEflNERSVILLE  2 5 MILES
     Tanks that contributed to spill.
Figure  5-3.  Tank location and  flow direction of
      1977 spill  at Destructo Chemway.     [5-5]
                          102

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     Two days after the spill  on June 5,  an  extensive  fish  kill  in
the Reservoir began.   The bottom-feeding  catfish  and carp were
the first to be affected by the spill.   By June  6,  an  extensive
number of bottom-feeders died.   On  June 7, the  fish kill continued
with all but the bass dying, and by June  8,  even  the bass had
died.  The State Wildlife Resources Commission  reported  a 90 to
99 percent fish kill  amounting to several  tons.   Prior to the
spill, the Reservoir was reported to have had  a  balanced population
of yellow perch, sun fish,  pumpkinseed, bluegills,  and bass.   A
total of 16 different species including shell  crackers,  warmouths,
yellow perch, and bass died due to  the contamination.  The
chemical later identified as likely ca'using  the fish kill was
2-methyl-l, 3-dia!lyloxy propane; however,  not enough  data  was
taken to show the mechanism of the  fish kill.

     Samples of the reservoir water analyzed by U.S.  EPA
revealed the presence of fuel oil,  toluene,  ally! ether, xylene,
dichloroethane, trichloroethane, and 2-methyl-l,  3-diallyloxy
propane.  Prior to the fish kill, the U.S.  EPA believed  that  the
chemical spill would not be soluble in water and that  20 percent
of the chemical spill would be adsorbed into the ground  as  the
spill ran along the ditch.   Qnce the fish began dying  and  additional
tests were conducted, it became evident that the material  had
become water soluble and that possibly some had later  settled
out to contaminate the floor of the Reservoir.  As a result of
the fish kill and analytical evidence, the Reservoir was declared
by the State Health Department to be unsuitable for use  as
drinking water.

     As a result, the Town shifted to alternate water  supplies,
obtaining approximately 40 percent of its water demand from the
Winston-Salem/Forsyth system and 60 percent from an old  supply
lake.  Water obtained from these two sources met only  67 percent
of Kernersvil le's daily demand.  Therefore, curtailment  of water
useage was necessary while connections were made to the  adjacent
town to provide the total water  flow.  Two textile mills in the
area had to pay for delivery of water via tankers  and for process
modifications to conserve water.  The water consumption  at the
two mills was cut by 90 percent  and layoffs and cutbacks in
working hours resulted  from the  water shortages.   Adams-Mil 11s
Corporation, one of the textile  mills, now receives its  supply
via private wells.  Meanwhile,  a temporary pumping station and
a pipeline improvement  project  has  increased the flow of water
from the Winston-Salem/Forsyth  system.

     In 1978, Destructo vacated  the site, with Carolawn taking
over operations.  Since that time,  the North Carolina Division  of
Health  Services has continued Jt,o test  the water  at the  Reservoir
and has found it to be  within  drinking water standards.   Within
14 days of the  spill,  schools  of newly hatched fish (golden
shiners) were seen in  the  Reservoir and  no second  fish  kill has
                               103

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been observed since.  This evidence pointed toward the volatile
nature of the toxic material.  By October 1977, water samples
showed that the concentration of all chemical  compounds discharged
from the Destructo facility were at less than  detectable levels.
In spite of this data indicating that resumed  use of the Kernersville
Reservoir as a drinking source was acceptable, the North Carolina
Department of Health has refused to approve the use of the water
as long as a chemical disposal plant remains located in the
watershed near the Reservoir.  Therefore, the  problem associated
with the operation of Carolawn at this site has involved the
"threat" of pollution (not pollution itself) from the storage
of waste chemicals within the Reservoir's watershed.

     Brenner officials terminated Carolawn's lease in July 1979,
requiring that they vacate the site within 30  days.  Carolawn
departed from the site between August and November of 1979, leaving
behind their plant, equipment, and chemical wastes.  The wastes
left behind included lubricating oil, waste oil, waste paints,
printing inks, and halogenated and non-halogenated solvents.
Waste generators were reported to have included Monsanto, Dupont,
Mobil Chemical,  Piedmont Publishing Company, and Kingsport Press.
The general characteristics of the abandoned wastes included the
following categories:  corrosive, toxic, ignitable, reactive,
highly volatile, and flammable.   Records reportedly had been
kept by Carolawn, but were not available for review.  The wastes
left behind posed the following  pollutant hazards:

     1.  Potential  for runoff into the Town Reservoir.

     2.  Potential  contamination of the food chain due to runoff.

     3.  Potential  for fire.

     Although earlier reports had indicated that only 45 m3
(12.,000 gal) of  chemical wastes  remained at the Kernersvill
Plant, it was later determined that 2,461 drums and 272.1 n
(71,880 gal) of  chemicals in  tanks (see Table  5-2) were left at
the site.  It is this waste which must be removed before the
North Carolina Department of  Health will approve use of the
Reservoir for drinking water  purposes.

REMEDIAL ACTION

     As a result of the spill of 1977, the following corrective
actions were instituted:

     1.  A floating boom containing sorbent materials was
         deployed at the mouth of the unnamed  tributary into
         the Reservoir.

     2.  A large underflow siphon dam was installed at the
         stream  junction to allow the lower zone of water to
                              104

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TABLE  5-2.   CAROLAWN'S INVENTORY AS  OF
            JULY 31,  1978.   [5-6]
TankObservedActual Volume
No.	Vol time	(m3)	

 33           Full
 34           Full
 41         2.1 m high
 42           Full
 81            Ful1
 91            Full
101            Full
102           Full
171            Full

Total                         272.1
                      105

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         flow into the Reservoir.   Later the siphon dam was
         modified with the addition of a blanket of peat moss
         to assist in the removal  of dissolved organics.  A
         catch basin and siphon dam were also installed at the
         road culvert as it exits  the property.

     3.  Two straw barriers were constructed downstream from
         the source of the spill.   However, only a  small
         quantity of oil had accumulated behind the barriers
         indicating that most of the spilled material  passed prior
         to the barrier construction.

     4.  Approximately 906 m3 (32,000 ft3)  of contaminated soil
         was removed from the drainage swale leaving the site.
         Debris was also removed from the dry wash  area.  Soil
         was likewise excavated around the  spilled  tanks up
         to 2.4 m (8 ft) deep.

     5.  A landfill site 30 m x 30 m x 1.5  m (100 ft x 100 ft  x
         5 ft) was excavated on the upper terrace at the southeast
         corner of the facility site.  The  excavated pit was
         lined with 0.15 mm (6  mil) polyethylene plastic.
         Contaminated soil, debris, dead fish, and  sorbent
         materials were placed  in  the pit with intermittent
         layers of agricultural lime.  The  filled pit  was
         subsequently sealed with  a  0.15 mm (6 mil) layer of
         plastic and with a layer  of clay to prevent infiltration
         of precipitation.

     6.  The liquid from the two dams and from depressions along
         the creek bed were removed and stored in Tanks 81 and  91.
         About 150 m3 (40,000 gal) of solvents stored  in bulk
         tanks at the site were removed.  Approximately one-third
         of the chemicals were  removed from the site for
         incineration.  Additionally, Industrial Marine Service
         from Norfolk, Virginia was contracted to remove oil
         and sorbent materials  from the Reservoir.   A  dike and
         other safeguards were  provided to  prevent  remaining
         chemicals from causing further contamination.

     The principal action instituted during the spill  consisted
of attempts to contain the spilled material to prevent its
migration to the Reservoir.  Initial visual inspection of the
Reservoir indicated that the measures might have been  successful
in containing the contaminant which at that time was reported  to
be allyl ether and 75 percent oil  and water.  Subsequent analysis
and the fish kill identified other organic  substances  and
2-methyl-l, 3-diallylexy propane which had  rapidly  dispersed
over the Lake.  Since the spill, the fish population has been
returning to the Reservoir and  no  second fish kill  has been
observed.  Laboratory analyses  likewise reveal that the
contaminants have decreased to  non-detectable levels.
                             106

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     During the spill, a mobile bioassay laboratory,  analytical
laboratory, and pilot treatment plant were used to determine if
the Kernersville Wastewater Treatment Plant could be  modified
to use activated carbon in its treatment sequence.   The concen-
trations of the toxicants were significantly reduced  following
carbon filtration.  However, in fish mortality tests  performed
subsequently, some mortality did occur even though  chemical
analyses had failed to find the toxicants at detectable levels
in the carbon-filtered water (see Table 5-3).

     About $60,000 in U.S. EPA funds, $23,000 in Kernersville
funds, $6,000 in State funds, and $25,000 in Fish and Wildlife
Service funds were spent during the cleanup plus an undetermined
number of man-hours required for cleanup activities.   The water
shortage after the spill magnified the problem.

     Based upon the conditions at the site since the  spill  of
1977, further action became necessary before the people of
Kernersville would be allowed to resume use of the  Reservoir for
drinking water.  The State of North Carolina Health Department
has insisted that the Town cannot safely begin using  the Reservoir
as long as a chemical waste disposal plant remains  in the
watershed.  Therefore, Brenner, under pressure from the Townspeople,
began eviction of Carolawn in April 1979.  Carolawn's activities
were reported to have ceased at the site about August 1979.  In
a proposal contract of January 1980, Carolawn was to  remove all
equipment, waste inventory and drums, and Brenner was to deposit
$32,000 in the North Carolina United Bank to be  paid  to Carolawn
upon completion of their corrective actions.  After removing
approximately 80-0.2  m3 (55 gal) drums, Carolawn abandoned the
site.  Five times as much waste was found on the property in
August 1979, as had been reported earlier.  In August, it was
estimated that approximately 272 m3 (72,000 gal) of chemicals
were stored in large tanks on the property along with about
2,500-0.2 m3 (55 gal) barrels.  Since Carolawn abandoned the
site, the landowner pursued the cleanup activities  by contracting
BFI to remove the barrels, waste equipment, and  the upper 15 to
30 cm (6 to 12 in.) of soil.  BFI was  also to apply  imported
soil to the site and grade and seed it.  This corrective activity
was completed during the Summer of 1980.

     Barrels were segregated according to waste  composition
prior to removal.  The landowner would not comment  on the
remedial activities of the site, but government  officials
reported that the major portion of removed waste (aqueous waste/
sludge) was sent to BFI deepwell injection and landfill facilities
in Calcashieu and Livingston, Louisiana.  Other  waste  (aqueous
oil and chlorinated waste) was disposed in a BFI Baltimore,
Maryland landfill and a small portion of removed waste was sent
to an SCA facility in Pinewood, South Carolina.   An estimate of
the total remedial cost funded by Brenner ranges from $250,000
to $500,000.

                             107

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         TABLE 5-3.   BIQASSAY  STUDY    [5-4]
SurvtvaEflHy Count*
Test
1







F1sh and Water Type
BlueqlU
Raw Lake Water
Filtered Lake Water
Control Water
Catfish
Raw Lake Water
Filtered Lake Water
Control Water
0 hr

100
100
100

100
100
100
24 hr

97
100
97

0
100
100
48 hr

83
97
97

—
100
100
72 hr

70
87
97

..
100
TOO
96 hr

63
87
97

—
80
100
120 hr

S3
63
97

—
60
100
      Raw Lake Water (12 days
       after spill)          100     100     100

     Catfish

      Raw Lake Water (12 days
       after spill)          100      91      91
* Percent of fish surviving at time Intervals shown.
                               108

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     One of the procedures used in removing the waste consisted
of withdrawing'1iquid waste from the 0.2  m3 (55 gal) drums and
transferring the liquid to a tank truck for transport to the
BFI Louisiana  facilities.  Empty drums were crushed and ramoved
along with contaminated soil from the site and likewise transported
to an acceptable landfill.  On June 23, 1980, as some of the
remaining drums were being crushed for removal, a 17-year-old
worker was sprayed as he was removing his protective face shield
18 m (20 yd) away.  Although thought to be empty, the drum
actually contained a 30 percent concentration of phenol.  All
efforts to revive the worker failed and the cause of death was
later reported to be dermal toxicity in which all nerve impulses
to the heart stopped.

     According to government officials,^cleanup activities are
now reasonably complete.  All  free chemicals (i.e., drummed waste
and sludge from a holding pond) have been removed.   Both the upper
and lower terraces have been graded and seeded with wheat straw
and grass.  Contaminated material  remaining on-site consists of
the top soil layer and the spill burial pit.  Soil  samples
indicate soil contamination exists in some areas at depths up to
50cm (20 in.).  The pit containing contaminated spill debris was
left intact.  The State plans  to install  five monitoring wells
(two around the spill burial pit with one up-gradient and one
down-gradient) and three down-gradient from the entire Destructo/
Carolawn site.  Once surface water runoff and ground water has
been adequately monitored, the State Solid and Hazardous Waste
Division will submit a report  to the State Water Supply Branch,
which will make a determination on whether the Kernersville
Reservoir can again be used for drinking water.  If the ban on
water use is removed, Kernersville will have the option to return
to their previous water source.

CONCLUSION

     Three years after 110 m3  (30,000 gal) of chemicals spilled into
Kernersville's drinking water  supply, the Town's Reservoir remains
unused.   The State of North Carolina has  banned use of the Reservoir
as a source of drinking water  as long as  the existing chemical
waste facility is located in the Reservoir's watershed.  The
equipment and waste were removed from the watershed by the land-
owners,  and depending upon results from ground and  surface water
sampling, the Town will  soon have  the option of resuming use of
the Reservoir.

     During the past three years,  the residents have been sharply
divided  over whether use of the 20.2 ha (50 ac) Lake/Reservoir
should resume (see Appendix 5-1).   The decision to  resume use
of the Reservoir has become a  heavily debated topic in the Town.
A letter to the editor of the  Kernersville News of  January 1980
exhibits the sensitivity of this volatile issue.
                              109

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     This site provides an example of an entire Town's  acute
awareness of an environmental  issue.   The awareness  was brought
about initially by the need of a portion of the Town to evacuate
their homes during the spill.   Citizens within the vicinity of
the Destructo site during the  spill  showed health-related effects
including nausea, vomiting, headaches,  and mucous  membrane
irritation.  All  of the Townspeople  became aware of  improper
management of industrial  wastes when  the Town's water supply
became contaminated.   Loss of  the Town's drinking  water supply
caused inconvenience, loss of  income  (due to curtailments placed
on local  industries), and loss of revenues from expected industrial/
business  growth.   The recent death of a worker assisting in the
site's cleanup activities again highlighted the danger  associated
with the  site.

     Generally, weakness  in the laws  became evident  to  the people
of Kernersville with their battle to  resume use of the  water supply.
The involved governmental officials  relayed that they had found
their past State  regulations ineffective or inappropriate in
dealing with the  management of hazardous materials.   Their laws
had not given them authority to remove  a waste until it became
an imminent hazard.  Under the laws'  prior to 1980, the  Destructo/
Carolawn  site was a storage site, rather than a waste disposal
site.  Therefore, the State's  Solid  and Hazardous  Waste Division
had no jurisdiction over  the site.  This site was  covered under
an air quality permit issued by the  County; however, the pollution
problem was that  of water quality damage and endangerment.  With
each separate agency having its own  jurisdictional limits, it
was difficult for the agencies to respond quickly  and effectively
to the problems surrounding the site.

     Some of the  government officials who are involved  with the
Destructo/Carolawn incident believe  that bureaucratic confusion
could be  overcome by giving authority to one agency  and one
individual to coordinate  environmental  affairs concerning air,
land, and water.   They believe that  time delays and  duplicated
efforts could be  avoided  and the overall environmental  quality
enhanced.
                              110

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               SITE D REFERENCES AND BIBLIOGRAPHY
'5-1  Clarification of aerial photo of 4/7/78, provided by North
     Carolina Department of Transportation, Forsyth County,
     North Carolina, City-County Planning Board, Winston-Salem,
     North Carolina.

5-2  Personal communication and file review with Russell  Radford,
     Water Quality Section, Department of Natural Resources and
     Community Development, Winston-Sal em, North Carolina.
     June 11, 1980.

5-3  Jackson, Howard.  "Another View of the Kernersville Spill1.'.
     Greensboro Daily News.  September 7, 1977.

5-4  Stonebreaker, Jack, et al.   "Cleanup of an Oil and Mixed
     Waste Spill at Kernersville, North Carolina, June 1977".
     Proceedings of 1978 National Conference on Control of
     Hazardous Materials.  Miami Beach,  Florida.  April 11-13,
     1978.  pp. 182-186.

5-5  Personal communication and file review with Steve Phibbs and
     Ernest Cain, Solid and Hazardous Waste Branch, Department
     of Human Resources, Winston-Sal em,  North Carolina.  June 11,
     1980.

5-6  Personal communication and file review with William Meyer,
     Solid and Hazardous Waste Management Branch, Department of
     Human Resources, Raleigh, North Carolina.  June 10,  1980.

5-7  Personal communication and report review with Edward Gavin,
     Enforcement Officer, Department of Natural Resources and
     Community Development, Raleigh, North Carolina.  June 10, 1980.

5-8  Personal communication with Jonathan Hale, Forsyth County
     Environmental  Affairs Department, Winston-Sal em,  North
     Carolina.  June 19 and 23,  1980.

5-9  Personal communication and  file review with Joseph^Young,
     Residuals Management Branch, U.S. Environmental Protection
     Agency Region IV,  Atlanta,  Georgia.   May 1980.
                               Ill

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       APPENDIX 5-1



SITE D NEWSPAPER ARTICLES
           112

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 ^(TIS STUFF  TASTES
  M  PHETlTGOOD!\VlIiVi;S
              IT?
                                                                                        ORIlliiNSBORO  DAILY NEWS
                                                                                           SUNDAY.  JANUARY  27,  1980
 Kernersville  Divided    On   Reservoir   Use
           BY WILLIAM KKKSLER
              D»ily Ntwl 11*11 WrMtr

    KERNERSVIU.E - Two :iml 3 half years alter .in
estimated M 000 gallons ol chemicals spilled  mlo Ker-
nersville s water system. Die town's main reservoir  re-
mains i>u( ol commission
    Residents .ire sh.irply divided over when, il over.
use ol (lie approximately  50-.irre Like  should resume
    IVh.ite  on  Ihe question has  heroine entangled in
(lie town's politics and in  Hie cunliuumg struggle over
in issue that has laced the IIIMII lor years Should Ker-
nersulle be  a suburb - a  bedroom community (or sur-
rounding municipal ginnls (Ireensbnro, Winston-Salem
and High I'omt" Or should it he  a self sufficient com-
mercial and industrial comiiuinity with an identity  all
ils own1
    The reservoir was cont.iminaled on June 2. 1977,"
when thousands ol gallons nl chemicals (lowed  out ol
tanks at the Oeslrurto l'liemw;iy  Corp waste disposal
plant, down  a hill and imp  a cn-ck (ceding into the lake
Vandals were blamed lor turning Ihe valves on  Ihe
UnJu
    The chemicals polluted the lake, killed thousand!
ol  lish a/id  (orced Ihe temporary evacuation ol 1.000
area residents The town was forced to  close the reser-
             •
 voir and  begin buying w.iler Irom Ihe Winston S.i
 lem/Forsyth County waier system.
    According to officials with the w.tler supply branch
 of Ihe N.C Division o( Health Services. Ihe water in (he
 reservoir has been tested periodically suite and is  now
 Iree ol contamination  O.iiohwn  Co , which look over
 operation  ol Ihe silc Irom liestruclu. moved out o( Ker-
 nrrsville in November and is  now constructing a waste
 disposal planl in Fort Lawn. S C .  about 45 miles south-
 west ol Charlotte
    When  Carolawn moved, il left behind an estimated
 50.000 gallons of chemicals in nibting Sf>-gallun nu'l.il
 d'rurns  According to Charles Runilgren, head of  the
 state water supply branch, the potential for further con-
 tamination exists.
    Slate officials have recommended bul say  they do
 not h.ne Ihe power to require that Ihe town keep Ihe
 reservoir closed until Ihe chemicals are removed If me
 town begins using the Like sooner, it will have (o bear
 Ihe liability for  any resulting contamination. Rundgren
 said
    Despite this warning, some Kernc-rsvillc cituens
 want to use Hie reservoir immediately On Dec 4. re-
versing an  earlier decision, the (own Board of Aldermen
voted 3-2 to disconnect Irom the Forsyth walcr system
and hook bach onto Ihe  lake
    This ch.inge of mind sent shivers ol horror through
 other town  resident  Morgan Culliton and his wil«,
 Kay, filed a class action suit seeking a permanent in-
 junction against reopening Ihe reservoir, charging that
 doing so would be  'the first step in a perilous course lo
 eventual catastrophe lor both Ihe city and its citizens "
    F.arly this month (he  board  reversed itsell again,
 voting 32 to postpone resuming use ol Ihe reservoir un-
 til .liter the chemicals arc removed But Ihe class action
 suit is pending
    At this lime. Ihe Cullilons and Ilieir attorney. John
 Stone, a leader in the opposition lo the December board
 decision, want the reservoir closed Inr good, even if lh«
 chemicals are removed tt'hile Ihe water could be used
 lor  industrial purposes, they say, it should not b« al-
 lowed lor human consumption.
    Stojie believes  Kernersville could become another
 1-me Canal - Ihe  New York catastrophe ol the mid-
 l!)70s In  which  people began having miscarriages  fend
other health  problems alter building homes on lop ol
an old chemical waste dump He contends Ihe Kerners
ville reservoir still  may contain undetected chemicab
that could be stored in the bo!  I
                                                          113

