HRS DOCUMENTATION RECORD COVER SHEET

Name of Facility: Red Panther Chemical Company

EPA ID No. MSD000272385

Contact Persons

U.S. Environmental Protection Agency (EPA), Region 4:

Ralph Howard, Remedial Project Manager

(404) 562-8829

Jennifer Wendel, NPL Coordinator

(404) 562-8799

Investigation: Preliminary Assessment 06/01/1984

Preliminary Assessment Reassessment 02/22/1990

Screening Site Inspection 01/31/1991

 Site Investigation Prioritization 01/30/1992

Site Investigation Report 09/22/2008

Preliminary Scoring Strategy 05/29/2009

Air Deposition Study 11/11/10

Documentation Record: Alexis McKinnon, Project Manager

Oneida Total Integrated Enterprises, Inc. (OTIE), START

(678) 355-5550

Pathways, Components, or Threats Not Scored

The Red Panther Chemical Company is being scored on the ground water migration 

and soil exposure pathways. The evaluation of the ground water migration and 

soil exposure pathways yields a score above the National Priorities List (NPL)

listing cutoff value of 28.50. Level I and Level II residential targets have been 

identified in a neighborhood adjacent to the Red Panther Chemical Company 

facility, and municipal drinking water wells are located within a 4-mile radius

of the sources. The surface water and air migration pathways were not scored and 

do not affect the listing decision. 
1

HRS DOCUMENTATION RECORD

Name of Facility: Red Panther Chemical Company

EPA Region: 4 Date Prepared: March 2011

Street Address of Facility*: 1201 Normandy Avenue

City, County, State, Zip: Clarksdale, Coahoma County, Mississippi, 38614

General Location in the State: Northwest

Topographic Map: Clarksdale, Mississippi

Latitude:* 34° 11' 14.67" North Longitude:* 90° 33' 41.85" West 

(Refs. 3, 49)

The geographic coordinates were calculated from the north corner of the office 

and labs building on the property (See Figure 2)(Ref. 49, pp. 1-2). 

*The street address, coordinates, and contaminant locations presented in this 

Hazard Ranking System (HRS) documentation record identify the general area in 

which the site is located. They represent one or more locations that the U.S. 

Environmental Protection Agency (EPA) considers to be part of the site based on 

the screening information EPA used to evaluate the site for National Priority 

List (NPL) listing. EPA lists national priorities among the known "releases or 

threatened releases" of hazardous substances; thus, the focus is on the release, 

not precisely delineated boundaries. A site is defined as where a hazardous 

substance has been "deposited, stored, placed, or otherwise come to be located." 

Generally, HRS scoring and the subsequent listing of a release merely represent 

the initial determination that a certain area may need to be addressed under the

Comprehensive Environmental Response, Compensation, and Recovery Act (CERCLA). 

Accordingly, EPA contemplates that the preliminary description of facility 

boundaries at the time of scoring will be refined as more information is 

developed as to where the contamination has come to be located. 

Scores

Air Pathway Not Scored

Ground water Pathway 53.89

Soil Exposure Pathway 57.60

Surface Water Pathway Not Scored

HRS SCORE 39.43
2

WORKSHEET FOR COMPUTING HRS SCORE

 S S2 

1. Ground water Migration Pathway Score (Sgw) 53.89 2904.1321 

2a. Surface Water Overland/Flood Migration 

Component

(from Table 4-1, line 30)

 NS NS 

2b. Ground water to Surface Water Migration 

Component

(from Table 4-25, line 28)

 NS NS 

2c. Surface Water Migration Pathway Score (Ssw)

Enter the larger of lines 2a and 2b as the 

pathway score.

 NS NS 

3. Soil Exposure Pathway Score (Ss)

(from Table 5-1, line 22)

 57.60 3,317.7600

4. Air Migration Pathway Score (Sa)

(from Table 6-1, line 12)

 NS NS 

5. Total of Sgw2 + Ssw2 + Ss

2 + Sa2 6,222.8921

6. HRS Score

Divide the value on line 5 by 4 and take 

the square root 39.43

NS - Not Scored

Reference 1, Table 3-1
3

GROUND WATER MIGRATION PATHWAY SCORESHEET

Factor Categories and Factors Maximum Value Value Assigned

Likelihood of Release to an Aquifer:

1.Observed Release 550 550 

2.Potential to Release:

2a. Containment 10 

2b. Net Precipitation 10 

2c. Depth to Aquifer 5 

2d. Travel Time 35 

2e. Potential to Release [lines 2a x 

(2b + 2c + 2d)]

500 

3.Likelihood of Release (higher of lines 

1 and 2e)

550 550

Waste Characteristics:

4.Toxicity/Mobility a 10,000

5.Hazardous Waste Quantity a 10

6.Waste Characteristics 100 18

Targets:

7.Nearest Well 50 20

8.Population:

8a. Level I Concentrations b 0

8b. Level II Concentrations b 0

8c. Potential Contamination b 424.1

8d. Population (lines 8a + 8b + 8c) b 424.1

9.Resources 5 0 

10.Wellhead Protection Area 20 5 

11.Targets (lines 7 + 8d + 9 + 10) b 449.1

GROUND WATER MIGRATION SCORE FOR AN AQUIFER

12.Aquifer Score

[(lines 3 x 6 x 11)/82,500]c 100 53.89

GROUND WATER MIGRATION PATHWAY SCORE

13.Pathway Score (Sgw), (highest value from 

line 12 for all aquifers evaluated)c 100 53.89

a

Maximum value applies to waste characteristics category.

b

Maximum value not applicable.

c

Do not round to nearest integer.
4

SOIL EXPOSURE PATHWAY SCORESHEET

Factor Categories and Factors Maximum Value Value Assigned

Resident Population Threat:

Likelihood of Exposure

1.Observed Contamination 550 550

Waste Characteristics:

2.Toxicity/Mobility a 10,000

3.Hazardous Waste Quantity a 10

4.Waste Characteristics 100 18

Targets:

5.Resident Individual 50 50

6.Resident Population:

6a. Level I Concentrations b 376.6

6b. Level II Concentrations b 48.42

6c. Resident Population 

 (lines 6a + 6b) 50 425.02

 7. Workers 15 5

 8. Resources 5 0

9. Terrestrial Sensitive Environments c 0

10. Targets

(lines 5 + 6c + 7 + 8 + 9) b 480.02

Resident Population Threat Score:

Resident Population Threat Score

(lines 1 x 4 x 10) 

b 4,752,198

a

Maximum value applies to waste characteristics category.

b

Maximum value not applicable.

c

Do not round to nearest integer.
5

SOIL EXPOSURE PATHWAY SCORESHEET (Continued)

Factor Categories and Factors Maximum Value Value Assigned

Nearby Population Threat

Likelihood of Exposure:

12. Attractiveness/Accessibility* 100 0

13. Area of Contamination 100 5

14. Likelihood of Exposure 500

Waste Characteristics:

15. Toxicity/Mobility a NS

16. Hazardous Waste Quantity a NS

17. Waste Characteristics 100 NS

Targets:

18. Nearby Individual 1 NS

19. Population within 1 mile b NS

20. Targets

 (lines 18 + 19) b NS

Nearby Population Threat Score:

21. Nearby Population Threat Score

 (lines 14 x 17 x 20) b NS

Soil Exposure Pathway Score:

22. Soil Exposure Pathway Score

(lines [11 + 21]/82,500) 

100 57.60

a

Maximum value applies to waste characteristics category.

b

Maximum value not applicable.

c

Do not round to nearest integer.

NS – Not Scored

*The Nearby Population Threat was not scored because the Attractiveness/ 

Accessibility factor value is zero. Therefore, the threat does not significantly 

change the Soil Exposure Pathway score (Ref. 1, Table 5-6).
/

ill £c

Q.

4,000 I

Feet

1,000 2,000 I

Clarksdale

Coahoma County,

Mississippi

RED PANTHER CHEMICAL

CLARKSDALE

COAHOMA COUNTY,

MISSISSIPPI

TOO No: TNA-oS-o03-o004

BASEMAP REFERENCE: USGS

CLARKSDALE, MISSISSIPPI NE/4

CLARKSDALE 15' QUADRANGELE,

N3407.5- W9030f7.5, 1967, AMS

2852 II NE- SERIES V843 A

.. unirea Sta~s Enlf1r~Ml&rnal Pl"GlectJCln AgenCy EPA

FIGURE1

FACILITY LOCATION MAP oI

/

,I

,I

,I

/ ,I

,I

,I

"

,I

"

34
FIGURE 2

PROPERTY LAYOUT MAP

300

I

Feet

75 150

I

RED PANTHER CHEMICAL

CLARKSDALE

COAHOMA COUNTY,

MISSISSIPPI

TOO No: TNA-oS-o03-o004

o

I

Legend

o Facility Boundary

o Adjacent Red Panther Property

,

"

a

I

"

i

I

§'" '- ...J
N 

t
 

a 200 400 I 

SCALE IN FEET 

LEGEND 

D LEGAL PROPERTY BOUNDARY 

ADJACENT RED PANTHER PROPERTY rzzzJ 

o RP-TW-ll1 

• SN-31-8S 

TEMPORARY MONITORING WELL LOCATION 

SOIL SAMPLE LOCATION 

REFERENCES: 

RESIDENTIAL SAMPLE LOCATIONS FROM: WESTON, F1N.'11. REMOYH. ASSaBilBfT 

LETTER RENOV.... REPORT: 18TH STREET NEIGHBORHCXlD, ~22,ZlOrl.

TW 

ss 

TEMPORARY WELL 

SOIL SAMPLE 

FIGURE 3 

SAMPLE LOCATION MAP 

BASEMAP FRON: WESTON. FINAL REMOVAL ACTION LETTER REPORT, REVISION 1: 

RED PANTHER CHEMICW" CONPANY, CECB&II: 21, ZlOli. 

GROUNOWATER LOCATlat8 FROM: TNIA, lUTE INVESTla.'..rlCtt REPCfn' Fa!: THE 

RED PANTHER CORPORATION, REVISION 1, SEPTB&II: 22, ZlOll. 

RED PANTHER CHEMICAL COMPANY 

CLARKSDALE, COAHOMA COUNTY, MISSISSIPPI 

EPA ID NO. MSD000272385 

FlLE NAME: FIGURE::5 - SA"lPLE LOCATION MAP - NOV :lOlO.DWG 
Legend

1,500

Feet

750

Air Deposrtion Stucly

Sample Locations

~L~OTIE • o..dIT'NlIfttIl~EntIfJM'iHt.

4ir._~••'!1

o

RED PANTHER

CHEMICAL COMPANY

CLARKSDALE,

COAHOMA COUNTY,

MISSISSIPPI

EPA ID No. MSD000272385

FIGURE4

Air Deposition Study

Sample Location Map

Source" R.fs 31:40: 49

o Red Panther Chemical Company

-- Legal Parcel Boundary

§'" '- --'w

'"f '-----------------''''

,------------------,8b

i

::;;
10

REFERENCES

Ref.

No. Description of the Reference

1. U.S. Environmental Protection Agency (EPA). Hazard Ranking System, 40 CFR 

Part 300, Appendix A, 55 FR 51533. December 14, 1990. Excerpt. 34 pages. 

[A complete copy can be obtained from the Regional Docket upon request.]

2. EPA. Superfund Chemical Data Matrix. January 2004. Excerpt. 54 pages. A 

complete copy of SCDM is available at 

http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm.

3. Oneida Total Integrated Enterprises (OTIE). Red Panther Chemical Company, 

Clarksdale, Coahoma County, Mississippi, Map including Municipal Well 

Locations and Target Distance Rings of Red Panther Chemical Company. EPA ID 

No. MSD000272385. January 29, 2010. 1 map.

4. Weston Solutions, Inc. (Weston). Final Removal Action Letter Report, 

Revision 1: Red Panther. Prepared for the U.S. Environmental Protection 

Agency (USEPA) Region 4. December 27, 2005. 160 pages.

5. Mississippi Bureau of Pollution Control (BPC). A Preliminary Assessment 

Reassessment (PAR) Report for Red Panther Chemical Company. February 22, 

1990. 10 pages.

6. URS Corporation (URS). Phase I Removal Action Report, Red panther Site, 

Clarksdale, MS. Prepared for Red Panther PRP Group. March 18, 2003. 311 

pages.

7. EPA Region 4. Administrative Order on Consent for Removal Action. In the 

Matter of Red Panther Pesticide Superfund Site. Signed July 2001. 48 

pages.

8. Oneida Total Integrated Enterprises-T N & Associates, Inc. (OTIE-TN&A). Email Correspondence between Stacy Kowalski, OTIE-TN&A and Tom Davis, 

Treasurer, Red Panther Chemical Company. Subject: Number of Workers at 

Coahoma Warehousing Facility (former Red Panther Chemical facility). 

January 27, 2010. 2 pages.

9. EPA Region 4. Action Memorandum. Subject: Request for an Enforcement 

Removal Action at the Red Panther Site, Clarksdale, Mississippi. Signed 

September 6, 2001. 12 pages.

10. EPA Envirofacts Warehouse. Envirofacts query results for “MSD000272385”. 

EPA Facility Information and Superfund CERCLIS query results. Internet

address: http://oaspub.epa.gov/enviro/multisys2.get_list?facility_uin=110

023128630. Accessed September 21, 2009. 4 pages.

11. Mississippi Office of Pollution Control (OPC). Screening Site Inspection 

Report: Red Panther Chemical Company. January 31, 1991. 47 pages.

12. Mississippi Department of Environmental Quality (MDEQ). Site Investigation 

Prioritization (SIP). January 30, 1992. 30 pages.

13. Tetra Tech EM, Inc. Superfund Technical Assessment and Response Team 

(START). Letter Report: Red Panther Chemical. Prepared for EPA Region 4. 

September 2, 1999. 53 pages.

14. EPA Region 4. Environmental News. Subject: EPA Announces the Availability 

of the Administrative Record for the Red Panther Chemical Site, Clarksdale, 

Mississippi. December 22, 2003. 1 page.

15. URS. Report, Phase I Soil Characterization Report: Red Panther Site. 

Prepared for Red Panther PRP Group. March 18, 2003. 390 pages.

16. URS. Phase II Final Design Sampling Draft Report: Red Panther Site. 

Prepared for Red Panther PRP Group. August 5, 2004. 224 pages.
11

REFERENCES (Continued)

17. NewFields and URS. Phase II Soil Removal Report: Red Panther Site 

Clarksdale, Mississippi. Prepared for EPA. October 14, 2005. 218 pages.

