EXPLANATION OF SIGNIFICANT DIFFERENCESto the

RECORD OF DECISION

OPERABLE UNIT #1

AMERICAN CREOSOTE WORKS, INC.

CERCLANPLSITE

JACKSON, MADISON COUNTY, TENNESSEE

TND007018799

DECLARATION

U.S. Environmental Protection AgencyRegion IV

Atlanta, Georgia

September 17, 1993

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EXPLANATION OF SIGNIFICANT DIFFERENCESTO THE

OPERABLE UNIT ONE RECORD-OF-DECISION

SITE NAME AND LOCATION

American Creosote Works, Inc. (Operable Unit One)Jackson, Madison County, Tennessee

STATEMENT OF BASIS AND PURPOSE

This document presents an explanation of the significant differences between the original OperableUnit One Record of Decision selected remedy and the remedy which was actually accomplished forOperable Unit One of the American Creosote Works, Inc. CERCLA NPL Site, Jackson, MadisonCounty, Tennessee. This explanation of significant differences was developed in accordance withCERCLA, as amended by SARA, and the National Contingency Plan. The following documentsform the basis for this explanation of significant differences to the original selected remedial action:

Remedial Investigation ReportFeasibility Study ReportRecord of Decision1989 remedial action report1991 remedial action report

DESCRIPTION OF THE SIGNIFICANT DIFFERENCES

The purpose of this explanation of significant differences is to explain the differences between theoriginal Record-of-Decision with the actual remedial design and remedial action accomplishments.

The major components of the original selected remedy included;

Deed restrictions limiting further use of the Site;Construction of a flood protection levee around theSite and Site stabilization;Removal and disposal of tanked liquids and sludges;Removal and disposal of Site structures; andInstallation of security fencing around the Site.

The components of the actual remedy as implemented include:

• Deed restrictions still need to be imposed.• Flood protection levee, including two drainage devices,

has been constructed. Site stabilization is being undertakenby the State through a cooperative agreement with USEPA.

• Removal and proper disposal of tanked liquids and sludges hasbeen completed.

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DECLARATION

The majority of the process area structures have been demolishedand salvaged or disposed. Some scrap metal remains on-Site.Three buildings in the northeastern part of the Siteremain standing.

The installation of a security fence around the entire perimeter of theSite has been accomplished.

The modified remedy is protective of human health and the environment, attains Federal and Staterequirements that are applicable or relevant and appropriate to the remedial action, and is cost-effective. This remedy satisfies the statutory preference for remedies that employ treatment thatreduces toxicity, mobility, or volume as a prinicipal element and utilizes permanent solutions andalternative treatment technologies to the maximum extent practicable.

Because this remedy may result in hazardous substances remaining on-Site above health-basedlevels, a review will be conducted within five years after the commencement or remedial action toensure that the remedy continues to provide adequate protection of human health and theenvironment.

Date Patrick M. TobinActing Regional Administrator

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EXPLANATION OF SIGNIFICANT DIFFERENCESto the

RECORD OF DECISION

OPERABLE UNIT #1

AMERICAN CREOSOTE WORKS, INC.

CERCLA NPL SITEJACKSON, MADISON COUNTY, TENNESSEE

TND 007018799

U.S. Environmental Protection AgencyRegion IV

Atlanta, Georgia

September 17,1993

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CONTENTS

1.0 INTRODUCTION....................................................................... 1

1.1 Site Location and Description................................................... 1

1.2 Lead and Support Agencies.......................................................!

13 Circumstances Leading to the Need for the ESP........................... 2

1.4 Statutory Requirements........................................................... 2

2.0 SUMMARY OF SITE HISTORY AND THE SELECTED REMEDY...... 7

2.1 SiteHistorv.............................................................................7

2.2 Enforcement Activities.............................................................!!

2.3 Role of Operable Unit OneWithin USEPA's Site Strategy................ .................................. .11

2.3.1 Operable Unit One..........................................................l22.3.2 Operable Unit Two..........................................................l22.3.3 Operable Unit Three........................................................l22.3.4 Site Stabilization Activities................................................l3

2.4 Community Relations Historv...................................................l4

3.0 DESCRIPTION OF THE SIGNIFICANT DIFFERENCESAND THE BASIS FOR THOSE DIFFERENCES................................^

3.1 Response Actions Undertaken BEFORE theOriginal January 1989 Record-of-Decision....... .......................... ..14

3.2 Response Activities Accomplished in 1989and 1990 AFTER the Januar 1989

3.2.1 Implementation of the ROD Remedy. ............................. .....15

3.2.1.1 Pumping of Sludges from Tanks......... ...... .....................163.2.1.2 Filtration and Dewatering of

Tank Sludges.................... ...................................... ...163.2.1.3 Oil/Water Separation and

De-emulsification of Effluentfrom Dewatering of Tank Sludges...................................l6

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3.2.1.4 Metals Precipitation from Effluentfrom Dewatering of Sludges.........................................17

3.2.1.5 Filtration of Suspended Solids......................................173.2.1.6 Adsorption Utilizing Activated

Carbon Beds............................................................173.2.1.7 Discharge Limits and Effluent

Water Analyses.........................................................173.2.1.8 Transportation and Disposal of

Waste Streams..........................................................l93.2.1.9 Building Demolition...................................................193.2.1.10 Levee Improvements..................................................19

3.2.2 Remedial Action in 1991..................................................20

3.2.2.1 Introduction.............................................................203.2.2.2 Remedial Action Summary..........................................21

3.2.3 Remedial Action in 1992..................................................21

3.3 Basis for Differences Between Remedy inRecord-of-Decision AND Actual OperableUnit One Remedial Actions Completed AFTERJanuary 1989.......................................................................21

4.0 SUPPORT AGENCY COMMENTS...............................................22

5.0 STATUTORY DETERMINATIONS..............................................23

6.0 PUBLIC PARTICIPATION ACTIVmES.......................................23

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FIGURES

1.0 Location of Site in USEPA Region IV..................................3

1.1 Location of Site in Jackson, Tennessee................................4

1.2 Location of Site: Jackson-South 7V2 Minute Quadrangle.........5

2.0 Layout of Original Wood Preserving Facility WithCertain Remediation Details Described................................8

2.1 Layout of Original Wood Preserving Process Area.................9

3.0 Design of Water Treatment System Utilized in1989 Remediation of Process Area.....................................18

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1.0 INTRODUCTION.