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    Residents  Sharply    Divided
                  From H-l
    Chemicals still could be in the floor of the reser-
voir, he said, and  they have seeped into the soil of the
disposal site, creating a potential runoff problem. Stone
said he has been told some of the fish killed in the 1977
spill are buried in the watershed, raising another possi-
.btlity of contamination. He and Culliton also fear that a
cteekside landfill at the metal recycling plant beside the
.Waste disposal plant site could cause further problems.
'. '  "This scares  the hell out of me," said Culliton. "I
don't  see  how they can say it's safe. They just don't
know."
 ?
    "We don't know exactly what chemicals went in
there,"  said  Stone,  31. a  Kernersville resident' with a
wife and a child.  "When chemicals get together, they
form  compounds. The reactions  can vary.  Nobody
knows what  compounds were  formed
    "If  there's one chance in a million  that there's
something harmful  out there,  then I don't think we
should take that chance of hurting our families and our
friends."
 y
  ..  Officials of the state water supply branch said tests
of the reservoir bottom have shown no contamination
problem. According to Roy Rettinger, a state environ-
mental  engineer  based in  Winston-Salem, preliminary
results from  a recent test just downstream from the re-
cycling  plant landfill showed  no runoff problem there.
    The state's solid and  hazardous waste branch and
the U.S. Environmental Protection Agency are  now in-
specting the waste disposal site to identify the  remain-
ing chemicals and determine how  to dispose of them.
Once the chemicals are identified, more water tests will
be performed, said M.O.  Caton of Winston-Salem, the
water supply branch regional  engineer.
    The three aldermen who voted to reopen the reser-
voir in  December say the  water is safe to drink now.
One of them, Larry Brown, went so far as to dip raw
water out of the lake in late 1978 and drink it, passing it
through a coffee  filter only once for protection.
    Brown,  36, who operates a local clothing outlet,
swears  he and  his  dog drank about 25 gallons of the
stuff during a period of several months, with no noticea-
ble; ill effects.
  , ' "We feel like we have one of the best-quality water
supplies in the Southeast or the nation,"  Brown said.
 "Even despite the chemical spill, we have a good-quali-
ty} water."
    He said that  since the spill a dike and other safe-
guards  have been provided at the waste  disposal site
 that will prevent  the remaining chemicals from causing
 further contamination.
  f* Brown helped  lead  the campaign against a town
 proposal in 1978 to issue $1.2 million in bonds to finance
 a permanent hook-up to the Winston-Salem/Forsyth
 County system. The referendum was viewed as a battle
 between  those  wanting  to control the  growth of  the
 town (Brown's group), and those wanting an increased
 supply  of water to recruit new industry (a group unoffi-
 cially headed  by Mayor  Roger Swisher).  Inextricably
 bound  up in the  fight was the stricken reservoir. The
 bond proposal failed by a substantial margin.
   "! "There  are some people in the city who want a no-
 growth policy,"  said Swisher, 49, a  local car dealer.
"They figure that if you don't have any water, the city
will stagnate.  It can't grow.

    "If Kernersville is going to stay a strong and inde-
pendent community, we're going to have to grow. We
can't stand still. We'll be swallowed up by the commun-
ities around us."

    Brown's group, however, maintains it opposes only
uncontrolled growth. They say Kernersville should seek
clean industries,  like product distribution centers, in-
stead of heavy manufacturing operations that would use
large amounts  of water.
    The group also strongly resists the idea of ceding
to the county the responsibility of supplying  water. Ac-
cording to Alderman Larry Cain, another who voted for
reopening the reservoir in December, the town already
has given up too much.
    "If they've got our sewage, they've got our water,
they've got our schools, they've got our library, they've
got our YMCA, what else does the town have other than
garbage collection?"  said Cain, 37, a local funeral home
director. "And we could have a private garbage service
take that. If we give everything we've got away, then I
think we've lost our identity as a town."  ,
    Alderman  Inez Davis cast the deciding ballot  in
both the December and January board votes. Davis, 49,
a substitute schoolteacher, voted for reopening the res-
ervoir in December, she said, because among other rea-
sons, after two and  a half years nobody — the town,
the state. Carolawn or Carolawn's landlord, Brenner In-
dustries of Winston-Salem — had done much about the
problem. She voted  against in January,  she said,  be-
cause finally it appeared action had started.
    The state solid and hazardous waste branch and the
EPA have entered the controversy since the  first of the
year. O.W. Strickland, solid and hazardous branch head,
said identifying and disposing of the chemicals probably
would be a "rather slow process." There is no disposal
site available  in North Carolina.
    Officials for Brenner, Carolawn and the town held"a
negotiating session last  week. Swisher said  afterwards
that Brenner is negotiating a contract with Carolawn to
remove the remaining chemicals. He said he is hopeful
that the chemicals can  be removed by the first week
in March and that the state can then come in for final
testing.
    Telephone calls to Carolawn and to Brenner, which
also is the operator of  the metal recycling  plant next
door to the waste disposal site, were not returned.
    Besides the matter  of the chemicals, there still  is
considerable litigation to resolve. Kernersville has a $1.5
million  suit  pending against Carolawn and Destructo
Chernway, and the  state recently filed a $24,500 suit
against  Destructo and its president, David M. Neill of
Charlotte.
    "Law, there were times I thought we would never
get anywhere," Davis said. "Now it looks like we're fi-
nally getting somewhere. But I won't believe it until I
see it."
                                                      114

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             A     Little  Watergate!
 Utter to the Editor:
  Do  we  have  a   little
Watergate going on in Her-
nersville?    Why all  the
secrecy  about, our  water
situation?
  When was it  decided that
our water plant was really in
need     for    substantial -
.renovation or. replacement?
How long has this been in the
making?  It's  been  in the
making for a long time, or it
would seem so.
  A group of engineers set up
office in Kernersville  and a
 temporary  water  line was
laid prior  to  the  chemical
spul at Destructo in June of
W77.     Who  hired  these
engineers to whom we owe a
substantial debt of $120,000?
Was it the town manager or
 the aldermen?
  If our system was in such a
 rundown condition, why did
 our officials spend $100,000 on
 a parking lot? Would you call
 this good planning for the
 future of the citizens?
 . I suggested to some  of our
 aldermen a long  time ago
 that I and other* would rather
 pay a substantial increase in
 our water rates if we could
 use our own "dean, spring-
 fed lake"  rather  than the-
 Yadkin River for our water
 supply.
  But this wouldn't be good
 for a big industry boom or
 Urge developments,  would
 It?
  Since we are required to
 operate our utilities on a self-
 sustaining,   enterprise
 system,  why can't we, with
 the population  we have of
 over 7,000?  We've had this
 large   population   " for
 sometime now  and if s just
 come to  light that this utility
 must pay for itself and that it
has not done so for the past
four years. Very interesting!
  Yet we keep on annexing,
overloading our water, sewer
lines  and  streets.    Good
planning!
  This  was  one  way  of
phasing out our present wa ter
plant, of which we do have
sufricierU.wat^rrfor ;the next
16-15 years.
  If  we  go  to  city-county
water, and   that's  exactly
where we're going, then we
can expect to be the first cut
off if any  malfunctions  or
water shortages occur in the
future. This is exactly what
happened last summer.
  Going  to  county  water
would  really  help  Ker-
nersville to  have a big in-
dustry boom and develop*
ment would really blossom,
and that's what if s all about.
  Come on,  dtizens,  wake
up!
  Because of poor planning,
"power," and "what I want"
rather than what's best for
the  citizens, we have a
dearer  picture of why we
have insufficient sewer lines
and streets.
  When our  dean lake  is
dosed for our water supply, I
wonder who stands to  gain
from this move?  Who will
profit?  Who is  really in-
terested in our lake?  A great
recreation center, you might
say.   If  the  water  isn't
suitable for us to drink, then
would we be allowed to eat
fish that are caught from it?
  Since the mention  of fish
comes to mind, I wonder why
the fish did  not die down-'
stream from the lake during
the oil spill that supposedly
killed the fish in the lake? Oh
yes, why did the fish die first
at pie opposite end of the lake
 after the oil spillage?
   A   meeting  has  been
 scheduled  for Monday, Feb.
 13, at 6:30 p.m. in the Pad-
 dison  Library to hear from
 citizens who depend on  the
 town for their water supply,
 to find out whether or not they
 want to again use the dean
 lake .for our water supply cr
 gcr to county water.  ' '    ' T ."•'
   Call your aldermen and let
 them  know how you  feel
 about this situation. They are
 Larry Brown, Max Coltrane,
 David  Holt, Aubrey Morris
 and Ivey Redmoa
   Our mayor said at the last
 Board meeting that Mr. M. O.
 Caton, of the North Carolina
 Department   of   Human
 Resources, would be present
 at this meeting.  Will he? If
. so,  come  and  bring  your
. questions to the man who has
 declared our  lake safe  for
 drinking, and to the engineers
 who have  been the town's
 advisors in this situation and
 have  given  our  aldermen
 several alternatives to take.
   I have said several times
 and I  will  say again that I
 would like to use our lake
 again as a water supply and
 use the county  water as a
 backup source.
   We  have  asked  that a
 dipping be run in this week's
 Kernersvlll*   « wa asking
 whether  the  citizens  of
 Kernersville would like to use
 our lake again as our primary
 water supply or go to county
 water.
   If it is run, please sign your
 name and state the. reason
 why you would or would not
 be in favor of this move and
 return it to the newspaper
 .before Feb. 13.
                                    115

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   APPENDIX 5-2
SITE D PHOTOGRAPHS
       116

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As a result of the spill  in 1977,  more than 90 percent
of the fish in  Kernersville Lake died  (top photo).
The fish were  gathered,  removed from the Lake, and
placed in barrels (bottom photo).
                      117

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Berms (top photo)  were placed around the tanks
following the 1977 spill.   By March 1980 pools of
water had collected in the bermed area around the
tanks (bottom photo).
                      118

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 Dead fish and contaminated soil  and
 placed in a limed,  lined pit  at  the
 Carolawn site in 1977.
debris were
Destructo/
This incinerator was used  by Destructo  prior  to
the spill  of June 1977.   Carolawn  reportedly
only used  the site as a  storage  and transfer  station,
and did not use the incinerator.
                     119

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 As  evidenced  by  the  photo  of March  1980,  the  site
 was poorly  managed  by  Carolawn,  the successors  to
 Destructo.
After Carolawn vacated the site, initial  cleanup
activities were implemented by the landowner,
Brenner.   One of the first steps was to
segregate the waste according to characteristics
                      120

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                          SECTION 6

                            SITE E
                    WHITMOYER LABORATORIES
                    MYERSTOWN, PENNSYLVANIA
INTRODUCTION

     Whltmoyer Laboratories, Inc. has operated an animal pharma-
ceutical manufacturing facility In Myerstown, Pennsylvania
since 1934.  In July 1964, they became a subsidiary of the
Rohm and Haas Company of Philadelphia.  Rohm and Haas sold
Whitmoyer Laboratories in early 1978 to Beecham, Inc., but
Whitmoyer Labs has retained its identify as a separate company.

     When Rohm and Haas purchased Whitmoyer Labs in 1964,
extensive arsenic contamination of the soils, ground water,
and a nearby stream became apparent to Company officials.
Emergency remedial actions were taken to stop further contamin-
ation and to remove the contamination that existed.  Ground and
surface water studies were conducted and a ground water monitor-
Ing, extraction, and treatment program initiated which consisted
of three parts:  clean-up and recovery; development of cones
of depression; and stream and well monitoring.

     Actions to remove arsenic from the ground and surface
waters have been fairly successful.  However, insoluble arsenic
remains in the soils and ground water of the facility and the
sediment of the creek.  These levels are expected to slowly
decline.

SITE DESCRIPTION

     Whitmoyer Labs 1s located on North Railroad Street In
Myerstown, Pennsylvania.  Myerstown is located between Harrisburg
and Reading, Pennyslvania, approximately 95 km (60 ml) northwest
of Philadelphia.

     The normal annual precipitation for the area 1s 110 cm
(44 In.) and is distributed fairly evenly year round.  Snow fall
averages 90 cm (35 1n.).  The average wind is 12 km/hr (7.7 mi/hr)
The average temperature is 11°C (53°F) with the highest daily
maximum of 24°C (76°F) occurring in July and the lowest of
-1°C (30°F) occurring in January.

     The facility lies adjacent to Tulpenocken Creek 60 km
(37 ml) upstream from Its confluence with the Schuylklll  River
and about 25 km (16 ml) upstream from the upper end of the
Blue Marsh Dam Project (see Figure 6-1).  Myerstown is situated
                             121

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•WHITMOYER PLANT
                                            BLUE MARSH DAM
    Figure 6-1.  Location of Whitmoyer  Labs  [6-1]
                         122

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a few miles upstream of Whitmoyer Labs.   Womelsdorff is the
first town downstream at approximately 6 km (4 mi).   There are
some farms, which use the local  ground water,  located nearby
on both sides of Tulpehocken Creek.   A 45 m (150 ft) deep
calcite quarry lies 2.4 km (1.5  mi)  west of Whitmoyer Labs.

     There are several  buildings on-site used  for production and
administration (see Figure 6-2).  The old lagoons are covered
and there is a temporary storage building situated on one part
and a Buckeye pipeline pumping station located on another part
of the lagoons.   There is also a 25  m (83 ft)  by 37  m (123 ft)
by 3.6 m (12 ft) high concrete vault on  site which is completely
filled with arsenic wastes.   A cooling canal flows through the
property beginning and ending in the Tulpehocken Creek.

     The drainage basin of the Tulpehocken Creek covers 550 km2
(211 mi2) and is 54 km (33.5 mi) long.  The average  and minimum
flows at the confluence of the Tulpehocken Creek with the
Schuylkill River during Septemberand October 1964 were 1.6 cms
(58 cfs) and 1.5 cms (56 cfs), respectively. The average annual
flow for the creek is approximately  5.7  cms (200 cfs) and the
maximum flood flow was 200 cms (9,890 cfs) on  December 7, 1953.
The general direction of the stream  follows the east northeast
strike of the carbonate bedrock.  The ground water found under
Whitmoyer Labs is potable and used by local residents and farmers
There are some artesian wells found  nearby but the static water
level in most wells lies near the ground water table.

     Whitmoyer lies close to a ground water divide in a system
of limestone aquifers underlying the Lebanon Valley.  Prior to
the industrialization of the Lebanon Valley area, the natural
ground water divide was probably conformable to the  present
topographic divide which lies between the headwaters of
Tulpehocken Creek and Quittaphalla Creek, about 5 km (3 mi) west
of the plant.  A calcite quarry, located 2.4 km (1.5 mi) to the
west of Whitmoyer, has  pumped ground water from the  bedrock
aquifers while continuing quarry operations.  This has shifted
the ground water divide east so  that it  is now located just
to the west of Whitmoyer as  seen in  Figure 6-3.

     The position of the ground  water divide determines the
flow direction of wastewater produced by Whitmoyer.   This
wastewater has been a source of  recharge to the local ground
water aquifer for several years.  The majority of the flow
moves east but some pollutants which originated from the plant
have been found  to the  west.  Figure 6-3 shows the ground water
level contours at the plant  on July  23,  1973.   Ground water
flow was to the  northeast to a ground water trough coinciding
with Tulpehocken Creek.  There is another ground water divide
east of Womelsorff (see Figure 6-1)  which interrupts the
flow down valley.  Therefore, no arsenic wastes reach Blue
Marsh Lake via the ground water.
                             123

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  Figure 6-2.   Detailed site location for Whitmoyer Labs.  [6-2]
Figure 6-3.  Ground water contour map  for Whitmoyer  Labs.  [6-2]
                             124

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     The bedrock under the plant consists of limestones and
dolomites which strike east-northeast and exhibit a dip of
30 degrees to the southeast.  Whitmoyer lies directly over the
Ontelaunee Formation (dolomite) which is -approximately 275 m
(900 ft) thick (see Figure 6-4).  Underlying the Ontelaunee,
and surfacing about 460 m (1,500 ft.) north of the plant, is
the Annville Formation (high calcium limestone).  The Epler
Formation (a dolomite not present at the plant) overlies the
Ontelaunee surfacing about 130 m (425 ft) south of the plant.
The Hershey Formation (a tight shaley, silty limestone) under-
lies the above formations and, together with the Epler Formation
contains the ground water in the Ontelaunee and Annville Forma-
tions.  Any cones of depression formed by purging wells will
not be conical, but ellipsoidal in shape following fractures
and solution channels in the rock.

     The soil  mantel averages 1.5 m to 2 m (5 to 7 ft) thick
and is made up of alluvial  sand, silt, and gravels.   It is
fairly permeable and allows for rapid recharge to the bedrock
aquifers.  The area has a gently rolling topogrpahy  resulting
from erosion by the Tulpehocken Creek and its tributaries.
The valley walls to the north slope upward from the  creek's
elevation of 140 m (450 ft) at the site to 150 m (500 ft)  in
1  km (0.6 mi).   To the south it is steeper,  reaching 150 m
(500 ft) in 0.5 km (0.3 mi).

     The area near the Whitmoyer site is predominantly farmland.
It is used for grazing and crops.   Deciduous trees are found
along water courses and on hillsides.  The Whitmoyer site  is
vegetated with short grasses and a few outlying trees.

SITE OPERATION AND HISTORY

     Whitmoyer   Labs employs approximately 100 people and
manufactures a  diverse line of pharmaceutical and nutritional
products for the poultry, livestock, and feed industries.
These products  include sulfur compounds, vitamins, antibiotics,
feed additives,  and supplements based on arsenic chemicals.
In 1963, Whitmoyer's consolidated  sales totaled nearly
$9,000,000.   Their products are sold over the counter, not
distributed through veterinarians.   Some of  their major
products include:

     1,   Arsanilic Acid - used to  prevent dysentery  and
         promote  growth in  swine.

     2.   Biodin  and Ethylenediamine  Dihydroiodide (EDDI) -
         used  to  prevent  foot rot  in cattle  and used as
         a  source  of iodine.

     3.   Piperazine -  used  as a low  cost dewormer for chick,ens,
         turkeys,  and  swine.
                             125

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WNW
                                                              ESE
                              WHITMOYER PLANT
                                   ONTELAUNEE FM.
HERSHEY FM.
                                 SCALE : I'9600
   Figure 6-4.   Generalized  geologic cross section drawn
           perpendicular  to  the strike direction.
                            126

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     4.  Carb-0-Galn and Carb-0-Sep - used to prevent black
         head and promote growth in turkeys.

Whitmoyer also packages and labels their products for shipment.

     Whitmoyer Labs was founded in September  1934 when Mr.  C.  W.
Whitmoyer's firm merged with a similar pharmaceutical  company.
Whitmoyer began production of arsenic compounds at Myerstown
in 1959.

     The wastewater generated by their manufacturing plant  was
treated with lime and handled as a slurry for disposal in an
unlined lagoon.  The arsenic wastes were primarily organically
bound arsenic compounds (arsenical compounds),  calcium arsenate,
and calcium arsenite.  A total of about 450,000 kg (1  million
Ibs) of waste was lagooned.  The plant's Sanitary sewage and
other non-varsenic bearing wastes are discharged to the Myerstown
Sewage Authority Treatment Plant.

     In July 1964, the Rohm and Haas Company, a Philadelphia
based chemical company, bought Whitmoyer Labs.   Although Whitmoyer
became a wholly-owned subsidiary, it retained its former
managerial  staff.

