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BACKGROUND
The Southeastern Wood Preserving Site is an abandoned wood preservation plant facility which operated from 1928 until it filed for bankruptcy in early 1979. The Site covers approximately 20 acres and is located in a predominantly commercial/residential area just east of downtown Canton, Madison County, Mississippi. Batchelor Creek and Illionois Central Gulf Railroad border the Site to the north. The railroad is no longer operational. The City of Canton's drinking water well field lies just south of the Site. An abandoned industrial area lies to the east and a residential area borders the Site to the west.
The production process involved debarking of the Southern Yellow Pine timbers and placing them in retort cylinders for drying and pressure treatment using creosote and pentachlorophenol as preservatives. Prior to 1977 and the Clean Water Act, the facility reportedly discharged approximately 50,000 gallons of wastewater directly into Batchelor Creek. In May of 1977, the company was hooked into the City of Canton sewage system. The wastewaters were to be pre-treated prior to discharge into the City lagoons. On several occasions the City ordered the facility to cease discharge due to failure to adequately treat the wastewaters.
Batchelor Creek flows through a City park approximately 1 mile downstream from the Site, passes through a residential area and then continues through downtown Canton before leading into the Big Black River approximately 10-12 miles downstream. There is evidence of fishing and recreational usage in the Big Black River.
PREVIOUS ACTIONS
The Site has a long history of EPA involvement. The Emergency Response and Removal Branch (ERRB) of the EPA initiated an emergency response in early 1986 in order to stabilize three unlined surface impoundments that were overflowing on-site. Each impoundment contained creosote sludge and waters. The response action consisted of pumping 30,000 gallons of water from flooded areas of the Site, treating it, and discharging it into Bachelor Creek. Subsequent to this response, it was evident that the Site would be referred to ERRB for a removal action.
The initial Action Memo was signed in May 1986. It requested that site activities be addressed and funded in two phases. The scope of the first phase consisted of excavating and stockpiling hazardous waste on-site. The contaminated soils and sludges in the vicinity of the former lagoons were stabilized with lime kiln dust, placed in a stockpile and fenced. The second phase of the action was to consist of on-site treatment or off-site disposal of the material, but this action was delayed for several years.
In 1988 the Soil Conservation Service (SCS) contacted EPA after observing oily waste leaching into the Creek from the Southeastern Wood Preserving Site. SCS had designed a soil erosion prevention plan that called for excavating and widening Bachelor Creek. Through an Interagency Agreement, SCS contributed $190,000 towards the excavation work. The Creek was widened according to Plan and a geofabric liner was placed in the bed of the Creek. The bed and the banks were then covered with rip rap in order to prevent erosion.
An exemption from the twelve-month statutory limit and ceiling increase as approved in August of 1989 in order to address the second phase of the removal action. A composite sample from the waste pile indicated a PAH concentration of 5016 ppm and a phenol concentration of 62 ppm. The 8000 cubic yard on-site stockpile was to be treated through bioremediation landfarming techniques. A ceiling increase and $2 million exemption was approved in 1990 once proposals were received. The RCRA Land Ban treatment standards and air emission standards required a slurry phase treatment due to the health based risk associated with the Site's surrounding residential/commercial areas. The removal action required the treatment of the contaminated soil to the K001 waste code Land Disposal Requirements (LDR) standards. The contractor proposed to utilize a batch bioremediation process consisting of screening, mixing with water, slurrying in two parallel biological slurry reactors (BSRs), and final treatment and drying in a double lined land treatment unit (LTU).
In 1992 An Amendment to Removal Action Memoranda Requesting a Treatability Variance was approved. After several failed attempts to reach the K001 LDR Standards with the bioremediation technique, it became apparent that a treatability variance would be necessary. The clean-up levels for phenanthrene and pyrene were adjusted without compromising the goals of the Removal Action by maintaining concentration of total PAHs below 100 ppm.
On February 26, 2003, representatives from the EPA and the Mississippi Department of Environmental Quality (MDEQ) met at the Site for a reconnaissance. During the reconnaissance the non effective treated soil was observed. It was noted that the pile had sunken over the years and could possibly be leaking into Bachelor Creek.
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