This Explanation of Significant Differences (ESD) is being issued by Region IV of the U.S.Environmental Protection Agency according to the policies in the Office of Solid Waste andEmergency Response (OSWER) Directive 93553-02, Chapter 8, and under the auspices of Section113(k) of the Comprehensive Environmental Response, Compensation, Liability Act of 1980(CERCLA) as amended by the Soperfond Amendments and Reauthorization Act of 1986 (SARA).This Explanation of Significant Differences (ESD) explains the differences between the originalOperable Unit One remedy as set forth in the Record of Decision which was issued on January 5,1989, and the Operable Unit One remedy as implemented and as described in Section 3.0 herein.

This ESD explains the modification of the Record-of-Decision selected remedy for Operable Unit #1.This change does not represent a substantial change in the remedy, but is a significant change suchthat a formal explanation and public notification is necessary.

1.1 Site Location and Description.

The American Creosote Works, Inc. (ACW) CERCLA NPL Site is located in central MadisonCounty, Tennessee, on the Jackson South 7-1/2 Minute Quadrangle (See Figures 1.0 and 1.1.). TheSite covers approximately 60 acres southwest of downtown Jackson, Tennessee. The Site is boundedon the south by the Seaboard Railroad, on the southwest by the South Fork Forked Deer River, andon the east by a lumber mill (See Figure 1.2.). The general area is characterized by a gently rollingtopography with wide, marshy flood plains. Maximum relief is on the order of 100 feet (350 ftMSL to 450 ft MSL), with relief on the plant site of about 20 feet. The surface topography of theSite included numerous small swales, four (4) lagoons and other low lying areas (See Figure 2.0.).These low lying areas accumulate contaminated surface water and sediments.

1.2 Lead and Support Agencies.

The USEPA has categorized the ACW Site as a Federal Fund-lead site, which means that theUSEPA takes the lead for all Site remediation activities. Over the last several years the State hasparticipated in Site responses by means of Support Agency Cooperative Agreements (SACA) (40CFR 35.6240 et seq.) which provide the State with ninety (90) percent (or, in one case, one hundred[100] percent) of its management and response costs up to a given ceiling (CERCLA Section104(c)(3)(C)). The Tennessee Department of Environment and Conservation (TDEC) has itsSouthwest Branch office in the city of Jackson within one mile of the Site.

In March 1989 the State signed a Superfund State Contract (SSC) (40 CFR 35.6800 et seq.) withthe USEPA to share the costs (90% federal/10% state split) for the conduct of the Operable UnitOne Remedial Action. Currently, the SSC remains in effect, and will continue to be viable untilall the Operable Unit One Remedial Action costs are reconciled by both USEPA and the State, andOperable Unit One is Closed-Out by agreement between USEPA Region IV and the State ofTennessee.

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1.3 Circumstances Leading to the Need for the BSD.

The original Operable Unit One Record of Decision was completed in January 1989. Immediatelyafter the completion of the ROD, the USEPA Region IV determined that a mix of Superfundemergency response and remedial authorities would be utilized to expedite the Remedial Design andRemedial Action processes. Some of the Remedial Design work was undertaken by Superfundemergency response contractors, TAT and ERCS, with USEPA Region IV oversight, and the restof the Design tasks were completed under an Interagency Agreement (IAG) with the U.S. ArmyCorps of Engineers. The RD/RA work began in July 1989 and ended prematurely in January 1990due to budget constraints and regulatory problems. Therefore, all of the tasks which constitutedthe selected remedy were not completed as planned. Subsequently, two separate mobilizations byRegion IV emergency response personnel occurred; one in 1991 and one in 1992. These twomobilizations resulted in the completion of those Remedial Action tasks, such as the installation ofthe perimeter security fence, which did the most towards the reduction of Site hazard and risk.Certain tasks required by the ROD selected remedy remain to be accomplished. These remainingtasks include: the razing of buildings in the northeastern portion of the Site and concrete structuresin the process area, and the disposal of debris into a permitted construction debris landfill; salvageof scrap metal from the dismantling of the process area tanks and structures; imposition of land-useand ground water use restrictions. An April 1993 Support Agency Cooperative Agreement (SACA)for Site Stabilization, as described in the Operable Unit One SSC and alluded to in the originalROD, provides the State with funding for five (5) years of management of site stabilizationactivities, which include monitoring of lagoon water quality, repair of the site drainage system, andmaintenance of the perimeter security fence. This ESD explains the differences and reasons forthose differences between the original ROD selected remedy and the remedy as implemented.

1.4 Statutory Requirements.

The issuance of this ESD is in accordance with CERCLA, Section 117(c), which states:

(c) EXPLANATION OF SIGNIFICANT DIFFERENCES. - Afteradoption of a final remedial action plan —(1) if any remedial action is taken,(2) if any enforcement or consent decree under

section 106 is taken, or(3) if any settlement or consent decree under

section 106 or section 122 is entered into,and if such actions, settlement, or decreediffers in any significant respects from thefinal plan, the President or the State shallpublish an explanation of the significantdifferences and the reasons such changeswere made.

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Site Location

American Creosote Works, Inc.CERCLA NPL Site

Jackson, Madison County, TennesseeFigure 1.0

ERA

JACKSON

307 Meadow StrutJackson, Tennwte

Not fo scale

en

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ERAAmerican Creosote Works,Inc.

CERCLA NPL SiteJackson, Madison County, Tennessee

Figure 1.1

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American Creosote Works, Inc..CERCLA NPL SEfe

Jackson, Madison County,, Tennessee.Figure 1.2

SEPA

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The issuance of this ESD is also in concert with the National Contingency Plan (NCP), Section300.435(c)(2)(i), which says, in part:

(2) After the adoption of the ROD, if the remedial actionor enforcement action taken, or the settlement orconsent decree entered into, differs significantlyfrom the remedy selected hi the ROD with respect toscope, performance or cost, the lead agency shallconsult with the support agency, as appropriate, andshall either:

0) Publish an explanation of significant differenceswhen the differences in the remedial or enforcementaction, settlement, or consent decree significantlychange but do not fundamentally alter the remedyselected in the ROD with respect to scope,performance, or cost. To issue an explanation ofsignificant differences, the lead agency shall:

(A) Make the explanation of significant differencesand supporting information available to thepublic in the administrative record establishedunder Section 300.815 and the informationinformation repository; and

(B) Publish a notice that briefly summarizes theexplanation of significant differences,

including the reasons for such differences,in a major local newspaper of generalcirculation; or ....

The ESD will become part of the Administrative Record File as required in NCP 300.825(a)(2).Copies of the Administrative Record are maintained in two locations. The addresses and otherparticulars of these repositories follow.