18. Weston Superfund Technical Assessment Response Team-2 (START-2). Final 

Removal Assessment Letter Report: 18th Street Neighborhood. Submitted to 

USEPA Region 4. December 22, 2005. 175 pages.

19. T N & Associates, Inc. (TN&A). Site Inspection Report: Red Panther 

Chemical Company, Revision 1. Prepared for EPA Region 4. September 22, 

2008. 325 pages.

20. USGS and Mississippi Research and Development Center. Water for Industrial 

and Agricultural Development in Coahoma, De Soto, Panola, Quitman, Tate, and 

Tunica Counties, Mississippi. 1976. Excerpt. 17 pages. 

21. USGS. Characterization of Aquifers Designated As Potential Drinking-Water 

Sources In Mississippi. Date unknown. Excerpt. 13 pages.

22. Alexis McKinnon, Project Manager, OTIE. Project Note to File. Subject: Red 

Panther Municipal Well Search Results. February 14, 2011. 5 pages.

23. USGS and Mississippi Research and Development Center. Sources for Water 

Supplies in Mississippi. 1980. 120 pages.

24. U.S. Census Bureau. American FactFinder. Fact Sheet for Coahoma County, 

Mississippi, 2005-2009 American Community Survey 5-year Estimates Data 

Profile Highlights. Access: http://factfinder.census.gov. Accessed on 

February 8, 2011. 2 pages.

25. Environmental Data Resources, Inc. (EDR). The EDR Radius MapTM Report with 

GeoCheck®. Prepared for the Red Panther Site, Inquiry Number 2561917.2s. 

August 14, 2009. 315 pages.

26. Eco-USA.net. Toxaphene. Accessed online at: http://www.ecousa.net/toxics/chemicals/toxaphene.shtml. October 4, 2009. 2 pages.

27. Eco-USA.net. Aldrin. Accessed online at: http://www.ecousa.net/toxics/chemicals/aldrin.shtml. October 4, 2009. 2 pages.

28. MDEQ, Robert Huckaby. Memorandum to Red Panther File. Subject: Review of 

Clarksdale Sanborn® Maps. August 7, 2009. 1 page. 

29. EDR. The EDR Aerial Photo Decade Package. Prepared for the Red Panther 

Site, Inquiry Number 2561917.5. August 14, 2009. 10 pages.

30. MDEQ, Robert Huckaby. Memorandum to Ralph Howard, EPA Region 4. Subject: 

September 15th & 16th, 2009 Trip Report – Red Panther Site – Clarksdale, MS. 

Included with the memo is an attachment of historic and current industry 

listings for Clarksdale, MS. 20 pages.

31. Technical Service Industries, Inc. (TSI). Coahoma County, Mississippi. 

Plat Map. 18th Street Neighborhood. 1 map.

32. Air and Water Pollution Control Commission, State of Mississippi. Report of 

Field Investigation. Subject: Riverside Chemical Company, Clarksdale, 

Coahoma County, Mississippi. May 6, 1975. 2 pages.

33. EPA. Office of Emergency and Remedial Response, Hazardous Site Evaluation 

Division (5204G). Quick Reference Fact Sheet. Using Qualified Data to 

Document an Observed Release and Observed Contamination. November 1996. 18

pages.
12

REFERENCES (Continued)

34. MDEQ. Mississippi Source Water Environmental Quality, Office of Pollution 

Control. Mississippi Source Water Assessment Program, Source Water 

Protection. Accessed online at: 

http://www.deq.state.ms.us/MDEQ.nsf/pdf/GPB_MSSourceWaterAssessmentProgram/$

FILE/msswapp.pdf?OpenElement. January 28, 2009. Excerpt. 12 pages. 

35. Stacy Kowalski, Project Manager, OTIE. Phone Record with Rusty Manuel, 

Operator of Records, Clarksdale Public Utilities. Subject: Clarksdale 

Municipal Wells. January 28, 2010. 1 page.

36. World of Molecules. DDT Pesticide Molecule. Accessed online at: 

http://www.worldofmolecules.com/pesticides/ddt.htm. January 28, 2010. 3 

pages.

37. Stacy Kowalski, Project Manager, OTIE. Project Note to File. Subject: 

Pesticide Information Profiles. January 28, 2010. 37 pages.

38. Author Unknown. 2,4-D fact sheet. Accessed online at: http://www.panuk.org/pestnews/Actives/24d.htm. January 28, 2010. 3 pages.

39. IPCS INCHEM. Chlordane JMPR 1974. World Health Organization Pesticide 

Residues Series 4. Accessed online at: 

http://www.inchem.org/documents/jmpr/jmpmono/v074pr09.htm. January 28, 

2010. 3 pages.

40. Greg Kowalski, OTIE. Letter with Attachment to Ralph Howard, EPA. Subject: 

Air Deposition Study Report, Revision 1, Red Panther Chemical Company. 

November 11, 2010. 298 pages.

41. OTIE. Quality Assurance Project Plan/Site Sampling Plan, Pesticide 

Contamination – Air Deposition Study, Red Panther Chemical Company, Revision 

1. June 25, 2010. 54 pages.

42. Douglas Fraley, OTIE. Email to Alexis McKinnon, OTIE. Subject: Property 

Lines for Red Panther. November 15, 2010. 1 page.

43. EPA. USEPA Contract Laboratory Program Statement of Work for Inorganic 

Analysis, Multi-Media, Multi-Concentration, ILM05.3. March 2004. 93 pages.

44. EPA. Office of Solid Waste and Emergency Response. Multi-Media, MultiConcentration for Organic Analytical Service for Superfund (SOM01.2). EPA 

Publication 540-FS-07-001. August 2007. 6 pages.

45. Shanna Davis, Tetra Tech EM Inc. Record of Telephone Conversation with 

Charlie Appleby, Quality Assurance Section, Science and Ecosystem Support 

Division, Management and Technical Services Branch, EPA Region 4. Subject: 

Definitions Of Minimum Reporting Limit, Minimum Quantitation Limit, Contract 

Required Quantitation Limit, And Sample Quantitation Limit. July 9, 2008. 1 

page.

46. Stacy Kowalski, OTIE. Email with Attachment to Alexis McKinnon, OTIE. 

Subject: FW: Air Permits. November 10, 2010. 46 pages.

47. United States Department of Agriculture, Natural Resources Conservation 

Services (NRCS), National Water and Climate Center. Wind Rose Data. 

Accessed online via: 

http://www.wcc.nrcs.usda.gov/ftpref/downloads/climate/windrose/ 

tennesee/memphis/memphis_dec.gif. 15 pages.

48. Greg Kowalski, OTIE. Email with attachment to Alexis McKinnon, OTIE. 

Subject: 1938 Aerial Photo of 18th Street Neighborhood. November 11, 2010. 

2 pages.
13

REFERENCES (Continued)

49. Alexis McKinnon, Project Manager, OTIE. Project Note with Attachment. 

Subject: Source of Base Images and Latitude/Longitude. February 8, 2011. 2 

pages.

50. Robert Huckaby and Tommie Whitten, MDEQ. Email with Attachments. Subject: 

Coahoma County Well Logs. February 9, 2011. 5 pages.
14

General Facility Description and History

The Red Panther Chemical Company (Red Panther) is located at 1201 Normandy Avenue

in Clarksdale, Coahoma County, Mississippi (see Figure 1 of this Documentation 

Record) (Refs. 3; 8, p. 1). The geographic coordinates of the property on which 

Red Panther operated are 34° 11' 14.67" North latitude and 90° 33' 41.85" West 

longitude as calculated from the north corner of the office and labs building on 

the property (Refs. 3; 49, pp. 1-2) (See Figure 2). The facility is bordered to 

the north by commercial property (Graeber Brothers), to the south by commercial 

property (Master Mix Concrete, Inc.), to the east by Normandy Avenue, and to the 

west by East Tallahatchie Street (Ref. 4, p. 4). For the purposes of this HRS 

documentation package, the Red Panther site consists of contaminated soil on the 

Red Panther Chemical Company property, contaminated ground water associated with 

releases from the contaminated soil source, and contaminated soil in the

residential area surrounding the Red Panther facility.

The Red Panther property is comprised of approximately 6.5 acres (Refs. 5, p. 4; 

6, p. 8; 7, p. 2). Former operation features included a septic tank and 

drainfield located on the north side of the property, and three hazardous waste 

above-ground storage tanks (ASTs) with a total capacity of 33,000 gallons located 

on the south side of the property (Ref. 5, p. 4). A small wastewater settling 

basin was located on the east central side of the property (Ref. 5, p. 4). 

Several structures remain on the property and are still used by Coahoma, Inc. as a 

warehouse storing feed and farm supplies (Refs. 6, p. 8; 7, p. 2; 8, p. 1). See 

Figure 2 of this Documentation Record for the property layout map.

Red Panther operated as a pesticide formulation plant between 1949 and 1996

formulating liquid and dry herbicide, insecticide, and fungicide products (Refs. 

4, p. 4; 5, p. 3; 6, p. 8; 7, p. 2). Chemicals used in the formulation process 

included toxaphene; aldrin; arsenic; 1,1,1-trichloro-2,2-bis(p-chlorophenyl)ethane 

(4,4’-DDT); methyl parathion; chloropyrifos; 2,4-dichlorophenoxy acetic acid (2,4-

D); malathion; carbaryl; diazinon; methoxychlor; disodium methanearsonate (DSMA);

monosodium acid methanearsonate (MSMA); chlorothalonil; and parathion (Refs. 6, p. 

8; 7, p. 3; 9, p. 2). Four stacks were part of the manufacturing process, with 

heights between 20 and 30 feet (Ref. 46, p. 29). According to air permit records, 

arsenic; 2,4-D; methanol; xylene; and ethylene glycol were emitted at the facility 

from the four stacks (Ref. 46, pp. 28-31, 42). Wastewater and solvents containing 

pesticide and solvent residues were generated from equipment cleaning (Refs. 5, p. 

3; 6, p. 8). Prior to obtaining interim status, wastewater containing pesticide 

and solvent residues were generated during equipment cleaning at the facility and 

discharged either directly to a drainage ditch or into an underground septic tank 

and drain field on the facility property (Refs. 5, p. 5; 6, pp. 8-9). 

Contamination on the property is believed to have originated from numerous spills 

during loading and unloading operations, contaminated wastewater releases, from 

spills and leaking underground piping in the tank farm area, as well as 

particulate releases to surrounding areas (Refs. 9, pp. 2, 3). 

Previous owners of the facility include Coahoma Chemical Company, Riverside 

Chemical Company, and MFC Services (Refs. 6, p. 8; 7, p. 2). The property is 

currently used by Coahoma, Inc. as a storage facility for feed and farm supplies

(Refs. 6, p. 8; 7, p. 2; 8, p. 1).

A query for MSD000272385 in the EPA Envirofacts database listed a site discovery 

date of November 1, 1979 (Ref. 10, p. 4). In 1980, Red Panther filed for a 

Resource Conservation and Recovery Act (RCRA) hazardous waste management activity 

notification and Part A application for the storage of wastewater and used 

solvents (Refs. 4, p. 5; 5, p. 3; 6, p. 8). In November 1984, the Mississippi 

Bureau of Pollution Control (MBPC) granted the facility a RCRA Part B permit to 

store wastewater and spent solvents at the facility (Ref. 5, p. 4). 
15

A Preliminary Assessment (PA) was conducted in June 1984 (Ref. 10, p. 4). In 

August 1984, the MBPC conducted a sampling inspection at the facility (Ref. 5, p. 

5). Environmental samples were collected around the property to determine and 

characterize any hazardous substances present. Two composite soil samples were 

collected from the adjacent ditch along Normandy Street and Patton Street (Ref. 5, 

p. 5). One water sample was collected from where wastewater leaves the property 

and discharges into the ditch (Ref. 5, p. 5). One subsurface composite soil 

sample was collected around the septic tank and drainage field (Ref. 5, p. 5). 

All samples were analyzed for pesticides and total arsenic (Ref. 5, p. 5). 

Results indicated elevated levels of several pesticides and arsenic in the soil 

and sediment samples (Ref. 5, p. 5). 

In November 1985, a fire erupted at one of the Red Panther warehouses (Refs. 5, p. 

5; 11, p. 5). Contaminated runoff resulting from the fire-fighting efforts caused 

a fish kill in the nearby Sunflower River (Ref. 11, p. 5). The contaminant was 

determined to be Lorox, a slightly toxic herbicide (Ref. 11, p. 5). A large 

volume of contaminated water was contained on the property and later shipped to a 

commercial hazardous waste disposal facility (Ref. 11, p. 5). During cleanup of 

the fire, approximately 382 old fiber drums were discovered in the crawlspace 

below the warehouse (Ref. 11, p. 5). Of those drums, 287 were empty and were 

crushed and sent to the local municipal landfill (Ref. 11, p. 5). Ninety-five 

drums contained trace residues of technical grade dieldrin and were disposed of at 

a commercial hazardous waste facility. A new warehouse was built over this area 

in 1986 (Ref. 11, p. 5).

In November 1986, the Red Panther RCRA storage permit was terminated because Red 

Panther lost its liability insurance coverage that is required for long-term 

storage of hazardous wastes (Ref. 11, p. 5). At that time, Red Panther reverted 

to the status of a hazardous waste generator with short-term (less than 90 days) 

storage only (Ref. 11, p. 5). 

On February 22, 1990, MBPC submitted the Preliminary Assessment Reassessment (PAR) 

report to EPA Region 4 (Ref. 5, pp. 1-8). The PAR report summarized the 

investigations and findings at the facility and recommended a Site Screening 

Investigation (SSI) on a medium priority basis (Ref. 5, pp. 1-8).

