Prepared ForVertac Chemical Corporation'5100 Poplar AvenueMemphis, Tennessee58137
VT3.2.7
TABLE OF CONTENTS
Page No.I. INTRODUCTION
1. Author i t y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12. P u r p o s e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
II. RESPONSES TO "EPA REVIEW OF DISC REPORT OF OCTOBER 1982"1. TCDD Action L e v e l s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 _,002. Old Equalization B a s i n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 °0
v03 . Reasor-Hill L a n d f i l l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Qj
04 . Cooling Water P o n d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 ^5. On-Site Surface C o n t a m i n a t i o n . . . . . . . . . . . . . . . . . . . . . . 86 . Contamination From Production P r o c e s s e s . . . . . . . . . . . . 87 . Potential Groundwater Contamination at
Miscellaneous L o c a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88. Computer Groundwater Flow M o d e l . . . . . . . . . . . . . . . . . . . . 129 . Cooling Pond Water I n t e r a c t i o n . . . . . . . . . . . . . . . . . . . . . 13
10. Water Samples . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1311. Estimated Waste Volumes . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1612. Topographic Contours from DISC Blueprints . . . . . . . . . . 1613. Subsurface G e o l o g y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1914. DISC Drawing No. 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1915. Site G e o l o g y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 191 6 . Well I n v e n t o r y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1917. Rainwater I n f i l t r a t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
03225609
CONTINUED
Page No,III. REMEDIAL ALTERNATIVES
1. G e n e r a l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 222. Cooling Water Pond S e d i m e n t . . . . . . . . . . . . . . . . . . . . . . . . . . 223. North Waste Burial A r e a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 234. Reasor-Hill L a n d f i l l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 85. Old Equalization B a s i n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
0^28 00
vO29 (M
00
30 '
6 . Influence of Production Areas of Surface W a t e r s . . . . . . 287. East Ditch S e d i m e n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 298. Central Ditch S e d i m e n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 299 . Surface S o i l s . . . . . . . . . . . . . . . . . . . . . . . .
APPENDICES
Appendix ABC
List of EPA CommentsComputer Model DataSurvey Traverse Closure
I. INTRODUCTION
1. AuthorityPreparation of this supplemental report was authorizedby Mr. R. D. Karkkainen, Director of Environment andSafety, Vertac Chemical Corporation. This report isin response to the United States Environmental ProtectionAgency (EPA) letter of 23 November 1982 addressed toMr. R. D. Karkkainen'concerning the "DISC Report ofOctober 1982".
2. PurposeThere are two objectives of this report: ( i ) to address Qthe seventeen comments or concerns listed by EPA and —(i i ) to present evaluations of the various remedialactions that may be required. It is beyond the scope ^of this report, however, to recommend that remedial CMactions be taken. Part II of this report presents 0responses to the concerns of EPA. Also presented in QPart II are the results of analyses performed subse-quent to the preparation of the DISC Report ofOctober 1982. Part III presents remedial alternatives.Estimated costs are also given for the various options.
II. RESPONSES TO
"EPA REVIEW OF DISC REPORT OF OCTOBER 1982"
The paragraphs which follow are responses to the concernsexpressed by EPA. Responses are enumerated per EPA's listof concerns, included in Appendix A of this report.
1. TCDD Action LevelsIt is beyond the scope of DISCOS study to determine actionlevels for TCDD or other contaminants. Such determinationsare under the realm of .ttoxicology, a science not included T"in DISC'S scope of services. Part III of this report ^presents evaluations of the various remedial actions that 0may be required. (\j
02. Old Equalization Basin
All evidence indicates that the remedial actions taken inthe past have been successful in the old equalizationbasin area. Specifically,1) Analysis of water samples taken from Rocky Branch,
the ultimate interceptor of groundwater in that area,indicate that there is no increase in contaminationdownstream from the old basin;
i2) There is no evidence of leachate seeps in the area;and
3) The objective of the past remedial actions was tocollect all leachate via a downgradient french drainand inhibit further leachate production by blockingincoming groundwater flow and infiltration by claywalls and cover. Construction records indicatethat these remedial measures were accomplished asplanned. The quantity of leachate pumped from thefrench drain is said to have decreased considerablysince remedial construction, indicating the effect-iveness of the remedial construction.
Construction of a monitoring well between the french drainand Rocky Branch would contribute little in determiningthe effectiveness of the past remedial measures. Some ofthe reasons are:
0
3 03225612
1) While there is adequate space for construction ofa well between the french drain and Rocky Branch,the well would have to be located very near thefrench drain. The well would then only be capableof detecting "leaks" in a very short segment ofthe french drain's total length. Numerous wells wouldbe required to detect deficiencies in the impoundment.