USEPA's Administrative Records Center in Atlanta. Georgia

USEPA - Region IVSuperfund Administrative Records Center

Ground Floor345 Courtland Street, N.E.

Atlanta, Georgia 30365(404) 347-0506 or (800) 435-9233

Hours: 8:00 am - 5:00 pmMonday - Friday

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Site Information Repository in Jackson. Tennessee.

Jackson-Madison County Library433 East Lafayette

Jackson, Tennessee 38301(901) 423-0225

Hours: 9:30 am - 9:00 pmMonday - Thursday9:30 am - 5:30 pmFriday - Saturday

2.0 SUMMARY OF SITE HISTORY AND THE SELECTED REMEDY.

2.1 Site History.

The American Creosote Works, Inc., began operation as a wood preserving facility in the early1930's and continued until December 1981. The wood preserving operation used both creosote andpentachlorophenol (PCP). Wastewater sludges from the creosote and PCP treatment of woodproducts are listed as K001 waste under RCRA, Untreated process wastewater and potentiallycontaminated storm water run-off were discharged directly into Central Creek until 1973. Themajor sources of contaminated water were the treatment cylinder condensate and surface waterrun-off over contaminated soils. During 1974 and 1975, a wastewater treatment system wasinstalled. The system operated through 1981 (See Figure 2.1.). The engineering report for thetreatment system states that 25,000 gallons of groundwater per day entered the sump under thepressure treatment cylinders. This report also indicated that there was an expected accumulationof five tons of sludge per year in the sand filters. It has been reported that a few loads of sandfilter sludge were spread on the back road at the east end of the property. The American CreosoteWorks, Inc., ceased operations in December 1981. In May 1982, ACW filed for bankruptcy underChapter 11 of the U.S. Bankruptcy Code. Response actions at the ACW Site began immediatelyprior to the closing of the facility and continue to the present. The response actions taken includethe following.

A levee was constructed in 1973 to retain surface water run-off from the Site and to reduce thepotential for flood waters from the South Fork of the Forked Deer River from inundating the Site.The soil borrow pits used for the levee construction subsequently became sludge storage lagoons.Figure 2.0 shows the general Site facilities and historical lagoon locations.

— November 1981; Tennessee Department of Health and theEnvironment (TDHE, currently the TDEC) installed fourshallow groundwater monitoring wells around the propertyline.

LEGEND

pi COVERED LAGOON

•„""•• SOIL DARKENED AREA

\

American Creosote Works, Inc.CERCLA NPL Site

Jackson, Madison County, Tennessee______ Figure 2.0

IkApproximate Scale: 1"

0 350'350'

700'

cnv£>

CJi

\9 ERA

I ISand Filters

T-3

Shop

T-7© I

T-10

T-1

T-12 I I

Main ProcessBuilding

T-13

T-1 6Sump sndTreatment Cylinder!*

Not t

envo

CDCD

Gate

OWaterTank

Gate

Ci f\American Creosote Works, Inc.

CERCLA NPL SiteJackson, Madison County, Tennessee

Figure 2.1

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December 1981; National Pollution Discharge FJimiition System (NPDES) Permit #TN0001904 issued. ACWfacility ceased operation.

June 1982; TDHE sampled the Site. High concentrationsof PCP and creosote were present.

Mav 1983; Sampling at the ACW Site by USEPAEnvironmental Services Division (ESD) personnelindicated the sludge, surface soils, lagoon waters andshallow groundwater south and southwest of the lagoonswere contaminated with organic compounds associatedwith wood preserving using creosote and PCP. Lagoonsludge was consolidated and stabilized with lime andkiln dust in lagoons #1 and #3 (See Figure 2.O.), andcovered with a clay cap.

February 1985; Repair work to mitigate the effects ofleaking storage tanks was undertaken by the USEPA.

June 1985; The USEPA issued a Remedial Action Plan,which included site assessment, analytical data summaries,remedial action alternatives, and cost estimation.

January 1987; The USACE and the USEPA began field workfor the Remedial Investigation/Feasibility Study.

October 1988; The RI/FS Report was completed.

• January 5. 1989; The Record-of-Decision was signed.

• January-February 1989; USEPA sampled all the tanks andpits within the process area for a dewatering treatabilitystudy.

July 9. 1989; The USEPA began the field work for theRemedial Design and Remedial Action at the Site.

November 1989; The USEPA finished demolition, disposal,and regrading of most of plant facility; awaited timeslot for use of incinerator for contaminated soils andsludges. Construction of new drainage pipe and ditchat southwest corner of Site completed.

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— January 30. 1990; Remedial Action work started inJuly 1989 is completed.

— December 1990; At the request of the State, USEPA initiateddesign and installation of replacement drainage controlsystem which included a submersible pump and a re-contouringof the landfill cap.

— June 5. 1991; USEPA mobilized to the Site to begin stabilizationfieldwork.

— June - July 1991; USEPA oversaw the salvaging of scrap metalfrom the old process area.

— August 1991; Security fence around entire Site perimeter wascompleted by USEPA.

2.2 Enforcement Activities.

In December 1981, American Creosote Works Tennessee, Inc. (ACW), in Jackson, Madison County,Tennessee, received its National Pollution Discharge Elimination Systems (NPDES) Permit#TN0001904; however, shortly thereafter, the facility ceased operation. On May 21, 1982, ACWfiled for Chapter 11 bankruptcy.

In June 1983, USEPA used CERCLA emergency response funds to dewater the Site, remove andbury sludge, and cap certain areas with clay. On June 1, 1983, the Technical Assistance Team(TAT) took samples at the Site. On June 3,1983, the USEPA arranged for water from the Site tobe pumped to the South Fork of the Forked Deer River. USEPA consolidated the sludge into acontrol area (a former lagoon) and capped the area with day. All on-Site operations werecompleted by August 13, 1983. Costs for the above-described activities were approximately$750,000. In October 1984, the Site was placed on the National Priorities List (NPL). OnSeptember 19, 1985, USEPA began a Remedial Investigation and Feasibility Study (RI/FS) of theSite which cost approximately $800,000 to complete.

On July 25, 1983, USEPA filed a proof of claim for $3,500,000 in the Chapter 11 bankruptcyproceeding. Due to ACW's lack of adherence to the court's procedures, on April 20,1988, the U.S.Bankruptcy Court for the Northern District of Florida, Pensacola Division, dismissed ACW's case.Based upon accumulated evidence and the fact that the Tennessee Secretary of State revoked ACW'scharter of incorporation on April 9, 1985, ACW is a defunct organization and is not a viablepotentially responsible party (PRP) for cost recovery purposes. Therefore, the federal Superfundand state funds are paying for the Site investigations and remediations.