POLLUTION AND REMEDIAL ACTION

     The arsenic pollution problem was first  identified by
Thomas lezzi of Rohm and Haas in September 1964.   Ground and
surface water in the vicinity of Whitmoyer Labs was found to
have been affected by the arsenic wastewater  production.
Therefore,  on-site treatment and disposal practices were dis-
continued in December 1964.  The ensuing recovery and rehabili-
tation program consisted of three phases:  (1)  clean-up and
recovery, (2) development of cones of depression, and (3) stream
and well monitoring.

     At this time, four wells began purging ground water
containing  the arsenic compounds.  Subsequently,  the Rohm and Haas
Research Department perfected a treatment process to remove
the arsenic from the purged water in the form of  insoluble
precipitates.  They added ferric sulfate at the ratio of
approximately two parts ferric sulfate to one part arsenic, and
adjusted the pH to neutral  conditions by adding lime.   This
process reduced the arsenic content from more than 2,000 ppm
to 1 ppm.  All the recovered water was handled  in alternating
batch mixing tanks on a continuous feed treatment schedule
and sent to the lagoons to dissipate via slow percolation to
the subsoil.

     Yields of extracted arsenic peaked at 5,000  kg (11,000 Ibs)
per week, later leveling off at about 2,000 kg  to 2,300 kg  (4,500
to 5,000 Ibs) per week by April 1965.  The water  from the


                             127

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contaminated aquifer initially contained 10,000 ppm arsenic.
After 400 m3 (100,000 gal)  of ground water was  pumped,  the
arsenic level  dropped first to 6,500 ppm,  and then  to 100  ppm.

     Early in  1965 sludge was removed from the  lagoons  as  well
as the contaminated soils underlying the lagoons.   These
materials were deposited in an impervious  concrete  bin  43  m
(123 ft) long, 25 m (83 ft) wide,  and 3.5  m (12 ft) deep.
The bin was filled to capacity and covered.  Three  additional
purging wells  began operations in  early 1965.  Approximately
450 m3 (120,000 gal) per day of wastewater was  treated,  and
about 200,000  kg (400,000 Ibs) of  arsenic  compounds were
purged and treated.  The plant was reopened in  the  spring  of
1965 on a no-discharge basis.  They began  trucking  treated
wastes to a holding area in New Jersey to  await ocean dumping.

     The second phase (entailing development of cones of
depression via counterpumping) began as the arsenic recovery
rates from the seven wells  continued to decline.   By the  end
of 1966, 23 new wells had been drilled.  These  original	
seven wells and seven of the new wells were then  used as
production wells to form cones of depression east  of the  plant.
Ten of the remaining wells  were used for observation, five  were
abandoned, and one later used to replace one of the original
seven purging  wells.  Arsenic concentrations in water from
the new extraction wells ranged from 33 ppm to  440  ppm.   The
increased rate of arsenic removal  is seen  with  the  addition of
seven wells:

     •   Initial 7 wells  - 28 kg/day (62  Ibs/day)  arsenic

     •   Initial 14 wells - 44 kg/day (97  Ibs/day)  arsenic.

The well locations may be seen in  Figure 6-5.  Table 6-1
indicates the  well number,  well depth, amount of  water  pumped
initially, and the arsenic  concentration present  at the  time
of completion.

     Whitmoyer Lab's production rate was partially  dependent
on its purging rate and the development of the  cones of  depres-
sion.  Nearly  all of the liquid extracted  from  the  ground  was
returned.  Natural precipitation also contributed  to the  recharge
adding to the  aquifer's volume.  The cones of depression  were
developed to stop the migration of the ground water.  Therefore,
as the volume  of the aquifer contained by  the cones of  depression
grew, it became more and more difficult to maintain the
existing cones of depression.  With the addition  of the  seven
new purging wells, the cones of depression were initially
increased and  Whitmoyer Labs could increase their  production
rates.
                              128

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ro
 / DISPOSAL  \
/ SITE    i

'        I  LB
                                                                       i i  i i  i i  i i i i  i i i i  I i  i i i is
                     Figure 6-5.  Location  of wells on Whitmoyer Labs property.   [6-2]

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TABLE 6-1.   INITIAL ARSENIC CONCENTRATIONS
             FROM PLANT WELLS

Well
No.
5-A
9
9-A
10-A
11
16-B
17

Depth
(m)
48
29
30
30
30
37
21
Extraction
Rate
(m^/mi n )
0.036
0.150
0.190
0.098
0.045
0.038
0.303
Arseni c
Concentration
(ppm)
326
155
102
440
349
146
297
 1  m = 3.28 ft
 1  m^/min = 264 gpm
                   130

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     The treatment of the ground water continued until  late 1968
when Whitmoyer Labs began to discharge the purged water directly
to Tulpehocken Creek.  Permission to do so was granted  by the
Delaware River Basin Commission.  By December 1968,  direct
discharge of the total  amount of purged water to the Creek had
been attained.  The discharge rate of all  14 wells increased
to 950 m3/day (250,000  gpd) and then dropped as the  cones of
depression began to expand.  Direct discharge to the Creek
ceased in April  1969 but resumed in September of the same year.

     Early in 1971 there was a public outcry against the dumping
of arsenic in both the  Atlantic Ocean and  local surface waters.
Rohm and Haas ceased operation of their purging wells and of
their discharge  to Tulpehocken Creek.  The cones of  depression
never developed  to their full potential, but they did contribute
to an improvement in conditions.  Approximately 22,000  kg
(50,000 Ibs) of  arsenic was recovered and  disposed of during the
second phase.  But there probably was a considerable amount of
arsenic waste carried ultimately to the Atlantic Ocean.  Runoff
and ground waters which contained arsenic  flowed to  Tulpehocken
Creek which flowed to the Schuylkill River to the Delaware Bay.

     There were  two forms of arsenic wastes involved,in Whitmoyer
Labs ocean dumping:  solids and liquids.  Only 0.5,-percent of
the arsenic found in the liquid.waste was  trivalent  (which is
considered toxic).  The balance, including solids, was  pentavalent
In March 1971, Whitmoyer Labs produced approximately 1.4 million
kg (3 million Ibs) of liquid wastes per month.  This included
mother liquids from the Arsanilic Acid and Carb-0-Sep crystal-
lization process.  The  components were as  follows:

     	Component	     Val ue

     Organic arsenic (Arsanilic Acid)       2.43%
     Inorganic arsenic  (HaAsO^             5.82%
     Arsenite (toxic)                       0.59%
     NaCl                                  13.20%
     Water                                 77.96%
     PH                                     5.90
     Specific gravity                       1.166

     Whitmoyer sent nearly 18,144 kg (40,000 Ibs) of waste per
day to a 3,700 m3 (1  million gal) hoi ding  tank in New Jersey to
await ocean dumping.   Approximately 1,900  to 3,400 mj
(500,000 to 900,000 gal) of wastes were dumped by ship  on one
trip.

     Solid wastes produced and ocean dumped included tar-like
aniline still bottoms,  and carbon filter cake produced  from
the Arsanilic Acid clarification filters.   The content  .of the
aniline still bottoms was as follows:
                             131

-------
         	Component	     Content

         Arsenic                           12-13%
         Aniline (free and combined)       30-40%
         TTAA                              25-35%

The arsenic is in a tightly bound molecular form.  Aniline
degrades rapidly but should not have migrated rapidly into the
sea water while present in the still bottoms. [6-3]

     In March 1971, Representative Charles W. Sandman (New
Jersey) filed a civil  action in U.S. District Court against:

     •   Pennsylvania  Department of Environmental Resources,
         Industrial Waste Division.

     •   Pennsylvania  Department of Health.

     •   Whitmoyer Laboratories.

     t   Rohm and Haas Company.

     •   Norton Lilly  and Company (a shipping agent).

A temporary restraining order prohibited further ocean dumping.

     The third phase of the recovery and rehabilitation program.
(stream and well monitoring) began after the discontinuation
of the counterpumping.  Quarterly monitoring of existing wells
and of Tulpehocken Creek helps to identify the arsenic levels.
Since 1972, the wastewater has been reduced in volume via
evaporation (boiling), centrifuged, and drummed.  The waste is
then shipped to a .secure landfill in New York State.   Totals  of
the drummed wastes and by-products of the arsenic process for
1978 and 1979 are as follows:

                                   Number of Drums
          Drum Contents             19781979

          Arsenic salt             1,778     1 ,573
          Arsenic carbon             681       734
          Arsenic Tar                  84        85
          Total                    2,543     2,392

     The U.S. Army Corps of Engineers began sampling  surface
waters which would feed their proposed Blue Marsh Lake early  in
the 1970's.  Figure 6-6 shows the location of sampling stations
that the Corps established along Tulpehocken Creek.  They found
the following arsenic  concentrations in samples taken from
September 1971 to August 1972:
                             132

-------
     •   Tulpehocken Creek Water

            Near Blue Marsh Dam

            Total arsenic = 0.03 ppm
              (range * 0.01 to 0.062 ppm)

            Inorganic arsenic = 0.01 ppm

            Near Whitmoyer Labs

            Total arsenic = 0.088 ppm
              (range = 0.03 to 0.18 ppm}

            Inorganic arsenic = 0.04 ppm

     •   Tulpehocken Creek Mud

            Near Blue Marsh Dam

            Total arsenic = 43 ppm

            Near Whitmoyer Labs

            Total arsenic = 152 ppm

     The following gives the arsenic content found in several
wells drawing ground water at the Whitmoyer site:


Date
5/72
7/72
7/72
7/72

Well
No.
7
5
7
9
Total
Arsenic
(ppm)
370
124
412
66
Inorganic
Arsenic
(ppm)
224
126
280
49
Tri valent
Arsenic
(ppm)
115
—
150
™ ™*
Organic
Arsenic
(ppm)
146
—
132
• ••
     Figure 6-7 shows the seasonal  changes in arsenic concentra-
tion found in Tulpehocken Creek waters.   Higher contents of
total arsenic occur generally with  higher stream flows.   The
organic arsenic decreased in the winter  months.  In October
1975, wastewater containing about 2 kg (4 Ibs) or less of
arsenic was discharged accidentally into Tulpehocken Creek.
Preventative measures to protect the creek from a similar
accident were taken.

     A plot of residual  arsenic release  in the vicinity  of
Whitmoyer Labs is asymptotic in a declining rate.  The waters
of Tulpehocken Creek contain  less  than  0.05 ppm arsenic and
the arsenic contents in some private wells have dropped.
Although arsenic compounds still remain  in the ground water,


                             133

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                                         BLUE MARSH DAM'
            -WHITMOYER PLANT
                       4KM
  Figure 6-6.  Location of sampling stations  established by
           the U.S.  Army Corps  of Engineers.  [6-1]
         IB
         M
         06
               J	I	L
   J	I	I	I	I	I	I	L
            1971
                  NOV.
JAN.
1972
                               MAR
MAY
JULY
SEPT
1972
Figure 6-7.   Arsenic  content at  Station 2  at  Whitmoyer  Labs.  [6-2]
                               134

-------
soil, and subsoil, a large amount has been removed or re-
covered.

CONCLUSION

     Rohm and Haas has attempted, since their ownership  of
the Whitmoyer facility, to control  the flow and reduce the
amount of arsenic on and around their plant site (see Figure
6-8).  The first phase of remedial  action cleanup and recovery
halted the production of arsenic wastes and removed quantities
of sludge and contaminated soils.  The plant was shut down
until a process could be developed  to remove arsenic from  the
wastewater.   This phase eliminated  the possibility of new
arsenic compounds being added to the soils and subsequently
to the ground and surface water.

     The next phase (removal  of arsenic from the ground  water)
was also largely successful.   The recycling and treatment  of
the purged water did reduce the level of arsenic in the  ground,
and succeeded in controlling  its movement.  Little work  was
done to remove the arsenic from the mud and waters of Tulpehocken
Creek since  it would have involved  the dredging of miles of
creek bottoms and banks.  Arsenic levels in the creek water
have been brought under the limits  set by the U.S. Department
of Health and they continue to decline.  Whttmoyer continues
to supply bottled water to some area residents whose wells
remain affected.

     The third phase, monitoring, tracks arsenic levels  to
ensure that  they do not increase, either through release of
arsenic from bottom muds, or  via spills from the plant.
Remedial actions taken seem to have been the logical and
effective response to limit and reduce arsenic contamination.
                              135

-------

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   1  1965   11966     11967     11968     H969    H970     11971
Figure 6-8.  Cumulative graph of arsenic  removed  from
       the ground water at the plant  site.  [6-2]
                          136

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             SITE E REFERENCES AND BIBLIOGRAPHY
6-1   File Review at State Water Quality Division,  Department of
     Environmental  Resources,  Harrisburg,  Pennsylvania.

6-2   Wood, C.R., Evaluation of Arsenic Concentrations in
     Tulpehocken Creek Basin,  Pennsylvania.   U.S.  Geological
     Survey.

6-3   Whitmoyer Laboratories.   Description  of Whitmoyer Labora-
     tories,  Myerstown, Pennsylvania.   March 23, 1971.
                              137

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   APPENDIX 6-1
SITE E PHOTOGRAPHS
       138

-------
View of an old lagoon with  final  cover and  vegetation.
The grass has had adequate  time to become well  established
                         139

-------

View of the Buckeye Pumping  Station  located  atop
an old lagoon.
                         140

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                           SECTION 7

                             SITE F
                    WESTERN SAND AND GRAVEL
                   BURRILLVILLE, RHODE ISLAND
INTRODUCTION

     Western Sand and Gravel is a hazardous waste disposal  site
located in northwestern Rhode Island.  Waste disposal  operations
were initiated in 1975.  Liquid septic and industrial  wastes
were transported to the site by municipalities and industries
for disposal in pits where they were allowed to either evaporate
into the air or percolate into the ground.

     Since the start of operations,  numerous complaints have been
registered with the Rhode Island Department of Health  (RIDOH).
RIDOH attempted to close the site in 1977 but were unable to do
so until 1979 when the Superior Court declared the existing
guidelines, laws, and regulations governing disposal  sites
sufficient legal support.

     In February 1980, the U.S. Environmental Protection Agency
(EPA) assumed jurisdiction over the site.  Remedial work
sponsored by EPA consisted of pumping liquid and solid wastes
from four of the disposal pits and transporting them off-site.
Solid residues from the cleanup are currently being stored  at the
disposal site in 0.2 m3 (55 gal) drums and in a mound  mixed with
sawdust and covered with a polyethylene cover.  The removal of
septic wastes from other on-site disposal pits will commence in
the near future.

     A hydrogeologic study is currently underway to determine the
extent of any ground water contamination.  Work to date has
shown'that unless immediate action is undertaken the water  supply
down-gradient from the site will be permanently damaged forcing
residents to find alternate water supplies.  The total  cost for
such cleanup activities has been estimated at $1,000,000.

SITE DESCRIPTION

     Western Sand and Gravel, Inc. (WS&G) is located in a sparsely
populated section of northwestern Rhode Island, approximately
24 km (15 mi) northwest of Providence and 8 km (5 mi)  southwest
of Woonsocket.  It is on the north side of Douglas Pike (Route 7),
2 km (1.3 mi) southeast of Nasonville in Burrillville,  straddling
the Burrillville-North Smithfield township line.  The  location
of the site is shown in Figure 7-1.

     The waste disposal area of the site is adjacent to the
Company's sand and gravel operations.  It consists of  12 in-ground


                              141

-------
 NOTE:  All elevations 1n ft above mean sea level.

 1  ft - 0.3 m
Figure  7-1.   Location of Western  Sand and
                 Gravel site.
                      142

-------
 pits  or  trenches  on  2.8  ha  (7  ac)  of  land.  The  largest pit is
 45  m  (150  ft)  by  15  m  (50  ft)  and  the  deepest pit is about 2.4 m
 (8  ft) deep.   A sketch of  the  site and  pit  locations are shown
 in  Figures  7-2 and  7-3.  The pits  are  identified as Nos. 1 through
 12.   The respective  dimensions,  volumes, and uses of each pit are
 presented  in Table  7-1.

      The climate  of  Rhode  Island is characterized by moderately
 heavy precipitation, high  evaporation,  and  a wide range of
 temperature.   In  general,  the  winters  are cold,  having extreme
 temperatures of short duration, and the summers are cool  but humid.
 Based on 30 years of record, the average annual  temperature in
 the area is 15°C  (59°F)  and the average annual precipitation is
 108.6 cm (42.75 in.).  There are an average of 123 days between
 October and April with minimum temperatures of 0°C (32°F) or
 less.

      The site  lies in a  hilly  northwestern  upland of Rhode Island,
 a continuation of the New England  Upland of eastern Connecticut
 and southeastern Worchester County in Massachusetts.   The ground
 surface of the waste disposal  site slopes gently to the northwest.
 Immediately to the west, the ground surface drops steeply to
 Tarklin Brook  which ultimately enters Slatersville Reservoir.   The
 Slatersville Reservoir,  approximately 300 m (1,000 ft)  north of
 the site, currently supplies the City of Woonsocket with 13.2
 m3/sec (58.3 gal/sec) of water.  The reservoirs are popular
 recreational areas and were originally constructed for supply
 water for power generation, processing, and waste disposal  for
 textile mills.   There are also a number of  lakes, ponds,  and
 swamps in the  area.  The land  is mostly wooded and has  some open
 pastures for grazing.  The general  topography of the  site has
 been  radically altered from its natural state by the  sand and
 gravel mining  operations.

      Although  the ground water in the general  area is  relatively
 undeveloped, the WS&G site is located above the major  aquifer  and
 principal recharge area of the Slatersville Reservoir.  [7-1].   The
 quality of this aquifer is such that little treatment  is  required
 for its use as  a municipal  water supply.  The aquifer  consists
 of layers of sorted gravel, sand, silt, and clay drift  that were
 deposited in valleys from glacial meltwater.  Ground water  flow
 beneath the site is to the north in the direction of the
 Slatersville Reservoir with velocities on the order of  0.3  to  0.9
 m (1  to 3 ft) per day.

     Till and bedrock aquifers, hydraulically Interconnected with
 the stratified  drift aquifer, have  much lower ground water
yields.   The till  Is a poorly sorted,  non-stratified,  dominantly
 sandy deposit composed of varying proportions  of clay,  silt,
 sand,  gravel, and  boulders.  The till  covers the bedrock  surface
 in uplands  and  lies beneath the stratified  drift at most  places
                              143

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          /

          /
           TARKLIN
        I (
        I I
              0


               .
                           c - -: A.
                          /
                            /
,  '•«

''/
I  /(^DISPOSAL

\  I    AREA ->



 \\     1
   \ \
    \ \


       \\
       \ \
        \ ^ -
         \


         \ \


   \      / /
  \ \  F  / /
  CONVENTIONAL

A MONITORING WELL


0 MULTI-PROBE

  MONITORING WELL
                             \ \
                                   (ALL WELL LOCATIONS ARE APPROX.)
                                                       W,'FE
                                                         i
                              ROUTE 7
    4OO'»



  100m
Figure  7-2.   Site  environs  and monitoring  well   locations
                                144

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                                    I
                                    A
\.
      V  •**
     \ \
                                    DISPOSAL AREA
                 F r
                n
               A
\
 \
  \
  I
 f
s   v
                                                               A CONVENTIONAL
                                                                  WELL

                                                               A MULTl-PROBE MONfTQRING
                                                                  WELL

                                                                200H
                                                            50m
             Figure 7-3.   Well  and  pit  location map.
                                   145

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              TABLE  7-1.   PIT  DIMENSIONS AND VOLUMES
Pit
No.
Depth
(m)
Width
(m)
Diameter
(m)
Depth
(m)
Volume
(m3)
Pit Use
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
27.4
5.2
3.4
27.4
45.7
18.2
18.2
18.2
30.5
9.1
18.2
9.1
3.7
1.5
9.1
15.2
4.6
4.6
4.6
6.1
4.6
4.6
30.5
Subtotal  -  Oil  and chemicals
Subtotal  -  Septage
Total  - All  Uses
1.8
1.5
0.6
1.8
1.8
1.8
1.8
1.8
1.8
1.8
1.8
1.8
  450
   29
    3
  450
1,250
  150
  150
  150
  335
   75
  150
1.315
Septage
Oil  and chemicals
Chemicals
Chemicals
Septage
Septage
Septage
Septage
Septage
Septage
Oil  and chemicals
Septage
                    4,507
1  m = 3.28  ft
1  m3 = 264  gal
                                  146

-------
in the lowlands.  The bedrock aquifer consists of igneous and
metamorphic bedrock (granite beneath the site) and water occurs
almost exclusively in a network of irregularly spaced fractures.
Subsurface flow from bedrock to stratified drift is a source of
recharge to the stratified aquifer.  Three well logs from the
site are presented in Appendix 7-1.