2) The area between the french drain and Rocky Branch,topographically and piezometrically downgradientfrom the old equalization basin, was said to havebeen contaminated prior to remedial construction.Therefore, detection of contaminants in wellsconstructed in this area would not necessarilyindicate an inadequacy in the past remedialconstruction. CVI
(^For the reasons listed above, it is felt that continued <,- monitoring of the waters of Rocky Branch is the best, measure of the effectiveness of the past remedial CM
0construction in this area. Such monitoring is beingrequired by Vertac's State Water Permit.•-^ T-omi i i-pri hv Vpr-t-ar-' <=; R-t-a-t-p Wa-hiar Pfarmi-1-- 0
•:"•)
3. Reasor-Hill LandfillReports of site inspections made prior to remedial con-struction at the Reasor-Hill Landfill by others andinterviews with knowledgeable plant operating personneland others indicate that prior to remedial construction,the Reasor-Hill Landfill was an obvious source of con-tamination. Leachate seeps were apparently abundantnear Rocky Branch and some "'buried" wastes protrudedabove the ground surface. There is little doubt thatunder these circumstances the areas located downgradientfrom the landfill would become somewhat contaminated.Remedial actions in this area have included constructionof upgradient barrier walls and a surface clay cover.The intent of these actions was to reduce the leachateproduction in the landfill and lower the piezometricgradient to reduce leachate flow. Construction detailsindicate that the designs were appropriate for theintended purposes. There is no evidence that construc-tion was not carried out essentially as planned. (Evidence,see paragraph 2 above, indicates that similar constructionat the old equalization basin was successful.)Evidence that would indicate that the remedial constructionhas been successful is conflicting, but explainable. Seepswere not noted in this area during any of the numeroussite inspections made by DISC personnel, indicatingremedial success. However, analyses performed on ground-water samples taken from well numbers 9 and 18 indicatethe presence of contamination in a downgradientdirection frori-i the landfill, indicating possible
remedial failure. It is very probable that this contam-ination is residual from past contaminant transportprior to remedial construction described above. Thesuccess of the remedial construction would in essencecreate a nearly stagnant groundwater condition within thelandfill. Groundwater immediately downgradient, suchas that at well numbers 9 and 18, would be expected tobe as contaminated now as it was prior to remedialconstruction. For this reason, it is felt that analysesperformed on samples taken from well numbers 9 and 18do not unquestionably depict a flow of contaminantsfrom the Reasor-Hill Landfill. The absence of leachateseeps is a definate improvement that strongly indicatesremedial success.As in the case of the old equalizaition basin, the bestverification of remedial success is surface wateranalysis at Rocky Branch. State permits require string-ent water quality standards for Rocky Branch. Thiscontinued monitoring should verify the success of allpast and planned remedial measures in this area.
KV(s0CM00
4. Cooling Water Pond
The groundwater levels measured in the monitoring wellsand shown on the well sketches do not reflect the eleva-tion of the piezometric surface at the well locations.Considerable time is required for the groundwater levelin these large diameter wells to stabilize. Piezometers,on the other hand, were installed in small diameterboreholes, allowing a much more rapid stabilizationAlso, due to development procedures and frequent sampleremoval from the monitoring wells, the water level vasnever given sufficient time to stabilize until recently.Water levels measured in monitoring wells were not usedin preparation of groundwater contours; piezometermeasurements were. Figure 1 1 . 4 . 1 is a geologic sectionthrough well numbers 12, 14 and 19 and extends to thecooling water pond. The piezometric gradient, based ongroundwater level measurements made in these wells on15 December 1982 (sufficient time has passed forstabilization), verify that flow is toward the coolingwater pond.
When resampled on 17 September 1982, contamination wasnot detected in well number 17 as it was in the sampleobtained on 05 August 1982. For the reasons stated inthe DISC Report of October 1982, and reemphasized inparagraph 10, below, results of the earlier samplesshould be heavily discounted.
Further discussion concerning the contamination of thecooling pond or resampling is not called for becauseVertac's expressed intention of performing remedialmeasures in this area. Remedial options are discussed
5. On-Site Surface ContaminationAnalysis of the surface soil sample obtained from AreaNo. 1, See Figure 1 1 . 5 . 1 , on 07 July 1982, indicatedthe presence of TCDD in a measurable concentration. Theanalytical laboratory (Specialized Assays) did notfeel comfortable with this test result and did notinclude a "number" on their report. The area wasresampled by DISC on 08 October 1982. Samples wereobtained at approximately the same locations as inJuly 1982.., The area was subdivided and two compositesamples were formed from the individual samples. \QFigure 11.5.2 shows the approximate location of each Q\individual sample and the area boundaries. TCDDwas not detected in the samples collected on 08October 1982 in measurable concentrations (detection CMlimit between 50 and 100 p p t ) . An aliquot of the 0original composite sample was then submitted for con- 0firmatory analysis. TCDD was detected in a reported ,concentration of 490 ppt. Test results concerningarea No. 1 are tabularized on Table 1 1 . 5 . 1 .EPA has indicated its intentions of resampling thesurface soils for TCDD analysis. In DISC'S resamplingof area No. 1, no TCDD was detected. We anxiously awaitEPA' s resampling (we .would ask to witness sampling andreceive splits) so that the degradation of TCDD in thesurface soils can be verified. ~-'Duplicate samples were obtained from area number 5 , asshown on Table 1 1 . 3 . 1 of DISC Report of October 1982.TCDD was not detected in either sample.
6 . Contamination From Production ProcessesRemedial options are discussed in Part III of this Report.
7. Potential Groundwater Contamination at Miscellaneous LocationsThe central ditch discharges into the cooling pond whichthen discharges to Rocky Branch. Contaminant migrationfrom the site by surface water flow certainly then out-weighs migration by ground water flow. Assuming that thewater flowing in the central ditch is unacceptable forrelease into the environment (by surface water on ground-water transport), remedial actions will be required (seePart III of the Report.) Hence, further analysis ofthe effects of the central ditch on the groundwater arenot necessary.
In each case that trace concentrations were reportedin the original water sample taken from the monitoringwells, when the wells were resampled, the retests showedno noticeable contamination. Resampling by the EPAContractor, with DISC receiving splits, will resolveall discrepancies. Otherwise, for the reasons statedin the DISC Report of October 1982 and paragraph 10below, the existing retest results are consideredmore reliable than the original test results.