On January 31, 1991, the Mississippi Department of Environmental Quality (MDEQ) 

Office of Pollution Control (OPC) submitted the SSI report (Ref. 11, p. 1). The 

sampling investigation was conducted at the facility on November 12 and 13, 1990 

(Ref. 11, pp. 3, 21-47). A total of nine samples were collected during the SSI 

including one surface soil, three sediment samples, two subsurface soil samples, 

and three ground water samples (Ref. 11, pp. 10-11, 16). From the nine samples, 

one surface (RPC-SDS-03) and one subsurface soil (RPC-SBS-04) sample were 

collected from the commercial property north of the Red Panther property and were 

designated as background samples (Ref. 11, pp. 10-11, 16). Samples were analyzed 

for all compounds listed in the EPA Target Compound List (TCL) (Ref. 11, pp. 10, 

16). According to the 1991 SSI, sediment samples contained high levels of 

pesticides, metals, volatile organic compounds (VOCs), and semi-volatile organic 

compounds (SVOCs) (Ref. 11, pp. 10-12, 17-20). Ground water samples contained 

only detections of metals (Ref. 11, pp. 11-12). Based on these results, MDEQ OPC 

recommended further investigation on a medium-priority basis (Ref. 11, p. 12).

On January 30, 1992, MDEQ submitted a Site Investigation Prioritization (SIP) to 

EPA Region 4 (Ref. 12, p. 1). The SIP recommended that no further remedial action 

be planned (NFRAP) for Red Panther, due to the low score generated using data from 

the 1991 SSI report (Ref. 12, p. 1). The site score, which was calculated based on 

the sample results available during the SIP evaluation, was not sufficient to 

place the site on the NPL (Ref. 12, p. 3). The site was archived on January 31, 

1992 (Ref. 10, p. 4).
16

In 1999, EPA tasked Tetra Tech EM, Inc., under the Superfund Technical Assessment 

and Response Team (START)contract, to conduct surface and subsurface soil sampling 

of the drainage ditches to the east of the property, the former facility leaching 

field and septic tank on the north side of the property, and the rail spur in 

front of the loading dock that runs along the west side of the property (Ref. 13, 

pp. 4, 5, 13-26). Samples were analyzed for RCRA metals and pesticides (Ref. 13, 

p. 10). The results from the sampling event indicated that the facility was 

contaminated with arsenic, organochlorinated pesticides, and the degradation byproducts including, but not limited to, aldrin; chlordane; dieldrin; 4,4’-DDT;

endrin; endosulfan II; and toxaphene (Ref. 13, pp. 10, 27-41). The analytical 

results also revealed a wide concentration range for lead; however, lead 

concentrations were below 400 mg/kg (Ref. 13, pp. 10, 27-41). 

On September 4, 2001, an Administrative Order on Consent for the Red Panther 

property between the Potentially Responsible Parties (PRP) and EPA Region 4 was 

finalized (Ref. 7, pp. 25-48). The Administrative Order on Consent identified 

four constituents of concern (COCs) for surface soil criteria and three COCs for 

subsurface soil criteria (Ref. 7, pp. 6-7, 21-24). The surface COCs were 

identified as arsenic, toxaphene, dieldrin, and total chlorinated pesticides (Ref. 

7, p. 6). The subsurface COCs were identified as arsenic, toxaphene, and dieldrin 

(Ref. 7, p. 7). The Administrative Order on Consent required the PRPs to perform 

two phases of removal activities and disposal of excavated materials under all 

requirements of the Administrative Order on Consent (Ref. 7, pp. 5-9). EPA 

subsequently submitted the Action Memorandum documenting approval of the proposed 

removal action (Ref. 9).

The PRP commenced the removal action on November 11, 2002 and had completed the 

activities by July 29, 2005 (Ref. 10, p. 3). The PRP retained NewFields and URS 

Corporation (URS) to perform the work required to fulfill the requirements of the

Administrative Order on Consent (Ref. 6, p. 9). The Administrative Order on 

Consent required the work to be performed in two phases. Phase I consisted of the 

following components:

• Excavation of surface soils from drainage ditches between the Red Panther 

property boundaries and Route 49, and the disposal or temporary stockpiling 

of the excavated material, 

• Characterization of facility soils and the remaining ditch soils,

• Design of Phase II removal activities, and

• Preparation of a Phase II Work Plan detailing additional removal tasks 

necessary to complete the requirements of the Administrative Order on 

Consent (Ref. 6, p. 6).

On March 18, 2003, URS submitted the Phase I Removal Action Report and the Phase I 

Soil Characterization Report (Refs. 6, p. 1; 15, p. 1). Based on the results, URS 

recommended addressing the soils exceeding performance standards and addressing 

disposal options for the stockpiled soils in Ditch 1 in the Phase II Work Plan 

(Ref. 6, p. 17). The report was approved by EPA on April 10, 2003 (Ref. 16, p. 

8). 

Administrative records were compiled on November 6, 2003 (Ref. 10, p. 3). On 

December 22, 2003, EPA announced the availability of the Red Panther 

Administrative Record for public review (Ref. 14, p. 1). The Administrative 

Record includes documents that form the basis for selection of the removal action 

(Ref. 14, p. 1). 

Phase II of the removal action consisted of on-site soil removal activities (Ref. 

16, p. 8). On October 14, 2005, URS and NewFields submitted the Phase II Soil 

Removal Report for Red Panther (Ref. 17, p. 1). The PRP Group requested a “No 

Further Action” and termination of the order based on the successful completion of 

the Administrative Order on Consent requirements (Ref. 17, p. 8). The 

Administrative Order on Consent requirements were completed by implementing the 
17

Phase I ditch characterization and removal in 2002, the Phase I characterization 

of the facility soils in 2002 and 2003, and the Phase II soil removal in 2005 

(Ref. 17, p. 8).

All PRP removal activities were overseen and documented by Weston Solutions, Inc. 

(Weston) under EPA’s START-2 contract at the request of EPA (Ref. 4, p. 4). After 

completion of the removal activities, EPA tasked Weston to conduct an 

environmental assessment of the nearby 18th Street Neighborhood located just west 

of Red Panther (Ref. 18, p. 4). On December 22, 2005, Weston submitted a Final 

Removal Assessment Letter Report for the 18th Street Neighborhood site (Ref. 18, p. 

1). 

On August 9, 2005, Weston began collecting samples for EPA at the 18th Street 

Neighborhood for the Removal Assessment (Ref. 18, p. 7). The 18th Street 

Neighborhood is a residential area located to the west of Red Panther (Refs. 3; 

18, pp. 4, 13; 31). The neighborhood consists of single family dwellings on

approximately 0.25 acre lots (Ref. 31). The areas sampled included properties on 

13th, 14th, 15th, 16th, 17th, 18th, 19th, and West Tallahatchie Streets (Ref. 18, p. 

7). 

During the Removal Assessment, a total of 31 composite samples including a 

background (SN-01-SS) were collected from the residential yards in the 18th Street 

Neighborhood (Ref. 18, pp. 7, 24-47). The background sample was collected from the 

B.F. McLaurin Park as a reference to determine what direct impact Red Panther 

operations might have had on the soils in the neighborhood (Ref. 18, pp. 7, 40-41, 

49). During the investigation, four active municipal ground water supply wells 

were also sampled (Ref. 18, p. 8). Of these four wells, two were shallow wells 

(approximately 600 feet deep) and two were deep wells (approximately 1,000 feet 

deep) (Ref. 18, p. 8). All samples collected during the investigation were 

analyzed for pesticides, aluminum, arsenic, iron, and other metals (Ref. 18, pp. 

16-22, 78-171). Of the 30 residences sampled, 24 soil samples were elevated above 

background concentrations for pesticides (Ref. 18, pp. 16-22). No pesticides were 

detected in the municipal ground water samples. No metals were detected at

elevated concentrations in any samples (Ref. 18, pp. 78-171). 

Red Panther Chemical was removed from the EPA archive list on November 7, 2005 

(Ref. 10, p. 3).

In October 2007, T N & Associates (TN&A) under the START contract conducted a Site 

Investigation (SI) to fill data gaps related to the Ground water Migration Pathway 

(Ref. 19, pp. 15-16, 288-304). Fourteen ground water samples were collected; nine 

temporary monitoring well samples, one permanent monitoring well sample, and four 

municipal well samples (Ref. 19, pp. 16, 288-304). The temporary monitoring wells 

were installed to depths ranging from 25.12 feet to 47.8 feet (Ref. 19, pp. 16, 

288-304). The temporary monitoring wells were compared to sample RP-TW-02, and 

elevated concentrations of contaminants were detected in all wells except well RPTW-01 (Ref. 19, pp. 162-286). Constituents detected at elevated levels in the 

temporary monitoring wells included pesticides and metals (Ref. 19, pp. 36-37). 

One existing on-site permanent monitoring well (RP-TW-02) was sampled and 

indicated the presence of pesticides and metals; however, no background well was 

available for comparison (Ref. 19, pp. 173-174, 202). Four municipal wells 

located within a 4-mile radius of the property were also sampled (Ref. 19, p. 17). 

Two wells completed in the Sparta aquifer (shallow aquifer) indicated the presence 

of several metals including barium, copper, iron, lead, manganese, and zinc at 

HRS-elevated concentrations; however, no site-attributable constituents were 

detected (Ref. 19, pp. 35, 86-93, 116, 121, 123, 125, 127, 129, 131, 133, 135, 

160). The deeper municipal wells, completed in the Meridian Upper-Wilcox aquifer, 

indicated no elevated levels of analytes (Refs. 19, pp. 35, 44-80; 22, pp. 3-4).
18

During the week of June 28, 2010, Oneida Total Integrated Enterprises 

(OTIE)(formerly TN&A) conducted an Air Deposition Study (ADS) on behalf of EPA in 

the areas surrounding the former Red Panther facility (Refs. 40, pp. 5, 14; 41, 

pp. 1, 6). The purpose of the ADS was to evaluate the presence of pesticides in 

the surface soils surrounding the former Red Panther facility and to identify 

background soil samples outside the area of influence for the Red Panther facility 

(Refs. 40, p. 5; 41, pp. 24-25). Field investigation activities included the 

collection of surface soil samples in every direction from the facility to 

determine if contaminant concentrations previously identified in the residential 

neighborhood to the west of the facility (18th Street Neighborhood) were a result 

of the pesticide formulation activities at the facility or if the presence of the 

nearby agricultural fields contributed to the pesticide contamination (Ref. 40, p. 

5). A total of 76 composite surface soil samples were collected in a 0.25-mile 

area surrounding the facility (Refs. 40, pp. 14-17; 41, pp. 31-32). Three 

background composite samples were collected northwest and north/northeast of the 

facility from areas 0.7- to 1.1-mile distant from the facility to ensure an 

adequate background for comparison purposes (Refs. 40, pp. 14-17, 25; 41, pp. 31-

32). Although other pesticide constituents were detected in the background 

samples, toxaphene was not detected in any of the three background samples (Ref. 

40, p. 18-20). Concentrations of DDT, 4,4’-dichlorodiphenyldichloroethane (DDD), 

and 4,4’-dichlorodiphenyldichloroethylene (DDE) increased in areas closer to the 

facility (Ref. 40, p. 18-20, 28, 29, 31, 35-48). Toxaphene was identified in 

eight samples collected near the facility, with concentrations increasing closer

to the facility (Ref. 40, p. 20, 30, 35-48). Modeling of the toxaphene contaminant 

concentrations suggests the facility is the source of toxaphene, not general 

agricultural use in the area (Ref. 40, p. 20). Dieldrin was identified in half of 

the samples collected, generally in higher concentrations near the facility 

declining to non-detect concentrations in the outlying samples (Ref. 40, p. 20). 

The highest dieldrin concentration (3,800 micrograms per kilogram [ug/kg]) was 

identified in the sample collected closest to the facility (Ref. 40, p. 20). 

According to the ADS, the absence of dieldrin in samples adjacent to agricultural 

fields and the presence of higher concentrations near the facility indicate that 

Red Panther is the source of dieldrin contamination in the area (Ref. 40, pp. 19-

20). In general, the ADS concluded that the higher contaminant concentrations 

located near the facility suggested contamination is the result of historic Red 

Panther facility activities, not the result of pesticide application in nearby 

agricultural fields (Ref. 40, pp. 20-21). 
19

2.2 SOURCE CHARACTERIZATION

Number of the source: 1

Name and description of the source: Contaminated soil at the Red Panther 

facility

HRS Source Type: Contaminated soil

Contaminated soil is located throughout the Red Panther property at a depth of 2 

feet and greater below ground surface (bgs) (Ref. 17, pp. 22-25, 184-189).

The Phase I and Phase II removal actions were conducted during 2004 and 2005 by 

URS and Newfields for Red Panther in order to fulfill the requirements of the 

September 2001 Administrative Order on Consent (Ref. 17, p. 6). Based on 

confirmation samples collected from Area B (AST storage area), Area C (loading 

dock and Railroad spur), and Area D (silo area), hazardous substances including 

arsenic, toxaphene, and dieldrin are still present in the surface (2 feet) and 

subsurface soils at the property (Ref. 17, pp. 14, 22-25, 184-189).

Source contaminants sampled during the confirmation phase of the Phase II removal 

include arsenic, dieldrin, and toxaphene (Ref. 17, pp. 22-25, 184-189). Samples 

were analyzed using EPA Method 6010 for inorganic analysis, and EPA Method 8081A 

for the analysis of pesticides (Ref. 16, pp. 12-13, 31). 

Sampling at the property prior to the implementation of the Administrative Order 

on Consent indicated the presence of elevated levels of constituents in addition 

to those listed above, including: endrin; 4,4’-DDT; 4,4’-DDE; 4,4’-DDD; 

heptachlor; chlordane; gamma-BHC (lindane); and endosulfan II (Refs. 11, pp. 16-

20; 13, pp. 10, 27-41). These contaminants are documented to exist in association 

with historical operations or are degradation products of those substances 

produced, and are in samples collected from the property (Refs. 4, p. 4; 5, p. 3; 

6, p. 8; 7, pp. 2-3; 9, p. 2; 11, pp. 10-12, 16-20; 13, pp. 5, 9-10, 27-41; 15, p. 

8, 18-32, 99-390; 36, pp. 1-2). 

Location of the source, with reference to a map of the facility:

Contaminated soil is located throughout the Red Panther property at a depth of 2 

feet and greater below ground surface (bgs) (Ref. 17, pp. 22-25, 184-189). Maps 

of the sample locations can be found in Reference 17 on pages 184-189.

Containment:

Release to ground water: No liner beneath the contaminated soil at the property 

was documented during the Phase I Soil Characterization investigation or the Phase 

II Soil Removal (Refs. 15, pp. 11-17, 51-97; 17, pp. 11, 15, 19-26). Pesticidecontaminated ground water has been identified in ground water monitoring wells 

installed in the Mississippi River Valley Alluvial aquifer at the property (Refs. 

