&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
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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
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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
-------
Facility Type
Name and Location
-
I
a
n
I
O
l/t O
1 1
O i/1
c
O
4-»
,S
4-1
C
-------
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
-------
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
-------
Chlorine Plant
•"PMC
Figure 2-1. Aerial photograph of Olin
Chemical complex. [2-1]
22
-------
0 J OMLES
PRESSURE WELLS-*
MUCK PONDS -u»—•
GRAVITY FLOW LINES-
CONTROL.^
Figure 2-2. Site layout of Olin Chemical complex. [2-2]
23
-------
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.™..,,.. ,.„„ ,
-------
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]
-------
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
-------
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
-------
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
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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
-------
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
-------
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
-------
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
-------
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.
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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.
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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
-------
^(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
-------
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
-------
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
-------
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
-------
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
-------
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]
-------
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
-------
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
-------
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
-------
4
1
IO
6
J3
—
x 100,000 !
ro
CO
o
1
O
— .
.."•' '"'
I
- .•'* =
•
a
— • rr
1
» ^£
_ * UJ
UJ
g
H
UJ
. 0
- • 1
5
••
'
s
o
s
s
0
UJ
o
1
o
0)
s
1
en
CM
S?
Q
i
CO
CHARGE RE
CO
o
• •••* 1
..••• 1
C;
CD
«^
O
LiJ
CO
u5
UJ
o
5
CO
Q
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
-------
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
-------
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
-------
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
-------
/
/
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
Figure 8-3. Site layout after remedial action
at the Ferguson property. [8-1]
174
-------
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
-------
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
-------
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
-------
APPENDIX 8-1
SITE G PHOTOGRAPHS
178
-------
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
-------
A.
'
Burial area following second cleanup
Drainage diversion ditches around burial site
180
-------
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
-------
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
-------
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
-------
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
-------
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
-------
«- TO COUNTY 19
COTTAOE GRWE TOWNSHIP
Figure 9-3. Configuration of waste disposal pits
at 3M Woodbury site. [9-2]
187
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
APPENDIX 9-1
SITE H PHOTOGRAPHS
199
-------
I
IF',,
•«*•.. -
<*
w
Overall appearance of excavated pit area
at Woodbury Disposal pits
200
-------
The structure in the middle of the photo shelters
one of the barrier pumps
3M's Chemolite Incinerator
201
-------
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
-------
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
-------
Figure 10-1. Location of Whitehouse/Al1ied
Petroleum site.
204
-------
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
-------
rv
c
r
Figure 10-3. Layout of Whitehouse oil pits and diversion ditches (1976)
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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,
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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.
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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.
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APPENDIX 10-1
WELL LOG FOR SITE I
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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
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APPENDIX 10-2
SITE I PHOTOGRAPHS
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The Whitehouse site in July 1980.
Outcrop of oil sludge (July 1980).
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Oil pit being filled with refuse (1976)
Oil storage tanks and fuller's earth mixing
ope rations (1976).
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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
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