8. Computer Groundwater Flow ModelA report describing the computer model used in deter-mining contaminant transport in this study is being 0submitted under separate cover. The report describes Qthe procedures used and gives the mathematical basis ,^,of the model.Additional data has been gathered subsequent to the 0preparation of the DISC Report of October 1982. The 0computer model has been rerun with this new data. •'Tables B-l, B-2, and B-3 of Appendix B present theinput data used by the model in the latest run.The tables show the elevations of the heads atconstant head boundaries and the lower confiningboundary elevation and hydraulic conductivity ofeach grid point of the study area. Results of thelatest computer model run are presented on DrawingNo. A-l. Records of water level readings arepresented on Table B-4. "^The model assumes that the Reasor-Hill Landfill andold equalization basin have been separated from theremainder of the study area by past remedial construc-tion. This was accomplished by constructing thebarrier walls in these areas with clayey materialshaving a permeability of several orders of magnitudelower than the other nearby soils. The model doesaddress these areas, but determines that there isimmeasurable flow through' them.Because of the extremely low flow velocities ( 0 . 1 to1.0 ft. per year) determined by the model, only wellslocated very near (10 to 100 feet) to contaminantsources can be considered to lie within the plumecorresponding to the source. Due to these low velocities,contamination detected in wells located in isolatedareas, e . g . well number 15, cannot be the result ofgroundwater transport from a major source such as theNorth Burial area, or even the plant production area.Such trace contamination is either non-existent(erroneous sampling or analysis) or the result of alocalized and non-constant source of unknown origin.
12 032 5621
The contaminants leaving the site via groundwatertransport can only be from sources lying very near theplant boundaries or points of exfiltration (pointswhere groundwater intersects surface water or groundsurface). Since the Reasor-Hill Landfill and oldequalization basin are separated, as described above,only the North Waste Burial area and the apparentlycontaminated area to it's west are considered in themodel output, to be a source of contaminants that areleaving the site. This source is assumed to extendto the edge of the cooling water pond, thereforeattenuation is not considered. Well number 12 isassumed to represent the contamination conditionsat these points of exfiltration from the source.Based on the streamlines shown on Drawing No. A-land the contamination concentration of well Number12, a tout 1 pound of tracer contaminants are being 0transported, via groundwater, from the site per year. ^
(M9. Cooling Pond Mater Interaction 0
Remedial options are presented in Part III of thisReport.
10. Water SamplesSeveral water samples were recollected and analyzedbecause the original analytical results appearedquestionable. In each case, the original test resultsindicated the presence of noticeable concentrationsof contaminants in areas that, based on all otherinformation and analyses, should not have been contam-inated. For example, well number 10 is not locateddowngradient from any known source of contaminationand yet original analyses indicated the presenceof contamination. The retests were performed to ver-ify or negate the presence of contaminants in theseareas. The resampled test results are consideredmore valid, not because "the resampled values werefar less than the first s.et", as interpreted byEPA, but because they were more consistent with allother data. A third sampling by the EPA contractorwill verify or modify this conclusion. We requestsample splits for independent analyses.Records of past site inspections indicate that priorto remedial construction, the ground surface washighly contaminated in the vicinity of the presentlocation of well numbers 8, 14, and 19 . Inspectionsketches show open ditches and sumps then containedcontaminated wastes. There is little doubt that thedescribed activities would contaminate the areaaround these wells. It is further surmized that with
13
0
E-iSOO
E-iOOO
E-2500
E-2000
E-1500
E-lOOO
E-&OQ
too
-pa— DATE bESJRIPTION
SUPV T aDESIGNDRAWN HTCHECKED JLW :DATE . /O £VC. /fff
pCALE...^SWtMU
pEVELOPERSINTERNA-jt. piviSioy.pF pi
\ • ' . . ^EUPHIl , ..'.. ,
e-asqo
N
/ye .'MI a_____.wa
E-aooo
E-Z500 \(\
01^-CMoo
E-2000
E-1500
//<» iA//i}^^A»ia"' y'
E-1000
E-SOO
EOO
032°-5624^wo W^r£/? ^^D/£/YJ Ano ^r/f^ftfiWf D£W£>/>W £y ^fpvrw Atoo^
ENVIRONMENTAL ASSESSMENT STUDYVERTAC CHEMICAL CORPORATION SITE
______________ JACKSONVILLE. ARKANSAS
such surface contamination in this area, that areastopographically downgradient (well number 12 location)would become contaminated. This is the overland flowsuggested in DISC'S October 1982 Report.
The "overload flow" theory is the most probable mechan-ism that caused the contamination of the area nearwell number 12. Groundwater velocities have beencalculated to be much less than one foot per year inthis area. Sufficient time has not lapsed sincethe facility was constructed to allow contaminantsto be transported the distance between the locationsof well numbers 8, 14, and 19 and well number 12 viaground water transport. If the ground surface were <d"contaminated via overland flow (surface water Qtransport), however, contaminants would only have to' ^percolate several feet through the unsaturated soil.The low flow rate of groundwater would then allow a ^\"buildup of these contaminants in the groundwater 0beneath the contaminated- soil surface. Laboratory 0analyses performed on soil samples obtained from theunsaturated soil zone in this area verify the presenceof residual contamination. Test results are listedon the following pages.
(M
11. Estimated t\^ste Volumes
The total volume of wastes at the Reasor-Hill Landfillwas estimated based on estimated rock contours andground surface contours mapped before and afterremedial construction. The estimated average depthof the landfill multiplied by the area enclosed bybarrier walls equals the 30 ,000 yd3 estimate oftotal volume of materials lying within the landfill.No records are available that characterize the variouswastes buried in the landfill.
The volume of materials lying within the North WasteBurial Area was estimated in a similar manner. Recordsof a resistivity study were also utilized in this area.Records are also not available concerning the wastesburied in this area.
