Coalition of Communities for Environmental Justice

Environmental Justice is our Goal

Meridian, MS

September 30, 1997

4WD-RCRA

MEMORANDUM

SUBJ: Evaluation of Kerr-McGee Chemical Corporation's status

under the RCRIS Corrective Action Environmental

Indicator Event Codes (CA725 and CA750)

EPA I.D. Number: MSD 081 387 730

FROM: Russ McLean, Environmental Engineer

South Programs Section

THRU: Kent Williams, Chief

South Programs Section

TO: Narindar M. Kumar, Chief

RCRA Programs Branch

I . PURPOSE OF MEMO

This memo is written to formalize an evaluation of the KerrMcGee

Chemical Corporation (KMCC), Meridian, Mississippi

facility's status in relation to the following RCRIS corrective

action codes:

1) Human Exposures Controlled Determination (CA725),

2) Groundwater Releases Controlled Determination (CA750)

The application of these event codes at KMCC adheres to the

event code definitions found in the Data Element Dictionary for

the Resource Conservation and Recovery Information System

(RCRIS) .

Concurrence by the RCRA Branch Chief is required prior to

entering these event codes into RCRIS. Your concurrence with the

interpretations provided in the following paragraphs and the

subsequent recommendations is satisfied by dating and signing

above.

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II. HUMAN EXPOSURES CONTROLLED DETERMINATION (CA725)

There are five (5) national status codes under CA725.

 

The first three (3) status codes listed above were defined

in the January 1995 Data Element Dictionary for RCRIS. The last

two (2) status codes were defined in the June 1997 Data Element

Dictionary.

Note that CA725 is designed to measure human exposures over

the entire facility (i.e., the code does not track SWMU specific

actions or success). Every area at the facility must meet the

definition before a YE or NC status code can be entered for

CA725. The NO status code should be entered if there are current

unacceptable risks to humans due to releases of hazardous wastes

or hazardous constituents from any SWMU(s) or AOC(s). The IN

status code is designed to cover those cases where insufficient

information is available to make an informed decision on whether

or not human exposures are controlled. If an evaluation

determines that there are both unacceptable and uncontrolled

current risks to humans at the facility (NO) along with

insufficient information on contamination or exposures at the

facility (IN), then the priority for the EI recommendation is the

NO status code.

In Region 4's opinion, the previous relevance of NA as a

meaningful status code is eliminated by the June 1997 Data

Element Dictionary's inclusion of NO and IN to the existing YE

and NC status codes. In other words, YE, NC, NO and IN cover all

of the scenarios possible in an evaluation or reevaluation of a

facility for CA725. Therefore, it is Region 4's opinion that

only YE, NC, NO and IN should be utilized to categorize a

facility for CA725. No facility in Region 4 should carry a NA

status code.

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This particular CA725 evaluation is the first evaluation

performed by EPA for the KMCC, Meridian, Mississippi facility.

Because assumptions have to be made as to whether or not human

exposures to current media contamination are plausible and, if

plausible, whether or not controls are in place to address these

plausible exposures, this memo first examines each environmental

media (i.e., soil, groundwater, surface water, air) at the entire

facility including any offsite contamination emanating from the

facility rather than from individual areas or releases. After

this independent media by media examination is presented, a final

recommendation is offered as to the proper CA725 status code for

KMCC, Meridian, Mississippi.

The following discussions, interpretations and conclusions

on contamination and exposures at the facility are based on the

following reference documents:

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Confirmatory Sampling Report, 1997

Annual Groundwater Monitoring Reports, 1986-1996

Ditch Sediment Sampling Results Report, 1993

RCRA Facility Assessment, 1988

RCRA Part B Permit Application, 1987

Groundwater Assessment Report, 1985

III. FACILITY SUMMARY

Kerr-McGee Chemical Corporation (KMCC) owns property in

Meridian, Lauderdale County, Mississippi where a wood preserving

facility was previously located. The 120 acre property is bounded

on the west by the Norfolk and Southern Railroad right-of-way and

Highway 11, on the north by Interstate 20, on the east by an

undeveloped industrial park and on the south by a portion of the

undeveloped park and the city of Meridian's POTW. The facility

was originally built by Gulf States Creosote in 1924 and treated

railroad ties and utility poles. In 1933, American Creosote

bought the facility and later sold out to Union Camp Company in

the mid-1950s. In 1964, KMCC purchased the facility and has

owned it since. KMCC shut down production at the plant in 1986

and has since completely dismantled the facility. Only a metal

storage building and a small office building remain on the site.