2.3 Role of Operable Unit One Within The Site Strategy.

USEPA's overall approach to the investigation and remediation of the Site relies on the division ofwork-to-be-done into three (3) general Operable Units or phases.

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2.3.1 Operable Unit One.

Operable Unit One activities consist of a Remedial Investigation/Feasibility Study, a Record ofDecision (ROD), and certain remedial activities. Operable Unit One is comprised of those remedialactivities which focused on the remediation of the facility process area and the levee/lagoons areas.Operable Unit One activities will end with the issuance of this ESD which documents on-Siteactivities and State concurrence with those activities, although monitoring of ground water andsurface water will continue for the next five years (1993 - 1998). A Five-Year Review will beaccomplished in 1994, five years after the initiation of the 1989 remedial action. Operable Unit Onedoes not address ground water or surface water problems. Ground water and surface water areaddressed by Operable Unit Two.

The Remedial Investigation, which was arranged for through an Interagency Agreement (IAG) withthe U.S. Army Corps of Engineers (USAGE) and was accomplished by a government contractorunder USAGE management, identified general areas of contamination, but was not of sufficientscope to thoroughly define the extent of the contamination in soil, groundwater or surface water.The Feasibility Study identified these three local media as the principal threats posed by the Site.Data gaps were significant enough that a final remedy for all of these media could not be selectedat that time. Therefore, these media will be addressed in Operable Units Two and Three afterfurther investigation. The potential for direct exposure to surface contamination resulting fromdegradation of the tanks and Site structures and the potential for the increased spread ofcontamination due to flooding was minimized while additional information was developed andanalyzed. The remedial action for Operable Unit One disposed of process liquids and sludges (anestimated 500,000 gallons of contaminated water, 25,000 gallons of oil, and 115,000 gallons ofsludge) which were in on-Site containers, demolished and disposed of the process buildings andstorage tanks, isolated the Site with perimeter fencing, and built flood control structures.Implementation of a phased approach will mitigate the risk of human or environmental exposurethrough the use of proven technologies in a manner consistent with a more encompassing,permanent remedy.

2.3.2 Operable Unit Two.

Operable Unit Two or Phase Two consists of the investigation and possible remediation of bothground water and surface water under, on, and proximal to the facility. A hydrogeologicalinvestigation of the Site is being conducted by means of an Interagency Agreement (IAG) betweenthe USEPA Region IV and the U.S. Department of the Interior, the Geological Survey, in Memphisand Nashville, Tennessee. This investigation is expected to be completed in September, 1993, andwill describe the existing Site-specific geology, hydrogeology, and surface water conditions. AnRI/FS will be based upon the results of the USGS investigation. The Operable Unit Two ROD willfollow.

2.3.3 Operable Unit Three.

Operable Unit Three is to address the following:

(a) Determination of the volume of contaminated soils and sludges to be treated;

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(b) Determination of the nature and extent of contamination of soils and sludges and the mostfeasible remediation technologies;

(c) Decontamination and removal/disposal/salvage, as necessary, of all tanks, equipment, scrapmetal, buildings, unuseable railroad ties and tracks, concrete foundations, wood treatingequipment, and scrap metal;

(d) Revegetation of those areas of the Site needing it; and

(e) Imposition of/arrangement for land-use, water-use, and deed restrictions, as necessary.

Operable Unit Three may be split into two or more phases depending upon the availability offederal and state funding as well as the regulatory acceptability of a new multi-phasic plan.

2.3.4 Site Stabilization Activities.

USEPA determined that the "Site Stabilization" activities described in the Operable Unit OneSuperfund-State Contract (SSC), dated May 1989, and in the Support Agency CooperativeAgreement (SACA), awarded April 29,1993, would include the following tasks which are necessaryto the general housekeeping of the Site, but were not all required by the ROD.

(a) Sump pump repair and maintenance (Installation of an electric sump pump was notanticipated by the ROD.);

(b) Management, administration, payment of electric bill;

(c) Repair and maintenance of 24-inch diameter discharge pipe, sluice gate, and sluice gateoperation platform (Installation of a large diameter drainage pipe was notanticipated by the ROD.);

(d) Maintain perimeter fence, gates, and warning signs;

(e) Maintain the levee and the perimeter road;

(f) Sample the lagoon water periodically and before discharge to the River; and

(g) Keep vegetation inside the perimeter fence under control by mowing and trimming; and byrepairing erosion damage and re-seeding the grass cover where necessary.

The above-described tasks are not considered Operation and Maintenance (O & M) in the strictsense of the concept. The Site Stabilization activities are set forth in a Site Stabilization Plan (SSP)which effectively covers all three (3) phases or operable units of the total Site remediation. The SSPis to be considered separate and distinct from any O & M plan that is associated with a specificoperable unit or phase of the Site remediation.

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2.4 Community Relations History.

Community relations activities at the American Creosote Works Site have been handled with directinvolvement from the USEPA and the TDHE (TDEC). The initial contact with the public took placein Jackson, Tennessee, in 1982. It was in the form of interviews with representatives of the Cityof Jackson with respect to the upcoming Superfund removal action of June 1983. Two publicmeetings were held for the Jackson community. The first meeting was held in December, 1986,prior to initiating RI/FS field activities. The second meeting was held on August 29, 1988, todisclose the results of the RI/FS to the Jackson community. The remedial alternatives from the FSwere discussed as well as USEPA's Proposed Plan to address Site contamination.

Public involvement and participation regarding the Site have been limited, although, initially,representatives of the City of Jackson asked USEPA Region IV for greater involvement in responseplanning and implementation. The water and sewer authority has registered concern regarding thepotential impact of the Site remediation on the Jackson wellfield located 1.5 miles northeast of theSite, and on the sewer interceptor line located near the southern edge of the Site. Also, there isdiscernible interest from the City and the local business community in facilitating the commercialdevelopment of the Site and the surrounding area.

3.0 DESCRIPTION OF THE OPERABLE UNIT ONE PRE-ROD REMEDIAL RESPONSES, THEPOST-ROD REMEDIAL RESPONSES, AND THE DIFFERENCE BETWEEN THE RODREQUIREMENTS AND THE ACTUAL ACCOMPLISHMENTS.

Several response actions took place before the RI/FS and the ROD were completed. These responseactions were necessary to mitigate releases from the wood preserving facility and were conductedby federal and state emergency response personnel. After the ROD was signed, several removalactions were undertaken to accomplish the ROD's selected remedy and to further stabilize the Site.