12. Topographic Contours from DISC BlueprintsTopographic mapping of the site was accomplished byaereal methods. Accuracy is to within one half thecontour interval. Ground control was performed bytheodolite and electronic distance measuring device.Appendix C presents the ground control traverseclosure.
DISCDevelopers. International Services Corp.• CONSULTANTS• LABORATORIES• GEOTECHNICAL
PROJECT :CLIENT :SAMPLE TYPE :SAMPLE LOCATION :
Environmental Assessment Study JOB NO. 803Vertac Chemical CorporationSoil -DATE SAMPLED: 08 October 19823 . 0 ' Depth, Well No. 19
2 , 4 - D (ppb)2 , 4 , 5 - T (ppb.)2 ( 2 , 4 , 5 - T ) P (ppb)
18
< 25< 25< 25< 25< 25N . D .
202020202020
< 20N . D .
< 25< 25< 25N . D .
< 25
30059
< 50
\00r-0400
A DIVISION OF InternationalMEMPHIS. 'ENN1 9 0 1 1 396-• •:••'
LITTLE ROCK. ARK!SOll 37?.?;i'9
EL DORADO. ARK. GREENVILLE. MS RENO.NEV.
13. Subsurface GeologyA contour map of the subsurface geology, used in thecomputer groundwater flow model, is presented onDISC Drawing No. A-2. This geologic information canbe used in estimating the stratigraphy at any pointat the site, including that in the disposal areas.
14. DISC Drawing 14DISC Drawing No. 4 has been reproduced at a reducedscale of 1" = 2 0 0 ' . A copy is enclosed.
015. Site Geology r—
CMThe site lies on the fall line of the Interior Highlands Qand Coastal Plain geologic provinces. The Midway ^Group is a member of the Coastal Plain. The Atokais a member of the Interior Highlands. The site istherefore underlain by both the Midway and Atokaformations as stated in the DISC Report of October1982. Also, as also earlier stated, residual Atokasoils and Midway soils have many of the same propertiesin this area that can affect this study. The distinc-tion between them is of little consequence.
1 6 . Well InventoryExhibit IV, Part I, Section 2, Paragraph 3 , of theDISC Report of October 1982 states:"State and local permitting agencies were questionedconcerning the location of water wells in the vicinityof the study area. Only two domestic wells apparentlyexist in the vicinity; a 50 foot deep well locatedabout 1.5 miles to the west of the site and a 15 footdeep well located about 1 . 5 miles to the southeastof the site."
17. Rainwater InfiltrationBecause the capped areas are well drained and not sub-jected to ponding, very little precipitation willinfiltrate through the very low permeability claycovers. Evapotranspiration further reduces the effectsof precipitation. Rainwater infiltration through theclay covers was found to be insignificant in theoverall realm of the study.
The purpose of this section is to present remedialoptions is a conceptional manner for each of theareas which may require such action. Areas thatwill be covered in the following paragraphs willinclude (i) the cooling water pond sediment,(ii) the North Waste Burial area, (iii) the Reasor-Hill Landfill, (iv) the old equalization basin,(v) the influence of production areas on surfacewaters, (vi) the sediments of the east and centralditches and (vii) the surface soils.
2. Cooling Water Pond Sediment
Based on thickness soundings made during sampling,there are approximately 7500 cubic yards of sedimentin the cooling pond. Several remedial options willdeal with this apparently TCDD contaminated sediment.
2.1 The sediment can be removed, solidified, andplaced in an on-site, above ground landfill.This procedure, including landfill construc-tion with leachate collection system, wouldrequire a captital cost budget of 300 ,000 .to375 ,000 dollars. Maintenance and operatingcosts would be insignificant compared to theinitial capital cost. If sediment cannotbe safely removed without first drainingthe pond, plant process water would have tobe either temporarily cut off or cooledelsewhere (cooling towers). Assuming thata temporary shutdown is intolerable, coolingtower construction would be required.Approximately 125,000 dollars would berequired for this conversion. The totalcapital cost of this option should thereforerange from 300,000 to 500,000 dollars.
2 .2 The pond can be drained and the sedimentcovered in place with a clay cap. A frenchdrain would be constructed downgradientfrom the cooling pond to intercept leachate.Rocky Branch would be routed through a pavedchannel through the present cooling pond.Possible locations and preliminary sketches ofthese actions are shown on DISC Drawing No.R-l and R-2. The projected total costestimate for this option, including the costfor converting to the use of cooling towers,is 275,000 dollars. _ _ -
032^5631
2.3 Stabilization of the sediment in place with-out first draining the pond is not consideredtechnically feasable. It is feared that suchactivities would excessively stir up thesediment, possibly releasing TCDD to thesurface waters of Rocky Branch. Furthertechnical or cost discussion is thereforenot presented concerning such remedial options.
3. North Waste Burial AreaThree remedial options are presented below. Also,semi-annual analysis of groundwater monitoring wells ~located in this area is recommended. ~
l--3 . 1 A french drain can be constructed at a location 04
west of the contaminated area, parrallel to Qthe cooling pond. A french drain similar insection to that shown on DISC Drawing No. R-2would suffice. Approximately 400 lineal feetof such a drain would cost approximately 7000dollars. The presently uncapped area betweenthe presently capped area and the cooling pondshould be covered with clay. The cost wouldbe about 8000 dollars. Maintenance andoperational costs would be minimal. The totalestimated cost for this option is 15,000 dollars.
0
3 . 2 If option 2 . 2 is proposed, contaminant flowfrom this area would ultimately be interceptedby the french drain of that option. Furtherremedial work wuld not be required for theNorth Waste Burial area. There is thereforeno additional cost for this option.