While KMCC was in operation, the facility performed milling

on various wood products, primarily railroad ties, and then

treated these products primarily with creosote but also with

pentachlorophenol (PCP) solutions. In 1985 the facility ceased

use of PCP and dismantled the PCP storage areas shortly

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thereafter. Process wastewaters at the facility were discharged

directly to Sowashee Creek prior to the early 1950's. At that

time a surface impoundment was constructed to handle this

wastewater prior to discharge to the city's POTW. The

impoundment was used until 1982 when a new wastewater treatment

system, consisting of an API Separator and storage/treatment

tanks, was constructed. The impoundment generated listed

hazardous waste KOOl, bottom sediment sludge from the treatment

of wastewaters from wood preserving processes that use creosote

and/or pentachlorophenol. The impoundment was closed in

accordance with a closure plan approved by the Mississippi

Department of Environmental Quality (MDEQ) in September 1985. In

March 1988 MDEQ issued KMCC a Post-Closure permit for closure

cover maintenance and continued ground-water monitoring of the

closed surface impoundment.

A RCRA Facility Assessment (RFA) was conducted by EPA in

1988 and identified thirty-five (35) SWMUs and five (5) AOCs. A

total of fifteen (15) SWMUs and all five AOCs were indicated in

the RFA as having a potential for release to environmental media.

In September 1995 EPA issued the HSWA portion of the RCRA permit.

As all process and storage/ treatment equipment was removed and

all in-ground sumps, piping, foundations and visually impacted

soils had been excavated and removed after the RFA was conducted,

a Confirmatory Sampling program was required by the permit. The

Confirmatory Sampling Work Plan was designed to; identify areas

at the facility which continue to indicate soil or sediment

contamination, determine whether surface water draining the

facility contains hazardous constituents as a result of

continuing soil/sediment contamination, and determine whether

ground water underlying the facility has been impacted.

IV. MEDIA BY MEDIA DISCUSSION OF CONTAMINATION AND THE STATUS OF

PLAUSIBLE HUMAN EXPOSURES

Ground Water

Releases from SWMUs and/or AOCs have contaminated ground

water at concentrations above relevant action levels.

The uppermost aquifer underlying the KMCC facility is

composed of alluvial deposits extending to a depth of about

25 feet. The alluvium consists of a lower unit composed of

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fine to medium grained sand having an approximate thickness

of 12 feet, covered by a relatively impermeable 10 to 12

foot thick clay. Surficial soils developed on the alluvial

deposits belong to the Quitman series, a sandy clay loam

described as showing poor drainage and slow percolation.

Groundwater flow in the alluvial aquifer is to the southeast

toward Sowashee Creek, which flows southwest and intersects

the property at the southeast corner. Ground water in the

lower unit of the alluvial deposits is under confined

conditions due to the overlying clay, with a potentiometric

surface found 3 to 4 feet below ground surface.

Underlying the alluvium are the Hatchitigbee or Bashi

Formations of the Upper Wilcox Group. These formations are

composed of interbedded lignitic sands, sandy silts, and

silty or sandy clays. The major water bearing formations in

the area are found in the Lower Wilcox. The depth to the

top of the Lower Wilcox Aquifer is approximately 500 feet

and has a thickness of as much as 450 feet. Most wells in

the surrounding area produce water from below 800 feet in

depth.

In 1981, KMCC installed groundwater monitoring wells and

piezometers in the shallow alluvial deposits (upper aquifer)

to meet interim status regulations for the surface

impoundment. The original detection monitoring system has

undergone numerous well additions and modifications since

1981 and is currently comprised of seven (7) monitoring

wells and fourteen (14) piezometers.

In 1984 KMCC submitted a Groundwater Quality Assessment Plan

to the Mississippi Department of Environmental Quality

(MDEQ) in response to a statistically significant difference

from background levels of total organic carbon and/or pH in

downgradient monitoring wells MW-3 and MW-4. Subsequent

investigations indicated that no impact to the ground water

had occurred from the surface impoundment. However, it was

determined that contamination detected in well MW-3 was

attributable to an abandoned sewer line which had received a

spill of pentachlorophenol solution following a release of

overflow from a process sump. This line ran underground

from the process area eastward, under the surface

impoundment and adjacent to MW-3, terminating at a point

about 240' east of the impoundment. The termination point

previously contained an in-ground septic tank which had been

removed in 1982. The sewer line, east of the impoundment,

was excavated along with 2 feet of soils on each side of and

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beneath the line. On the west side of the impoundment an

excavation was made to the sewer line which was breached and

a cement/bentonite slurry was pumped into the portion of the

line underlying the impoundment. Following excavation and

plugging of the sewer line, a new monitoring well, MW-3A,

was installed, as a replacement for well MW-3. Analytical

data for this well has shown an historical reduction of

initially low levels of semi-volatile constituents to nondetects

in recent sampling events.