19, pp. 194-213, 288-304; 21, p. 3).

Based on Table 3-2 of Reference 1, the contaminated soil is assigned a containment 

value of 10.

Ground water Containment Value: 10

Reference: 1, Section 3.1.2.1, Table 3-2
20

2.4 WASTE CHARACTERISTICS

2.4.1 HAZARDOUS SUBSTANCES

- Phase II Soil Removal 

The contaminated composite surface soil samples listed below were collected during 

the Phase II Soil Removal activities conducted at Red Panther by URS and Newfields

on behalf of Red Panther (Refs. 16, pp. 5, 9; 17, pp. 22-25, 184, 186-187). No 

background surface soil sample was collected; the samples listed were collected as 

confirmation samples after removal activities at the property based on the 

requirements of the 2001 Administrative Order on Consent (Ref. 17, pp. 7-8, 22-

25, 184, 186-187). All constituents listed in this section were included in the 

2001 Administrative Order on Consent for Red Panther and agreed by the performing 

PRPs to be remediated (Refs. 7, pp. 1, 3-7, 48; 16, p. 7; 17, p. 12). The samples 

were analyzed by an on-site laboratory (E.C.C.S. Inc) for arsenic, dieldrin, and 

toxaphene using methods 8081A and 7010B (Ref. 17, pp. 209-217). Also, only data 

from samples collected from depths of 2 feet or less were included in the Phase II 

Soil Removal data package; therefore, only those samples are listed below. 

However, concentrations of arsenic (2.2 to 322 mg/kg), dieldrin (0.12 to 9.2 

mg/kg), and toxaphene (4.9 to 220 mg/kg) are also reported to remain at a depth of 

greater than 2 feet (Ref. 17, pp. 184-188). See Reference 17, pp. 184, 186-188 of 

this Documentation Record for sample locations.

-Background Concentrations: 

The background composite surface soil sample was collected from BF McLaurin Park 

located on Sunflower Avenue, near 6th Street, approximately 0.5 mile north of the 

18th Street Neighborhood (Ref. 18, pp. 4, 41, 49). Soil contamination in the area 

of the facility is largely due to air deposition of particulates from the Red 

Panther facility. There is no one prevailing wind direction in the area (Ref. 40, 

p. 18). Additionally, some pesticide presence in the background sample is to be 

expected due to usage in agricultural fields in the area (Ref. 40, pp. 19-21).

The background composite surface soil sample (SN-01-SS) listed below was collected 

August 10, 2005, during the Removal Assessment by Weston conducted on behalf of 

EPA Region 4 (Ref. 18, pp. 7-8). All samples collected during the investigation 

were submitted through the EPA Contract Laboratory Program (CLP) for CLP 

Pesticides analysis and CLP arsenic, aluminum, and iron analysis (Ref. 18, pp. 7-

8, 79-171). In 2005, the CLP Pesticide analysis and CLP arsenic, aluminum, and 

iron analysis were analyzed by methods SOM01.1 and ILM05.3 (Refs. 18, pp. 7-8, 79-

171; 43, p. 1; 44, p. 1). Results were validated by the EPA Science and Ecosystem 

Support Division (SESD); the data validation report is included in Reference 18 

(Ref. 18, pp. 8-9, 172-175). See Figure 3 of this Documentation Record for sample 

location.

Sample ID Sample Medium Depth Date Reference

SN-01-SS Soil 0-3 inches 8/10/05 18, pp. 40-41, 166

Sample ID Hazardous Substance

Concentration

(ug/kg)

Sample 

Quantitation 

Limit

(ug/kg)

Reference

SN-01-SS

Heptachlor epoxide 1.8U 1.8

18, pp. 85, 

125, 166; 

Endosulfan II 3.5U 3.5

4,4’-DDD 3.5U 3.5
21

Sample ID Hazardous Substance

Concentration

(ug/kg)

Sample 

Quantitation 

Limit

(ug/kg)

Reference

Endrin 3.5U 3.5 43, p. 93; 

Dieldrin 3.5U 3.5 45

4,4-DDE 15 3.5

Toxaphene 180U 180

Gamma-chlordane 1.8U 1.8

Alpha-chlordane 1.8U 1.8

Arsenic 20,000 1,000*

Notes:

ug/kg – Micrograms per kilogram

U - Constituent analyzed for but not detected above reporting limit. DDD - 4,4’-dichloro-2,2-bis(p-chlorophenyl)ethylene

DDE - 4,4’-dichloro-2,2-bis(p-chlorophenyl)ethane

* - Contact Required Quantitation Limit (CRQL) (Ref. 43, p. 93)

- Contaminated Samples

The composite surface soil samples listed below were collected during the Phase 

II Soil Removal activities conducted at Red Panther by URS and Newfields on 

behalf of Red Panther (Refs. 16, pp. 5, 9; 17, pp. 22-25, 184, 186-187).

Sample 

ID

Date 

Collected

Reporting 

Limit

(mg/kg)

Hazardous 

Substance

Hazardous 

Substance 

Concentration

(mg/kg) 

Background 

Concentration

(SN-01-SS)

(mg/kg) References

BGC-1 5/11/05 3 Toxaphene 3.5 0.18

17, pp. 184, 

203, 209; 18, 

pp. 125, 166; 

26, p. 1; 27, 

p. 1 

BGC-15 6/20/05

2 Arsenic 420 20 17, pp. 184, 

205, 212; 18, 

pp. 85, 125, 

166; 26, p. 1; 

27, p. 1

0.1 Dieldrin 2.6 0.0035U

3 Toxaphene 7.4 0.18

CGC-2 5/11/05

2 Arsenic 210 20 17, pp. 186, 

203, 213; 18, 

pp. 85, 125, 

166; 26, p. 1; 

27, p. 1

0.1 Dieldrin 0.89 0.0035U

3 Toxaphene 7.0 0.18

DGC-1 5/24/05

0.1 Dieldrin 0.54 0.0035U 17, pp. 187, 

201, 214; 18, 

pp. 125, 166; 

26, p. 1; 27, 

p. 1

3 Toxaphene 7.5 0.18

DGC-15 6/6/05

0.1 Dieldrin 11 0.0035U

17, pp. 187, 

202, 215; 18, 

pp. 125, 166; 

26, p. 1; 27, 

p. 1

3 Toxaphene 14 0.18U

DGC-16 6/2/05

0.1 Dieldrin 2.9 0.0035U 17, pp. 187, 

208, 216; 18, 

pp. 125, 166; 3 Toxaphene 220 0.18U
22

Sample 

ID

Date 

Collected

Reporting 

Limit

(mg/kg)

Hazardous 

Substance

Hazardous 

Substance 

Concentration

(mg/kg) 

Background 

Concentration

(SN-01-SS)

(mg/kg) References

26, p. 1; 27, 

p. 1

DGC-17 6/6/05

0.1 Dieldrin 0.83 0.0035U 17, pp. 187, 

202, 217; 18, 

pp. 125, 166; 

26, p. 1; 27, 

p. 1

3 Toxaphene 3.1 0.18U

Notes:

 mg/kg - Milligrams per kilogram
23

SD-Hazardous Waste Quantity

Source No. 1

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1.1 Hazardous Constituent Quantity

Insufficient data is available to calculate the hazardous constituent quantity.

Hazardous Constituent Quantity Value (S): Not Scored

Reference: 1, Section 2.4.2.1.1

2.4.2.1.2 Hazardous Wastestream Quantity

Insufficient data is available to calculate the hazardous wastestream quantity.

Hazardous Wastestream Quantity Value (W): Not Scored

Reference: 1, Section 2.4.2.1.2

2.4.2.1.3 Volume

Insufficient data is available to calculate the volume.

Volume Value (V): 0

Reference: 1, Section 2.4.2.1.3

2.4.2.1.4 Area

The area of contamination is formed by a perimeter of composite confirmation 

sample locations CGC-2, BGC-1, BGC-15, DGC-1, DGC-15, DGC-16, and DGC-17 collected 

during the Phase II Soil Removal by URS and Newfields for Red Panther (Ref. 17, 

pp. 184, 186-187). Removal activities were conducted by the PRP, and sufficient 

sampling to determine the extent of contaminated soil remaining has not been 

performed. Therefore, the area of contaminated soil was determined to be >0 

square feet (ft2

) (Ref. 17, pp. 184, 186-187).

Equation for hazardous waste quantity evaluation for the contaminated soil is 

A/34,000. Therefore, >0 ft2 /34,000 = >0

Area Assigned Value: >0

Reference: 1, Table 2-5

2.4.2.1.5 Source Hazardous Waste Quantity Value

Source Hazardous Waste Quantity Value: >0

Reference: 1, Section 2.4.2.2
24

2.2 SOURCE CHARACTERIZATION

Number of the source: 2

Name and description of the source: Contaminated soil in the area surrounding 

the facility due to air deposition

HRS Source Type: Contaminated soil

Contaminated soil related to facility operations is located throughout the 

area surrounding the Red Panther facility at a depth of 0 to 12 inches bgs 

(Refs. 18, pp. 29-47, 78-171; 40, pp. 15).

During a 1975 field investigation at Red Panther conducted by the Mississippi 

Department of Air and Water Pollution Control, the inspector noted highly dusty 

conditions inside the plant and open doors during product formulation. The 

inspector concluded that compounds produced at the facility could be escaping the 

plant through the open doors (Ref. 32, pp. 1-2). The inspection was a result of 

a citizen complaint of dead vegetation, including evergreen trees, tomato and 

pepper plants, and shrubs (Ref. 32, p. 1). The inspector collected samples of 

the dead vegetation at the residence for analysis and also noted dead vegetation 

in additional areas adjacent to the plant (Ref. 32, p. 2). The inspector noted 

in his report that the resident had been financially reimbursed by Riverside 

Chemical Company in 1974 for a garden that had been impacted (Ref. 32, p. 1). 

Elevated concentrations of 4,4’-DDD; 4,4’-DDE; 4,4’-DDT; aldrin; alpha-BHC; betaBHC; delta-BHC; dieldrin; endosulfan sulfate; endrin; endrin aldehyde; lindane; 

gamma-chlordane; heptachlor; heptachlor epoxide; and toxaphene were detected in 

the composite surface soil samples collected during the August 2005 Removal 

Assessment when compared to the highest concentration of the pesticide in all 

associated background samples (Ref. 40, pp. 35-48, 88-180). Although pesticide 

constituents were detected in the background samples, toxaphene was not detected 

in any of the background samples (Ref. 40, pp. 18-20, 35). Higher concentrations 

of DDT, DDD, and DDE were detected in areas closer to the facility (Ref. 40, pp. 

18-20, 28-30, 35-48). Toxaphene was identified in eight samples collected near 

the facility, with concentrations increasing closer to the facility (Ref. 40, pp. 

19-20, 30, 35-48). Modeling of toxaphene contaminant concentrations in the area 

suggests the facility is the source of toxaphene (Ref. 40, pp. 19-20, 30). 

Dieldrin was identified in half of the samples collected, generally in higher 

concentrations near the facility and declining to non-detect concentrations in 

the outlying samples (Ref. 40, pp. 19-20, 35-48). The highest dieldrin 

concentration (3,800 ug/kg) was identified in the sample collected closest to the 

facility (Ref. 40, pp. 19-20, 31, 35-48). According to the ADS, the absence of 

dieldrin in samples adjacent to agricultural fields and the presence of higher 

concentrations near the facility indicate that Red Panther is the source of 

dieldrin contamination in the area (Ref. 40, pp. 19-20, 31, 35-48). 

Source contaminants include 4,4’-DDD; 4,4’-DDE; 4,4’-DDT; aldrin; alpha-BHC; 

alpha-chlordane; beta-BHC; delta-BHC; dieldrin; endosulfan sulfate; endrin; 

endrin aldehyde; lindane; gamma-chlordane; heptachlor; heptachlor epoxide; and 

toxaphene (Refs. 18, pp. 16-21, 29-47, 85-117, 125-157, 159-171; 40, pp. 89-180).

Location of the source, with reference to a map of the facility:

Contaminated soil is located throughout the area surrounding the Red Panther 

facility at a depth of 0 to 12 inches bgs (Refs. 18, pp. 29-47, 78-171; 40, pp. 

15). Maps of the sample locations can be found in Figures 3 and 4 of this 

documentation record.
25

Containment:

Release to ground water: No liner beneath the contaminated soil in the 

neighborhood was documented during the August 2005 Removal Assessment

investigation of the 18th Street Neighborhood by Weston for EPA (Refs. 18, pp. 

29-47). The nature and extent of the source indicates a liner would be unlikely 

to be present throughout the area (Ref. 3). Pesticide-contaminated ground water 

has been identified in ground water monitoring wells installed in the surficial 

aquifer at the nearby Red Panther property (Ref. 19, pp. 194-213, 288-304). 

Based on Table 3-2 of Reference 1, the contaminated soil yields a containment 

value of 10.

Ground water Containment Value: 10

Reference: 1, Section 3.1.2.1, Table 3-2
26

2.4 WASTE CHARACTERISTICS

2.4.1 HAZARDOUS SUBSTANCES

A Removal Assessment of the 18th Street Neighborhood was conducted in August 2005 

by Weston for EPA to characterize the nature and extent of contaminated soil on 

residential properties in the neighborhood (Ref. 18, p. 4). Composite samples 

using three to five aliquots per sample collected from 30 residential properties 

in the neighborhood indicated the presence of contaminated soil at a depth of 

less than 1 foot bgs on several of the properties sampled (Ref. 18, pp. 7, 16-21, 

29-47, 85-117, 125-157, 159-171). The background sample (SN-01-SS) was collected 

from the B.F. McLaurin Park as a reference to determine what direct impact Red 

Panther operations might have had on the soils in the neighborhood (Ref. 18, pp.

7, 40-41). All samples collected during the investigation were analyzed for 

pesticides, aluminum, arsenic, iron, and other metals (Ref. 18, pp. 16-22, 78-

171). Of the 30 residences sampled, 24 soil samples were elevated above 

background concentrations for pesticides, including dieldrin; toxaphene; 4,4’-

DDD; alpha-chlordane; gamma-chlordane; endosulfan sulfate; and endrin (Ref. 18, 

pp. 16-22). No metals were detected at elevated concentrations in any samples 

(Ref. 18, pp. 78-171). 