3 . 3 A clay barrier wall, similar in section tothat shown on DISC Drawing No. R-2, constructedpiezometrially upgradient from this area andperpendicular to the groundwater flow linesshown on Drawing No. A-l that enter this areawould significantly reduce the already lowcontaminant transport from this area. Theoptimum length and location of this barrierwall can be determined by modifying computermodel input data. For this estimte, however,it is assumed that the required length is300 feet. The estimated cost would be5000 dollars.
^vT^^?rv ^^K^^^-ss^s^^z^r^»^-ry~»~—T-—<^ < •' >^——-/i — — • o ' — y — \ — / \. / 7 f 7'7 J' / / ^. l /\. I /\ I I i i T i 7
PRELIMINARY DESIGN
^NATIONAL SERVICES CORR' DISC INTERNATIONAL
TENNESSEE
ENVIRONMENTAL ASSESSMENT STUDY
VERTAC CHEMICAL CORPORATION SITE 0*12° KSCJACKSONVILLE ARKANSAS
Joa NO.80i
ORWG NO./("-/•
4. Reasor-Hill LandfillThe Reasor-Hill Landfill presently is covered by aclay cap and surrounded on all sides except down-gradient by clay barrier walls. Flow from thelandfill has undoubtably been greatly reduced bythis past construction. Continued monitoring ofthe waters of Rocky Branch, such as that requiredby Vertac's State Water Permit, will verify thesuccess of past or planned remedial construction inthis area.4.1 Construction of a french drain, similar in
section to that shown on DISC Drawing No. R-2will intercept contaminant flow from theReasor-Hill Landfill and prevent floodwatersfrom possibly flowing into the landfill.Approximately 800 lineal feet of such a drainwill cost an estimated 25,000 dollars.
5. Old Equalization BasinPast remedial construction in this area including adowngradient french drain, clay barrier walls on theother three sides and a clay cover, are bel-ieved tobe adequate. Continued sampling of the waters ofRocky Branch, as required by Vertac's State WaterPermit will verify the adequacy of remedial construc-tion in this area.5 . 1 Construction of a french drain, similar in
section to that shown on. DISC Drawing No.R-2 could be positioned to intercept flow from thearea between the present french drain andRocky Branch and prevent floodwater frombacking up into this area. Approximately300 lineal feet of this drain will cost anestimated 10,000 dollars.
6 . Influence of Production Areas oh Surface WatersThe surface waters that appear to be contaminated,namely the east and central ditches, originate withinplant production areas.6 . 1 A general upgrading in plant housekeeping
should significantly reduce this flow ofcontaminants. In general, rainwater thatfalls in non-contaminanted a r e a s , . e . g .building roofs and lawns, should be segre-gated from possibly contaminated rainwater.Possibly contaminated water should be stored,tested and properly disposed. Much of thiscan be accomplished by installing miscellan-
28
ecus curbing, drains, and sumps. Otheractions, such as burial of a noted pileof possibly contaminated soil, excavatedrecently during plant modification, shouldalso be taken. These actions can be takenby plant personnel at very little cost.It is recommended that such actions betaken on a "action-effect" basis in whichthe effects of certain actions are monitoredto determine if further action is required.
7. East Ditch SedimentContaminants, including TCDD, were detected in the r -sediment samples collected from the east ditch, yThere are several remedial alternatives for dealing ^with this sediment. _(M7 . 1 The ditch can be re-routed, with the existing ^
ditch being f illed- with the clayey material 0removed from the new ditch. This can beperformed for about 5 dollars per lineal foot.
7 . 2 Corrugated metal pipe could be laid in theexisting ditch and covered with clayey soil.The cost would be at least several timesmore than 7 . 1 above with no technicaladvantages. This alternative has thereforenot been further considered.
8. Central Ditch SedimentAs in the east ditch, contaminants were detected inthe central ditch sediment. This ditch serves as acooling water return channel to the cooling waterpond.8 . 1 If the cooling water pond is closed and cooling
towers are installed, the central ditch willnot be required. It can be filled withclayey soil and abandoned. This fillingoperation should cost less than 3000 dollars.
8 . 2 The central ditch can be paved with asphalticconcrete. A 12,000 dollar budget should besufficient for this construction.
8 . 3 Corrugated metal pipes could be laid in theexisting ditch and covered with clayey soil.This construction would cost much more than8 . 2 above and has not been further considered.
29
9. Surface Soils
If it is determined that the surface soils are contam-inated with TCDD(DISC samples do not indicate measurableTCDD at this time), every effort should be made toincrease the rates of degradation by ultra-violetradiation. Areas should be exposed to as much sun-light as possible. Grass should be mowed frequently.Contaminated areas, if any, should be monitoredannually to document the degradation.
30
APPENDIX A
LIST OF EPA COMMENTS
J-****^ •> £?Sl \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY1 W^ ? REGION v» ..V* '"•*'/• 1201 ELM STREET
<1" ' DALLAS, TEKAS 7S270 . .
Hovw^sr 23» 2982
Mr. Dick Karkkainen .Director of Environment and SafetyVertac Chemical Corporation -: . . .24th Floor, 5100 Poplar - 'Memphis, Tennessee 38137 . .
Re: DISC Report of October 1982 :
Dear Mr. Karkkainen: ' ,
The October 1982 DISC report has been characterized by both Vertac andDISC as the "Final Report" required by Paragraph VII of our ConsentDecree. However, DISC has failed to submit certain pieces of informationnecessary for full evaluation of the report. As you are doubtlesslyaware, for example, DISC mentioned in their report that several analyses had not been completed and would be submitted at a later date. Inaddition, DISC has failed to provide an evaluation of remedial actionalternatives for all appropriate areas of the Vertac site, as required bythe Decree (see DISC proposal, page 2). We see these as major deficienciesand request that Vertac submit the aforementioned data and evaluation ofremedial action alternatives no later than the submission of the proposalfor remedial work specified under Paragraph VIII of the Consent Decree.In addition, we suggest that Vertac and DISC meet with EPA and ADPC&Eas soon as possible to discuss these matters.