Confirmatory sampling, which was conducted in November 1996,

indicates that ground water beneath the process area and the

black tie storage areas is contaminated with semi-volatile

constituents and BTEX above relevant action levels. The

highest concentration of constituents was found beneath the

former process area with total semi-volatile constituents,

primarily PAHs, at 380 mg/l and BTEX at 1.31 mg/l.

Pentachlorophenol, with an MCL of .001 mg/l, was detected in

five (5) samples at concentrations ranging from 0.36 to 13

mg/l. Benzene, with an MCL of .005 mg/l, was detected in

four (4) samples at concentrations ranging from .003 to .566

mg/l. Table 1 presents the levels of total semi-volatiles

and volatiles detected during confirmatory sampling. Figure

1 depicts sampling locations with respective concentrations

and an isoconcentration map indicating the approximate

extent of the semi-volatile plume.

Groundwater samples were taken at five (5) locations at the

downgradient property boundary as part of the confirmatory

sampling effort. This sampling indicated only trace levels

of semi-volatiles in one boring. Soil boring SB-22 detected

fluoranthene at .02 mg/l and phenanthrene at .01 mg/l.

Relevant action levels for these constituents are 1.5 mg/l

and 1.1 mg/l respectively.

Although ground water is contaminated onsite above relevant

action levels, there are no drinking water wells located on

facility property that would allow exposure. Recent

groundwater sampling at the downgradient property boundary

has demonstrated that hazardous constituents are not

currently migrating off-site at levels above relevant action

levels. However, because control measures have not been

implemented nor has natural attenuation been demonstrated to

be effective in controlling the migration of contaminated

groundwater beyond the facility boundary, ground water

contamination at the facility is not controlled.

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Based on the above discussion, ground water in the alluvial

aquifer is contaminated above relevant action levels and all

plausible human exposures are not controlled.

Surface Water

The KMCC facility is located on a flat alluvial plain formed

by Sowashee Creek which is found just east and southeast of

the facility boundary. The entire KMCC property is within

the 100-year floodplain of Sowashee Creek. The property is

partially protected by a low levee on the eastern and

southern boundaries of the property. Surface drainage

within the facility is routed by two stormwater ditches to a

point on the south property boundary where two valved gates

drain the water through the levee. The gates can be closed

to contain runoff or prevent inundation by flood waters. A

ditch receives drainage outside the levee and directs flow

1800 feet south to Sowashee Creek.

Sowashee Creek flows south into Okatibbee Creek

approximately 2.5 miles south-southwest of the KMCC

property. The Okatibbee flows into the Chickasawhay River

12 miles farther south. Meridian obtains some of its water

from the Okatibbee and Sowashee, but upstream from the

facility. The nearest public drinking water usage of

surface water downstream of the facility is thought to be on

the Chickasawhay River at Waynesboro, about 40 miles away.

Surface water samples collected from the stormwater ditches

during confirmatory sampling did not detect any KOOl or BTEX

constituents.

Based on the above discussion, the limited sampling of

surface water draining the facility does not indicate

contamination. Additional investigations of surface waters

will be conducted during the RFI.

Releases from SWMUs and AOCs have contaminated soil at

concentrations above relevant action levels. During

confirmatory sampling, soil and sediment samples were

collected in the former process area, black tie storage area

and the unlined drainage ditches. In the former process

area carcinogenic PAH constituents were detected at

concentrations up to an order of magnitude greater than the

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relevant action levels and pentachlorophenol was detected at

concentrations up to four times the relevant action level.

Sample analyses of soils in the former black tie storage

area indicated concentrations of benzo (a) anthracene in three

borings at levels up to 26 mg/l (action level=.88 mg/l).

Because of matrix interference in three of the five samples

submitted for analysis in this area, due to high levels of

contamination, reported quantitation limits were, in the

case of the carcinogenic PAR constituents, two to three

orders of magnitude above the action levels and up to two

orders of magnitude above the action level for

pentachlorophenol.

Sediment sampling in the drainage ditches indicated levels

of carcinogenic PAR constituents in all samples analyzed

above the relevant action level. The highest concentration

measured was 21 mg/l for benzo(a)pyrene (action level=.088

mg/l) .

Relevant action levels for sediments and soils are based on

residential levels as there are no access controls on the

property. Also, the sediment contamination found in the

drainage ditches onsite has not been fully delineated.