3.1 Response Actions Undertaken BEFORE the January 1989 Record-of-Decision.

In November, 1981, four shallow monitoring wells were installed around the Site property line bythe Tennessee Division of Solid Waste Management (TNDSWM). In December, 1981, NationalPollutant Discharge Elimination System (NPDES) permit number TN0001904 was issued allowingthe discharge of collected storm water from the Site. The TNDSWM conducted several Siteinvestigations during 1982-1983 and sampled a number of process storage tanks in June, 1982. InMay, 1983, a sampling investigation was conducted by USEPA Region IV Environmental ServicesDivision (ESD) personnel.

On May 23, 1983, USEPA was authorized to remove hazardous waste from the ACW Site underCERCLA. From June 04 to June 22, 1983, Hazardous Waste Technology Services (HAZTECH)and the U.S. Coast Guard Gulf Strike Team worked together to remove 30,000,000 gallons ofcontaminated run-off water from the lagoons at the back of the Site. Plans were approved for theon-Site containment materials found in the borrow pit lagoons by stabilization with lime kiln dustand partially covering lagoon #1 and totally covering lagoons #3 and #4 with a clay cap (See Figure2.O.). A pump and gravity drain system was installed in conjunction with the altered drainagepattern to remove any future run-off water. In February, 1985, the State of Tennessee contactedO.H. Materials to repair a leaking tank containing pentachlorophenol (PCP) contaminated water.These repairs were completed within the month. In June, 1985, O.H. Materials submitted a

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Remedial Action Plan for the ACW Site which included sections on site assessment, analytical data,remedial action alternatives, and cost estimation. In February, 1986, the State of Tennessee taskedIT Corporation of Knoxville, Tennessee, to prepare a report concerning site security, spill responseplanning, and secondary containment. This plan was prepared, but never implemented. InJanuary 1987 the USAGE, its contractor, and USEPA began fieldwork for the RI/FS. In October1988 the RI/FS was completed. In October, 1988, USEPA contracted with O.H. Materials, whosubcontracted to a local company, to construct a fence around the process area and around aportion of the perimeter of the Site. In January and February, 1989, USEPA tasked the Roy F.Weston, Inc., Technical Assistance Team (TAT) to sample all the tanks and pits within the processarea for a dewatering treatability study prior to initiation of the remedial action.

3.2 Response Activities Accomplished in 1989 and 1990 AFTER the January 1989Record-of-Decision.

3.2.1 Implementation of the ROD Remedy.

The ROD issued on January 5,1989, described the selected remedy as follows:

"This operable unit will initiate action at the site while additionalinformation is developed and evaluated. The selected remedy includes:

* deed restrictions limited further use of the site* construction of flood protection dike around the site and

site stabilization* removal and disposal of tanked liquids and sludges* removal and disposal of site structures* installation of security fencing around the site

This operable unit includes: treatment of the water containedin the tanks; incineration of the oils and sludges from thetanks; decontamination, demolition and disposal of the tanks;and consolidation and incineration of sludges (spilled or leaked)in the immediate vicinity of the buildings and tanks. Water fromthe tanks will be treated on-site utililizing a sand filter,filter press and carbon adsorption unit. Treated water will beanalyzed to document treatment efficiency and discharged to theSouth Fork Forked Deer River or Central Creek. The oil and sludgesfrom the site will be incinerated off-site at a fixed facilityor on-site in a mobile incinerator if an off-site facility isunable to dispose of the waste. The site structures (buildings,tanks, pipes) will be decontaminated and disposed off-site at aSubtitle D facility to be selected in consultation with theTennessee Department of Health and Environment. Uncontaminatedor decontaminated salvageable materials will be sold if possibleto a scrap dealer or recycler.

Phase n of this remediation is intended to remediate more areasof the site by constructing a fence around the site boundary to

15

5 9 0023

deter access to casual visitors and construct flood-protectiondiking. This option may be implemented concurrent with orsubsequent to Phase I. Removal of non-process area structuresand other incidental construction is not planned during eitherphase, but will be addressed as part of the final remedy. Sitestabilization pending a final remedy will include monitoringwater levels on-site behind the dikes and pumping, treatment(as needed) and discharge of impounded water.

Remediation of the surface soils is not planned during eitherphase since bench- or pilot-scale testing is needed to verifythat the technologies discussed in the FS report are applicableto site conditions."

The implementation of the Operable Unit One ROD Remedy was conducted by the USEPA RegionIV Emergency Response and Removal Branch, using the Emergency Response Cleanup Services(ERCS) contractor, O.H. Materials, Inc. After arrangements had been made for the off-Sitedisposal of the creosote-bearing sludges and oils, as well as the design of the on-Site treatmentmachinery to process the creosotic wastewaters, USEPA, ERCS, and Technical Assistance Team(TAT) mobilized at the Site in July, 1989. A description of the remediation accomplishmentsfollows.

3.2.1.1 Pumping of Sludges from Tanks.

225,000 gallons of creosote sludge left in fifteen (15) above-ground storage tanks remaining afterplant operations ceased in 1981 were dewatered and disposed of.

3.2.1.2 Filtration and Dewatering of Tank Sludges.

The purpose of dewatering the sludge was to produce a dry waste stream that was easily transportedby truck to a fixed incineration unit in Deer Park, Texas, for final treatment and disposal.Pressurized filtration was the process selected for dewatering the creosote sludge. The unit utilizedin performing the process was a mobile plate and frame filter press. Chemical conditioning aidswere used to pre-treat the creosote sludge before it entered the filter press. The net effect was thethickening or coagulation of the solid particles that aided in reforming the sludge so that it couldbe dewatered in the filter press. Following discharge, the sludge cake was stockpiled to awaittransportation and disposal.

3.2.1.3 Oil/Water Separation/De-emuIsification of Effluent from Dewatering of Tank Sludges.

Effluent from the filter press was sent to a 50,000 gallon pool to await further treatment. Once asufficient amount of oil had settled to the top of the pool, it was pumped off to a 7,000 gallon tankerthrough an in-line cartridge filter which removed any residual solids. Once in the tanker, the oilwas transported to an incinerator for final disposal. Accumulated water was pumped from thebottom of the 50,000 gallon pool to a 10,000 gallon box clarifier using a submersible pump.Effluent water from the clarifier was sent to a 10,000 gallon pool to await the next step in thetreatment process.