We have listed our various concerns on the attached pages. If you haveany questions, please contact me at your earliest convenience. .
Sincerely,
\)^^^ (y^JL^ .Dennis GuildEnvironm&ntal Engineer
Enclosure/
cc: Bob Blanz, ADPC&E .Rohn Drye, Jr, P.E.
Developers, International - •Services Corporation : . . • .
/ 'QCMr-<M00
EPA Rfe ew of DISC Report of October 1 \. ,
1. TCC!) Action Levels '.'•"' . • • ' •: .
On p-ige 1 of the DISC report, it Is stated that the EPA -is in the processof creating a policy that will establish an action level for allowable2,3,7,8-TCDD concentrations. When these guidelines become available,feoedial action recommendations will be made, if necessary." •
Ms wish to note that the EPA is not creating such action levels and thatthere will be no such guidelines in the foreseeable future. Even in theabsence of such guidelines, we feel that certain remedial actions will benecessary and that DISC or Vertac should submit proposals for theseactions, as discussed in greater detail below.
2. Old Equalization Basin ' .v
Page 1 of the report states that past remedial actions have been successfulin the old equalization basin area. ^
We do not believe the DISC report provides justification for the alleged c\j
success of remedial actions in the equalization basin area. Further, we C>know of no environmentally sound method to ascertain the success of these 0remedial actions other than to install monitoring wells between thetrench drain downgradient of the equalization basin and Rocky BranchCreek. Figure A2 in DISC drawing 2 indicates that there is as muchas roughly forty feet between the trench drain and Rocky Branch Creek,and we believe this provides ample space tor the installation of mon-itor-ing wel ts. Further, monitoring of such wells should be conductedon a long term basis.
EPA would also'like information on current rates of leachate collection ,and on Vertac's handling and/or storage of that leac'nate.
3. Reasor-Hill Landfill
Page 1 of the report indicates that the remedial construction "hasnot been quantitatively determined," but that it is qualitativelysuccessful. • —
Regardless of the apparent qualitative success of these remedialmeasures, we believe the high levels of organics in wells 18 and 9in the Reasor-Hill area (10,652 ppb and 11,240 ppb total organics,respectively) provide adequate justification for rewdial actionhere. DISC should evaluate alternatives for collection or contain-ment actions in this area.
4. Cocking Water Pond
Pa^e 2 of the report states, " Ground a ter flow» frw t?>* surrounding ' -areas toward the cooling pood. There 1$ no Zhre^t o^ con^x»i«^»t<<» - --
• - ; ..--',^P%^^^N^^^^®S
migration from the cooling pond water or sediment to the groundwater."
Me agree that the dominant groundwater movement in the area aroundthe cooling water pond, as described by the groundwater contours inthe DISC report, should be toward the cooling water pond. It is notclear, however, that the groundwater flow is entirely toward thecooling water pond. DISC'S sketch for well j?12 shows the groundwaterlevel to be 14 feet beneath the ground surface. DISC'S blueprint^py-I shows the surface elevation of well ^12 to be 283 feet, makingthe groundwater elevation 269 feet. Drawing ^PW-I shows the coolingwater pond elevation to be roughly 275 feet. These data indicate aflow away from the cooling water pond, not toward it. Additionally, .we wonder if there might be seasonal differences in the direction offlow. We thus feel that some form of remedial action is necessaryhere. Our reasons are as follows:
CMa. The aforementioned water elevations at, well ?12 and the cooling CM
water pond. r--
b. Well ^17, which is on the opposite side of the cooling water pondfrom landfills on the Vertac site, is shown.by DISC'S sampling tobe contaminated with 45 ppb of chlorophenols and roughly 44 ppb ofherbicides. Unless DISC or Vertac can supply a more appropriateexplanation, we must assume that this contamination representsmigration away from the cooling water pond.
c. Me believe that the water above the sediments could provide apressure head sufficient to drive contamination downward throughthe sediments and to beneath the stream channel and along thedirection of the streamflow. We acknowledge that there should belittle lateral movement away from the pond (in east and westdirections, although the data from wells §12. and §\7 tend todiscount this), but we nevertheless believe that subsurfacemigration along the stream bed is a distinct possibility.
d. Samples from the cooling water pond sediment indicate that it isseverely contaminated. One EPA sample from April 14and-157—1981,for example, shows herbicides at over 16 ppm and TCDD at 892 ppb. \
Contaminants at these levels need not seep into groundwatel—to—present a threat deserving remedial action; the mere possibility
-that they could be swept out of the pond by high streamflows issufficient to recommend remedial action.
We request that DISC evaluate remedial action alternatives for this area.Unless Vertac can fix these contaminated sediments in place, we feelcompelled to recoi^nend that they be re'wved. As part of Vertac'sinvestigations in this matter, we request that you determine and supplyus with an estimate for the total volume of sedis»ent& to be addressedhere, and that you also supply us with the basis for t?iat estimate.
Me acknowledge substantial differences between the concentrations ofconta.-nnants found in the DISC cooling w^ter poM se<it-»<"t 4*Rplrt ver»ui
CM00
•the EPA samples. It is our opinion, however, that the concentrations ofcontaminants found by either contractor are high enough to justify remedialaction at the cooling water pond. Should Vertac want the cooling waterpond sediments resampled, we would concur with this resampling, but wewould want the EPA contractor present either to take the samples or toreceive splits.