SITE OPERATION AND HISTORY

     During the period of active dumping from 1975 to 1979,
large amounts of hazardous and septic wastes were dumped at the
site.  Records of the types of chemicals and the dates and
locations of the discharges are not available because the
operator failed to keep complete detailed records listing such
information.  Known wastes dumped include septage, oils, acid and
alkaline cleaning agents, heavy metals, cutting coolants, paint
residues, perchloroethylene, and aromatic and halogenated solvents
Most of the wastes consist of several phases of liquid,  suspended
solids, settleable solids, and sludges and slurries.

     An estimated total of 1,586 m3 (419,000 gal) of septage
has been dumped into the pits over the operational life  of the
site.  In addition, up to 125 'm3 (33,000 gal) of hazardous wastes
were disposed monthly, representing about 14 percent of  the
hazardous wastes land disposed in Rhode Island at the time.  About
80 percent of the wastes disposed into the pits were believed to
be aqueous acid or alkaline waste.   About 10 percent were a
mixture of oil, solvent, and acid and alkaline cleaning  agents.
The remaining was predominantly catch basin cleanout generated
by various companies.   The estimated volumes of sludge material
contained in the pits is presented in Table 7-1.

     In July 1975 WS&G asked and received permission from the
Rhode Island Department of Health (RIDOH) to dispose of  septage
into  two pits.   In late 1976  and early 1977 chemicals were
dumped into the pits  without approval from RIDOH.  The ensuing
citizen concern over the health and safety of the dump site
resulted in numerous  complaints.  In the spring of 1977, a
substantial  number of complaints were made to RIDOH, because of
the severe off-site odors originating from WS&G.   WS&G was
notified by the Town of Burrillville and the North Smithfie'td Fire
Department to remove the chemicals.  Several days later  the
chemicals were buried.

     Inspection of the site by RIDOH revealed WS&G to be
in violation of the guidelines for facilities receiving  septic
tank and cesspool  pumpings.  Specifically, pit length was found
to exceed 15.2 m (50 ft) and the depth exceeded 2.1  m (7 ft).-
There were no stakes or signs on the finished trenches and there
was no fencing around the pits.   Finally, five pits  were found
to exist exceeding the two pit limit established  in  1975.  The
site was ordered closed by the RIDOH.
                             147

-------
     At a hearing on May 2, 1977,  the site was ordered  to remain
closed.  This order was stayed by  the Superior Court on May 5,
1977 and the guidelines used to regulate disposal  facilities
were declared null  and void, allowing WS&G to continue  their
waste disposal  practices.   New laws and regulations  governing
the disposal of septic waste were  drafted in July  1977.  In the
spring of 1978, "The Rhode Island  Hazardous Waste  Management
Act" was passed by the Rhode Island legislature.   The law
created procedures for communities to sue for better enforcement
of existing regulations, to challenge regulations  if considered
inadequate, and even to stop environmentally harmful actions not
covered by the  regulations.

     On November 30, 1978, the Towns of North Smithfield and
Burril1ville, acting jointly, petitioned the Attorney General's
office to initiate legal action against WS&G as a  hazard to
public health.   On February 2, 1979, the special  assistant to
the Attorney General stated that the evidence did  not justify
closure of the  site and would not  support the initiation of
legal action against WS&G under any statutory or  common-law
principle.  However, legal action  was considered  if  evidence of
pollution should develop in the future.

     Inspection of the disposal site in the spring of 1979
revealed violation of the "Hazardous Waste Disposal  Facility
Rules and Regulations", which became effective December 21, 1978.
WS&G was found  in non-compliance for not preparing complete and
accurate manifests which describe  the chemical make-up  of wastes
disposed at the site.  Also, inspections were made since
residents living near WS&G complained of noxious  odors  from the
dump.  State inspectors confirmed  the complaints  by  determining
that objectionable odors could be  detected beyond  the facility's
property line in clear violcation  of the new State regulations.

     On April 24, 1979 the RIDOH issued an order  directing WS&G
to immediately  cease accepting or  disposing of any hazardous
wastes.  The order also required WS&G to prepare  and submit
plans to the RIDOH no later than May 7, 1979 for  permanent closure
of their disposal facility.  In accordance with the  RIDOH order,
the permanent closure had to take  place no later  than June 1,
1979.

POLLUTION

     For several years residents living near the  disposal site
and local officials have been concerned that toxic and  hazardous
wastes dumped at the WS&G would pollute surface and  ground water
supplies.in the area.  Water samples taken in December  1978
from a stream bordering the WS&G site revealed no  bacterial or
chemical pollution.  Water samples taken from drinking  water
wells located in the vicinity of WS&G also showed  no trace of
pollution attributable to the dumping site.
                             148

-------
     In a June 1979 meeting, RIDOH officials approved the
installation of six monitoring wells.  This was part of a
consent order for the permanent closure of the facility.  The
six monitoring wells were installed in November 1979 throughout
the disposal area and all were perforated through the entire
depth of the water table.  Well B was installed to drill auger
refusal; the remaining were installed to refusal or 21 m (70 ft).
wells D and E were located in the Tarklin Brook flood plain
adjacent to the disposal site (see Figures 7-2 and 7-3),

     Information obtained from the monitoring wells, residential
wells, and Tarklin Brook indicated the presence of a contamination
plume which was stratified with depth.  Contaminants appeared
to be concentrated at the top and bottom of the stratified drift
aquifer.  Visual observation and studies of the quality of water
in Tarklin Brook shewed that it was intercepting a portion of
the plume.  Leachate seeps in Tarklin Brook were noted.  However,
the monitoring wells could not fully determine the location or
extent of the plume.

     Because the six monitoring wells failed to clearly answer
questions regarding the ultimate destination of contaminants,
additional monitoring wells were required.  Ground water sampling
wells each with probes at multiple levels were chosen to provide
ground water quality information- with depth and to ultimately
assess the conditions of the aquifer in the vicinity of the
disposal site.  In February 1980, a consulting firm under
contract to ftlDOH installed1 these-muTti-probe wells.  The
installation details for each sampling location are presented
in Appendix 7-1.  A summary of the field permeability tests is
included in Table 7-2.

     On February 26, 1980 representatives of the Division of
Water Resources and the consultant met for the purpose of sampling
and measuring the various disposal  pits located at WS&G.  The
EPA conducted a sampling program of their own at the same time.
The primary purpose of  the sampling was to obtain sludge and
sediment samples for PCB analysis,  and to obtain samples from
the chemical pits for complete organic analyses.  The results
of the pit sampling are provided in Table 7-3.

     Samples from the multi-probe wells, conventional wells,
private wells, and surface water were taken on February 6 and
7 and again on May 1,  1980  through  State,  federal,  and private
testing.  Severe ground wate'r contamination has  been detected
on the site and points downstream from the disposal  area,  some
as far as  305 m (1,000 ft)  downstream where Tarklin  Brook
enters  the Slatersville Reservoir.   Chemical  contaminants  have
also been  found in five private wells  in  the vicinity of WS&G.
Results  of the testing are  presented  in  Tables  7-4  and 7-5.
                             149

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           TABLE  7-2.
SUMMARY  OF  FIELD  PERMEABILITY
 TESTING  RESULTS
Exploration
Number
A-2
A-2
A-2
A-2
A-2
A-2
E-2
E-2
F-2
LFRR-A
LFRR-A
LFRR-B
LFRR-B
LFRR-B
Depth
(m)
11.2
11.2
19.2
29.1
33.2
49
19
49
25-27
14.3
39.2
14.1
39.1
54.1
K- Range '
(cm/sec x 10'3)
2.3 - 2.6
0.7 - 0.8*
1.0 - 1.1
1.5 - 2.0
4.3 - 8.0*
0.4 - 0.5
0.35 - 0.37
0.41 - 0.43
—
0.4
0.15 - 0.24
0.10 - 0.14
0.5 - 0.8
1.3 - 1.9
Average K1
(cm/sec )
2.5 x ID'3
8.1 x 10-*
1.1 x 10-3
1.7 x 10~3
6 x ID"3
4.4 x 10'4
3.7 x 10-4
4.2 x 10-*
3.0 x 10'5*
4.0 x 10-4
2.0 x 10'*
1.2 x 10-*
7.0 x 10-*
1.6 x ID'3
Test Type
Flush Bottom
Wick Test
Flush Bottom
Flush Bottom
Wick Test2
Flush Bottom
Flush Bottom
Flush Bottom
Wick Test
Flush Bottom
Flush Bottom
Flush Bottom
Flush Bottom
Flush Bottom
Soil Strata
Description
Stratified Sand
Stratified Sand
Stratified Sand
Stratified Sand
Stratified Sand
S1lty Sand
Fine to Medium Sand
Stratified Sand
Glacial Till
snt
snt
SUty Sand
S1lty Sand
Fine to Coarse Sand
NOTES:

1.  K represents average mean coefficient of permeability for flush bottom tests and average horizontal  permeability for
   wick tests (denoted *).
2.  Constant head test. (All others falling head.)
3.  Calculations based on equations from Hvorslev (1949).

1 cm • 0.4 In.
1 m  - 3.28 ft
                                          150

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TABLE  7-3.    ANALYTICAL  RESULTS  FOR PIT
              SAMPLING ON 2/27/80
P1t 1
Parameter Sludge
Arsenic (nig/kg) 0.8
Lead (mg/kg) 7.0
Mercury (mg/kg) <0.3
Toluene (ppb)
Xylene (ppb)
Tetrachloroethylene
(ppb)
Trichloroethylene (ppb) —
1.1,1-Trfchloroethane
(ppb)
Methyl ene Chloride (ppb)--
CMo reform (ppb)
PCB (ppm) <50.0

Top
0.5
32.0
<0.3
20,000
390,000

2,900
1,600

6,800
2,800
.-
"
Pit 2
Liquid
..
—
..
360
630

2
S

—
—
—


Sludge
0.6
8.0
<0.5
—
—

—
—

—
—
--

Pit
Top
0.4
38.0
0.5
31,000
410,000

250,000
220,000

300,000
--
—
"
3
Sludge
0.7
47.0
0.6

	

—
__

	
..
	
~~

Liquid*

_ —
--
270,000
1 ,400,000

210,000
72,000

56,000
75,000
5,600

Pit 4
Liquid***

wv
	
6,300
9,700

19,000
25,000

21,000
66,000

_.

Sludge
0.6
82.0
<0.3

_„

__
	

^—
__
__
--
Parameter
Arsenic (mg/kg)
Lead (mg/kg)
Mercury 
-------
TABLE 7-4.  ANALYTICAL RESULTS FOR WELL  AND
         STREAM SAMPLING ON 2/7/80
well Location
Parameter
Benzene (ug/1 )
Toluene (ug/1)
Xylene (ug/1)
Carbon Tetrachloride (ug/1)
Trlchloroethylene (ug/1)
1,1,1-Triehloroethane (ug/1)
Bromodlchloromethane (ug/1)
Chloroform (ug/1)
Olbromochloromethane (ug/1)
PC8 (ug/1)
Tetrachloroethene (ug/1)
Arsenic (mg/1)
Barium (mg/1 )
Cadmium (mg/1)
Chromium (mg/1 )
Copper (mg/1)
Lead (mg/1)
Mercury (mg/1)
Nickel (mg/1)
Selenium (mg/1)
Silver (mg/1)
Zinc (mg/1)
F3-1
<200
164
533
<1
12
56
<1
7
<1
—
2
	
	
—
— •
—
— •
—
—
—
—
"
F3-Z
<20
<20

-------
TABLE 7-5.   ANALYTICAL RESULTS FOR WELL
           SAMPLING ON 5/1/80
Parameter
Benzene (ppb)
Xylene (ppb)
Toluene (ppb)
Chloroform (ppb)
Brorodtchloromethane (ppb)
Bromoform (ppb)
DlbromocMoromethane (ppb)
THchloroethylene (ppb)
Carbon Tetrachlorlde (ppb)
Tetrachloroethylene (ppb)
1,1,1-Trlchloroethane (ppb)
PCB (ppb)
Arsenic (mg/1)
Barium (mg/1)
Cadmium (mg/1)
Chromium (mg/1)
Copper (mg/1)
Lead (ng/1)
Mercury (mg/t)
Nickel (mg/1)
Selenium (mg/1)
Silver (mg/1)
Zinc (ng/1 )


"73-1
<20
<10
< 10
<1
<1
<1
<1
<1
<1
<1
<1
<10
<0
0
<0
0
0
0
0

-------
REMEDIAL ACTION

     Because of the immediate health  threat to  citizens  living
in the surrounding area,  RIDOH has been under pressure to clean-
up the site.  RIDOH issued an order against WS&G in December
1979 requiring WS&G to remove all  waste materials  contained in
the pits within a specified timeframe.   WS&G did not comply with
this order.   As a result,  RIDOH obtained legal  authorization to
undertake closure of the  site.

     Because wastes continued to seep into the  subsurface from
the pits, the EPA assumed  jurisdiction  under the 311 provisions
of the Clean Water Act in  February 1980 and ordered the  removal
of the contents from four  pits containing hazardous wastes.  Work
began on March 4, 1980 and 144 m3  (38,000 gal)  of  liquid were
pumped and transported to  Stoughton,  Massachusetts for storage.
In addition, 296-0.2m3 (55 gal) drums of sludge were removed
from the pits and are now  stored at the site.  An  additional amount
of sludge and contaminated sand has been mixed  with sawdust and
covered with polyethylene  and stored  at the east end of  the pits.

     On February 20, 1980, RIDOH was  given authority to  hire a
private firm for the removal  and disposal of the liquid  and
sludge septic wastes not  removed under  311 work.  Three  alterna-
tives were proposed:  (1)  sludge waste  removal  for on-site
storage; (2) sludge waste  removal  for off-site  disposal, and
(3) sludge waste disposal  on-site.  An  agreement has been reached
with the Blackstone Valley District Commission  for the disposal
of the liquid septage at  their facility in Lincoln, Massachusetts.
An estimated 317 m3 (415  yd3) of septage will be removed at the
direction and expense of  RIDOH.

     An interim hydrogeologic report  prepared by a consultant in
June  1980 concluded that "the major  water quality threat is to
private wells down-gradient of the disposal site,  primarily in
an area to the west of Tarkiln Brook  and south  of the Slatersville
Reservoir.  Therefore, if a do nothing  policy is adopted, a
permanent alternate water supply will have to be provided for
homes served by domestic  wells located  in the plume." [7-1]

     The cost to the State of Rhode Island for the removal of
wastes at WS&G is estimated to be over $1,000,000.  The
pumping of the septage and chemical wastes and  its removal' and
disposal is estimated to  be $483,724.  If a leachate collection
and treatment system is installed it  will cost  approximately
$362,000.  Contingencies  could cost another $250,000.  The
breakdown of total estimated  costs is given in  Table 7-6.

CONCLUSION

     Considering the poor records and disposal  methods encountered
at this site, the  identification of the precise limits of
                             154

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          TABLE 7-6.  ESTIMATED REMEDIAL ACTION COSTS
Pumping out septage pits (963,000 gal  @
     $0.04/gal)                                    $   38,520
     Tipping charge (@ $8.00/1,000 gal)                 7,704
Pumping out chemical  pits (250,000 gal  @
     $1.25/gal)                                       312,500
Sludge removal  and disposal  (100,000 gal @
     $1.25/gal)                                       125,000
Well  points                                            12,000
Leachate collection and treatment (2 years)           270,000
Site  preparation                                       30,000
Impermeable membrane                                    40,000
Subtotal                                           $  835,724
Contingencies (0 30 percent)                          250,717
Total                                               $1,086,441
                              155

-------
contaminated ground and surface water has  been  a  costly  under-
taking.   Since the mere identification of  the  problem was  not
considered a solution,  RIDOH proposed to establish  a  means  of
dealing  with the situation before it  had an  opportunity  to  spread
to adjacent land and water supplies.

     The remedial  action taken by EPA under  311  funds to remove
the hazardous wastes and the proposed work under  the  authority
of RIDOH to remove septic wastes is  a starting  point  for the
complete clean-up  of the site.  However, remedial  action should
have been initiated long before the  311  work.   WS&G is hydro-
geologically a poor location for a hazardous waste  site.  WS&G
should never have  been  permited to accept  waste and immediate
action should have been taken when it first  became  evident  in
1976 that WS&G was causing problems.

     Of  the remedial actions available to  abate or  control  the
contamination plume, the leachate collection and  treatment
system appears to  be the most cost-effective.   A  well point
dewatering system  could be implemented.  Since  the  contamination
plume has migrated beyond the boundaries of  WS&G,  it  would  be
necessary to install a  number of wells further  down-gradient
from the main cluster of wells.

     If  remedial actions are not initiated,  the ground water
and the  Slatersville Reservoir will  likely become  extensively
contaminated.  Alternate water supplies, including  new reservoirs
and a public water supply system to  local  residents,  would  be
needed in the near future.  In addition, it  will  jeopardize the
economic, industrial, and domestic development  of  the region  as
well as  endangering the health, safety,  and  welfare of the
citizens.  These costs  far outweigh  the  costs  of  cleanup.
                               156

-------
                SITE F REFERENCES AND BIBLIOGRAPHY
7-1    Johnston, H.E.  and D.C.  Dicker-man.   "Availability of Ground
      Water in the Branch River Basin, Providence County, Rhode
      Island".  U.S.  Geological Survey Water Resources Investi-
      gation 18-74.  December 1974.

7-2,   Barvenik, Matthew and Richard Cadwgan.   "BarCad Groundwater
      Sampling Systems".  Landfills and Lagoons,  Technical Bulletin
      80-3.

7-3   Preliminary Hydrogeologic Report by Goldberg, Zonio, and
      Associates, Inc.  Newton Upper Falls, Massachusetts, 1980.

7-4   Personal communication and file review with Frank B.
      Stevenson, Principal Engineer, Division of Air and Hazardous
      Materials, Department of Environmental Management.
      Providence,. Rhode Island.  June 1980.
                               157

-------
             APPENDIX 7-1

MULTI-PROBE WELL INSTALLATION DETAILS
              FOR SITE F
                 158

-------
                       INSTALLATION DETAIL A-2
-SOIL DESCRIPTION-
                 DEPTH
                                       SLOTTED 11/2" I.D. STEEL PIPE
  FINE SAND,
  LITTLE TO
  SOME  SILT
                                       WELL POINT A-2-2
  FINE TO COARSE
  SAND. LITTLE TO
  SOME GRAVEL,
  TRACE SILT
 FINE SAND,
 SOME SILT
 STRATIFIED WITH
 FINE SAND AND
 SILT            18.3m—
TIKIP Tfl eflAB5E 5AUB
  BEDROCK -GRANITE
                        :L-\--~-~l
                                   1    WELL POINT A-2-3
                       159

-------
                       INSTALLATION DETAIL E-2
-SOIL DESCRIPTION-
                 3.0m—1
                      I
                         I
                   6.1m— I
FINE TO COARSE         I
SAND .TRACE GRAVEL,
TRACE SILT WITH        "_
LAYERS OF FINE SAND,    b=
SOME SILT; & MED.  9.1m- f
TO COARSE SAND,        |
TRACE  SILT            I
                  12.2m— |=\^I-=^:
                         f
                  15.2m-
   FINE TO COARSE I8'3m   *=	
   SAND.SOME GRAVEL,
   SOME SILT
                                        SLOTTED  1 1/2" I.D. STEEL PIPE
                                    1    WELL POINT E-2 -2
                                 '/I


   \tn* 3.28ft.
                      !
               21.3m— L
                                        WELL POINT E-2-4
                          160

-------
                       NSTALLATION DETAIL F-3
- SOIL DESCRIPTION-
 FINE TO MEDIUM

 SAND           3.0m-
                6.lm_
                             : —j
 FINE TO COARSE SAND

 6 FINE TO COARSE        I

	9Jm_



 BEDROCK
                      \t>.~/,,*
                      m
                         ^  -* r< -f
                                     SLOTTED liyg1 |.D STEEL PIPE
WELL POINT F-3-Z
 lm-3.28f»
                     161

-------
   APPENDIX 7-2



SITE F PHOTOGRAPHS
       162

-------
                                <%'**
Two waste disposal pits at Western Sand and Gravel
Note the excavated sand characteristic of  the
disposal site.
                 163

-------
Location of leachate seep  into  Tarklin  Brook
emanating from the disposal  pits.