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5 9 0 0 2 4

3.2.1.4 Metals Precipitation from Effluent from Dewatering of Sludges.

At this point in the treatment system, the water was generally oil-free, but occasionally 10 to 20parts per million (ppm) ECA-4FC de-emulsifier was added to the 10,000 gallon pool to break anyresidual emulsions. The next step in the treatment process was the precipitation of the metals andother solids in solution. The 10,000 gallon pool served as an influent sump for the separator.

3.2.1.5 Filtration of Suspended Solids.

Filtration was performed in a two step process that resulted in a reduction of the total suspendedsolids (TSS) of the effluent water stream. Water was pumped from the filter press effluent pool toa multimedia sand filter housed in a pressurized vessel.

3.2.1.6 Adsorption Utilizing Activated Carbon Beds.

Adsorption is the physical adhesion of molecules or colloids to the surfaces of a solid, an adsorbent,without chemical reaction. In some respects, adsorption is similar to coagulation and flocculation.One distinction is that adsorption generally uses an adsorbent solid processed especially for watertreatment. In coagulation and flocculation, the adsorbent is produced in situ by reaction of achemical, such as alum with water. The adsorption media used in the ACW water treatment systemwas activated carbon. After carbon adsorption treatment, the water was held in a 12,000 gallonpool for sampling and analysis prior to discharge to Central Creek.

3.2.1.7 Discharge Limits and Effluent Water Analyses.

Consistent with the ROD, USEPA and TDHE determined that effluent wastewater could bedischarged into Central Creek, which borders the Site on the westernmost side. On May 9, 1989,the Tennessee Department of Water Pollution Control released their discharge criteria for dischargeinto Central Creek and the South Fork of the Forked Deer River. Central Creek is a zeroflow,ephemeral stream that convolutes with the South Fork of the Forked Deer River at the southwestcorner of the Site. Discharge criteria and statistics for the Creek and the River differ due to thevariable rates of flow in each. Discharge criteria for Central Creek and the South Fork of theForked Deer River are summarized in the Remedial Action Report, dated 1989, Attachment G,Water Discharge Report. Effluent water analyses are summarized in chronological order inAttachment H, Analytical Results, of the same report.

3.2.1.8 Transportation and Disposal of Waste Streams.

Remedial actions at the American Creosote Works Site resulted in the generation of a number ofdifferent waste streams. RCRA K001 wastes were generated by the dewatering of creosote sludge,the solidifying of bulk creosote sands, and the removal of creosote oils. Several drums of asbestosfrom piping insulation were shipped to a permitted landfill for disposal. The contents of a Sitelaboratory were lab-packed and sent for disposal. The filter cake, oils, and sand filters, allclassified as K001 wastes, were shipped in bulk containers to a fixed facility incineration unit inDeer Park, Texas. Creosote filter cake was shipped in containers sized to hold approximatelytwenty cubic yards of material. Bulk creosote sand material was also shipped in dump trailers thattypically held 40,000-45,000 pounds of material. Creosote oils were shipped in 7,000-gallon tankers.A complete summary of manifest information including weights, transportation charges, and

17

fc VVUHKbJACKSON, TENNESSEE

WATER TREATMENT SYSTEM25 AUGUST 1989

FLOATING OILTO TANKER TRUCKS

SANDFILTER

EFFLUENT

BAG FILTER(1004)

(w/Kl£WBORa}

00 LAMELLACLARIFIER

6 K

ACTIVATED CARBONBEDS

|JECA-4FC) 4(TO 10—20 ppm)

HYDRATED ALUM(TO 150 ppm)

50% CAUSTICpH B-B.5)

BOX CLARIRER10 K

SXIUUED OIL

SODIUM HYPOCHLORITE(FOR SULFITt OXTOATTON)

TREATEDWATER12 K

SULFURIC ACID(TO pH <-3)

DEEMULSIRER(AS NEEDED)

FILTERPRESS

Figure 3.0

NOT TO SCALE

SEPA

cn

vo

CDCDN3cn

5 9 0026

estimated disposal costs can be found in the Removal Action Report, dated 1989, Attachment J,Transportation and Disposal Table.

3.2.1.9 Building Demolition.

After Site start-up, building demolition became an integral part of the remedial action. Demolitionof the main process building facilitated access to two 100,000 gallon tanks and the pressuretreatment vessels. Most of the process equipment, boilers, pumps, compressors, etc. were salvagedand set aside for recycling. Demolition was accomplished utilizing a hydraulic shear mounted ona trackhoe, which allowed for cold cutting of metals, thus significantly reducing the chances of firehazards. Once the storage tanks were emptied of their contents, the shears were used to dismantlethem and set the scrap metal aside for decontamination at a later date. Decontaminated scrap metaland rubble from building demolition were stockpiled near the front gate of the Site in order tofacilitate pickup and disposal or recycling. The wooden buildings in the eastern part of the Sitehave yet to be demolished.

3.2.1.10 Levee Improvements.

USEPA contracted with the U.S. Army Corps of Engineers (USAGE) to design an upgradeddrainage system to improve the drainage of the cap area which is surrounded by a levee in thesouthwest corner of the Site. The cap overlies more than 10,000 cubic yards of stabilized creosotesludge. Since the ground water table was so high in this area, drainage control was necessary toprevent further migration of the contaminants from the Site or into the ground water as well as toslow the cap degradation. USEPA/USACE performed the installation as follows:

(a) Excavated the levee to allow placement of an effluent pipe, and excavated an additional 700linear feet of ditching to the River;

(b) Installed 72 feet of 24-inch diameter corrugated metal pipe constructed of polymer-coated,16-gauge, spiral, galvanized steel through the levee;

(c) Lined the contours of the drainage pipe ditch, which runs to the River, with geotextile fabricand rip-rap;

(d) Installed a spigot-back sluice gate to the end of the pipe located within the levee area; and(e) Constructed a walkway from the levee to the sluice gate with pressure-treated lumber.

3.2.2 Remedial Action in 1991.

3.2.2.1 Introduction.

Shortly after the work was completed in the summer of 1990, it became obvious that the drainagesystem, a part of the flood protection dike required by the ROD, installed during the remedialaction could not be made to operate properly. There were five basic problems with the drainagesystem.

a. On the landfill side of the levee the bottom of the 24-inch drainage line sat 2-4 feet above thecapped sludge lagoon. This meant that even when the sluice gate was open, two to four feet ofwater would stand on the landfill cap, thus forming a freshwater lagoon having a volume ofseveral million gallons.