5.- On-site Surface Contamination
Page 2 of the DISC report states, "Surface soils at the site.show nomeasurable concentrations of TCDD except in one area near the Reasor-Hill Landfill. This area has been subdivided and resampled, butanalytical data is not yet available, when the contamination is betterdefined, remedial actions may be required." .
In Table 11.3.1, where the results of this sampling were presented, c\t
the data for the sample from the contaminated area on Reasor-Hill were r"not included. We request that this data be supplied, in addition to CMthe data from the later samples. 0
0Table 11.3.1 also indicates that sample §S was a duplicate. Vlhathappened to the original sample j?5? Was it analyzed, and if so, whatwere the results?
In general, we are surprised that DISC detected no TCDD in eight ofthe nine surface soil samples. Me therefore plan to have our contractort<ike confirming samples, and if you desire, give Vertac splits. Thespecifics regarding this sampling will be established at a later date.If these analyses reveal the presence of TCDD, we would expect DISCto propose remedial action alternatives for this area.
6. Contamination from Production Processes
Page 4 of the DISC report states, "Certain chemical constituentsassociated with production processes have been reported in watersmifirating from the site. It is the intent of plant operators, pastand present, to determine the location, extent, source, nature, andprobable fate of any environmental contamination existing at thefacility. The goal of plant operators is to eliminate any environmentalpollution related to the operations and conditions at the Jacksonvilleplant."
Vi'e request that Vertac elaborate on these intents and describehow they plan to accomplish the above goals. We are especiallyinterested in Vertac's plans for controlling conta.'ni nation fron thecentral and east ditches at the site, described on page 10 of the DISCreport as follows: "The central and east ditches both carry surfacerunoff from production areas. Both also shon significant contamination,based on odor, appearance, and test results."
DSSC should evaluate remedial actions for thess areas-
7. Potential Gcoundwater Contamination at Miscellaneous Locations
Page 10 of the DISC report states, "The central ditch could contributeto groundwater contamination, since it flows continuously, however,chemical analyses of samples taken from wells Hos. 1 , 2 , and 3,
located downgradient from the central ditch, do not show theconcentrations of Phenoxy Acids that would be expected if this werethe case."
If at all possible, we recommend the installation of a monitoringweU nearer to the central ditch than wells 1, 2, or 3, but stiU tothe south of it, in order to more surely determine if the centralditch is in fact a source of groundwater. .
DISC wells 13, 10> 11. 15. 16. and 17, all located at the periphery rof the Vertac site and apparently not downgradient of any subsurface (Mdisposal areas, all showed noticeable contamination. Me request that r~-Vertac provide explanations and/or remedial plans for these apparent ^Jinstances of contamination. -\J
08. Computer Groundwater Flow Model
Page 9 of the DISC report states, "The computer groundwater flowmodel indicates that the total mass of tracer contaminants that leavesth° site via groundwater transport is less than one pound per year."
The DISC report does not adequately explain this model. If we are toaccept its results, we must first be given complete informationdescribing its method of calculations, its assumptions, its inputdata, how or if its output matches analytical data from the site,intermediate or other model outputs (i.e., groundwater velocities.contaminant concentration contours), etc. We request that thisdocumentation be submitted. The description presented in DISCExhibit IV if far too general to provide justification for its results.
In short, we request that DISC justify the results of this model, notpi^raly that it present them.
Additionally, we would like to know why the model fails to addresscontamination at the southwest portion of the site (i.e., near theequalization basin).
9. Cooling Pond Water Interaction
Page 9 of the DISC report states. "Output froa.the conputer sroun<iwaterflow model...indicates that the sroundwAter does transport ccnt»a<n4ntlto the cooling pond." It. further tt3te». "Analylll, of w^er 5An?le»taken from the central ditch ^ndlcat^S Uut it. too ll tr,»n» portlycontaminants to the cool 109 pond."
®32%e<S
DISC should evaluate remedial alternatives to prevent the continuedmigration of contaminants to the cooling water pond. We requestthdt the proposal for remedial work to be submitted by Vertac addressboth of the above sources of contamination. Due to the high levels ofcontamination in wells 8» 12. 14» and 19, we are especially concernedabout subsurface migration of contaminants into the cooling waterpond, and we believe that this potential migration can be prevented.
10. Mater SamplesPage 9 of the DISC report mentions, in effect, that both Rocky Branchand the groundwater monitoring wells were resampled, that the resampledvalues were far less than the first set, and that the resampled setwas therefore more valid. We fail to understand the basis for thisconclusion, and if Vertac feels it is correct, we request that Vertac i vexplain it. For example, were there differences in plant operations (Mbetween the two periods? Were there differences in weather or streamflow.conditions? Were there any other changes that night have caused the /\.second set of analyses to be lower than the first set? 0
0Page 9 of the DISC report recommends a third sampling for both RockyBranch and the groundwater monitoring wells, tie concur with thisrecommendation and request that the FIT be present and be given splitswhen this sampling is done. We of course expect advance notice ofthis sampling and assume that the precise details will be establishedin the near future.
Page 9 of the DISC report, states, "Wells 8. 1Z, 14. and 19.......showhigh concentrations of chlorophenols, chloroanisoles. and phenoxyacids. These high concentrations are believed to be the results ofoverland flow before past remedial construction took place."
We fail to understand the basis for this claim. If three of thesefour wells were only recently installed, well after the capping ofthis area, how could previous overland flow have caused the highconcentrations of contaminants in them? Further, page 9 also states,"Well 12, the farthest from the burial area, is the most contaminated."We wish to note that if the DISC analyses for well 14 are totalled,they yield an organic concentration of roughly 417,000 ppb, whilewell 12 yields a concentration of roughly 398,000 ppb. It thereforeappears that the above DISC statement regarding well s-12 is in error.
