CERCLA Case Studies
Aviation Materials - Memphis, Tennessee
The finding of soil and ground water contamination at this site near Memphis International Airport was attributed to the use of various solvent and cleaning solutions in the operation of an aircraft salvage and fuel cell repair facility over a twenty-year period. The site was listed under Administrative Order by the Tennessee Division of Superfund (TDSF) as the first State Superfund Site under its Voluntary Program. Contributing to the innovative clean-up remedies necessary for multi-media contamination was the application of stringent ground water quality criteria, the allowance for selected risk based determinations of threat and the placement of institutional controls that could be applied at the site. Biodegradation of solvent constituents in excavated materials was conducted on site. The designation of the site as a Superfund Site allowed for the excavated materials to be treated on-site, vacating RCRA permit regulations.
Each phase of the ground water component of the site investigation was critical in design and implementation in order to assure the public health concerns of TDSF in both deep and perched shallow aquifers. Design criteria focused on intercepting DNAPL plumes through use of chelation gateways and injection of biological agents augmented with flush and recovery systems. Ground water flow direction and velocity calculations were used in conjunction with sorbent analysis of vaporous emissions from the capillary fringe zones of the surficial aquifer to verify the contaminant plume delineation calculations. Strategically located deep monitoring wells and well nests were placed to measure the presence of the DNAPL component of the plume.
The project was given a conditional monitoring only status for a period of five years to determine the ability of natural attenuation at the site. This was necessary in part as a result of a determination that concentrations of DNAPL solvents, though exceeding maximum contaminant levels (MCLs), were lower than those estimated as sufficient enough to sustain a microbial population for continued degradation.
Magnetek, Inc. - Athens, Alabama
This site involved the contamination of ground water from the on-site disposal of cleaning solvents, most notably TCE, as part of routine work practices during periods prior to RCRA. Ground water concentrations of DNAPL were monitored for off-site migration and possible contribution by adjacent property owners. The Alabama Department of Environmental Management’s Land Bureau monitored the investigation and the design for the recovery, treatment and discharge of contaminated ground water. This project originated as a RCRA clean-up that was later determined, as a result of pre-RCRA activities, to be eligible for clean-up under CERCLA.
Firestone Tire Manufacturing- Memphis, Tennessee
As a result of vandalism at a closed tire manufacturing plant in Memphis, Tennessee, transformer oils containing high concentrations of PCBs were discharged to rooftop drains and flowed nearly ¾ of a mile through a storm sewer to a tributary of Leath Bayou. Under Section 104 of CERCLA, an emergency removal action was undertaken to investigate and remediate the observed contamination in accordance with the Toxic Substances Control Act (TSCA). An Administrative Order on Consent was entered with Region 4, USEPA, and an On-Scene Coordinator (OSC) was assigned to provide oversight to investigation and removal activities through a Technical Assistance Team (TAT) manager. CERCLA investigation and removal activities were conducted in accordance with TSCA policy relating to PCB and lead contamination in storm sewers and stream sediments associated with the drainage of the abandoned 85-acre industrial site. Removal activities under CERCLA were completed following approved remedial investigations to delineate the contamination and establish clean-up criteria in the sewer and the stream tributary to Leath Bayou. Disposal criteria were developed under TSCA, RCRA, and Asbestos regulations as a consequence of multimedia contamination at the site.
Metal Scrap Yard - Nitro, West Virginia
Contamination of soils from hydrocarbons, PCBs and heavy metals within an area of 11 acres within a 22-acre tract was attributed to the operation of a scrap metal facility. The facility operated over a period of more than 25 years on the banks of the Kanawha River in Nitro, West Virginia, approximately 20 miles downstream from Charleston, West Virginia. Soils at the abandoned scrap metal facility were observed to contain high concentrations of PCBs from transformer scrap operations, lead from battery salvage operations, and heavy metals, most notably mercury. The project was conducted in accordance with Section 106 of CERCLA and was under the oversight of USEPA Region 3. Preparation of a Response Action Plan as part of an Administrative Order was included in the Remedial Investigation/Feasibility Study for the project at a cost of $1.5 Million. The subsequent remediation was completed to the satisfaction of the Administrative Order by Consent at a cost of $2.4 Million. Under an innovative scenario, wastes were handled in a multitude of levels that included source separation to identify special waste categorization of a large portion of the materials, on-site treatment and disposal as special waste, and off-site transport, treatment, and disposal as hazardous waste. RCRA and TSCA handling and disposal considerations were pre-eminent in determination of logistics for removal.
Following the removal of 29,000 tons of waste from the site, an Army Corps of Engineers Docking and Unloading Permit was obtained for the delivery of over 21,300 cubic yards of backfill via river barge. The period of remedial activities lasted for nearly 100 days during 1996. Among other permits necessary to conduct the work, the following approvals were required: Hazardous Waste Generator Identification Number, National Discharge Elimination System General Permit for Discharge of Storm Water Associated with Industrial (Construction) Activity, West Virginia Corrective Action Order and Permit, Nitro Sanitary Board Discharge Permit, Spill Prevention Control and Countermeasures Plan and Permit for Fuel Storage, and an Erosion and Sediment Control Practices and Procedures Plan and Permit. All remedial activities were summarized in a Final Report of Removal Activities, dated October 11, 1996.
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