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5 9 O C 2 7

b. The discharge side of the 24-inch pipe sat low enough in the floodplain of the River that, withany significant rainfall, it would be submerged. This problem was exacerbated by the fact thatthe slope of the drainage line was fairly slight. As a result, whenever the South Fork of theForked Deer River would overflow its banks, the water level on the discharge side of the pipewould be higher than the lagoon side. At times when drainage was needed most, the sluice gatecould not be opened, lest water flow from the River to the landfill. In fact, the gate could notbe opened until several days after a significant rain event occurred.

c. The landfill cap had apparently settled unevenly, resulting in three large depressions. Theseareas would form large puddles several feet deep and would not drain toward the 24-inch line.

d. The compacted clay material which was used to seal the outer annulus of the 24-inch line wasinsufficient to prevent leakage. This allowed a sizable flow of water along the outside of thepipe back onto the landfill whenever the water level on the discharge side was high.

e. The sluice gate had to be opened manually. This required personnel from the TennesseeDepartment of Environment and Conservation (TDEC), Division of Superfund, to makefrequent time-consuming visits to the Site. It was impractical for TDEC personnel to makean inspection of the water level after each local rainfall event. TDEC expresseddissatisfaction with the design, and requested that an automatic discharge system be installed.

Because of the problems with the drainage system, the USEPA Region IV Remedial Programrequested the Emergency Response and Removal Program (ERRB) to design and install areplacement drainage control system in December 1990. The design selected by theOn-Scene-Coordinator (OSC) was comprised of a submersible, five (5) horsepower pump, whichwould be installed in a drainage sump near the 24-inch drainage pipe. In addition, the landfill capwould be regraded to drain more efficiently toward the collection sump.

Two more items were planned for this remedial action. The first was to regrade and reseed the oldfacility process area, since a grass stand had not developed in that area. The second was to extendthe fence that already existed on the eastern side of the Site between the old pole storage area andthe lumber yard next door.

3.2.2.2 Remedial Action Summary.

On June 5, 1991, USEPA, TAT, and the ERCS contractor, O.H. Materials (OHM), mobilized atthe Site to begin the stabilization actions called for in the ROD. The first task undertaken was toremove the standing water from the landfill cap. This was done by pumping the water over thelevee into the South Fork of the Forked Deer River. The dewatering of the landfill area actuallyproved to be the most difficult and time-consuming aspect of the action for two reasons. First,extra pumps had to be mobilized to drain the existing water to the River. Second, there wereseveral high rainfall events during the initial days of the mobilization. Heavy rainfall extended theresponse period more than thirty (30) days beyond the original schedule for the entire response.

After the area inside the levee was finally dewatered, and dry enough to allow for equipmentoperations, the cap regrading and sump pump installation went smoothly. The pump was installedin the southeastern corner of the lagoon area. The pump was equipped with an automatic floatswitch, which was tested for proper functioning.

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5 9 0028

Scrap metal and debris were cleared from the old process area in order to regrade and reseed thatarea. Originally, the material was to be collected for hauling to an off-Site scrap dealer. Prior todoing this, the Agency contacted a businessman who had purchased certain salvageable equipmentand scrap metal from American Creosote Works, Inc. just prior to its filing for bankruptcy. WithUSEPA approval, the businessman had removed some scrap material, as well as some process tanksand a treatment cylinder from the Site, during earlier removal actions. After discussions withUSEPA Region IV's Office of the Regional Counsel, the businessman agreed to sign anindemnification agreement and to conduct the salvage work at his own expense, but only under theoversight of the USEPA representative. Approximately fifteen twenty-yard truckloads of scrapmetal were removed from the old process area. In addition, the businessman's crew removed threelarge process tanks intact. Clean fill cover material was brought into the process area and thesurface was regraded and seeded.

The last task planned for the 1991 remedial action was the extension of the fence on the easternborder of the Site. Keeping trespassers off of the Site during the removal action was difficult.Consequently, USEPA contractor installed a six foot (eight foot in some places) fence around theentire Site perimeter.

3.2.3 Remedial Action in 1992.

During November 1991, the TDEC Project Manager in Jackson, Tennessee, noted that the sumppump was not working properly and notified the USEPA RPM. Due to USEPA regulatory andbudget constraints, USEPA contractors were not mobilized until March, 1992. Ponded water waspumped from the landfill side of the levee to the River after sampling and analysis of the water hadbeen completed. The removal of the ponded water was necessary in order to remove the sumppump for repair. The pump was repaired and reinstalled.

3.3 Differences Between Remedy in Record-of-Decision and Actual Operable Unit OneRemedial Actions Completed AFTER January 1989.

A task by task comparison of what the ROD required and what was actually accomplished follows:

a) REQUIRED BY THE ROD: Deed restrictions limiting further use of the Site.

ACTUAL ACCOMPLISHMENT: Deed restrictions have not been arranged. The property iscompletely fenced off and warning signs are posted, which will provide notice to prospectivepurchasers who visit the Site.

b) REQUIRED BY THE ROD: Construction of a flood protection levee around the Site andconduct of Site stabilization tasks.

ACTUAL ACCOMPLISHMENT: The major portion of the levee was constructed prior to thesigning of the January 1989 ROD. However, the TDEC, by means of a cooperative agreement withthe USEPA, completed the levee and the levee road bed repairs in 1990 utilizing its own contractor.The 24-inch corrugated metal drainage pipe, with sluice gate and control platform, was installedduring the 1989 Remedial Action by USEPA's ERCS contractor, O.H. Materials, Inc., accordingto a U.S. Army Corps of Engineers design.

21

5 9 0 0 2 9However, Site stabilization activities are outlined in a "Site Stabilization Plan" (SSP), which was

alluded to in Section 15 of the Superfund State Contract (SSC) for the Operable Unit OneRemedial Action. The Site Stabilization Plan was designed to be implemented under the provisionsof a separate Support Agency Cooperative Agreement (SACA) which was awarded to the State ofTennessee on April 29, 1993. The SSP does not describe operable unit-specific operation andmaintenance (O & M) activities, but provides a plan for general Site housekeeping tasks which areto be conducted by the State through April, 1998.

c) REQUIRED BY THE ROD: Removal and disposal of tanked liquids and sludges.

ACTUAL ACCOMPLISHMENT: The tanked liquids and sludges from the old process area wereaccumulated, treated on-Site, and the contaminated constituents resulting from treatment takenoff-Site for incineration in the 1989 Remedial Action by USEPA.

d) REQUIRED BY THE ROD: Removal and disposal of Site structures.