From June 29 to July 1, 2010, OTIE conducted an ADS on behalf of EPA within a 1⁄4-

mile area of the former Red Panther facility (Refs. 40, pp. 5, 14, 182-287; 41, 

pp. 1, 5). The purpose of the ADS was to evaluate the presence of pesticides in 

the surface soils surrounding the former Red Panther facility (Ref. 40, p. 5). 

Field investigation activities included the collection of surface soil samples in 

every direction from the facility to determine if contaminant concentrations 

previously identified in the residential neighborhood to the west of the facility 

(18th Street Neighborhood) were a result of pesticide formulation activities at 

the facility or if the presence of the nearby agricultural fields contributed to 

the pesticide contamination (Ref. 40, p. 5). A total of 81 nine-point composite 

surface soil samples were collected from 73 locations in a 1⁄4-mile area 

surrounding the facility, including eight duplicate samples, but not including 

the background samples (Refs. 40, pp. 14-18; 41, pp. 31-32). Four background 

composite samples, including one duplicate, were collected north and northeast of 

the facility from areas 0.7- to 1.1-mile distant from the facility to ensure an 

adequate background for comparison purposes (Refs. 40, pp. 14, 15, 19-20; 41, pp. 

31-32). The 73 composite soil samples were collected in a grid pattern with 300-

foot centers in all directions from the facility. At each 300-foot center, 

composite soil samples were collected from the 0- to 3-inch bgs interval; each 

sample consisted of nine aliquots within a 25-by-25 foot sampling sub-grid (Ref. 

40, p. 15). All aliquots of each composite sample were collected from within the 

respective property boundary and, for residential grids, less than 200 feet from 

the residential structure (Refs. 40, p. 15; 42, p. 1). Each 25-by-25 foot grid 

was approximately 300 feet apart, offset when needed to locate the grid 

completely over soil. The background samples were collected in the same manner 

from three residential properties located in neighborhoods of approximately the 

same age as the 18th Street Neighborhood (Ref. 40, pp. 15-16).

- 2005 18th Street Neighborhood Removal Assessment

The composite surface soil samples listed below were collected August 9 and 10, 

2005 during the Removal Assessment by Weston conducted on behalf of the EPA 

Region 4 (Ref. 18, pp. 7-8). All samples collected during the investigation were 

submitted through the EPA Contract Laboratory Program (CLP) for CLP Pesticides 

analysis and CLP arsenic, aluminum, and iron analysis (Ref. 18, pp. 8-9, 79-171)

In 2005, the CLP Pesticide analysis and CLP arsenic, aluminum, and iron analysis 

were analyzed by methods SOM01.1 and ILM05.3 (Refs. 18, pp. 8-9, 79-171; 43, p. 
27

1; 44, p. 1). Results were validated by the EPA Science and Ecosystem Support 

Division (SESD); the data validation report is included in Reference 18 (Ref. 18, 

pp. 8-9, 172-175). See Figure 3 of this Documentation Record for sample 

locations.

- Background Concentrations:

The background composite surface soil sample was collected from BF McLaurin Park 

located on Sunflower Avenue, near 6th Street, approximately 0.5 mile north of the 

18th Street Neighborhood (Ref. 18, pp. 7, 41, 49). Soil contamination in the area 

of the facility is largely due to air deposition of particulates from the Red 

Panther facility. There is no one prevailing wind direction in the area (Ref. 40, 

p. 18). Additionally, some pesticide presence in the background sample is to be 

expected due to usage in agricultural fields in the area (Ref. 40, pp. 19-21).

Sample ID Sample Medium Depth Date Reference

SN-01-SS Soil 0-3 inches 8/10/05 18, pp. 40-41, 166

Sample ID Hazardous Substance

Concentration

(ug/kg)

Sample 

Quantitation 

Limit

(ug/kg)

Reference

SN-01-SS

Heptachlor epoxide 1.8U 1.8

18, pp. 

125, 166

Endosulfan II 3.5U 3.5

4,4’-DDD 3.5U 3.5

Endrin 3.5U 3.5

Dieldrin 3.5U 3.5

4,4-DDE 15 3.5

Toxaphene 180U 180

Gamma-chlordane 1.8U 1.8

Alpha-chlordane 1.8U 1.8

Notes:

ug/kg – Micrograms per kilogram

U - Constituent analyzed for but not detected above reporting limit. DDD - 4,4’-dichloro-2,2-bis(p-chlorophenyl)ethylene

DDE - 4,4’-dichloro-2,2-bis(p-chlorophenyl)ethane

- Contaminated Samples

The composite surface soil samples listed below were collected by Weston for EPA 

during the 2005 Removal Assessment conducted at the 18th Street Neighborhood 

(Ref. 18, pp. 4, 7, 15-22). All composite surface soil samples were collected 

between 0 to 12 inches bgs from locations within 200 feet of the residences or 

play grounds located on the properties (see Figure 3)(Refs. 18, pp. 29-47, 156-

171). Generally, the soil samples were comprised of light brown sandy silt (Ref. 

18, pp. 29-31). The background composite surface soil sample was collected from 

the playground areas of the BF McLaurin Park located on Sunflower Road 

approximately 0.5 mile north of the 18th Street Neighborhood (Ref. 18, pp. 7, 

41). See Figure 3 of this Documentation Record for sample locations.

Sample ID Sample 

Medium

Depth 

(inches bgs) Date Reference

SN-03-SS Soil 0-12 8/9/05 18, pp. 30, 162, 166

SN-04-SS Soil 0-12 8/9/05 18, pp. 31, 162, 166
28

Sample ID Sample 

Medium

Depth 

(inches bgs) Date Reference

SN-05-SS Soil 0-12 8/9/05 18, pp. 31, 159, 166

SN-06-SS Soil 0-12 8/9/05 18, pp. 32, 54, 159, 

166

SN-07-SS Soil 0-12 8/9/05 18, pp. 36, 159, 166

SN-08-SS Soil 0-12 8/9/05 18, pp. 37, 159, 166

SN-11-SS Soil 0-12 8/9/05 18, pp. 38, 159, 167

SN-12-SS Soil 0-12 8/9/05 18, pp. 38, 159, 167

SN-13-SS Soil 0-12 8/9/05 18, pp. 39, 159, 167

SN-14-SS Soil 0-12 8/9/05 18, pp. 39, 160, 167

SN-16-SS Soil 0-12 8/9/05 18, pp. 39, 160, 167

SN-18-SS Soil 0-12 8/10/05 18, pp. 44, 160, 167

SN-19-SS Soil 0-12 8/10/05 18, pp. 44, 160, 167

SN-20-SS Soil 0-12 8/10/05 18, pp. 43, 160, 168

SN-21-SS Soil 0-12 8/10/05 18, pp. 44, 160, 168

SN-24-SS Soil 0-12 8/10/05 18, pp. 34, 71, 161, 

168

SN-25-SS Soil 0-12 8/10/05 18, pp. 47, 161, 168

SN-26-SS Soil 0-12 8/10/05 18, pp. 35, 161, 168

SN-27-SS Soil 0-12 8/10/05 18, pp. 46, 161, 168

SN-29-SS Soil 0-12 8/10/05 18, pp. 46, 161, 169

SN-30-SS Soil 0-12 8/10/05 18, pp. 42-43, 161, 

169

SN-31-SS Soil 0-12 8/10/05 18, pp. 35, 161, 169
29

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(ug/kg)

Contract 

Required 

Quantitation 

Limit (ug/kg)

Background 

Concentration

(ug/kg) References

SN-03-SS 4,4-DDE 58 3.3 15

18, pp. 125, 

127, 166; 44, 

p. 3

SN-04-SS 4,4-DDE 58 3.3 15

18, pp. 125, 

128, 166; 44, 

p. 3

SN-05-SS 4,4-DDE 78 3.3 15 18, pp. 125,129, 166; 44, 

p. 3 Dieldrin 42 3.3 3.5U

SN-06-SS

4,4-DDE 190 3.3 15 18, pp. 125,

130, 166; 44, 

Dieldrin 58 3.3 3.5U p. 3

SN-07-SS

4,4-DDE 540 3.3 15

18, pp. 125, 

131, 166; 44, 

p. 3 

Dieldrin 200 3.3 3.5U

Alpha 

Chlordane 5.2 1.7 1.8U

SN-08-SS

4,4-DDE 500 3.3 15

18, pp. 125, 

132, 166; 44, 

p. 3

4,4-DDD 64 3.3 3.5U

Dieldrin 360 3.3 3.5U

Endosulfan II 570 3.3 3.5U

SN-11-SS

4,4-DDE 160 3.3 15

18, pp. 125, 

136, 166-167; 

44, p. 3

4,4-DDD 19 3.3 3.5U

Dieldrin 77 3.3 3.5U

Alpha 

Chlordane 100 1.7 1.8U

Gamma 

Chlordane 110 1.7 1.8U

SN-12-SS

4,4-DDE 170 3.3 15 18, pp. 125, 

137, 166-167;

Toxaphene 4,500 170 180U 44, p. 3 

SN-13-SS

4,4-DDE 320 3.3 15

18, pp. 125, 

138, 166-167;

44, p. 3 

Alpha 

Chlordane 53 1.7 1.8U 18, pp. 125, 

138, 166-167; 

Gamma 44, p. 3

Chlordane 44 1.7 1.8U

SN-14-SS 4,4-DDE 170 3.3 15

18, pp. 125, 

139, 166-167; 

44, p. 3

SN-16-SS 4,4-DDE 73 3.3 15

18, pp. 125, 

141, 166-167; 

44, p. 3
30

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(ug/kg)

Contract 

Required 

Quantitation 

Limit (ug/kg)

Background 

Concentration

(ug/kg) References

SN-18-SS

4,4-DDE 280 3.3 15

18, pp. 125, 

143, 166-167; 

44, p. 3

4,4-DDD 19 3.3 3.5U

Gamma 

Chlordane 29 1.7 1.8U

Endrin 7.2 3.3 3.5U

SN-19-SS

4,4-DDE 260J 3.3 15 18, pp. 125, 

144, 166-167; 

44, p. 3

Gamma 

Chlordane 62J 1.7 1.8U

SN-20-SS Dieldrin 10 3.3 3.5U

18, pp. 125, 

146, 166, 

168; 44, p. 3

SN-21-SS

4,4-DDE 270 3.3 15

18, pp. 125, 

147, 166, 

168; 44, p. 3

4,4-DDD 20 3.3 3.5U

Dieldrin 380 3.3 3.5U

Heptachlor 

Epoxide 4.6 1.7 1.8U

Alpha 

Chlordane 6.1 1.7 1.8U

SN-24-SS

4,4-DDE 150 3.3 15 18, pp. 125, 

150, 166, 

Toxaphene 4,700 170 180U 168; 44, p. 3

SN-25-SS

4,4-DDE 82 3.3 15

18, pp. 125, 

151, 166, 

168; 44, p. 3

Toxaphene 1,900 170 180U

Gamma 

Chlordane 7.2 1.7 1.8U

SN-26-SS

4,4-DDE 180 3.3 15 18, pp. 125, 

152, 1663, 

168; 44, p. 3

Endosulfan II 12 3.3 3.5U

Toxaphene 810 170 180U

SN-27-SS

4,4-DDE 110 3.3 15 18, pp. 125, 

153, 166, 

4,4-DDD 7.2 3.3 3.5U 168; 44, p. 3

SN-29-SS

4,4-DDE 90 3.3 25

18, pp. 125, 

155, 166, 

169; 44, p. 3

Dieldrin 36 3.3 3.5U

Alpha 

Chlordane 3.5 1.7 1.8U

SN-30-SS

4,4-DDE 250 3.3 15

18, pp. 125, 

156, 166, 

169; 44, p. 3

Dieldrin 42 3.3 3.5U

Alpha 

Chlordane 6.6 1.7 1.8U

SN-31-SS

4,4-DDE 130 3.3 15 18, pp. 125, 

157, 166, 

Dieldrin 32 3.3 3.5U 169; 44, p. 3

Notes:
31

a - The Contract Required Quantitation Limit is equivalent to the 

Sample Quantitation Limit (Ref. 45). 

J - Constituent was detected, value is an estimate

ug/kg - Micrograms per kilogram

U - Constituent was analyzed for but was not detected at or above 

reporting limit.

- 2010 OTIE Air Deposition Study

The composite surface soil samples listed below were collected June 29 to July 1, 

2010 during the ADS conducted by OTIE on behalf of EPA Region 4 (Ref. 40, pp. 5, 

14). A total of 80 nine-point composite surface soil samples were collected from 

73 locations in a 0.25-mile area surrounding the facility, including 8 duplicate 

samples (Refs. 40, pp. 14-17, 19; 41, pp. 31-32). Four background composite 

samples, including one duplicate sample, were collected north and northeast of 

the facility from areas 0.7- to 1.1-mile distant from the facility to ensure an 

adequate background for comparison purposes (Refs. 40, pp. 14-17; 41, pp. 31-32).

The composite soil samples were collected in a grid pattern with 300-foot centers 

in all directions from the facility. At each 300-foot center, composite soil 

samples were collected from the 0- to 3-inch bgs interval; each sample consisted 

of nine aliquots within a 25-by-25 foot sampling sub-grid (Ref. 40, pp. 14-15). 

All aliquots of the composite were collected from within the respective property 

boundaries and, for residential grids, less than 200 feet from the residential 

structure (Ref. 40, p. 15). Each 25-by-25 foot grid was approximately 300 feet 

apart. The background samples were collected in the same manner from three 

residential properties located in neighborhoods of approximately the same age as 

the 18th Street Neighborhood (Ref. 40, pp. 15-16).

All samples collected during the investigation were submitted to the EPA SESD 

laboratory for routine TCL pesticide analytical services using EPA Method 8080

(Ref. 40, pp. 16, 89). Results were validated by EPA SESD; the data validation 

report is included in Reference 40, pages 90 through 180. See Figure 4 of this 

Documentation Record for sample locations.

- Background Concentrations:

The four background composite surface soil samples, including one duplicate, were

collected from residential properties located 0.7- to 1.1-mile distant from the 

facility to ensure an adequate background for comparison purposes (Ref. 40, pp. 