View of the sludge contaminated sand  and sawdust
mixture stored at Western Sand and Gravel,   Note
the polyethylene cover.
                    164

-------

Collecting samples from multi-probe well  used
provide ground water quality data at Western
Sand and Gravel  site.
to
                    165

-------
                          SECTION  8

                            SITE G
                      FERGUSON PROPERTY
                   ROCK HILL,  SOUTH CAROLINA
INTRODUCTION

     Approximately 2 ha (5 ac)  of land in north-central  South
Carolina was leased from the Ferguson Family by Industrial
Chemical Company,  Inc.  (ICC) in the mid-1960's.  The land was
used to store solvents  prior to their reclamation.   In 1966 ICC
vacated the site,  leaving behind approximately 2,500 to  5,000
drums of waste.   Subsequently,  the situation came to the attention
of the South Carolina Department of Health and Environmental
Control (SCDHEC) in 1976.  A site investigation found many of the
drums to be corroded and leaking.  Sample analyses  of the drummed
material revealed  highly flammable and toxic material.  It was
suspected that some of  the leakage had seeped into  a nearby
stream.

     SCHDEC attempted to persuade ICC and the landowner  to
come to a mutual agreeement for cleaning up the site.  Since
neither party would accept responsibility and since the  site
represented a fire and  pollution hazard, the U.S. Environmental
Protection Agency  (EPA) Region  IV, Environmental  Emergency
Branch (EEB) initiated  cleanup  activities.  After their  first
containment attempt was ineffective, EEB returned to remove
drummed wastes and contaminated rainwater.   The  contaminated
rainwater was removed and hauled to a wastewater  treatment plant
for processing.   A substantial  amount of the drummed waste was
removed from the site and reclaimed, with deteriorated drums  and
some contaminated  soil  buried on-site.

     Currently some liquids and sludges in drums  and tanks remain
at the site, even  after the second remedial activity described
above.  It is expected  that some additional actions will be
necessary to remove the long term threat to the environment.   To
this end, the SCDHEC is pursuing legal action to  assign
responsibility for future cleanup costs.

SITE DESCRIPTION

     As shown in Figure 8-1, the site is located  in north-central
South Carolina about 3  km (2 mi) west of the City of Rock Hill.
The site occupies  1.2 to 2.0 ha (3 to 5 ac) of 42.3 ha (104.5 ac)
owned by the Ferguson Family.  The site is bordered by a tributary
to Fishing Creek,  which is a tributary to  the  Catawba River.

     The area's  normal  precipitation is approximately 107 cm/year
(42 in./year); average  snowfall is approximately  13 cm/year (5 in./
                              166

-------
year).  The annual  average wind speed is  12 kph (7.5 mph).   The
average daily high  temperature is 16°C (61°F),  with the highest
daily maximum in July at 31.3 C (88.3°F)  and lowest in  January
at 0.1°C (32.1°F).

     The topography of the area is characteristically rolling
hills.  The slope range is 0 to 30 percent and  the total  relief
is about 15 m (50 ft).  Vegetation is extensive,  covering nearly
all of the land.  The site itself was covered with tree growth
and kudzu (a leguminous vine) prior to implementation of remedial
measures.

     Deep ancient soils (saprolite) developed in  the general  area
on Precambrian and  Paleozoic metamorphic  and igneous bedrock.
Little site specific information exists about the stratification
and depth of soil to bedrock underlying the site.  It is known
that a minimum 2 m  (8 ft)  thick layer of  red clay soil  covers  the
former drum storage area.   The depth to ground  water is likewise
unknown; however, ground water movement occurs  through  a network
of irregularily spaced fractures.  Small  springs  or diffuse
seepage issuing from fault zones or joints are  sources  of
recharge for area streams.

     The site is located in the Piedmont  Province approximately
24 km (15 mi) west  of the Fall Line, a sharply  defined  boundary
marked by a line of rapids and falls separating the slightly
elevated rocks of the Piedmont Province from the  lower  formations
of the Atlantic Coastal Plain.  The crystalline metamorphic and
igneous rocks of the Piedmont Province are grouped in five  north-
east trending lithologic belts which are  interpreted to be
zones of different  grades  of regional metamorphism.  Underlying
the site is the Charlotte Belt, which is  composed of feldspathic
gneiss and migmatite of the albite-epidote amphibolite  facies.
Cross-cutting granite fills fractures.  Granite plutons shaped
like inverted tear  drops occupy folds in  localized regions  to
the east.

SITE OPERATION  AND HISTORY

     Industrial Chemical Company, Inc. (ICC) operated as a  solvent
reclaimer, extracting useable solvents from chemical wastes by
distillation.  During the years 1963 to 1966, ICC leased lands
belonging to L.B. Ferguson, Sr. for storing reclaimable industrial
waste solvents.  In practice, the Ferguson property was used more
for drum storage than reclamation.  Materials such as paints,
inks, and solvents  were brought to the site in  0.2  m3  (55  gal)
drums and stored in drums  and tanks prior to reclamation.

     When the original landowners, Mr. and Mrs. L.B. Ferguson, Sr.,
died in a car accident, the property ownership  was placed in an
estate.  In 1967, a dispute arose between the heirs to  the  Ferguson
                              167

-------
               GASTONIA
                                                  NO. CAROLINA
                                                  liO.CAROLINA
FERGUSON SITE
Figure 8-1.   Location  of  Ferguson site  in Rock  Hill,
                     South  Carolina.
                            168

-------
estate and ICC regarding the lease.   According to W.  D.  Neal ,
president of ICC, one of the property heirs demanded  immediate
payment of rent due.  Since ICC was  unable to make immediate
payment, ICC was informed that neither officers nor employees
of ICC were allowed to enter the property for any purpose.  [8-1]

     ICC vacated the site in 1967 and since that time has had
no dealings with the Ferguson heirs.   ICC is a smal1, family-owned
corporation.  After vacating the property in 1967, ICC purchased
property outside of Rock Hill and moved their operations to that
site, where it now has a permitted incinerator and landfill.

POLLUTION

     For a period of four years, the South Carolina Department of
Health and Environmental Control (SCDHEC) tried to persuade the
Ferguson heirs and ICC to come to a  mutual agreement  for removing
drums on the Ferguson site.  The first SCDHEC site inspection  was
conducted in March 1978, revealing 2,500 to 5,000 corroded,
leaking drums.  These drums were unprotected from the elements
and placed directly on the ground.  Drums were stacked three  or
more high in many places and were either leaning or fallen  over.
A large number of drums had also been stacked on the  bank of  a
small stream bordering the site.  There were no provisions  to
prevent leakage of drum contents from entering the stream.
Brush growing around the drums indicated that the site had  not
been maintained for several years.

     In October 1978, acting under South Carolina's "Emergency
Regulations for Storage of Hazardous Waste", SCDHEC tried to  get
the two parties to voluntarily resolve the problem at the site,
requesting that a mutually agreed-upon plan be submitted to
remedy the hazards.  Again conferences were scheduled to finalize
the agreement between the two parties, but no agreement could
be reached.  SCDHEC personnel re-inspected the site in July 1979
and collected representative samples for analysis to  determine the
toxicity of the material.  Analyses  revealed highly flammable
and toxic wastes.  The inspection also revealed no change had
occurred from the time of the previous inspection and that  some
discharge into the environment was occurring.

     In October 1979, samples were collected from the site  by
the U.S. EPA Surveillance and Analysis team out of Atlanta,
Georgia.  Analyses revealed hazardous substances similar to the
chemical compounds being incinerated and reclaimed at the new
ICC facility.  If these were the same wastes, they could be
expected to include dirty paint and  ink solvents consisting of
compounds such as xylene, ethyl chloride, diethyl carbomethoxy
phosphate, alcohols, ammonia, and acetic acids.  Table 8-1  lists
concentrations of primary pollutants found in the drummed waste
                               169

-------
                      TABLE 8-1

 1979  U.S.  ENVIRONMENTAL  PROTECTION  AGENCY
         DRUM  AND  SOIL  ANALYSIS  [8-1]
         Pollutant
                                          Concentration ting/Kg)
                                     Drummed Waste
                                                       Soil
Lead
Chromium
Z1nc
Copper
Napthalene
Dimethyl Phthalate
B1s (2-ethylhexyl) Phthalate
Aroclor 1,254
1 ,1 ,1-Trlchloroethane
Benzene
Toluene
Ethylbenzene
 20,430
  3,450
  1 .987
   125
    82
  1,500
  1,800
    67
    26
    93
340.000
  7,400
  394
  335
1 .471
  175
  ND
  ND
1 .800
  ND
  ND
  ND
   9.1
  <5
ND = Not Detected.
                           170

-------
 and  in  the  soil.   Concentrations of priority pollutants in excess
 of background  levels were not detected in the creek.  However,
 the  investigation  was conducted in dry weather.  High concentrations
 would be more  likely in wet weather when rainfall could carry
 pollutants  from the site surface into nearby drainage ways.

     Another site  inspection was conducted by the SCDHEC and U.S.
 EPA  Region  IV  Environmental Emergency Branch (EEB) in December
 1979.   No significant change in site conditions was found.
 Figure  8-2  displays the location of drums prior to remedial
 activities.  The site is located near residences, a heavily
 traveled highway,  and a stream.  If the stacked drums along the
 stream  edge fell and ruptured, the stream could become contaminated.
 In addition, it was suspected that large quantities of chemicals
 had  discharged into the stream over a period of years from 800
 empty drums stacked at the edge of the stream.  However, stream
 samples never  indicated detectable contaminants.  In addition to
 potential stream and soil contamination, the drummed chemicals
 left on the Ferguson property posed a fire hazard.

 REMEDIAL ACTION

     When it was determined that an agreement between heirs of
 the  Ferguson property and ICC was unlikely to be consummated in a
 timely manner, EEB initiated a 311  action to eliminate the fire
 hazard and  prevent further contamination of the stream and soil.
 Temporary containment measures implemented by EEB included
 removal  and relocation of drums and construction of an under-
 ground storage area.

     During cleanup operations, workers used vinyl suits,  plastic
 splash guards, and carbon canister masks.   Oil  in a 23 m3  (6,000
 gal)  tank was purchased and removed by Alternate Energy Resources of
 Augusta, Georgia.   The empty tank was repositioned and used for
 storage of  liquids withdrawn from deteriorated drums.   Chemicals
were transferred from rusting leaking barrels to durable containers
and  relocated away from the stream.  The ground above the  creek
was  leveled with bulldozers and intact barrels  were arranged in
 rows  and sections.  Earthen dikes were constructed around  each
 section of  drums.   To prevent rainwater infiltration,  the  sections
were covered with  a double layer of 0.1  mm (4 mil) polyethylene
and  thence a 15 cm (6 in.) thick layer of clay to prevent
infiltration of rainwater.   Pipes were installed through the
cover to vent any  build-up of pressure inside the mound.  A dike
a*nd  diversion ditch was constructed around the  area to divert
runoff and the area was seeded.   A total  of 1,835 drums  were
moved to the storage area and 800 empty drums were crushed and
stored in a containment trench.   The  complete process  took the
contractors (O.H.  Materials,  Inc.,  of Findlay,  Ohio)  and the EPA
                              171

-------
                        BRANCH OF WILDCAT CREEK
Figure 8-2.   Location  of drums on  Ferguson property. [8-1]
                             172

-------
Region IV EEB about a week to complete.   This phase of temporary
remedial  action was completed on January 29, 1980 at a cost of
about $55,000.

     In mid-March 1980, approximately six weeks after completion
of the above activities, the SCDHEC noticed that the vent pipes
installed in the burial mound were discharing liquids resembling
contaminated rainwater.  It was speculated that the fumes from the
waste had decomposed the polyethylene cover allowing overlying
soil  to cave in.  Approximately 20 cave-in areas were noted in
the burial  mound.  It was suspected that rainwater had entered
the buried sections containing the drummed waste through these
cave-in areas.

     Region IV EEB responded promptly to clean up the contaminated
rainwater.   The water was  first pumped  from the four disposal
sections  and colledted in the on-site bulk storage tanks.  A
collection trench was constructed near the creek to prevent
spill drainage entering the surface water.  The solvents were
sampled by M&J Solvents of Atlanta, Georgia to determine the
feasibility of reclaiming them.  Samples were also taken of the
contaminated  rainwater and analyzed by  an EPA contractor and the
SCDHEC.  Analyses revealed that the contaminated rainwater could
be processed at the Rock Hill Manchester Creek Wastewater
Treatment Plant; it was also determined  that the solvents could
be reclaimed.

     Subsequently, the contaminated rainwater was hauled to the
treatment plant and 140 m3 (38,000 gal)  of solvents were pumped
out of the barrels and trucked to M&J Solvents in Atlanta.  The
emptied drums were removed from the burial cells to a separate
diked area where they were crushed for later disposal.  All of
the remaining solids, contaminated soil, and empty damaged drums
were  consolidated,  crushed, and buried  in saw dust pits.  The
pits  were then covered with top soil and the area was seeded.
Approximately 70 drums, which were in good condition, were
consolidated and placed at the upper end of the site.  Approximately
7.6 to 11 m3 (2,000 to 3,000 gal) of wet sludge were left at the
site  in two tanks.

     Figure 8-3 displays the pit, barrels, and tank locations at
the site  after completion of the second  set of remedial  activities.
Approximately two weeks were required for the second temporary
remedial  activity.  The second set of remedial actions cost
$88,000 bringing the total temporary remedial cost to $143,000.
Table 8-2 further defines the cost of the two temporary  contain-
ment  efforts,  As was stated before, this action was carried out
to minimize potential fire hazards and the possibility of a
chemical  spill reaching the nearby stream.  The permanent/long term
remedial  action will  be forthcoming when a legal determination
has been  made as to the responsible party.
                              173

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Figure 8-3.   Site  layout  after  remedial  action
            at  the Ferguson  property.  [8-1]
                      174

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       TABLE  8-2.   COST  OF CONTAINMENT  REMEDIAL MEASURES
                         AT  FERGUSON PROPERTY  [8-3]
                                      Expenditures by Region  IV  EEB
                                I/Z1/8U-         J/TZ/BTP
	Item     	V28/80	3/29/80           Total

Labor and other  expenses         $31,056          $56,259        $87,315

Per Diem                          3,640            6,232           9,872
Subcontractor:  (subcontractor
  and rental equipment)           17,844           22,968          40,812
Miscellaneous  (stone, seed,
  sawdust, plastic, etc.)          2,512            2,667           5,179
Total                           $55,052          $88.126        $143,178
                                  175

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CONCLUSION

     When the environmental problems at the Ferguson property
were first discovered in 1976, SCDHEC tried to persuade both
parties to remove the corroded, leaking drums containing flammable
chemicals.  Neither the Ferguson heirs nor ICC were willing to
meet together and discuss and resolve the problem.  SCHEC did
not have legal power to force removal of the drums.  There were no
regulations governing how hazardous wastes could properly be
di sposed.

     Since neither the landowner nor ICC would accept voluntary
responsibility for the barrels, EPA resorted to 311 action to
contain the site for a two to four year period.  It was believed
that the temporary cleanup measures as outlined by EEB would keep
the cost down and would allow pressure to be maintained on one
or both parties to achieve permanent disposal  of the barrels.
However, the first measures instituted by EEB were not adequate.
EEB was required to return to the site, remove the solvents, and
crush the drums.  The solvents were sent to a solvent reclaimer.
The crushed drums, solids, and contaminated soil  were all  buried.
The site was then regraded, diversion ditches were installed,
and the area was seeded.

     The total cost of the two temporary corrective actions was
approximately $143,000.   Both actions were to ensure no seepage
problem occurred while the State legally determined the responsible
party.   The State is responsible for ensuring  completion of
permanent cleanup actions once the responsible party is determined.
Permanent  cleanup would  include removal  of the remaining solvent
waste (i.e.,  drummed solvent waste and the oil  sludge waste
located in the tanks).
                              176

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              SITE G REFERENCES AND BIBLIOGRAPHY
8-1   Personal communication and file review with Gary Hogue,
     Environmental Quality Manager, Catawba District, South
     Carolina Department of Health and Environmental Control,
     Fort Lawn, South Carolina.  June 13, 1980.

8-2   Personal communication and file review with Joe Young, U.S
     Environmental Protection Agency, Region IV, Residual
     Management Branch, Atlanta, Georgia.  May and June 1980.

8-3   Personal communication with Jan Rogers, U.S. Environmental
     Protection Agency, Region IV, Environmental Emergency
     Branch,  Atlanta, Georgia.  May, June, and July 1980.
                              177

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   APPENDIX 8-1



SITE G PHOTOGRAPHS
       178

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Site appearance prior to any remedial  action.
 During the first applied  remedial  action  the
 drums  were placed in  trenches  and  a  plastic
 liner  placed  on  top  prior to  soil  addition.
                   179

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                A.
         '



   Burial area following second cleanup

Drainage diversion  ditches  around  burial  site
                     180

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 38  m3  (10,000  gal)  barrel containing solvent sludge
    remaining at  site  pending  further cleanup.




Approximately 70 barrels  in  good  condition  left  at
            site pending  further  cleanup.
                       181

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                          SECTION  9

                            SITE H
                          3M COMPANY
                     WOODBURY, MINNESOTA
INTRODUCTION

     From 1960 until 1966, spent solvents and acids from the
Minnesota Mining and Manufacturing (3M) Chemolite and St.  Paul
scotch tape, sandpaper, and chemical  manufacturing operations
were disposed in pits at a site in Woodbury Township, Minnesota.
In May 1966, a nearby private well was found to be contaminated
with isopropyl ether, an organic solvent.  Subsequently, disposal
in the pits was discontinued and comprehensive monitoring  of
other wells in the area initiated.  Based on the data collected,
it was determined that only the one originally affected well had
been contaminated with organic solvents.

     In January 1968, the waste in the pits was removed and burned
on-site.   Between 1966 and 1971, solvent  waste produced by 3M was
sent to incinerator facilities off-site.   Better controls  were
then exercised over in-house operations to reduce the amount of
waste requiring disposal.  In 1971, an incinerator was constructed
on-site by 3M to dispose of waste solvents.

     To prevent further migration of  pollutants in the ground
water, four barrier wells were installed  at the Woodbury site.
These wells are pumped continuously,  and  discharged to the
Mississippi River.  Monitoring data collected since implementation
of these actions indicates that the barrier wells are effective
in preventing further contaminant migration.

SITE DESCRIPTION

     Figure 9-1 shows the location of 3M's Woodbury disposal site
in relation to Chemolite, Minneapolis, St. Paul, and the
Mississippi River.  The 3M Woodbury disposal facility is located
on the eastern side of the Twin Cities Metropolitan Area.   The
3M Chemolite manufacturing facility which provided a major
portion of the waste disposed at the  Woodbury site, is located
about 6 km (4 mi) south of the Woodbury disposal facility.

     The normal annual  precipitation  for  the area is 66 cm (26 in.)
and the normal annual snowfall is 117 cm  (46 in.).  The average
wind speed is 16.9 kph (10.5 mph).  The annual daily maximum
temperature is approximately 12°C (54°F)  with the monthly  high
occurring in July at 28°C (82.4°F), and lowest in January  at
-6°C (21 .2QF).
                              182

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                             MINNEAPOLIS-ST.PAUL
                                 AND VICINITY
                                                   VWODBim
                                                i  I DISPOSAL
                                                	FACILITY
                                             COTTAGE GROVE
                                                     3M CHEMOLITE
                                                     MFG.
                                                     WCILITY
                                             v  —"
Figure 9-1.   Location  of 3M  disposal site
            in Woodbury,  Minnesota.
                       183

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     The geology in the area consists of Paleozoic bedrock over-
lain by glacial  drift averaging 15 to 30 m (50 to 100 ft)  thick.
The site lies in a buried glacial  valley.   During an earlier
time period, the valley was apparently cut by a tributary  which
fed into the nearby Mississippi River.  The channel  was subse-
quently filled with sand and gravel  from more recent glaciation.
The buried bedrock channel  trends  in a northwest to  southeast
direction and was carved out of the  Shakopee-Oneota  and Jordan
Formation.

     Beneath the glacial outwash,  Platteville Limestone, a
medium dense gray shaley limestone,  overlays the St. Peter
Sandstone.  The  St. Peter Sandstone  in turn overlays the
Shakopee-Oneota  Dolomite, which overlies the Jordan  Sandstone.
The Shakopee Dolomite contains fractures possibly created  by
previous glacial loadings.   The pits at the Woodbury disposal
site are located in the glacial outwash over the Shakopee  Dolomite,
Therefore, it is speculated that if  any contaminants reached
the Shakopee, easy access would be provided to the underlying
Jordan Aquifer.