Also regarding well ai2, page 9 of the DISC report states. "Soilsamples fron boring ?io. 12 from depths above the groundwater levelhad strong chenical odors. Soil samples from this area are now beinganalyzed. Results will be distributed when available". We areeanerly awaiting those results.
11. Estimated Waste Volumes
Page 8 of the DISC report indicates that the estimated total volumeof wastes at the Reasor-Hill Landfill is 30,000 cubic yards, and thatthe volume of wastes at the North Haste Burial area is 100,000 cubicyards.
Upon what information were these estimations based, and how were theycalculated? Is there information available indicating how much waste,and what types of wastes, are in each area of the two. landfillsmentioned above.
12. Topographic Contours from DISC Blueprints.
Upon what information were these contours based? \0
<Mr-<M13. Subsurface Geology0
It would be useful to have a contour map of the subsurface geology Q(i.e., the bedrock) for the Vertac site. Me suggest that DISC prepare .such a contour map.. In addition, geologic cross sections through thedisposal areas would be useful,
14. DISC Drawing ?4
We '.-.'ere pleased to sea the drawing of the burial areas shown in item Aof DISC drawing j?4. We suggest, however, that this drawing beenlarged to the 1"=200' scale, so that these burial areas can be moreeasily correlated with monitoring well locations end groundwater contours.
15. Site Geology
Our contractor informs us that he believes the Vertac site lies onthe Midway Formation, rather than on the Atoka Formation, as the DISCReport indicates. We suggest that DISC look further into this issue.
16. WsU Inventory
P^SS 2 of the DISC final report states that no wells are immediatelydowngradient- of the site. How was the well inventory conducted, overwhat areas was it conducted, and what were its specific results?
17. Rainwater Infiltration through Capped Areas
DiSC states on page 4 of their report that c-»pp<n9 o? diipowl Arcst*prevents the infiltration of rAin^lor. V^ ^1A ^o "ol Uut:
( 1 ) Capping decreases but does not prevent infiltration of rainwater;( 2 ) models are available to estimate infiltration of rainwaterthrough capped areas; and ( 3 ) we suggest that DISC use such modelsto estimate rainwater infiltration in these areas.
• TABLE B-l HEADS AT CONSTANT HEAD
1 2 3 4
277 .2 279.0 2 8 0 . 0 2 8 4 . 0
278 .3 X X
276 .0 X X
2 7 6 . 0 X
2 7 4 . 0
2 7 4 . 0 .
2 7 4 . 0
2 7 4 . 0
2 7 4 . 0
272 .0
2 7 4 . 0
IMPERMEABLE \^^BOUNDARY '
5
2 9 3 . 5
X
X
X
X
X
X
X
X
X
X
X
X
6
3 0 0 . 5
X
X
X
X
X
X
X
X
X
X
X
X
X
2 6 4 . 0
7
306 .
X
X
X
X
X
X
X
X
X
X
X
X
X
267.
BOUNUAKx.
8
3 3 0 7 . 5
X
X
X
X
X
X
X
X
X
X
X
X
X
2 2 6 8 . 4
9
309 .2
X
X
X
X
X
X
X
X
X
X
X
X
X
269 .5
10
310.2
X
X
X
X
X
X
X
X
X
X
X
X
X
267 .7
11
311.1
X
X
X
X
X
X
X
X
X
X
X
X
X
2 6 5 . 4
12
310 .0
X
X
X
X
X
X
X
X
X
X
X
X
264 .2
13
306
301
297
295
288
285
280
279
275
270
268
266
264
.0
.8
.8
.3
0
.0
.0
.5
.7
.0
.8
.0
.0
NOTE: X DENOTES ARBITRARY INITIAL VALUE OF HYDRAULIC HEADS.
101102103104105106107108109"111'112113114115116117118120121122123124125126127128129130131132133134135136137138139140141Note: Water table depth,@ piezometers,are measured from ground surface.
TABLE B-4WATER LEVEL READINGS
Well No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
1 9
21, 22 &Depft
9.
12.
14.
16.
20.
8.
11 .
12 .
4.
8.
9.
14 .
10.
7.
9.
6.
10.
12 .
23th•
67
25
25
70
10
00
80
30
90
88
25
83
42
38
00
13
42
42
July 1
E1.
270.
271.
271.
283.
283.
275.
275.
279 .
256 .
267.
275.
283.
280.
270.
258.
271.
257.
278.
982
01
61
78
79
96
76
60
23
10
70
75
67
38
92
10
87
55
38
15Dep
f
10.
12.
20.
8.
3.
7.
3.
9.
4 .
3.
4 .
9.
8.
8.
6.
5.
4 .
2.
11 .
Decemitht.
67
69
04
42
27
54
27
06
83
96
67
1 9
63
00
79
96
65
58
21
3er 1982
E1.
275.
271.
265.
291.
300.
276.
282 .
282 .
256.
283.
2 7 1 .
275 .
289 .
282 .
271.
261 .
2 7 3 .
2 6 5 .
279.
01
17
99
58
79 ^f^
22 r-
53 S47 0
1
17
64
91
81
87 ^
80
51
14
35
42
58
NOTE: Water Table Depth At fells Are Measured FromTop of Steel Casing.
![[On-Demand Webinar] How to find heavily discounted opportunities 150317 (1)](https://static.documents.pub/doc/80x56/58d1b75b1a28ab98278b571f/on-demand-webinar-how-to-find-heavily-discounted-opportunities-150317-1.jpg)