There is a reasonable possibility that sediments in the

ditches offsite contain constituents above action levels.

Based on the above discussion, soils and sediments are

contaminated above relevant action levels and all plausible

human exposures are not controlled.

Releases to air from soil and/or ground water contamination

at the facility is not known or expected to be occurring

above relevant action levels. As the constituents of

concern, semi-volatile PARs and pentachlorophenol, exhibit

low vapor pressures and tend to adhere to soil particles

rather than releasing to the air medium, vapor emissions

should be insignificant. Fugitive dust formation is also

not expected as the majority of the facility is covered by

vegetation and the annual rainfall in this area is

substantial.

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Based on the above discussion, air is not expected to be

contaminated above relevant action levels.

V. STATUS CODE RECOMMENDATION FOR CA725:

As discussed, ground water, soils and sediments at the

facility are contaminated above relevant action levels and all

plausible human exposures are not controlled. Based on the

information presented, it is recommended that CA725 NO be entered

into RCRIS.

VI. GROUNDWATER RELEASES CONTROLLED DETERMINATION (CA750)

.The first three (3) status codes listed above were defined

in January 1995 Data Element Dictionary for RCRIS. The last two

(2) status codes were defined in June 1997 Data Element

Dictionary.

The status codes for CA750 are designed to measure the

adequacy of actively (e.g., pump and treat) or passively (e.g.,

natural attenuation) controlling the physical movement of

groundwater contaminated with hazardous constituents above

relevant action levels. The designated boundary (e.g., the

facility boundary, a line upgradient of receptors, the leading

edge of the plume as defined by levels above action levels or

cleanup standards, etc.) is the point where the success or

failure of controlling the migration of hazardous constituents is

measured. Every contaminated area at the facility must be

evaluated and found to have the migration of contaminated

groundwater controlled before a "YEn status code can be entered.

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If contaminated groundwater is not controlled in any area(s)

of the facility, the NO status code should be entered. If there

is not enough information at certain areas to make an informed

decision as to whether groundwater releases are controlled, then

the IN status code should be entered. If an evaluation

determines that there are both uncontrolled groundwater releases

for certain units/areas (NO) and insufficient information at

certain units/areas of groundwater contamination (IN), then the

priority for the EI recommendation should be the NO status code.

In Region 4's opinion, the previous relevance of NA as a

meaningful status code is eliminated by the June 1997 Data

Element Dictionary's inclusion of NO and IN to the existing YE

and NR status codes. In other words, YE, NR, NO and IN cover all

of the scenarios possible in an evaluation or reevaluation of a

facility for CA750. Therefore, it is Region 4's opinion that

only YE, NR, NO and IN should be utilized to categorize a

facility for CA725. No facility in Region 4 should carry a NA

status code.

This evaluation for CA750 is the first formal evaluation

performed for the Kerr-McGee Chemical Corporation, Meridian, MS

facility. Please note that CA750 is based on the adequate

control of all contaminated groundwater at the facility.

The following discussions, interpretations and conclusions

on contaminated groundwater at the facility are based on the

reference documents cited in Section II of this memorandum.

VII. STATUS CODE RECOMMENDATION FOR CA750:

Based on data contained in the documents referenced in

Section II and summarized in the ground water portion of Section

III, releases from SWMUs and AOCs have contaminated ground water

above relevant action levels.

Although ground water is contaminated onsite above action

levels, no drinking water wells are located within the facility

boundaries. Ground water has been sampled at the downgradient

property boundary with no constituents detected above relevant

action levels. However, there are no controls currently in place

to prevent the migration of contaminated ground water beyond the

facility boundary. Additionally, it has not been demonstrated

that natural attenuation of the groundwater contamination is

occurring. It is recommended that CA750 NO be entered into

RCRIS.

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VIII. SUMMARY OF FOLLOW-UP ACTIONS

A RCRA Facility Investigation (RFI) has been imposed as a

result of the contamination identified during Confirmatory

Sampling. The RFI will require delineation and characterization

of contaminated soils, sediments and ground water in those areas

of the facility with identified contamination. As human exposure

to soil/sediment contamination is uncontrolled due to the lack of

access controls, interim measures will be required to construct a

perimeter fence at the facility. Additionally, sampling will be

conducted during the RFI in the offsite surface water drainage

ditches to determine if contaminated sediments are present and if

so, what interim measures may be required to control human

exposures. The groundwater contamination will be addressed

through the implementation of source removal/remediation

activities and the installation of engineered control systems to

prevent further migration of the plume. This activity will also

be required through interim measures/stabilization in accordance

with the conditions set forth in the HSWA permit.

 

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