     The outwash glacial material  in the area is typically clay
and gravel.   The soil is a  sandy loam provided by the glacial
material and is  reasonably  fertile.   The limestone provides an
alkaline pH  to the soil.  The soil lends itself to drought
conditions due to its sandy nature.   The topography  of the area
is also influenced by previous glacial movements.  The land is
slightly rolling to flat with only minor ravine systems.

     There are no drainage  creeks  or rivers in the immediate
site area since  the glacial till acts as a sponge.  The surface
drainage of  the  Twin Cities area consists  of potholes, swamps,
lakes, and a few small  river tributaries to the Mississippi
and Minnesota Rivers.  Due  to the  nature of the glacial drift,
drainage channels appear for only  a  short  distance before
terminating  in marsh areas.  The only significant drainage rivers
in the area  are  the Mississippi and  Minnesota.

     The primary commercial and residential water supply for the
area is ground water.  The  Jordan  Aquifer  supplies water for
industries in the Twin Cities area.   Prior to installation of
the barrier  wells, two bodies of ground water existed under the
pits in Woodbury:  perched  water and the Jordan Aquifer.
Figure 9-2 displays a generalized  geological cross section of
the area beneath the site.   Previous to barrier well installation,
the perched  water located in the glacial drift below the pits
supplied water to shallow wells in the area.  However, within
three years  after barrier well installation, all perched ground
water in the glacial till had dissipated.   Thus, the only
ground water body now located beneath the  old pit area is  the
Jordan Aquifer.   While it existed, perched water in  the glacial
                             184

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-1000
-BOO'
                                                      SHAKOPEE'ONEOTA DOLOMITE
_600
_500
_400'
                                                      JORDAN SANDSTONE
     ORIONAL STATIC WATER LEVEL PRIOR TO BARRIER WELL INSTALLATION
  Figure  9-2.   Geological  cross section of area  beneath
                 Woodbury  disposal site.  [9-1]
                                  185

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drift tended to flow southwestward to south toward the Mississippi
River.  The Jordan Aquifer, however, flows northwest from the site
toward Minneapolis and St. Paul.

SITE OPERATION AND HISTORY

     In 1960, Terminal Warehouse purchased 12 to 16 ha (30 to 40
ac) of farmland in Woodbury, Minnesota for use as a waste
disposal  site.   Wastes from 3M manufacturing plants were hauled
and disposed by Terminal  Warehouse in unlined lagoons (pits)
at the Woodbury site.  In August 1961, 3M purchased the land from
Terminal  Warehouse and continued to use it for disposal of waste
from their Chemolite plant (located in Cottage Grove, Minnesota)
and downtown St.  Paul facility.  Pits on the property were used
by 3M for dispsoal of spent solvents, sludges, and solid wastes
(e.g., scrap plastic).  3M also permitted Woodbury Township to
dispose their municipal  waste in the southeast corner of the
property.   Figure 9-3 shows the location of the pits at the
Woodbury  site.   The small amount of Woodbury municipal waste
disposed  at the site was  segregated and kept outside the pit
areas used for solvent,  acid, and facility waste of 3M.

     Little is  known about actual operations at the disposal site.
No records were kept as  to type and quantity of wastes disposed.
It has been estimated that 153,000 m3 (200,000 yd3) of wastes
were disposed in  the area.  The waste consisted of solvent
contaminated material, adhesive, rolls of film, rags, resins,
and off-specification materials.  About 50 percent of the liquid
waste consisted of an estimated 760 m3 (200,000 gal) of isopropyl
ether.  It has  also been  estimated that 23,000 m* (6,000,000 gal)
of wet scrap was  disposed at the site.

     The  solvents deposited at the site had been used as carrier
agents to maintain a fluid condition of the adhesives applied
on scotch tape  and sandpaper.  The chief solvent used as a carrier
agent was heptane.  Other solvents used were acetone, isopropyl
ether, and toluene.  Highly flammable liquid waste was sent to
a private incinerator facility in Newport, Minnesota.  Less
flammable liquid  wastes  and solid wastes not accepted by the
Newport facility  were placed in pits at the Woodbury site.

     Prior to 1963, various acids, primarily sulfuric, were
dumped in limestone pits  at the site.  In late 1963, the
Minnesota Water Pollution Control Commission (MWPC) informed
3M that ground  water contamination could occur as a result of
their practices.   They recommended that the dumping of acids be
discontinued and  that all other wastes be placed in clay pi.ts.
These recommendations were accepted and implemented by 3M.  In
1963 a limestone  pit was  constructed at the Chemolite plant and
disposal  of acids was discontinued at the Woodbury facility.
                             186

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    «- TO COUNTY 19
                     COTTAOE GRWE TOWNSHIP
Figure 9-3.   Configuration of waste  disposal  pits
             at 3M Woodbury site.  [9-2]
                         187

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     When evidence of ground water contamination appeared in 1966,
3M stopped all disposal activities at the Woodbury site.   House-
keeping practices were improved to decrease the amount of waste
being discarded.  Wet scrap was sent to Shakopee, Minnesota
for incineration from 1966 to 1971.   In July 1971, an incinerator
was put into operation at the Chemolite plant facility.

POLLUTION

     In May 1966, a private well  near the site was found  to be
contaminated with isopropyl ether, one of the solvents disposed
in the pits.  Eighteen residential wells were sampled in  Woodbury
Township and Cottage Grove Village around the disposal area.
Based on results obtained, it was determined that only the
originally-identified well was contaminated; none of these other
18 wells had any trace of organic chemical  contamination.

     By August 1966, all  the wells in the area had been  sampled
and use of the disposal site had  been discontinued.   A consulting
engineering firm was retained by  3M to determine the extent of
the problem and to recommend a solution.  A 61 m (200 ft) deep,
30 cm (12 in.) diameter test well was drilled on September 13,
1966.  Figure 9-4 locates the contaminated  well (at the
Schussler residence) in relation  to the disposal site and the
test hole (called Observation Well A).  Drilling of the  test
well stopped at two levels in the glacial drift, three levels in
the Shakopee-Oneota Dolomite, and one level  in the Jordan
Sandstone.  Water samples were collected from each level  for
analysis.  Water samples  were also collected from two 3M  existing
5 cm (2 in.) observation  wells and the caretaker's well  located
at the disposal site.  One of these is located in the northwest
corner of the site, one in the southwest corner, and the
caretaker's well is located east  of the disposal area between
the two observation wells.  The observation wells bottom  in the
St. Peter Sandstone and their well screens  are open to both
glacial drift and sandstone.

     Analysis on the wells showed contamination in the glacial
drift and upper levels of the Shakopee-Oneota Dolomite at a
depth of about 61 m (200  ft).  Contamination was found to
decrease substantially with increasing depth.  Insignificant
trace contaminants were detected  in the Jordan Sandstone.
Isopropyl ether was the major pollutant, with concentrations
varying from 4 to 5 ppm in the shallow drift to less than 0.1 ppm
at 47.5 to 61.0 m (156 to 200 ft).

     Since confirmation of contamination in the upper ground water
aquifer, regular monitoring of nearby, residential wells  has
been conducted.  Ten area wells are now sampled once every two
months by the Department  of Health and 3M.   Previously,  3M had
sampled 52 wells in the surrounding neighborhood on a bi-monthly
                             188

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LEGEND
V OBSERVATION
  WELL
• REMOVAL
  WELL

• BARRIER
   WELL
  Figure 9-4.  Location  of contaminated Schussler  well
              and  barrier  wells. [9-1. 9-3]
                            189

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schedule.   The 10 wells that are presently being sampled are
located in glacial material  and have shown no contamination
except for nitrates from barnyard runoff.   Schussler's well was
the only well  found to be contaminated with organics.   As a
result of barrier well water withdrawal, the glacial  perched
water was drained and Schussler's well went dry in about 1970.
Subsequently,  a new well was installed for the Schussler residence,
which retrieves ground water from the Jordan Aquifer.   Figure
9-5 exhibits the combined concentration of isopropyl  ether and
other compounds at the old shallow Schussler well.  The new
Schussler well has never shown any isopropyl ether contamination.

REMEDIAL ACTION

     Based upon the determination that the major contaminants
were located in the perched  shallow ground water, the  following
remedial actions were initiated:

     • All disposal activities at the site were discontinued.

     • New waste was sent to an outside incinerator/disposal
       facility.  In 1971, an incinerator  was constructed at
       the Chemolite facility to burn acceptable wet  scrap.

     • Waste within the pits was removed and burned.

     • Four barrier wells were installed to create cones of
       depression in the ground water down-gradient from the
       site.  The effect of  these cones of depression  was to
       prevent contaminated  ground water from migrating further
       down-gradient and to  remove the ground water that had
       already been contaminated.  The water thus removed was
       to be discharged directly to the Mississippi River.

     • A regular monitoring  program of residential wells in
       the immediate vicinity of the disposal site was
       instituted to detect  contaminants in the ground water.

     Several alternatives were considered  for reducing and
disposing the solvent and scrap waste located in the  pits.  For
lack of other viable alternatives, it was  decided that the waste
would be excavated from the  pits and open  burned.  It  was
postulated that a time limited, large-scale burning project
would rid the pits of solvents judged to be the source of ground
water contamination and would shorten the  time necessary to
return the ground water quality to acceptable levels.

     A trial open cell test  burn was conducted in August 1967.
A drag line was used to excavate the waste from the pits.  During
the burning process, the drag line was used to mix the burning
                              190

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3000-


28OO-


2600-


2400-


2200-


2000-


BOO -


1600-


1400-


1200-


1000 -


 800-


 600-


 400-


 200-
  BARRIER WELL
  NO. I
  INSTALLED
  1/2/68
                 BARRIER WELL
                 NO. 2
                 INSTALLED
                 6/26/68
SOND
     JFMAMOJASOND
     «C        1968      • — >•
                                        FMAMJJASON
                                       	1969 	
Figure 9-5.   Sum  of the  concentration of  Isopropyl  ether,
 isopropanol, and  dichloromethane  for shallow  well  at
                     Schussler  residence.
                             191

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mass and to accelerate the burning efficiency.   Following the
test, samples of the remaining residue were collected for analysis.
The volume of the waste subjected to the test burn had been
reduced by 95 percent.  Subsequently, the residue was soaked
with water and no contaminants were dectected in the wash water.
As an extra precaution, the burned residue was  placed above
ground, diked, and observed over a period of time before burying
it.

     Based on good results obtained from the test burn,  3M
obtained permission from Woodbury and Cottage Grove for  full-
scale burning of all wastes.   Burning was conducted in January
1968 to take advantage of the good air quality,  low temperatures,
and low vapor pressure.  Burning was conducted  continuously
until all  waste had been burned.  It is estimated that 153,000 m3
(200,000 yd3) of waste was burned during this period.  During the
burning the air was monitored with a network of  fixed sampling
stations and one mobile station.  Four fixed stations were placed
near residences on each of the four sides of the property; one
fixed station was placed in the Village of Cottage Grove.  The
mobile unit, provided by the  City of St. Paul,  sampled at
various locations in the burning area.  Air was  monitored for
carbon dioxide, sulfur dioxide, suspended particulate matter,
and settleable particulares.   A weather station  located  near the
burn area  provided data on wind direction, speed, and ambient
temperatures.

     Although a significant amount of smoke was  generated during
the burning, excessive concentrations of air pollutants  were not
detected by the monitoring stations.  Occassionally a slight odor
was noticed at one of the sampling stations, and as the  intensity
of the odor increased, the burning was reduced.   The air monitoring
program carried out during the burning period by 3M did  not
indicate any potential health or vegetation damage.  Growth tests
were conducted on collected ash in the air sampling network to
determine  the composition and effect of the ash  fallout  on
future-vegetation.  The ash was basically carbonaceous and it was
determined that it would not  adversely effect vegetation in this
area.

     Once  the burning was completed, the remaining residue (metal,
ceramic scrap, etc.) and ashwall was piled above ground, diked,
and observed for a period of  time, and then buried in the pits.
The waste  was reduced by more than 99 percent.   Vegetation was
then allowed to take root naturally.  Native grasses and trees
now cover  most of the land and only minor erosion-worn areas
are noticeable.  3M personnel have chosen not to fill the pits,
claiming that this allows rainwater to accumulate and subsequently
percolate  downward, in the process, flushing contaminants in
the soil to the ground water.  Once in the ground water, these
can be extracted by the barrier wells.
                             192

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     Based upon a hydrologic study, it was determined that
contamination was confined to shallow depths in one direction
from the disposal area, with the Schussler being at the leading
edge of contaminant migration.  Therefore, barrier wells designed
to operate continuously were installed to prevent further
contaminant migration and remove existing contamination from
the ground water.  The first barrier well (No. 1) went into
operation in January 1968; the last barrier well (No. 4) went
into operation in 1974.  Barrier Wells 1 and 3 withdraw water
from the Jordan Aquifer.  Ground water in the Jordan Aquifer is
not contaminated and is used to dilute the contaminated water
from the perched ground water withdrawn by Barrier Wells 2 and 4.
The four wells withdraw a monthly average of 0.16 m3/sec (3.6 mgd).
Originally, water from Barrier Well 1 was recycled back to the
excavated disposal pits to flush contaminants lodging in the soil;
this practice has since been discontinued.

     Presently, approximately 60 percent of the withdrawn water
from the Woodbury site is used at the Chemolite plant as non-
contact cooling water.  The remainder of the withdrawn water is
discharged directly to the Mississippi River.

     Table 9-1 provides performance data on the four barrier
wells. (The location of these wells was shown in Figure 9-4.)
Figure 9-6 demonstrates that a decrease in concentration of
isopropyl ether has been experienced since the introduction of
the barrier wells.  Table 9-2 displays 19 priority pollutants
which were found in the discharge water.  The discharge system
consists of a 10 km (6 mi) underground forcemain privately owned
by 3M and which allows effluent discharge into the Mississippi
River.  The forcemain consists of 5,000 m (16,400 ft) of 46 cm
(18 in.) diameter iron pipe and 3,286 m (10,782 ft) of 46 cm
(18 in.) diameter asbestos cement pipe.  After pumping water
through  the forcemain, the water flows down-gradient to the
Chemolite facility, and is discharged into a ravine which empties
.into the Mississippi River.

     The barrier wells are expected to operate indefinitely since
they now serve another function as a supply of cooling water.
Pumping is continuous.  When the wells were first installed,
power failure due to electrical storms occurred frequently
shutting the pumps off.  To correct the problem, the pumping
station was automated and a telephone circuit installed to relay
problem information to the Chemolite personnel.  The systems are
checked once each day.

     Initial attempts to use the withdrawn water resulted in
build-up of iron oxide, manganese oxide, and iron bearing bacterial
slime in the piping.  As a corrective measure, chlorine is added
initially to the well discharge to inhibit iron reducing bacteria
and a stabilizing chemical (Nalco 345) added to prevent precipi-
                             193

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TABLE 9-1.   HORSEPOWER AND DISCHARGE OF BARRIER WELLS
         Well       Motor     Average Discharge
          No .	Horsepower	(m3/mi n )
1
2
3
4
75
40
50
125
0.38
2.65
1 .89
4.54
         1  m3/min = 264.2 gal/min
   TABLE 9-2.  3M WOODBURY WELLS PRIORITY POLLUTANT
                   SAMPLING RESULTS
                                       Concentration
      Priority Pollutant	(ug/1 )

   Benzene                                 1
   1 ,2-Dichloroethene                      3
   1 ,1 ,1-Trichloroethane                   1
   1 ,1-Di chloroethanc                      3
   1 ,1 ,2-Trichloroethane                   4
   2 ,4,6-Trichlorophenol                   1
   Parachlorometa cresol                   1
   Chloroform                              5
   Ethylbenzene                            4
   Methylene Chloride                      8
   Phenol                                 <1
   Bis  (2-ethylhexyl) Phthalate            9
   Diethyl Phthalate                       2
   Toluene                                 2
   Trichloroethylene                       1
   Endosulfan-Alpha                       <0.01
   Endrin Aldehyde                         0.14
   Heptachlor  Epoxide                     <0.01
   BHC-Alpha                              <0.01
                          194

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   75


   70
 at

 Z  65


 I  60



 |  55


 ,  50


 "S.  45
 o.


 1  40
 i.

 ^  35



 ^  30

 °-  25
 o


 I  20


 ~  15


   10


    5
                       Barrier Well No. 1
                  70
                      T
                      71
~1	T
 72   73
   Year
~r
 76
~T
 78
        68
             69
                                     74
                                         75
                                                   77
  >,
  n
  X
     25
     20
     15
     10
                        Barrier Well No. 2
          NM
               NM
               69
                   70
                        71
                                 Year
                                      74
                                                76
                                                    77
                                                         78
     NM = Not measureabl e

     T  » Trace
     *  = No peaks observed
Figure  9-6.   Graphs  of  isopropyl  ether measurements

              for  Barrier  Wells  Nos.  1  to 4.
                             195

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Figure  9-6  (Continued)
                                    Barrier Well No.  3
             800 ^
             700
             600
             500 -
             400
           <- 300 •
           2 200 -
             100 -
                     1
                    68
1
72
~1	
 73

 Year
                          1
                         74
                                                         75
                     1
                    78
                         69
                              70
                                   71
                                                                   77
                                    Barrier Well No. 4
              85

             01
             at

             Z 75

             tt
             >

             « 65

             >>


             * 55
             I


             £45
             01


             £ 25
T
                                71
                                    7'2   7(3   7>4
        75
17"
                77
                     78
                                       Year
                                         196

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 tation  of  iron  and  manganese  oxides.   To  prevent  discharge  of
 chlorine  into  the  Mississippi  River,  the  withdrawn  chlorinated
 well  water is  dechlorinated with  sulfur dioxide prior  to
 discharge.

      In  1972,  a  $4.6  million  incinerator  was  constructed at  3M
 Chemolite  to burn  industrial  liquid  and semi-liquid chemical
 wastes  which had previously been  placed in  pits at  the Woodbury
 disposal site.   The incineration  system includes  a  large materials
 handling building,  five  38 m3  (10,000  gal)  tanks  for liquid  waste
 storage, a  specially  designed  feed system for 0.21 m-5  (55 gal)
 drums,  a large  rotary kiln with secondary combustion chamber,
 high  energy Venturf scrubber  for  air  pollution control, waste-
 water treatment  facility, and  a 60 m  (200 ft) high discharge
 stack.

      Not counting  the amount  spent on  development and operation
 of the  incinerator, 3M has spent  over  $7  million  dollars to  date
 in correcting environmental problems  at the Woodbury disposal
 site.   In  addition, approximately $95,000 is spent annually  on
 continued  operation of the barrier well system.

 CONCLUSION

     When  ground water contamination was  first identified at the
 Woodbury 3M facility,  3M immediately  took responsible actions to
 mitigate and correct  the problem.   Previous practices were
 stopped, an investigation was  undertaken  to determine the extent
 of the problem, and corrective actions were initiated.

     Within one and a half years,  the waste had been removed
 from the pits and burned.  It  should be noted that it is unlikely
 that such open burning would be allowed under current air quality
 regulations.  However, the Minnesota Pollution Control  Agency
 had not formulated an air control  policy  at the time of the
 burning, and had neither established a permitting  system nor
 promulgated air pollution regulations.  At the time, a  burning
operation was selected as the best method  of disposing  of the
solvents causing the  ground water  contamination.

     The use of four  barrier wells appears to have effectively
reduced the migration of contaminants from the area.  Presently,
3M uses some of the withdrawn water as a  non-contact coolant
and,  therefore, has chosen to derive benefits from money spent
on a  system used to correct a pollutant problem.

     In general, the Minnesota Pollution  Control  Agency has been
pleased with the efforts and  prompt action of 3M  and believes
that  the barrier well  system  is an appropriate corrective action.
Likewise,  good  public  relations exist between 3M  and the  Town of
Woodbury and Village of Cottage Grove and  several  public  meetings
have  been conducted over the  years to discuss the  problem.
                             197

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             SITE H  BIBLIOGRAPHY AND REFERENCES
9-1    Personal  communication with Russel  Susag,  Millard Goldsmith,
      and Michael  Santoro,  3M,  St.  Paul,  Minnesota, June 26,  1980.

9-2    Clarified aerial  photo, Sl/2  Section 35T 28N R 21W,
      Washington County.  G-209  Mark Hurd  Aerial  Survey, Inc.
      April  1976.