14-15; 41, pp. 31-32). The highest concentration of each constituent from all 

four background samples was used for comparison purposes. All samples were 

collected in accordance with the guidance presented in the EPA-approved sitespecific Quality Assurance Project Plan/ Site Study Plan (QAPP/SSP) and in 

accordance with the EPA SESD Field Branches Quality System and Technical 

Procedures (FBQSTP) (Refs. 40, pp. 6, 14; 41). Each aliquot of the composite 

sample was collected from inside the property boundary, within 200 feet of the 

residential dwelling (Ref. 40, p. 15). The neighborhoods selected for the 

background samples were of approximately the same age; the background composite 

soil samples consisted of similar soil types (Ref. 40, pp. 14-15). Soil 

contamination in the vicinity is largely a result of air deposition of 

particulates from the Red Panther facility. There is no one prevailing wind 

direction in the area (Ref. 40, p. 17). In addition, some pesticide presence in 

the background is to be expected due to the presence of agricultural areas and 

the application of pesticides (Ref. 40, pp. 19-20).

Sample ID Sample Medium Depth Date Reference

RP-CS-01

RP-CS-77 Soil 0-3 inches 6/29/10

40, pp. 15-16, 25, 

33, 194, 210, 295, 

297
32

Sample ID Sample Medium Depth Date Reference

(duplicate)

RP-CS-02 Soil 0-3 inches 7/1/10

40, pp. 15-16, 25, 

33, 194, 230, 288

RP-CS-03 Soil 0-3 inches 7/1/10 40, pp. 15-16, 25, 

33, 194, 229, 288

Sample ID Hazardous 

Substance

Concentration

(ug/kg)

Minimum 

Reporting 

Limit 

(ug/kg)a

Reference

RP-CS-01

4,4’-DDD 10U, D-4 10

40, pp. 91, 

96, 295

4,4’-DDE 20 5.1

4,4’-DDT 30 13

Aldrin 1U 1

Alpha-BHC 0.51U 0.51

Beta-BHC 1U 1

Dieldrin 21 5.1

Endosulfan sulfate 2.5U 2.5

Endrin 29U, D-4 29

Endrin aldehyde 4.4U, D-4 4.4

Gamma-chlordane 21 5.1

Heptachlor 2.4 0.76

Heptachlor epoxide 2.7U, D-4 2.7

Toxaphene 350U, D-4 350

RP-CS-02

4,4’-DDD 6.3U 6.3

40, pp. 91, 

159, 288

4,4’-DDE 4.8 3.1

4,4’-DDT 9.7 7.9

Aldrin 3.1U 3.1

Alpha-BHC 1.6U 1.6

Beta-BHC 3.1U 3.1

Endosulfan sulfate 7.9U 7.9

Endrin 6.3U 6.3

Endrin aldehyde 7.9U 7.9

Gamma-chlordane 3.1U 3.1

Heptachlor 2.4U 2.4

Heptachlor epoxide 3.1U 3.1

Toxaphene 310U 310
33

Sample ID Hazardous 

Substance

Concentration

(ug/kg)

Minimum 

Reporting 

Limit 

(ug/kg)a

Reference

RP-CS-03

4,4’-DDD 6.3U 6.3

40, pp. 92,

94, 160, 

288

4,4’-DDE 20 7.8

4,4’-DDT 18 7.8

Aldrin 3.1U 3.1

Alpha-BHC 1.6U 1.6

Beta-BHC 3.1U 3.1

Dieldrin 52 7.8

Endosulfan sulfate 7.8U 7.8

Endrin 6.3U 6.3

Endrin aldehyde 7.8U 7.8

Gamma-chlordane 4.1 3.1

Heptachlor 2.4U 2.4

Heptachlor epoxide 3.2 3.1

Toxaphene 310U 310

RP-CS-77

4,4’-DDD 34 10

40, pp. 91, 

94, 97, 297

4,4’-DDE 22 5.1

4,4’-DDT 34 13

Aldrin 1.0U 1.0

Alpha-BHC 0.51U 0.51

Beta-BHC 1.0U 1.0

Dieldrin 23 5.1

Endosulfan sulfate 2.5U 2.5

Endrin 10U, D-4 10

Endrin aldehyde 2.5U 2.5

Gamma-chlordane 27 5.1

Heptachlor 2.1U, D-4 2.1

Heptachlor epoxide 3.6U, D-4 3.6

Toxaphene 100U, D-4 100

Notes:

ug/kg – Micrograms per kilogram

a - Minimum reporting limit is equivalent to the Sample Quantitation

limit (Ref. 45).

U - Constituent analyzed for but not detected above reporting limit. D-4 - MRL elevated due to interference.

Q-4 - Greater than 40% difference between primary and confirmatory GC

columns.

DDD - 4,4’-dichloro-2,2-bis(p-chlorophenyl)ethylene

DDE - 4,4’-dichloro-2,2-bis(p-chlorophenyl)ethane

DDT - 4,4’-trichloro-2,2,-bis(p-chlorophenyl)ethane

BHC - Benzenehexachloride

- Contaminated Samples

The composite surface soil samples listed below were collected by OTIE for USEPA 

from locations in a 1⁄4-mile area surrounding the Red Panther facility (Ref. 40, 

pp. 1, 14, 15, 18). All composite surface soil samples were collected from 0-to 

3-inches bgs and were comprised of a nine aliquots collected from a 25-by-25 foot 

grid (Ref. 40, pp. 14-15). The centers of the 25-foot grids were located 300 

feet apart (Ref. 40, pp. 14-15). All aliquots of each individual sample was 

collected from within the respective property boundary and, in the case of 

residential samples, within 200 feet of the building (Ref. 40, pp. 14-15). See 

Figure 4 of this Documentation Record for sample locations.
34

Sample ID Sample 

Medium

Depth 

(inches bgs)

Date Reference

RP-CS-05 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 197, 295

RP-CS-06 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27,

33-34, 194, 247, 295

RP-CS-08 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 260

RP-CS-09 Soil 0-3 7/1/10 40, pp. 14-15, 26, 27, 

33-34, 194, 277, 288

RP-CS-11 Soil 0-3 6/30/10 40, pp. 14-15, 26, 27, 

33-34, 194, 224, 291

RP-CS-12 Soil 0-3 6/30/10 40, pp. 14-15, 26, 27, 

33-34, 194, 218, 291

RP-CS-18 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 248, 295

RP-CS-19 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 199, 295

RP-CS-20 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 261, 291

RP-CS-23 Soil 0-3 7/1/10 40, pp. 14-15, 26, 27, 

33-34, 194, 278, 288

RP-CS-24 Soil 0-3 6/30/10 40, pp. 14-15, 26, 27, 

33-34, 194, 276, 288

RP-CS-26 Soil 0-3 6/30/10 40, pp. 14-15, 26, 27, 

33-34, 194, 267, 291

RP-CS-28 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 250, 295

RP-CS-29 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 202, 295

RP-CS-32 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 255, 296

RP-CS-38 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 254, 296

RP-CS-39 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 204, 296

RP-CS-47 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 206, 296

RP-CS-50 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 257, 297
35

Sample ID Sample 

Medium

Depth 

(inches bgs)

Date Reference

RP-CS-57 Soil 0-3 6/29/10 40, pp. 14-15, 26, 27, 

33-34, 194, 208, 297

RP-CS-60 Soil 0-3 6/28/10 40, pp. 14-15, 26, 27, 

33-34, 194, 259, 297

RP-CS-61 Soil 0-3 7/1/10 40, pp. 14-15, 26, 27, 

33-34, 194, 228, 297

RP-CS-62 Soil 0-3 7/1/10 40, pp. 14-15, 26, 27, 

33-34, 194, 281, 289

RP-CS-66 Soil 0-3 6/30/10 40, pp. 14-15, 26, 27, 

33-34, 194, 264, 293

RP-CS-75 Soil 0-3 7/1/10 40, pp. 14-15, 26, 27, 

33-34, 194, 284, 290

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(ug/kg)

Minimum 

Reporting 

Limita (ug/kg)

Background 

Concentration

(ug/kg) References

RP-CS-05

4,4’-DDD 220 95 34

40, pp. 91-

92, 96-97, 

99, 159, 160

4,4’-DDE 220 48 22

4,4’-DDT 310 120 34

Aldrin 12 4.8 3.1U

Dieldrin 230 48 52

Gammachlordane 530 48 27

Heptachlor 210 36 2.4

Heptachlor 

epoxide 290 48 3.2

RP-CS-06 Dieldrin 160 4.5 7.9U

40, pp. 91-

92, 96-97, 

99-100, 159, 

160

RP-CS-08 Endrin 

aldehyde 11 7.8 7.9U

40, pp. 91-

92, 96-97, 

129, 159, 

160

RP-CS-09 4,4’-DDE 84 7.7 22

40, pp. 91-

92, 96-97, 

159, 160-161

RP-CS-11

4,4’-DDE 94 7.4 22 40, pp. 91-

92, 94, 96-

97, 130, 

159, 160 4,4’-DDT 110 19 34

RP-CS-12 Alpha-BHC 3.4 1.7 1.6U

40, pp. 91-

92, 96-97, 

131, 159, 

160
36

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(ug/kg)

Minimum 

Reporting 

Limita (ug/kg)

Background 

Concentration

(ug/kg) References

RP-CS-18

Aldrin 34 4.7 3.1U 40, pp. 91-

92, 96-97, 

104, 159, 

160

Dieldrin 840 93 52

RP-CS-19 4,4’-DDE 68 4.7 22

40, pp. 91-

92, 96-97, 

105, 159, 

160

RP-CS-20 Endrin 

aldehyde 8 7.6 7.9U

40, pp. 91-

92, 96-97, 

135, 159, 

160

RP-CS-23 4,4’-DDE 82 7.7 22

40, pp. 91-

92, 96-97, 

159, 160, 

164

RP-CS-24

4,4’-DDD 120 15 34

40, pp. 91-

92, 96-97, 

159, 160, 

165

4,4’-DDE 260 76 22

4,4’-DDT 240 19 34

Dieldrin 2200 380 52

Toxaphene 5300 1500 350U

RP-CS-28 4,4’-DDE 110 42 22

40, pp. 91-

92, 96-97, 

106, 159, 

160

RP-CS-29 4,4’-DDE 99 8.8 22

40, pp. 91-

92, 96-97, 

107, 159, 

160 

RP-CS-32 4,4’-DDT 110 12 34

40, pp. 91-

92, 96-97, 

111, 159, 

160

RP-CS-38

4,4’-DDT 330 120 34 40, pp. 91-

92, 96-97, 

114, 159, 

160 

Heptachlor 

epoxide 51 4.7 3.2

RP-CS-39 4,4’-DDT 130 13 34

40, pp. 91-

92, 96-97, 

115, 159, 

160 

RP-CS-47

4,4’-DDT 170 27 34 40, pp. 91-

92, 96-97, 

117, 159, 

160 

Beta-BHC 9.7 1.1 3.1U

RP-CS-50 4,4’-DDE 90 9.6 22

40, pp. 91-

92, 96-96, 

120, 159, 

160

RP-CS-57 4,4’-DDE 88 9.6 22 40, pp. 91-

92, 96-97, 
37

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(ug/kg)

Minimum 

Reporting 

Limita (ug/kg)

Background 

Concentration

(ug/kg) References

122, 159, 

160 

RP-CS-60

4,4’-DDE 180 19 22 40, pp. 91-

92, 96-97, 

125, 159, 

160 4,4’-DDT 280 48 34

RP-CS-61

4,4’-DDE 1100 140 22

40, pp. 91-

92, 93, 94, 

96-97, 116, 

159, 160, 

171 

4,4’-DDT 950 180 34

Beta-BHC 56 7.2 3.1U

Dieldrin 3800 360 52

Endosulfan 

sulfate 80 18 7.9U

Endrin 110 14 29U

Toxaphene 5900 2900 350U

RP-CS-62

4,4’-DDD 80 16 34

40, pp. 91-

92, 96-97, 

159, 160, 

172

4,4’-DDE 390 79 22

4,4’-DDT 140 20 34

Dieldrin 1700 320 52

Toxaphene 2400 790 350U

RP-CS-66 4,4’-DDT 120 16 34

40, pp. 91-

92, 96-97, 

159, 156, 

160

RP-CS-75

4,4’-DDE 87 7.2 22 40, pp. 91-

93, 94, 96-

97, 159, 

160, 180 Dieldrin 210 29 52

Notes:

a - Minimum reporting limit is equivalent to the Sample Quantitation 

limit (Ref. 45).

J - Constituent was detected, value is an estimate

ug/kg - Micrograms per kilogram

U - Constituent was analyzed for but was not detected above the 

reporting limit.
38

SD-Hazardous Waste Quantity

Source No. 2

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1.1 Hazardous Constituent Quantity

Insufficient data is available to calculate the hazardous constituent quantity.

Hazardous Constituent Quantity Value (S): Not Scored

Reference: 1, Section 2.4.2.1.1

2.4.2.1.2 Hazardous Wastestream Quantity

Insufficient data is available to calculate the hazardous wastestream quantity.

Hazardous Wastestream Quantity Value (W): Not Scored

Reference: 1, Section 2.4.2.1.2

2.4.2.1.3 Volume

Insufficient data is available to calculate the volume.

Volume Value (V): 0

Reference: 1, Section 2.4.2.1.3

2.4.2.1.4 Area

The area of contamination is formed by the following composite sample locations 

collected during the 18th Street Neighborhood Removal Assessment by Weston for 

EPA Region 4 and during the 2010 ADS conducted by OTIE on behalf of EPA: 

SN-03-SS, SN-04-SS, SN-05-SS, SN-06-SS, SN-07-SS, SN-08-SS, SN-11-SS, SN-12-SS, 

SN-13-SS, SN-14-SS, SN-16-SS, SN-18-SS, SN-19-SS, SN-20-SS, SN-21-SS, SN-24-SS, 

SN-25-SS, SN-26-SS, SN-27-SS, SN-29-SS, SN-30-SS, SN-31-SS, RP-CS-05,RP-CS-06, 

RP-CS-08, RP-CS-09, RP-CS-11, RP-CS-12, RP-CS-18, RP-CS-19, RP-CS-20, RP-CS-23, 

RP-CS-24, RP-CS-26, RP-CS-28, RP-CS-29, RP-CS-32, RP-CS-38, RP-CS-39, RP-CS-47, 

RP-CS-57, RP-CS-60, RP-CS-61, RP-CS-62, RP-CS-66, and RP-CS-75 (Refs. 18, pp. 29-

161; 41, pp. 26, 33-34, 91-180, 194). All soil samples were collected within the 

property boundaries of each property. Soil contamination due to air deposition 

from Red Panther facility operations was largely continuous from the facility to 

the residential sampling locations, but the area of the source was not determined 

because some data show lack of significant levels of contamination between 

sampling locations (Refs. 40, p. 15; 42). Therefore, the area of soil 

contamination was estimated to be >0 ft2

. 