ACTUAL ACCOMPLISHMENT: Most of the Site/facility structures have been dismantled ordemolished. The only structures left standing in the old process area are the partially demolishedreinforced concrete walls of the sand filter, the concrete vacuum pool and a small shed next to it.All sixteen empty and decontaminated metal tanks were either dismantled using a hydraulic shearand stockpiled on-Site for future salvage or left intact for recycling. There are several piles of scrapmetal and construction debris proximal to the old process area. Complete demolition of remainingstructures and disposal of the debris was not feasible in the first Operable Unit and USEPAdetermined that, due to the restricted Site access, immediate removal was not needed to ensureprotectiveness. Removal of the debris will be addressed in subsequent Operable Units, as necessary.East of the old process area the old facility office remains. It is a building which is overgrown withvegetation and is no longer useable. The two wooden buildings, which USEPA determined posedno environmental risk, in the northeast corner of the Site next to the adjacent lumber company, arestill standing, but in a state of disrepair. Razing these structures is not necessary to insureprotectiveness.

Virtually all railroad rails and ties have been salvaged. All other small buildings, pipes, andpads have been demolished and/or salvaged.

e) REQUIRED BY THE ROD: Installation of security fencing around the Site.

ACTUAL ACCOMPLISHMENT: Prior to 1989, an eight foot high, chain-link fence was installedacross the front of the facility. Keeping the trespassers off of the Site during the 1989, 1990, and1991 removals action was difficult. Consequently, a six foot high (in some places eight foot) chain-link, security fence was installed around the entire Site perimeter. Maintenance and repair of theperimeter security fence for the next five years is provided for in the Site Stabilization Plan.

4.0 SUPPORT AGENCY COMMENTS.

During the close-out walkthrough meeting on June 29,1993, and in their July 8,1993 commentaryon the draft ESD, the Tennessee Department of Environment and Conservation (TDEC) madecomments on the three aspects of the remedy which were not completed in accordance with theROD. Those comments, along with the USEPA's response to the comments, are summarized below.

22

5 9 0030

1. TDEC's Comment: The TDEC suggested that deed restrictions limiting further use of the Sitebe placed on the property.

USEPA's Response: USEPA cannot unilaterally place deed restrictions on the Site property.It has been determined that such restrictions are not currently necessary, as described above,but will be addressed, as necessary, in a later response action.

2. TDEC's Comment: TDEC recognized that the needed repair of the flood protection dike aroundthe Site will be addressed.

USEPA's Response: The flood protection levee was completed in 1990. Since 1990 the levee hasleaked around the discharge pipe, which was installed by USEPA's ERCS contractor during thepost-ROD remedial action. This leak, associated with problems with the submersible pumpinstalled in 1991, and the location of the discharge pipe being at a higher elevation than part ofthe old lagoon, allowed water to remain in the lagoon almost continuously since beingconstructed. The TDEC, under the recent Support Agency Cooperative Agreement (SACA) forSite Stabilization will review the need for levee and/or discharge pipe repair.

3. TDEC's Comment: The TDEC commented concerning the removal and disposal of Sitestructures.

USEPA's Response: Several of the old buildings remain at the Site, but demolition of non-process area buildings was not required by the ROD. Currently, the USEPA and the TDECsee no reason to demolish the remaining structures, because they are not in an area requiringremediation, they do not present a threat to the public health or environment, and theirrazing is not necessary to insure continued protection by the remedy.

The scrap metal from the demolished tanks, etc. is still piled at the Site and will be addressedin future Operable Units as discussed in Section 3.3 d) above.

Upon a thorough review of the ESD and with the registration of the comments above, the TDEChas concurred with this modification of the original Record-of-Decision remedy.

5.0 STATUTORY DETERMINATIONS.

Considering the new information that has been developed and the changes that have been made tothe selected remedy, the USEPA and the State of Tennessee's Department of Environment andConservation (TDEC) believe that the remedy as implemented remains protective of human healthand the environment, complies with federal and state requirements that were identified in the RODas applicable or relevant and appropriate to this remedial action at the time the original ROD wassigned, and is cost-effective. In addition, the revised remedy utilizes permanent solutions andalternative treatment (or resource recovery) technologies to the maximum extent practicable for theSite.

6.0 PUBLIC PARTICIPATION ACTIVITIES.

The Site community relations history is set forth in Section 2.4 herein. There has been very littleinvolvement by the community recently. The TDEC has a branch office within a mile of the Site

23

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and that office typically handles enquiries by members of the community.

The Administrative Record continues to be available for review and comment at the Site repositorylocation described in Section 1.4 herein.

USEPA is not required to hold a public meeting for an Explanation of Significant Differences (ESD),but may choose to do so if warranted by public interest.

24

5 9 0 0 3 2

Attachment 1.0

State's Letter of Concurrence

5 9 Q C 3 3

STATE OF TENNESSEEDEPARTMENT OF ENVIRONMENT AND CONSERVATION

• • • • . ,Division of Superfund

401 Church Street4th Floor Annex, L & C Building

Nashville, Tennessee 37243-1538

July 21, 1993

Mr. Tony DeAngelo, SRPMWaste Management DivisionU.S. EPA, Region IV345 Courtland Street, N.E.Atlanta. GA 30365

Re: 57-508 American Creosote Works Site, Jackson, TN, Close out Letter Response

Dear Mr. DeAngelo:

We are in receipt of your July 8, 1993 letter regarding the close out of Operable Unit #1 at the above site. In a'-tar of that date, Mr. Ron Sells outlined TDSF comments on the significant differences between the OU#1

}'s remedy and the remedial response work accomplished for OU# 1. Those differences along with our^ponses are:

1. Deed restrictions have not been imposed to limit on-site installation of potable wells, recreational or-commercial use of the property. The TDSF suggested in the letter that EPA Region IV complete this'requirement. "-'

2. Removal and disposal of site structures has not been completed. The TDSF suggested the scrap metalbe properly decontaminated (if necessary) and salvaged. Also, the existing buildings need not bedemolished because they are not in an area requiring remediation.

3. Construction of a flood protection dike around the site was completed, but still requires additionalv repair work. The SACA approved In 1993 for site stabilization will allow TDSF to conduct the

necessary repair to the dike.

Since the TDSF does not believe these differences are significant, and the remedial response workaccomplished is acceptable, the TDSF concurs with EPA Region IV that the Operable Unit # 1 at the site maybe closed out.

If you should have any questions regarding this matter, please contact me at (615)532-0900. Thank you foryour cooperation in this matter.

Sincerely,

ton W. Wilierjctor

icc: JFO, Ron Sells

Central Office Site File