9-3    Personal  communication and file review with Gary Kimball,
      Minnesota Pollution Control Agency, Division of Water
      Quality,  Permits  Section, Roseville, Minnesota.  June
      25 and 27, 1980.
                              198

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   APPENDIX 9-1



SITE H PHOTOGRAPHS
        199

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                                       I
               IF',,



     •«*•.. -





                                  <*

     w



Overall  appearance of excavated pit area
        at Woodbury Disposal  pits
                   200

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The structure in the middle of the photo  shelters
            one of the barrier pumps
           3M's Chemolite  Incinerator

                     201

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                           SECTION 10

                             SITE I
                  WHITEHOUSE/ALLIED PETROLEUM
                     JACKSONVILLE, FLORIDA
INTRODUCTION

     Seven waste oil  pits near Whitehouse,  Florida have been  a
surface and ground water pollution problem  for many years.   Allied
Petroleum Products Company,  a waste oil  reclaimer, constructed
the first of these pits in 1958.   The pits  were used for the
disposal  of waste oils for about  ten years.   In 1969,  Allied
abandoned the pits and filed for  bankruptcy.   Subsequently,  the
City of Jacksonville  moved to reinforce  the  earthen dikes around
the ponds and built a limestone filtering system for the water
in the pits to prevent pollution  problems.   However, due to
budget  constraints the City was  forced  to  discontinue further
remedial  measures in  1975.

     One  of the pits  ruptured in  June 1976,  spilling its contents
onto an adjacent property and into a creek.   After the spill,
analyses  conducted by the U.S. Environmental  Protection Agency
(EPA) on  the remaining oil showed that the  PCB concentration
exceeded  the federal  discharge limit of  1 ppb.  Subsequently,
EPA, State of Florida, and City officials developed a
comprehensive plan to dispose of  the remaining oil and pollutants
including (1) immobilization of the oil  on-site to prevent  further
spillage, and (2) drainage of the ponded oils through  an on-site
treatment system to maintain PCB  concentrations in site
effluents at less than 1 ppb.

     After dewatering, treated soils were mixed with the remaining
sludge to combine with the oily matter.   Next a layer  of packing
material, consisting  of a foam rubber and upholstery material
from car  seats and other dry material, were  layered on top  of
this mixture.  Finally, a layer of fill  dirt  was used  to cover  the
area.  Subsequent remedial actions performed  during the summer
of 1980,  included covering the site with impermeable soil,
revegetating the site, rerouting  drainage,  and creating a fence
or barrier to restrict public access.

SITE DESCRIPTION

     The  Whitehouse/Al1ied Petroleum site is  located in Duval
County in northeastern Florida approximately  16 km (10 mi)  west
of downtown Jacksonville.,  The site is situated between Machelle
Drive and Chaffee Road north of U.S. Highway  90.  The  site
consisted of seven pits covering  a combined  area of approximately
                              202

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 24,000  m2  or  2.5  ha  (250,000  ft   or  6  ac).   The  alignment of
 the seven  pits  was  in  an  east-west  direction with  estimated
 depths  from 1.5 to  4.6 m  (5  to  15 ft).   The  location  and layout
 of the  site are shown  in  Figures  10-1,  10-2, and 10-3.

      The  climate  of  Jacksonville  and vicinity is humid  subtropical
 with  warm,  wet  summers and mild,  relatively  dry  winters.  The
 average annual  temperature is 20°C  (68°F)  and the  average annual
 precipitation  is  138 cm (54  in.), most  of  this in  late  spring
 or early  summer.  The  average annual  snowfall  is a trace.

      The  topography  of Duval  County  is  mostly  low, gentle to flat,
 and composed  of a series  of ancient  marine terraces.  Surface
 drainage  from  the site occurs through  two  drainage ditches which
 surround  the  site on three sides.  These drainage  ditches combine
 with  McGirts  Creek which  empties  into  the  St.  Johns River
 approximately  16  km  (10 mi) southeast  of the  site.   The area in
 the vicinity  of the  site  is rural to  residential.  There is some
 agriculture  in  the area,  but most of  the land  is forested with
 pine  trees  harvested for  pulp production.  The elevation of the
 site  is approximately  23  m (75 ft) above sea level.

      The principal aquifer for municipal,  industrial, and domestic
 water supplies  in the  area of the Whitehouse  site  is a sequence
 of  permeable limestones known  as the  Floridan Aquifer.   Overlying
 the Floridan Aquifer from a depth of  30 to 160 m (100 to 525 ft)
 are confined or secondary aquifers in clays, sands, and limestones
 of  the Hawthorn Formation.  The water table  or unconfined aquifer
 in  undifferentiated  PIio-Pleistocene deposits consists of
 alternating beds of  sand, clay, and  sandy  clay to a depth of
 about 0 to  30 m (0 to  100 ft).  The water  table and secondary
 aquifers of the Hawthorn  Formation are  used  primarily for domestic
 purposes.   At Whitehouse, the water table  is generally within 1.5 m
 (5  ft) of the land surface and the potentiometric surface of the
 Floridan Aquifer is  about 13 m (43 ft) above sea  level or 9 m
 (30 ft) below the land surface.   Ground water flow  for the  water
 table is to the west towards  McGirts Creek.  A well log  of  the
 subsurface at the Whitehouse  site is provided in  Appendix  10-1.

 SITE HISTORY AND POLLUTION

     The Whitehouse/Al1ied Petroleum oil pits were  operational
 between 1958 and 1968.   They  were used during this  period
 as a disposal site by  the Allied Petroleum  Products Company,  a
waste oil  reclaimer,  for the  disposal of acid sludges, clay  wastes,
 and waste  oils from  their processes.   The Company used oil,  such
as used motor and  transformer oil, for their crude.  This crude
was acid-  and clay-treated to produce a motor oil and  the waste
 from this  operation  was dumped into  the pits.  The  seven waste
oil pits were abandoned in 1969  when the Company  went  bankrupt.
The City of Jacksonville acquired a  third of the  property by  tax
default.


                              203

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Figure 10-1.   Location of Whitehouse/Al1ied
               Petroleum site.
                      204

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                                          NEW DITCH TO BE-
                                          CONSTRUCTED
       McGIRTS
        CREEK
TRIBUTARY
              LIMESTONE FILTERS
              AND SETTLING PONDS(I966)
              CARBON ADSORPTION
              TREATMENT PLANT
                 258 O
ABANDONED OIL
SLUDGE P'lIS 1-7
                                                              UNPAVED ROAD
                        RW?M POND
                     (REPORTED SPRING)
                              Ol58
        0    200   400   600 FT
                                                     APPROX. LOCATION
                                                     OF PRIVATE WELL.
Figure   10-2.    Layout  of  Whitehouse  oil  pits   (1976)
                                    205

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rv
c
r
                 Figure  10-3.   Layout  of  Whitehouse  oil  pits  and  diversion  ditches  (1976)

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      On  several  occasions  levees  from  the waste  oil pits  ruptured
 following  heavy  rainfalls.   In  1967  Pit  No.  7  ruptured  spilling
 its  contents  onto  adjacent  private property  and  into McGirts
 Creek.   The  City of  Jacksonville  Mosquito Control Branch,
 recognizing  the  threat  of  other pits rupturing if the water
 level was  not  controlled,  began to build a two cell oil/water
 separator  in  conjunction with a limestone filtering system in
 an attempt to  dewater the  pits.   The City attempted to  reinforce
 the  ponds' retaining walls  to prevent  further  pollution problems
 in 1967, 1972, and 1974.   An attempt was made  to have the White-
 house site declared  a mosquito control project,  along with an
 adjacent swamp area  since  the swamp  could not  be properly
 drained without addressing  the oil pits  first.   The request was
 denied by  the  Florida State Bureau of  Entomology in 1974.  In
 1975 an attempt was  made to obtain Florida State Department of
 Environmental  Regulation pollution restoration funds to rectify
 and  close  out  the problem area.   This  request was also denied.

     To compound the  situation, erosion caused by motorcycle
 and  four-wheel drive vehicles weakened the retaining berms.
 On June 29,  1976, after abnormally heavy precipitation, the
 retaining  berm of Pit No. 6 on the western edge of the site
 collapsed  during some minor repair work by Mosquito Control
 Branch personnel.  The  resulting  breach allowed approximately
 757  m3 (200,000 gal) of the captured waste oil material and an
 undetermined amount of  highly acidic water to flow into McGirts
 Creek and the adjacent  natural  water collection basin.   An oil
 spill emergency was declared and  the U.S. Coast Guard,  a private
 consulting firm, and the Bio-Environmental  Services Division  (BESD)
 of the Jacksonville Department of Health, Welfare, and Bio-
 Environmental Services were mobilized under the direction of  the
 Oil  Spills Group of the EPA Region IV Environmental  Emergency
 Branch.   Cleanup measures were initiated on the evening of
 June 29, 1976.

    Waste oil remained in six pits until  cleanup  measures were
 completed on May 15, 1977.   The wastes left in the pits contained
 high concentrations of PCB's, lead,  and other metals,  and had a
 pH of less than one.   The lighter weight material,  a black, oil-
 like fluid, floating on top had segregated  in some  areas into
 a thicker, yellow-colored greasy material.   It contained 10 to
 25 percent water and a 30 percent oil mixture consisting of 50
percent  homogenized oil.  Approximately 1 m  (3 ft)   of  this
material  floated over a layer of water and  bottom oil  sludge.
The top  of the sludge was unstable becoming  firmer  with depth.
Total thickness of  the sludge was  2  to  3  m  (6 to  10  ft).   In
1974, there was an  estimated 7,500 m3 (1,982,000  gal)  of oil,
rainwater,  and sludge in the pits.
                             207

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REMEDIAL ACTION

First Phase

    Initially the EPA and the Coast Guard had concentrated their
efforts on cleaning up the spill  and stabilizing the walls of
the pits to prevent further collapse.   However, it was recognized
that the remaining six oil pits presented a potential  for a
similar or possibly larger spill  unless corrective actions were
taken.  Therefore, EPA and Coast  Guard officials authorized the
use of federal  Emergency Contingency Funds to (1) cleanup the
existing oil  spill, (2) repair the oil pit filter system origin-
ally built by the City of Jacksonville, and (3) provide material
for the construction of access roads to each of the six remaining
pits so that pump-out operations  could proceed.  Total cost for
the above operations was estimated at  $100,000.

    After the EPA enacted the federal  response to the oil spill,
disposal became the next major obstacle.   The spilled material
was disposed in a proper manner in Duval  County.  To eliminate
the imminent threat of another spill from the pits, alter-
native and more econcomical disposal sites were sought.  The
City proposed several sites but could  not get approval from
the State to use them.  Because of the lack of a suitable dis-
posal site or method, a ten day delay  was encountered.

    The delay allowed the agencies to  become more familiar with
the material  in the pits.  It was determined that the only
feasible means  of disposal was to reactivate the oil/water
separator and filter system the City had employed during
previous efforts.  This would allow the pits to be dewatered
and eliminate the threat of another major spill.

    The City of Jacksonville suggested that after the pits were
dewatered they  would mix the remaining oil and sludge with dry
trash and dirt  and fill all the pits.   Because of the emergency,
State and City  agencies agreed to the  following at a July 6, 1976
conference:

    1.  On an emergency basis, Mosquito Control Branch equipment
        would be used to re-establish  the filter beds and
        construct the necessary pit access roads.

    2.  The dewatered pits could  be designated as a dry trash
        landfill.  Material such  as dry tree limbs, leaves,
        building materials, and any other absorbent materials
        would be employed to stabilize the sludge remaining
        at the  bottom of the pits.  These materials were to
        be selected loads of refuse from the City-operated
                             208

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         disposal  sites.   The absorbent materials  would be
         deposited in the pits which had been  emptied of the  oil
         and oil  emulsion and the materials  graded and
         compacted  by a  crawler tractor.   Upon  completion of
         the filling and  after consolidation of  the debris,
         portions  of the  pit embankment walls  would be graded
         over the  pit to  provide soil  cover  for  surface drainage.

     3.   The necessity for a sanitary  landfill application and
         operating permit would be waived.   State  Water Pollution
         Control  personnel would monitor the leachate from the
         defluidized stabilized system and  from  time to time
         would report the need to haul away  additional petroleum
         residues  at the  expense of the City.

     The dewatering operation was one  day  from start-up when  the
EPA received word  from the Coast Guard that  there  was a possibility
the oil  in the pit was contaminated with PCB's.   Until then,  the
spill  had been handled as a routine oil spill.   This new informa-
tion not only halted the  entire operation,  but required the
chemical analysis  of the  material in the pits  and  surface and
ground water monitoring.

     After evaluating the data, three  alternatives were considered
by the EPA Regional Response Team for  the  ultimate disposal  of
the PCB  contaminated waste oil:

     1.   The impounded material would  not  be treated on-site.
         Rather,  all of the PCB contaminated waste oil would  be
         placed in sealed containers and shipped to an approved
         facility.  A conservative estimate  of the amount of
         contaminated material was made and  using  a Rollins
         Environmental Services price  sheet, it  was calculated
         that approximately $7.5 million would be  needed.  This
         estimate  did not include labor charges.  It was obvious
         from the  cost figures, together with  the  fact that
         federal  funds were no longer  available, that this was
         not a viable alternative.

     2.   The impounded material would  be discharged without
         treatment, and the remaining oil and sludge disposed
         at an approved facility.  This alternative was finally
         rejected  because the cost of  hauling  the  semi-solid
         materials was still prohibitively  high  and data
         suggested that concentrations of  PCB's  exceeding 1  ppb
         could be  expected in any water discharged to McGirts
         Creek.  At that  time, the EPA was  recommending that
         manufacturers not exceed 1 ppb of  PCB in  any discharge.

     3.   The oil  would be immobilized  on-site  and  a water treatment
         system designed  that would produce  an effluent less  than
                               209

-------
         1  ppb PCB.  Since current technology was available
         for producing an effluent of 1  ppb using activated
         carbon, this appeared to be the best of the alternatives.

     The task of immobilizing the oil was assigned to the City
of Jacksonville in conjunction with the  EPA Region IV Residual
Management Branch and the Florida Department of Environmental
Regulation.  The remedial action selected included draining as
much water as possible through a treatment system and stabilizing
the remaining fluids.  The treatment system was designed by the
EPA and modified by City employees during construction to treat
and dewater all the pits (the City Finance Committee approved
$13,000 for the project).  The system included (1) treatment of
water which had been drained from the remaining oil  pits to
separate the oil and water;  (2) two limestone filtering beds to
neutralize acid and filter out oil, metals, and other contaminants;
and (3) a carbon mixing and  settling system to adsorb and remove
PCB's.   The treatment system was devised to be practical,
inexpensive, easy to operate, and have the capability to reduce
the PCB level below 1 ppb for all water  discharged to McGirts
Creek.   The system was to be a temporary measure and only minimum
maintenance would be required.

     It was obvious from the initial  discovery of PCB's in the
pits that the only effective treatment of the water  would be
with activated carbon.  Research and practice had shown that
carbon  adsorption was the best available field method for removing
PCB's from wastewaters.  Carbon adsorption systems in industrial
applications could remove PCB's from wastewater effluents to
concentrations less than 1  ppb; however, these systems all
employed carbon adsorption  columns and the carbon column was not
the best method of treatment in this emergency situation for the
fol1owi ng reasons :

     1.  Construction of the columns was considered  too costly
         and time-consuming.  Also, the  columns would have
         required additional pumps.

     2.  Due to the limited  laboratory facilities nearby and
         the inconsistent quality of the influent, it would have
         been difficult to  determine when the carbon in the
         column had become  saturated.

     3.  Replacement of carbon in column would be difficult.
         Moreover, the oily  water would  tend to coat the surface
         of the granular coarbon and reduce its adsorption
         effectiveness.

     4.  Granular activated  carbon was twice as expensive as
         powdered carbon.  Moreover, the nearest source was
         approximately 965  km (600 mi) from the spill  site.
                              210

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     A system using powdered activated carbon for removing PCB's
from water had never been employed in other than
laboratory-scale experiments.  These experiments all yielded
treated effluent PCB levels well  below the acceptable level  of
1 ppb.  With these results and previous experience in the use of
activated carbon for removing organics from water, a treatment
system was designed using powdered activated carbon. [10-2]

     The carbon treatment system consisted of four units: (1) a
collection sump, (2) a carbon mixing chamber, (3) a sedimentation
basin, and (4) a sand filter (see Figure 10-4).   A collection
sump was used to collect water draining from the oil pits.   When
sufficient water was collected, the sump pump directed the liquid
to the carbon mixing chamber at a rate of 227 1/min (60 gal/min).
The carbon slurry was injected at a concentration adjusted to
maintain an effluent concentration of less than  1 ppb of PCB in
the waste.  The chief goal of the sedimentation  basin was to
provide adequate detention time for gravity sedimentation of the
carbon and absorbent contaminants.  A final sand filter was
provided to filter the effluent prior to discharge into McGirts
Creek.

     After dewatering, fuller's earth was mixed  with the remaining
oil and sludge to combine with the oily matter.   Fuller's earth
is a semi-pulverized clay which absorbs oil and  water rapidly.
Laboratory experiments had shown  this mixture was stable and
did not release oil or sludge even when submerged in water.
Approximately 7,200 metric tons (8,000 tons) of  fuller's earth
was  mixed in this manner.

     To provide adequate control  over the mixing operation,  a
batching pit was prepared just south of Pit No.  4.   Pumpable
material was taken out of the pits and placed into an 11 m3
(3,000 gal) settling tank.  Water obtained from  the settling
tank was drained to Pit No. 7 and passed through the treatment
system.  The remaining settleable material was mixed by heavy
equipment in the batch pit and then placed in the oil  pit which
was being closed out.

     The sludges remaining in the pit were stabilized by placing
a layer of clean trash consisting of scrap lumber,  trees, and
wood chips to form a matrix which penetrated into and bridged
over the viscous sludge in the pit bottom.  The  less viscous
sludge was displaced by this material to a centralized location.
The more viscous sludge remained  in place and in time was
absorbed and solidified under the pressure of the overburden.
The minimum thickness  of trash overburden was determined by  the
depth required to support heavy equipment and prevent swelling
of the pit material.

     Auto shredder waste, consisting primarily of upholstery
and similar absorbent  and highly  compressible material,  was
                              211

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  CARBON
  MIXING
  CHAMBER-
tf
"^
- —
hl£>
D
ft




\


^ i * i *.|
.
i i i



SEDIMENTATION BASIN


   PLAN

  (NO SCALE)
     BAFFLE
                                     RNAL
                                      FILTER
                                                FINAL
                                                DISCHARGE
                                                      TW
                    ACTIVATED CARBON
                       DRUMS
                                      SAND
                    (NO SCALE)
Figure  10-4.   Carbon  adsorption treatment
            plant for  PCB's.  [10-2]
                         212

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placed above the clean trash for support.  This sealed the
surface voids in the trash and provided a base for the mixture
of oil and fuller's earth placed in a layer above it.  In this
way, the fuller's earth mixture provided an impermeable blanket
that kept rainwater from percolat-ing downward.  This was to
eliminate the major driving force for ground water contamination
migration and keep the viscous sludge and fugitive oil in a
state more conducive to solidification over time.   A final  layer
of clean fill dirt was placed above the clay blanket and graded
to take maximum advantage of the natural slope of the site  for
drainage (see Figure 10-5).

     After treatment of water and sludge had been accomplished
and the pits filled and packed, several  drainage ditches were
constructed around the former pits to help divert runoff through
the limestone filters and to intercept ground water entering the
site and leachate leaving the site.   The basic plan was.to  take
maximum advantage of the site topography to isolate the pits
hydraulically from the surrounding ground water.   This process
was completed on May 15, 1977.

Second Phase

     Because stabilization efforts were  not permanent or completely
effective,  a permanently stabilized  area became necessary to
eliminate the seepage of contaminated material.  On June 30, 1980
the City of Jacksonville agreed to assume responsibility to
accomplish the following tasks:

     1.   Covering the entire site with soil.

     2.   Vegetating the cover material.

     3.   Rerouting surface drainage.

     4.   Erecting a fence to restrict public  access.

First,  the  entire site was covered with  46  cm (18  in.)  of soil
purchased under City contract.   The  first 15  cm (6 in.)  of  the
material  consisted of tight  clay and  the top  30 cm (12 in.)  was
borrow fill  dirt  (primarily  sand).   The  cover material  serves
several  purposes.   It provides  a thick uncontaminated zone  to
permit a  good growth of grasses.   Cover  material  was  also used
to level  out the  irregular surface settling that  had  occurred.
By establishing  a  good drainage gradient and  a  continuous clay
blanket  across  the site surface,  downward percolation of rainwater
has been  minimized.   Grasses help to  remove surface  water through
evapotranspiration.   This in turn has reduced the  hydraulic
gradient  on  the  contaminated material  and the forces  tending to
cause it  to  migrate through  the berms and off site.
                              213

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                                200
                  CLEAN DIRT FILL
      \\\\ VV
        / / / / XAUTOX SHREDDER
                     CLEAN TRASH
      I cm = 039mOm
20-30 em

13-25 cm
7.6em.min.
                                          90cm. min
Figure  10-5.  Pit profile  after stabilization.  [10-2]
                      214

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    A major effort of this project was to reroute drainage on
the north edge of the pits.  The new ditch has routed drainage
around the contaminated area, thus eliminating the opportunity
for rainfall to carry contaminants from the site.  At the same
time the new ditch was being excavated, the old ditches were
filled with clay materials to prevent lateral  movement away
from the site.  An attempt was made to scrape all the contam-
inated material out of this area and place it atop the pits
for proper burial prior to filling the old ditches.