Equation for hazardous waste quantity evaluation for the contaminated soil is 

A/34,000. Therefore, >0 ft2 /34,000 = >0

Area Assigned Value: >0

Reference: 1, Table 2-5

2.4.2.1.5 Source Hazardous Waste Quantity Value

Source Hazardous Waste Quantity Value: >0

Reference: 1, Section 2.4.2.2
39

SUMMARY OF SOURCE DESCRIPTIONS

Source 

No.

Source Hazardous 

Waste Quantity 

Value

Containment

Ground water

Surface 

Water Soil

Air 

Gas Particulate

1 >0 10 NS 10 NS

2 >0 10 NS 10 NS

SUM >0

Notes:

NS- Not Scored

Reference: 1, Section 2.4.2.2, Table 2-6

OTHER POSSIBLE SOURCES

Stacks, Above Ground Storage Tanks, Septic Tank and Drainfield, Waste Water 

Settling Basin, Drainage Ditch –

Former operation features at Red Panther included a septic tank and drainfield 

located on the north side of the property, and three hazardous waste above-ground 

storage tanks (ASTs) with a total capacity of 33,000 gallons located on the south 

side of the property (Ref. 5, p. 4). A small wastewater settling basin was 

located on the east central side of the property (Ref. 5, p. 4). Four stacks were 

part of the manufacturing process, with heights between 20 and 30 feet (Ref. 46, 

p. 29). According to air permit records, arsenic; 2,4-D; methanol; xylene; and 

ethylene glycol were emitted at the facility from the four stacks (Ref. 46, pp. 

28-31, 42). Prior to obtaining interim status, wastewater containing pesticide 

and solvent residues were generated during equipment cleaning at the facility and 

discharged either directly to a drainage ditch or into an underground septic tank 

and drain field on the facility property (Refs. 5, pp. 3, 5; 6, pp. 8-9). 

Contamination on the property is believed to have originated from numerous spills 

during loading and unloading operations, contaminated wastewater releases, from 

spills and leaking underground piping in the tank farm area, as well as 

particulate releases to surrounding areas (Refs. 9, p. 2). In November 1985, a 

fire erupted at one of the Red Panther warehouses (Refs. 5, p. 5; 11, p. 5). 

Contaminated runoff resulting from the fire-fighting efforts caused a fish kill 

in the nearby Sunflower River (Ref. 11, p. 5). The contaminant was determined to 

be Lorox, a slightly toxic herbicide (Ref. 11, p. 5). A large volume of 

contaminated water was contained on the property and later shipped to a 

commercial hazardous waste disposal facility (Ref. 11, p. 5). During cleanup of 

the fire, approximately 382 old fiber drums were discovered in the crawlspace 

below the warehouse (Ref. 11, p. 5). Of those drums, 287 were empty and were 

crushed and sent to the local municipal landfill (Ref. 11, p. 5). Ninety-five 

drums contained trace residues of technical grade dieldrin and were disposed of 

at a commercial hazardous waste facility. (Ref. 11, p. 5).
40

3.0 GROUND WATER MIGRATION PATHWAY

3.0.1 GENERAL CONSIDERATIONS

Ground Water Migration Pathway Description

The source of contamination to the Ground Water Migration Pathway is contaminated 

soil located on the Red Panther property and in the adjacent 18th Street 

neighborhood (Refs. 11, pp. 10-12, 16-20; 13, pp. 5, 9-10, 27-41; 15, p. 8, 18-32, 

99-390; 18, pp. 125-167). The interconnected aquifers being evaluated are the 

observed release to the Mississippi River Valley Alluvial aquifer, and the 

underlying hydraulically connected Sparta Sand aquifer (Refs. 19, pp. 19-20, 162-

212; 20, pp. 4, 6-7, 13, 15). The Mississippi River Valley Alluvial aquifer is 

located at land surface in Clarksdale and is the most productive aquifer in the 

area; however, it is principally used for irrigation and industry (Ref. 20, p. 15). 

The Sparta Sand aquifer is not confined from the overlying Mississippi River Valley 

Alluvial aquifer and the two are hydraulically connected in Clarksdale, within 2 

miles of the sources at the site (Refs. 20, pp. 4, 6-7, 13, 15; 50, pp. 3-5). All 

drinking water in the study area comes from ground water sources. 

Regional Geology/Aquifer Description

Clarksdale is located in the northwestern portion of the State of Mississippi within 

the Mississippi Alluvial Plain physiographic district (Ref. 20, p. 3). The property 

is underlain in descending stratigraphic order by: the Mississippi River alluvium, 

Sparta Sand, Zilpha Clay and Winona Sand, Tallahatta Formation, Meridian-Upper 

Wilcox Aquifer, and Lower Wilcox Aquifer (Ref. 20, pp. 4, 6-7).

 

The Mississippi River Valley alluvium directly underlies the property (Ref. 20, pp. 

4, 6-7). The alluvium ranges from approximately 140 to 200 feet thick in the 

vicinity of Red Panther (Refs. 20, pp. 4, 6; 21, p. 3). It consists of clay, sand, 

silt, and gravel (Refs. 20, p. 15; 21, p. 2; 50, pp. 3-5). The lower part of the 

Mississippi River Valley Alluvial aquifer consists of coarse sand and gravel which 

grades upward through coarse sand, fine sand, silt, and clay (Refs. 20, p. 15; 50, 

pp. 3-5).

 

The Sparta Sand underlies the alluvium beneath the Red Panther property and is 

composed of rounded, well-sorted quartz grains in two or three thick beds separated 

by beds of clay (Refs. 20, pp. 4, 6-7; 21, p. 5; 50, p. 3). It contains more sand 

relative to overall thickness than any other aquifer in the State and to the 

northwest near Memphis, Tennessee; it combines with underlying sand beds and is 

known as the Memphis Aquifer (Ref. 21, p. 5). The thickness of the Sparta Sand is 

approximately 500 feet in the area (Refs. 20, pp. 4, 6-7; 50, p. 3).

The Zilpha Clay and Winona Sand underlie the Sparta Sand and are approximately 100 

feet thick in Clarksdale (Ref. 20, pp. 4, 6-7). The Tallahatta Formation underlies 

the Zilpha Clay and Winona Sand and is hydraulically connected to these overlying 

units (Ref. 20, pp. 6-7, 13). The Tallahatta generally contains several thick to 

very thin sand beds that are separated by clay (Ref. 20, p. 13). The Tallahatta is 

approximately 350 feet thick beneath the property (Ref. 20, pp. 4, 6-7). The 

combined Zilpha Clay, Winona Sand and the basal beds of the Tallahatta Formation 

serve as an impermeable confining layer between the Sparta Sand and the underlying 

Meridian Upper-Wilcox Aquifer (Refs. 20, pp. 6-8; 21, p. 9; 23, pp. 48, 60; 50, p. 

3). Based on the overall lithology (clay), the average hydraulic conductivity of 

this confining layer is approximately 10-8 cm/sec (Ref. 1, Table 3-6).

The Wilcox Group underlies the Tallahatta and is a massive unit consisting of fineto-coarse micaceous sand that dips west to southwest (Ref. 21, p. 9). The Wilcox 
41

Group is approximately 1,000 feet thick in Clarksdale (Ref. 20, pp. 4, 6-7).

The Meridian Sand Member of the Tallahatta Formation, together with the uppermost 

sands of the Wilcox Group form the Meridian-Upper Wilcox aquifer beneath the 

property (Refs. 20, p. 11; 21, p. 9). Pumping tests of the aquifer indicate 

hydraulic conductivities between 30 to 68 ft3

/d (Ref. 20, p. 13). The aquifer 

ranges in thickness from 50 to 350 feet and wells in Clarksdale screened in the 

aquifer are completed to depths of 1,122 to 1,299 feet bgs (Refs. 22, pp. 3-4; 20, 

p. 11). The regional ground water flow in the Meridian Upper-Wilcox aquifer is 

westward (Ref. 20 p. 13).

Site Geology/Aquifer Description

- Aquifer/Stratum 1 (uppermost): Mississippi River Valley Alluvium

The Mississippi River Valley alluvium directly underlies the property (Refs. 20, pp. 

4, 6-7; 50, pp. 3-5). The alluvium ranges from approximately 140 to 200 feet thick 

in the vicinity of Red Panther (Refs. 20, pp. 4, 6; 21, p. 3; 50, pp. 3-5). It 

consists of clay, sand, silt, and gravel (Refs. 20, p. 15; 21, p. 2; 50, pp. 3-5). 

The lower part of the Mississippi River Valley Alluvial aquifer consists of coarse 

sand and gravel which grades upward through coarse sand, fine sand, silt, and clay 

(Refs. 20, p. 15; 50, pp. 3-5).

The Mississippi River Valley Alluvial aquifer is the most productive aquifer in the 

area; however, it is principally used for irrigation and industry (Ref. 20, p. 15). 

Water levels in the aquifer average 20 feet bgs, but fluctuate seasonally from 

approximately 30 feet bgs during the summer and fall and near land surface during 

the spring (Ref. 21, p. 2). Generally, recharge to the aquifer is from the direct 

infiltration of rainfall and ground water flow is generally south toward streams in 

the area (Refs. 20, p. 15; 21, p. 2). The transmissivity of the aquifer is commonly 

greater than 10,000 square feet per day (Refs. 21, p. 2; 23, p. 20). Based on the 

lithology of the alluvium, the estimated hydraulic conductivity is approximately 10-

4 centimeters per second (cm/sec) (Ref. 1, Table 3-6; 20, p. 15).

- Aquifer/Stratum 2 (lower): Sparta Sand

The Sparta Sand underlies the alluvium beneath the Red Panther property and is 

composed of rounded, well-sorted quartz grains in two or three thick beds separated 

by beds of clay (Refs. 20, pp. 4, 6-7; 21, p. 5; 50, p. 3). It contains more sand 

relative to overall thickness than any other aquifer in the State (Ref. 21, p. 5). 

The thickness of the Sparta Sand is approximately 500 feet in the area (Refs. 20, 

pp. 4, 6-7; 50, p. 3). Water levels in the Sparta range from 450 to 100 feet above 

sea level (Ref. 21, p. 5). The Sparta aquifer crops out and receives its recharge 

in parts of DeSoto, Panola, and Tate counties located to the northeast of Coahoma 

County (Ref. 20, pp. 12-13). The Sparta Sand aquifer is not confined from the 

Mississippi River Valley Alluvial aquifer and the two are hydraulically connected in 

Clarksdale, where the Red Panther property is located (Refs. 20, pp. 4, 6, 13, 15; 

50, p. 3). The regional movement in the Sparta Sand is from east to west (Ref. 20, 

p. 15). The average hydraulic conductivity of the Sparta Sand in Mississippi is 67 

cubic feet per day per square foot ((ft3

/d)/ft2) or 10-6 cm/sec (Refs. 1, Table 3-6; 

20, p. 15). Municipal wells in Clarksdale that are screened in the Sparta Sand 

aquifer are completed to depths of 667 to 760 feet bgs (Refs. 22, pp. 3-4; 35, p. 1; 

50, p. 3).

- Aquifer Interconnection/Distance from Source

The Sparta Sand aquifer is not confined from the Mississippi River Valley Alluvial

aquifer and the two are hydraulically connected in Clarksdale, where the Red Panther 

property is located (Refs. 20, pp. 4, 6, 13, 15; 21, p. 2; 50, pp. 3-5). The Sparta 

Sand underlies the alluvium beneath the Red Panther property and is composed of 
42

rounded, well-sorted quartz grains in two or three thick beds separated by beds of 

clay (Refs. 20, pp. 4, 6-7; 21, p. 5; 50, p. 3). A persistent clay layer has not 

been found to be continuous between the Sparta Sand and alluvium within 2 miles of 

the sources at the site (Refs. 20, pp. 6-7; Ref. 21, p. 5; 50, p. 3). 

The Zilpha Clay, Winona Sand and the basal beds of the Tallahatta Formation, 

generally greater than 50 feet thick, serve as an impermeable confining layer 

between the Sparta Sand and the underlying Meridian Upper-Wilcox Aquifer (Refs. 20, 

pp. 6-8; 21, p. 9; 23, pp. 48, 60). Based on the overall lithology (clay), the 

average hydraulic conductivity of this confining layer is approximately 10-8 cm/sec 

(Ref. 1, Table 3-6).

For purposes of this site scoring, strata below the Sparta Sand are not evaluated as 

part of the Mississippi River Valley Alluvial aquifer and the underlying 

hydraulically connected Sparta Sand aquifer.
43

3.1 LIKELIHOOD OF RELEASE

3.1.1 OBSERVED RELEASE

Aquifer Being Evaluated: The interconnected Mississippi River Valley Alluvial 

Aquifer and Sparta Sands Aquifer

An observed release of has been documented in the Mississippi River Valley Alluvial 

Aquifer (Ref. 19, pp. 19-20, 162-212). The Mississippi River Valley Alluvial 

aquifer is the most productive aquifer in the area; however, it is principally used 

for irrigation and industry (Ref. 20, p. 15). The underlying Sparta Sand aquifer is 

not confined from the Mississippi River Valley Alluvial aquifer and the two are 

hydraulically connected within 2 miles of the sources at the site (Ref. 20, pp. 4, 

6, 13, 15). 

Direct Observation

An observed release by direct observation has not been documented.

Chemical Analysis

Monitoring Well Samples

- 2007 SI Sampling Investigation 

Temporary monitoring wells were installed, as per the November 2001 EPA Region 4 

Environmental Investigations Standard Operating Procedures and Quality Assurance 

Manual (EISOPQAM), on the Red Panther property during the 2007 SI field sampling 

event conducted by TN&A START for the EPA (Ref. 19, pp. 15-16). Ground water 

samples collected from the temporary monitoring wells located on the Red Panther

property contained elevated concentrations of DDT (Ref. 19, pp. 19-20, 162-212). 

See Figure 3 of this Documentation Record for temporary monitoring well locations.

The analytical citations for the ground water samples listed below are from the 2007 

SI field sampling event (Ref. 19). The concentrations detected in the ground water 

samples were compared to sample RP-TW-02 located on the north end of the property. 