    Extensive vandalism has occurred in the past at the site.
Cars, four-wheel drive vehicles, and motorcycles have used the
area, allowing little vegetation to grow.  Because of the impor-
tance of establishing and maintaining adequate ground cover, a
fence may be installed.  The fence and signs would serve as a
serious warning to the public of the hazardous nature of some
of the material buried there and of the desire to restrict
access as a public safety measure.  If an attempt is not made
to restrict site access, much of the improvement associated
with the proposed project could be lost over a fairly short time.

    The total  cost to the City of Jacksonville and the EPA for
the first phase of remedial action (between June 29, 1976 and
May 15, 1977)  was estimated at $250,000.   A partial accounting
for these costs is shown in Table 10-1.  It should be noted that
most of this cost was borne by the City of Jacksonville.   In
addition, a cost of $67,191 was projected for the second phase
of remedial action beginning in July 1980 as shown in Table 10-2.

MONITORING

    As a result of the PCB contamination, a full scale sampling
and analysis program was initiated in which samples of the
creek, ground  water, raw water (in the pits),  sludge, and well
water (from nearby homes) were taken and  analyzed for PCB's,
heavy metals,  phenols, and pH.   An initial  monitoring effort on
July 13, 1976  consisted of the BESD analyzing  samples from four
private water  supply wells in the vicinity of the Whitehouse
site for possible contamination (see Figure 10-2 and Table 10-3).
The results of the analyses are contained in Table 10-4 and
indicate that  the water quality in these  wells was not affected
by the oil  pits.   The iron and phenol  contents of two of the
wells were considered slightly high; however,  the iron content
is not unusual  for shallow wells in Duval  County, and the phenol
content was not so high as to require closing  of the water
supply for drinking water purposes.   Surface water samples were
also obtained  from the limestone filtering  system and McGirts
Creek, and analyses revealed no PCB's  were  present.

    At the request of EPA, a sampling  team  from the EPA Athens
Laboratory was  dispatched to the Whitehouse site on July  20, 1976
Samples were obtained on July 21, 1976 from the sidewalls of
                             215

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TABLE  10-1.   PARTIAL  REMEDIAL  ACTION  COSTS  FOR  FIRST  PHASE
Cost Item
Vehicles/Equipment/Personnel
Supplies. Fullers Earth, Etc.
Services and Charges
Capital Outlay
Mosquito Control Costs
Total

6/29/76 thru 7/9/76
{34,325
—
—
3,433
—
$37,758
Date
8/04/76 thru 9/30/76
$17,417
27,688
485
4,657
17,902
$68,149

10/1/76 thru 2/01/77
$36.118
2,691
—
—
40,745
$79,554
Total
$ 87.860
30.379
485
8.090
58.647
$185.462
           TABLE  10-2.
PROJECTED  REMEDIAL  ACTION  COSTS
 FOR  SECOND  PHASE
                                Item
                                                        Cost
                       Cover Material (sand and clay
                         borrow fill dirt)                  $33,848
                       Equipment Use (lease Mosquito
                         Control Gradal and operator plus
                         borrowed front-end loader)            4,000
                       Site Vegetation                      12,620
                       Night Security                       1,048
                       Port-0-Let Rental                       85
                       Fencing or Other Access
                         Restricting Means                   11,600
                       Clearing and Grubbing                   290
                       Miscellaneous Equipment, Supplies
                         and Materials
                       Total
                                        216

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TABLE 10-3.   DEPTH  OF MONITORING AND  PRIVATE WELLS
        Well Number	               Depth (m)
EPA #1
EPA #2
EPA #3
U.S.G.S.#1
U.S.G.S.#2
U.S.G.S.#3
158 Machelle Drive
233 Machelle Drive
258 Machelle Drive
263 Machelle Drive
21-24
15-18
6-9
5-6
5-6
5-6
Unknown
41
Unknown
Unknown
    1  m = 3.3 ft
                         217

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                                      TABLE 10-4.   WATER QUALITY  IN WELLS*
ro

00
Well
Number
EPA 11



EPA 12



EPA 03



USGS 11



USGS t2



USGS *3



158 Machelle Dr.

233 Machelle Dr.

258 Machelle Dr.

263 Hachelle Dr.

Date
5/20/77
7/18/77
1/3/79
5/23/79
5/20/77
7/18/77
1/3/79
5/23/79
5/20/77
7/18/77
1/3/79
5/23/79
5/20/77
7/18/77
1/3/79
5/23/79
5/20/77
7/18/77
1/3/79
5/23/79
5/20/77
7/18/77
1/3/79
5/23/79
7/13/76
1/3/79
7/13/76
1/3/79
7/13/76
1/3/79
7/13/76
1/3/79
PH
7.05
7.35
6.80
--
6.90
7.30
6.70
--
3.85
3.80
3.45
--
5.75
5.85
5.50
--
3.55
3.55
3.55
--
5.00
4.95
4.70
--
7.4
--
7.1
•
7.2
7.85
7.1
7.05
Fe
0.54
0.74
0.28
1.19
3.89
0.54
0.23
0.42
114.4
12.6
212
198
9.12
0.114
7.8
1.19
27.02
0.23
29.8
41.2
0.75
0.03
0.51
0.383
0
--
0.6
--
0.7
0.18
0.6
1.9
PCB
None
None
--
<0.0002
None
None
--
<0.0002
None
None
--
<0.0002
None
None
--
<0.0002
None
None

<0.0002
None
None

<0.0002
—
—
—
—
—
~-
—

Oil &
Grease
1.8
4.3
3.6
0.007
1.7
9.4
4.5
0.003
1.3
4.4
4.1
0.0042
1.4
5.2
1 .9
0.007
0.04
5.4
5.5
3.0
0.02
6
2.5
0.004
—
—
—
. — —
—
~~
~

coo
<10
45.6
--
--
52
56.1
--
--
22
119
--
--
52
175
_-
'
648
1901
--
--
120
56.1
--
--
—
—
—
~~
~
—
~

Phenols
0.002
0.13
--
0.019
0.005
0.001
-.
0.015
0.003
0.001
--
0.021
0.02
0.002
--
0.019
<0.04
1
--
0.90
0.004
0.004
--
0.016
0.001
--
0
--
0.002
<0,0005
0.002
<0.0005
Zn
0.009
0.09
0.014
0.012
0,009
0.31
0.003
0.03
0.04
0.02
3.6
0.035
0.02
<0.01
0.11
0.012
2.10
0.03
0.30
0.096
0.009
<0.01
<0.003
0.062
0.42
--
0.42
--
0.32
0.096
0
0.262
Pb
0.17
0.55
<0.03
<0.25
0.08
0.6
<0.03
<0.25
0. 28
0.78
0.36
<0.25
0.34
0.75
0.25
<0.25
0.17
0.60
0.10
<0.25
0.08
0.60
<0.03
<0.25
0.008
--
0.002
--
0.001
<0.031
0
<0.031
Cd Cu
0.
0.
<0.
<0.
0.
0.
<0.
<0.
0.
0.
0.
<0.
<0.
0.
0.
<0.
0.
0.
0.
<0.
0.
0.

-------
 the  pits.   No  bottom  sludge  samples were obtained due to the
 unknown  depth  and  the  hazards  involved  in reaching the center
 of  the pits.   The  analyses indicated that PCB's were present in
 the  sludge  of  five of  the six  oil pits  in concentrations ranging
 from 8.7  ppm to  23.3  ppm.  Because PCB's are soluble in an oil-
 water mixture  at low  pH, it  was anticipated that PCB's were being
 discharged  from  the pits.  Complete analytical results are
 listed in Tables 10-5  and 10-6.  Quantitative tests for copper,
 lead, zinc, cadmium, and chromium, as expected, appeared in
 insignificant  quantities.  These are typical metals found in the
 waste oil process  so these results were not surprising.

      The  EPA Surveillance and  Analysis  Division (S&A), due to
 manpower  shortages, was only able to lend limited sampling and
 analysis  support after the initial oil   sludge samples were handled.
 Treatment system samples were  split between S&A and the BESD.
 This  procedure produced a lengthy "turn-around time" for actual
 results.  In order to  obtain a more rapid indication of PCB
 removal,  the BESD was  requested to run chemical oxygen demand
 (COD) tests.   Organic  contaminants are expected in any oily
 waste and these contaminants will tend to occupy adsorption sites
 on the carbon  filter along with the PCB's.   Hence,  COD tests
 will  indicate  an increase or decrease in the effectiveness  of
 removal  of all  the organics  (both toxic  and  non-toxic)  by the
 carbon.   A correlation exists  between removal  of organics and
 PCB  reduction,  therefore, lower COD values  indicate lower PCB
 concentrations.  Also, the COD tests  were less expensive  and a
 more rapid indicator of PCB  removal  efficiency than direct  PCB
 analysi s.

     The initial  discharge on September  20,  1976 was  analyzed
 for  PCB's and  COD.   Samples were taken  from  the water as  it  j
 entered  Pit No. 7 and from the effluent  as  it  entered McGirts
 Creek.  Then the treatment process was  discontinued until  treatment
 efficiency results  were obtained.   These results  indicated  that
 the  PCB  concentration was below 1  ppb in the effluent and that
 the carbon feed was initially correct.   Using  the  COD test  as an
 indicator, the  PCB  concentration was  kept consistently  below
 Ippb in  the effluent.   Samples were  obtained once  each  day  that
 the  system had  been running.   Some results  of  effluent monitoring
 are shown in Table  10-7.   It  should  be  noted that  the carbon
 mixing proportions  were continually  adjusted based  upon  laboratory
 analysis  with the goal of keeping PCB levels in the effluent
well below 1 ppb.

     Another problem  considered was  that of  migration of  PCB's
to the ground water table.   To assist  in determining  the  extent
of migration from the pits,  the EPA  Region  IV  Residual Management
Branch contracted a consultant to  perform a  ground  water  study
of the Whitehouse site.  The  objective of the  study was to  ascer-
tain whether or not migration of hazardous wastes  had occurred  in
                              219

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TABLE  10-5.    INITIAL  PCB ANALYSIS  OF  SLUDGE  SAMPLES
Location
Pit Ho.
Pit No.
Pit No.
Pit No.
Pit No.
Pit No.

1
2
3
4
5
6
PCB
PCB
Aroclor 1242
6.0
10.0
ND
9.3
6.9
3.3
Concentrations
PCB
Aroclor 1254
2.8
3.5
ND
4.3
3.7
2.3
(ppm)
PCB
Aroclor 1260
5.6
9.7
ND
7.6
6.5
3.1
PCB
Total
(ppm)
14.4
23.2
—
21.2
17.1
8.7
         ND = Not detectable
   TABLE  10-6.    QUANTITATIVE  ANALYSIS  OF OIL  SLUDGE
Sampl e
Number
2
3
4
5
6
7
Total Metals
Lead
2.800
5,300
1.830
1,320
2.640
7,060
From Ashed Sludge -
Copper Zinc
25 56.5
37 43
15 17
8 6
31 24
62.5 56
Wet Weight of Sludge (ug/g)
Cadmium Chromium
0.6 7.5
0.5 11
0.3 4
0.2 8
0.3 9
0.8 12
                              Qualitative Scan of 011 Sludge
                           Elements Detected 1n Sample From Pit 2
        Lead
        Cerium
        Lanthanum
        Barium
        Antimony
        Tin
        Cadmium
        Silver
        Ruthenium
        Molybdenum
        Zirconium
        Strontium
Rubidium
Bromine
Selenium
Arsenic
Gallium
Zinc
Copper
Nickel
Cobalt
Iron
Manganese
Chromium
Vanadium
Titanium
Scandium
Calcium
Potassium
Chlorine
Sulfur
Phosphorous
Silicon
Aluminum
Magnesium
Fluorine
                                   220

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           TABLE  10-7.   ANALYSES OF TREATMENT SYSTEM
                       REMOVAL  EFFICIENCIES
Date
9/20/76
9/25/76
9/26/76
9/28/76
9/29/76
9/30/76
10/1/76
10/6/76
10/7/76
10/8/76

PCB
(ppb)

0.73
0.56
2.22
7.7
0.93
1.49
1.15
0.66
0.62
Influent
COD
(ppm)
369
—
1,068
—
988
932
942
1,068
1,000
1,225

Carbon
(ppm)
27.0
10.7
10.7
10.2
10.2
28.6
28.6
25.9
43.5
43.5
Effl
PCB
(ppm)
<0.2
ND
ND
0.26
0.4
0.99
0.29
0.14
<0.2
<0.2
uent
COD
(ppm)
66
399
282
—
419
394
463
399
571
372
Percent
PCB
Removal
_—
--
--
88
95
--
81
88
70
68
ND = not detectable.
                                221

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the ground water adjacent to the waste oil  pits (see Figure 10-3).
In September 1976,three piezometers were placed to depths  of 10,
18, and 24 m (30, 60, and 80 ft) (see Appendix 10-1  for well
log)  and were developed using compressed air.  After pumping
each well at a rate of about 0.3 I/sec (5 gal/min) until  clear
water was obtained, water samples were obtained for chemical
analyses.  Water quality analyses on the three wells indicate
that ground water contamination may have occurred to a depth  of
at least 24 m (80 ft) beneath the oil pits.   The results  of the
three samples from the EPA wells are summarized in Table  10-4.

     Under a cooperative program between the City of Jacksonville
and the U.S. Geological Survey (U.S.G.S.),  three additional
wells were installed around the site perimeter in early 1977.
These wells along with the wells drilled by  the consultant
contracted by the EPA were monitored periodically.

     In 1979 an increase in leachate from the site was noticed in
the perimeter ditches which surround the site.  This leachate
had a slight oil  sheen and odd odor.  Biological and chemical
sampling upstream and downstream from the site indicated  that
the leachate was having a detrimental effect on the quality of
the water.

     To determine the effect of the leachate from the site on
the biota of McGirts Creek, macro-invertebrate samples  were  taken
by the Florida Department of Environmental  Regulation (DER)  on
October 11, 1979 and December 6, 1979.  During the October sampling,
33 types of organisms were found present in  a tributary upstream.
Each time a sample net ran through the substrate it was teeming
with organisms.  The bottom was a mixture of aquatic grasses,
sand, and detritus.  The tributary had all  the indications of a
healthy aquatic environment.  Downstream from the site, only
four types of organisms and a total of eight organisms had been
found after two and one-half hours.  No vegetation was present
in the water.  The only growth on the bottom was described as a
"sewage slime".  Chemical analysis of water  samples revealed
toxic levels of heavy metals, traces of PCB's,  and extremely  low pH.

CONCLUSION

     When the retaining berm of the waste oil pit collapsed
contaminating  McGirts Creek with the highly acidic oil and  sludge
in 1976, EPA and the City of Jacksonville took actions to  correct
the problem.  Within one year, the waste either had been  removed,
treated, or stabilized within the pits.

     The main problem facing the project since the first  cleanup
efforts began in 1967 was the financial constraints  within which
it had to operate.   If City crews had been  given the proper funds
in 1974 and 1975 and allowed to complete the dewatering operation,
                              222

-------
 the  oil  spill  in  1976  could  have  been averted.  However, the
 possibility  of future  spills would  have  remained unless the
 waste  oil  and  sludge  (the  ultimate  source of pollution) were
 part of  the  cleanup program.   Therefore, the 1976 spill did
 bring  the  seriousness  of the problem to  the attention of the
 EPA  and  City officials, resulting in a comprehensive effort to
 mitigate the problem.

     The  carbon  filter  was  successful.  PCB concentrations in the
 effluent were  maintained below 1  ppb.  However, short term
 analysis of  the stabilization  efforts indicates that the oil
 sludge has not  been totally  stabilized.  Numerous leachate out-
 croppings  have  been noted  along the eastern and western margins
 of the site.   In  addition, the sampling  of McGirts Creek in
 1979 and 1980  has shown a  severe  disruption of the local biota
 downstream from the Whitehouse site.  Evidence indicates toxic
 leachate is  leaving the site and  migrating into McGirts Creek.
 Some of  the  possibilities  for  the above  problems include the
 following:   (1) the decomposition of the truck and auto shred-
 dings  from the acid sludge,  (2) an  insufficient value of
 absorbent material added to the acid sludge and oil,  (3) high
 ground water levels, and/or  (4) the absence of a site covering
 to prevent rainwater infiltration.

    The second phase of remedial  action which began  in 1980
 may alleviate many of the problems.   A new ditch has  been
 constructed up-gradient from the site and several  existing
 ditches are being filled with clay material.   The  effect should
 be to lower the ground water table and to divert ground and
 surface water around the site.   The clay cover should consid-
 erably reduce the seepage of toxic wastes into the  ground water.

    Even though the second  phase should considerably  reduce
 the pollutants  in the ground water and McGirts Creek, chances
 are that some problems will continue at the site and  more money
 will  be required to permanently stabilize and/or isolate the
wastes  to protect the surface and ground water of  the area.
 Frequent monitoring will  be required to ensure future problems
 do not develop.
                            223

-------
              SITE I REFERENCES AND BIBLIOGRAPHY
10-1   Bentley, C.B., "Aquifer Test Analyses from the Floridan
      Aquifer in Flagler, Putnam, and St. Johns Counties,
      Florida".   U.S. Geological  Survey Water Resources
      Investigation 77-36.   1977.

10-2   Stroud, Fred B.,  Raymond T. Wilkerson, and A.I. Smith,
      "Treatment and Stabilization of PCB Contaminated Water
      and Waste  Oil:  A Case Study".   Proceedings of 1978
      National Conference on Control  of Hazardous Materials.

10-3   Personal communication with Jan B.  Rogers, Raymond T.
      Wilkerson, and Fred B. Stroud,  Environmental  Emergency
      Branch, Region IV,  U.S. Environmental Protection Agency,
      Atlanta, Georgia.   July 23, 1980.

10-4   Personal communication with Gary V. Weiss, Jacksonville
      Department of Health,  Welfare,  and  Bio-Environmental
      Services.   Jacksonville, Florida.  July 24, 1980.
                             224

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   APPENDIX 10-1
WELL LOG FOR SITE I
         225

-------
                WELL LOG AT WHITEHOUSE OIL PITS
                                                          Depth
	Description	(m)
Black silty sand, with trace of clay (fill)                 0-2
Very fine to fine dark gray sand, oily matrix,
  withtracesofsiltandclay                             2-5
Very fine to fine, dark brown sand, with traces
  ofsiltandclay                                         5-7
Very fine to fine, dark brown to black sand,  some
  cementation,  with trace of silt                          7-8
Very fine to fine, reddish brown sand                      8-9
Very fine, olive green sand, with traces of  silt           9-12
Very fine, silty, light gray sand                         12-14
Very fine, greenish-gray sand                             14-16
Very fine, light gray sand, with traces of silt
  and clay                                                16-22
Very fine green sand with light to medium gray  shell
  fragments interbedded with clay and silt                22-26
Silty green clay with traces of shells and very
  fine sand, with one thin bed of weathered  coquina
  at 34 to 35 m of depth                                  26-37

1  m = 3.3 ft
                              226

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   APPENDIX 10-2



SITE I  PHOTOGRAPHS
        227

-------
The Whitehouse site in  July 1980.

Outcrop of oil sludge (July 1980).
                   228

-------
Oil  pit being filled with refuse (1976)
Oil  storage tanks and fuller's earth mixing
ope rations (1976).
                    229

-------
Aerial  photograph  of the  Whitehouse  oil pits (1976).
       Oil  flowing to McGirts  Creek from
                 ruptured  pit  (1976)
•U.S. GOVERNMENT PRINTING OFFICE:  1981-0-720-016/5987
                            230

-------