Based on the westward ground water flow direction, RP-TW-02 is located in an 

upgradient/sidegragient location of ground water flow at the property (Refs. 19, pp. 

290-300; 20, p. 15; 21, p. 2). See Figure 3 of this Documentation Record for 

temporary monitoring well locations. Analytical data sheets and QA/QC information 

are presented in Reference 19. All temporary well ground water samples collected 

during the TN&A SI field sampling event were analyzed by an EPA CLP laboratory (Ref. 

19, pp. 40-286). The samples were analyzed for organic compounds including EPA TCL 

VOCs, extractable SVOCs, pesticides, and polychlorinated biphenyls (PCBs) using EPA 

method CLP SOM01.2, and Target Analyte List (TAL) metals and cyanide using EPA 

method CLP ILM05.4 (Ref. 19, pp. 40-286, 315-322). Data validation was performed by 

EPA Region 4 SESD personnel (Ref. 19, pp. 162-286). Analytical data sheets and 

QA/QC information are presented in Reference 19.

Background sample

Sample ID

Total 

Depth 

(feet)a

Depth to 

Water

(feet) Sample Location

Date 

Sampled References

RP-TW-02 35 9.30 North end of Red 

Panther property 10/11/07 19, pp. 29, 32, 198, 295

Notes:

a Total depth, depth to water, and screened interval measured from ground

surface
44

RP – Red Panther Chemical Company

TW – Temporary monitoring well

Sample ID

Hazardous 

Substance Concentration (ug/L)

MRL

(ug/L) References

RP-TW-02 4,4’-DDT 0.015 Ja

(0.1071) 0.10 19, pp. 199, 205, 318; 

Notes:

ug/L - Micrograms per liter

RP - Red Panther Chemical Company

TW - Temporary monitoring well

MRL - Minimum Reporting Limit – the analyte concentration which corresponds to 

the lowest quantitative point on the calibration curve or the lowest 

demonstrated level of acceptable quantitation (Refs. 19, p. 251; 45).

J - Constituent was detected, value is an estimate a - The result is qualified “J” due to it being below the low calibration 

point. The “J” result is estimated, below the SQL or equivalent, and biased 

unknown. The adjusted value is 0.015 x 7.14 = 0.1071(Refs. 19, pp. 199, 205; 

33, pp. 8, 16)

Contaminated Sample

Sample ID

Total 

Deptha

(feet)

Depth to 

Water

(feet) Sample Location

Date 

Sampled References

RP-TW-07 45.00 25.55 Former drum waste 

storage tank area 10/10/07 19, pp. 29, 32, 198, 294, 317

Notes:

a Total depth, depth to water, and screened interval measured from ground 

surface

RP – Red Panther Chemical Company

TW – Temporary monitoring well

Sample ID

Hazardous 

Substance

Concentration 

(ug/L)

MRL

(ug/L) References

RP-TW-07 4,4’-DDT 0.78 J* 0.10 19, pp. 199, 205, 209, 

317-318; 45

Notes:

ug/L - Micrograms per liter

RP - Red Panther Chemical Company

TW - Temporary monitoring well

MRL - Minimum Reporting Limit – the analyte concentration which corresponds to 

the lowest quantitative point on the calibration curve or the lowest 

demonstrated level of acceptable quantitation (Refs. 19, p. 251; 45).

J - Constituent was detected, value is an estimate

* - The result is qualified “J” due to low surrogate recovery. Therefore, the 

“J” results are estimated and biased low. The result is usable without 

adjusting (Refs. 19, p. 199; 33, p. 8).

3.1.2 POTENTIAL TO RELEASE

Potential to release was not evaluated. 
45

Attribution:

Red Panther operated as a pesticide formulation plant between 1949 and 1996

producing liquid and dry herbicides, insecticides, and fungicides (Refs. 4, p. 4; 5, 

p. 3; 6, p. 8; 7, p. 2). Chemicals used in the formulation included toxaphene;

methyl parathion; chloropyrifos; 2,4-D; malathion; carbaryl; diazinon; methoxychlor;

disodium methanearsonate; monosodium acid methanearsonate; chlorothalonil; and 

parathion (Ref. 7, p. 3). Contamination on the property is believed to have 

originated from numerous spills during loading and unloading operations, 

contaminated wastewater releases, from spills and leaking underground piping in the 

tank farm area, as well as particulate releases to surrounding areas (Ref. 9, p. 2).

On September 4, 2001, an Administrative Order on Consent for the Red Panther 

property between the PRPs and EPA Region 4 was finalized (Ref. 7, pp. 25-48). The 

Administrative Order on Consent identified four COCs for surface soil criteria and 

three COCs for subsurface soil criteria (Ref. 7, pp. 6-7, 21-24). The surface COCs 

were identified as arsenic, toxaphene, dieldrin, and total chlorinated pesticides 

(Ref. 7, p. 6). The subsurface COCs were identified as arsenic, toxaphene, and 

dieldrin (Ref. 7, p. 7). The Administrative Order on Consent required the PRPs to 

perform two phases of removal activities and disposal of excavated materials under 

all requirements of the Administrative Order on Consent (Ref. 7, pp. 5-9). EPA 

subsequently submitted the Action Memorandum documenting approval of the proposed 

removal action (Ref. 9).

On March 18, 2003, URS submitted the Phase I Removal Action Report and the Phase I 

Soil Characterization Report (Refs. 6, p. 1; 15, p. 1). Based on the results, URS 

recommended addressing the soils exceeding performance standards and addressing 

disposal options for the stockpiled soils in Ditch 1 in the Phase II Work Plan (Ref. 

6, p. 17). The report was approved by EPA on April 10, 2003 (Ref. 16, p. 8). 

During the Interim Removal, the contents of eight ASTs ranging in size from 200 

gallons up to 15,000 gallons in the Tank Farm were cleaned out and the solids and/or 

liquids impacted with arsenic and/or pesticides were disposed of off the property 

(Ref. 17, p. 6). During the Phase II Removal, a total of 5,341.27 tons of arsenicimpacted soils and 200 tons of pesticide-impacted soils were removed from the AST 

storage area; 1,903.73 tons of hazardous pesticide-impacted soils were removed from 

the loading dock and railroad spur area. Additional soils were removed from the AST 

storage area, loading dock and railroad spur area, silo area and property ditches, 

but was not characterized as hazardous or pesticide-impacted soils (Ref. 17, p. 7).

Subsurface soil concentrations of pesticides, including DDT remain beneath the Red 

Panther property and ground water beneath the property has indicated elevated levels 

of DDT (Refs. 17, pp. 7-8, 22-25, 184, 186, 187; 19, pp. 19-20, 36-38). Several 

municipal wells are located within the 4-mile Target Distance Limit (TDL) of the Red 

Panther property (Refs. 3; 22, pp. 1-5; Figures 2 to 4 of this HRS documentation 

record).

Sampling at the property prior to the implementation of the Administrative Order on 

Consent indicated the presence of elevated levels of additional contaminants 

including: endrin; 4,4’-DDT; 4,4’-DDE; 4,4’-DDD; heptachlor; chlordane; gamma-BHC 

(lindane); and endosulfan II (Refs. 11, pp. 16-20; 13, pp. 10, 27-41). These 

contaminants are documented to exist in association with historical operations at 

the facility and in samples collected from the property (Refs. 4, p. 4; 5, p. 3; 6, 

p. 8; 7, pp. 2-3; 9, p. 2; 11, pp. 10-12, 16-20; 13, pp. 5, 9-10, 27-41; 15, pp. 8, 

18-32, 99-390; 36, p. 2). Analysis of ground water samples from the property during 

the 2007 SI indicated that metals and pesticides are present in the ground water 

beneath the property; however, low surrogate and matrix spike recoveries were 

encountered in several samples; therefore, those results were not used in the 

observed release documentation (Ref. 19, pp. 162-166, 194-197). Additionally, 

complete analytical data sets including validation reports, logbook notes, and 

dilution factors for the post-removal samples collected by URS for the performing 

PRPs during the Phase II soil removal were not included within the report (Ref. 17).
46

A radial search for businesses within 2 miles of the Red Panther was conducted by 

Environmental Data Resources, Inc. (EDR) (Ref. 25, pp. 1-315). The EDR radial 

report searched multiple databases including, but not limited to, federal, state, 

tribal, local land records, emergency release reports, and EDR proprietary records 

(Ref. 25, pp. 4-6, 227-243). Additionally, properties that could not be mapped 

(orphaned) are listed; however, their exact location in relation to the Red Panther 

property is unknown (Ref. 25, p. 226). No NPL sites, Indian Reservations, 

Department of Defense (DOD) sites, or manufactured gas plants are located within a 

2-mile radius of the Red Panther property (Ref. 25, p. 16). 

The EDR report identified a USS Agri-Chemicals facility located to the northwest 

within the 0.25 to 0.5-mile radius of the Red Panther property (Ref. 25, pp. 12, 16, 

77-78). USS Agri-Chemicals, EPA ID No. MSD000798850, is a private company listed as 

a RCRA-Non Generator (Ref. 25, p. 78). The facility is listed as having one waste, 

dimethoate, associated with the business and does not generate or transport 

hazardous waste (Ref. 25, p. 78). DDT was not shown to be associated with the 

facility operations (Ref. 25).

DDT was banned from use in the United States in 1972 (Ref. 36, p. 2). DDT was used 

in the 1940s and 1950s to control mosquitoes and the typhus carried by lice (Ref. 

36, p. 2). It was extensively used as an agricultural insecticide after 1945 (Ref. 

36, p. 2). DDT is persistent in the environment with a reported half-life of 26 

days in river water to 15 years and is immobile in most soils (Ref. 36, p. 1). It 

breaks down in the environment into DDE and DDD, which are also persistent and have 

similar physical and chemical properties (Ref. 36, p. 1). 

During the 2010 ADS, soil sampling results indicated higher concentrations of DDT, 

DDD, and DDE in areas closer to the facility (Ref. 40, pp. 18-21). In general, the 

ADS concluded that the higher contaminant concentrations near the facility suggested 

that the contamination is the result of historic Red Panther facility activities and 

not a result of the use of the compounds in nearby agricultural fields (Ref. 40, pp. 

20-21). 

Hazardous Substances Released:

4,4-DDT

Ground Water Observed Release Factor Value: 550
GW-Toxicity/Mobility

47

3.2 WASTE CHARACTERISTICS

3.2.1 TOXICITY/MOBILITY

Hazardous 

Substance

Source 

No.

Toxicity 

Factor

Value

Mobility 

Factor

Valuea

Toxicity/

Mobility

Does Hazardous 

Substance Meet 

Observed Release 

by chemical 

analysis? (Y/N) References

Aldrin 2 10,000 0.0001 1 N

2, p. BI-1; 

40, pp. 89-

180

Alphachlordane 2 10,000 0.01 100 N

2, p. BI-3; 

40, pp. 89-

180

AlphaHexachlorocy

clohexane

(Alpha-BHC)

2 10,000 1 10,000 N 2, BI-7; 40, 

pp. 89-180

Arsenic 1 10,000 0.01 100 N

2, BI-1; 17, 

pp. 184, 186, 

187

Gammachlordane 2 10 0.01 100 N

2, p. BI-3; 

40, pp. 89-

180

DDD 2 100 0.0001 0 N

2, p. BI-4; 

40, pp. 89-

180

DDE 2 100 0.0001 0 N

2, p. BI-4; 

40, pp. 89-

180

DDT 2 1,000 1b 1,000 Y

2, p. BI-4; 

40, pp. 89-

180

Dieldrin 1, 2 10,000 0.01 100 N

2, p. BI-5;

17, pp. 184,

186, 187; 40, 

pp. 89-180

Endosulfan 

II 2 100 1 100 N

2, p. BI-6; 

40, pp. 89-

180

Endrin 2 10,000 0.01 100 N

2, p. BI-6; 

40, pp. 89-

180

Endrin 

aldehyde 2 0 0.0001 0 N

2, p. BI-6; 

40, pp. 89-

180

Heptachlor 2 1,000 0.0001 0 N

2, p. BI-6; 

40, pp. 89-

180

Heptachlor 

epoxide 2 10,000 0.0001 1 N

2, p. BI-6; 

40, pp. 89-

180

Toxaphene 1,2 1,000 0.0001 0 N

2, p. BI-11; 

17, pp. 184, 

186, 187; 40, 

pp. 89-180
GW-Toxicity/Mobility

48

Notes:

a - Liquid, non-karst values used for those constituents not detected in ground

water. (Refs. 4, p. 4; 5, pp. 3, 4; 6, p. 8; 7, p. 2; 9, p. 2)

b – Mobility value of 1 due to observed release of 4,4’-DDT in ground water 

samples.

Toxicity/Mobility Factor Value: 10,000

(Ref. 1, Table 3-9)
49

GW-Hazardous Waste Quantity

3.2.2 HAZARDOUS WASTE QUANTITY

Source No. Source Type Hazardous Waste Quantity

1 Contaminated soil >0

2 Contaminated Soil >0

 SUM = >0

Sum of Values: >0

Ground Water Migration Pathway Hazardous Waste Quantity Factor Value:10*

*The hazardous constituent quantity is not adequately established for the source. 

The value assigned from Table 2-6 without consideration of the removal action 

would be less than 100. Therefore, a value of 10 has been assigned for the 

Hazardous Waste Quantity value (Ref. 1, Section 2.4.2.2 and Table 2-6).

3.2.3 WASTE CHARACTERISTICS FACTOR CATEGORY VALUE

Toxicity/Mobility Factor Value: 10,000

Ground Water Migration Pathway Hazardous Waste Quantity Factor Value: 10

Toxicity/Mobility Factor Value (10,000) X 

Ground Water Migration Pathway Hazardous Waste Quantity Factor Value (10) = 

100,000

Ground Water Migration Pathway Waste Characteristics Factor Category Value: 18

 (Ref. 1, Table 2-7)
GW-Targets

50

3.3 TARGETS

The Sparta Sand aquifer directly underlies the Mississippi River Valley Alluvial 

aquifer, and they are interconnected within 2 miles of the sources at the site(Refs. 

20, pp. 4, 6-7, 13, 15; 21, pp. 2, 5). During the 2007 SI, two wells completed in 

the Sparta aquifer (shallow aquifer) indicated the presence of several metals 

including barium, copper, iron, lead, manganese, and zinc at elevated 

concentrations; however, no site-attributable constituents were detected (Ref. 19, 

pp. 35, 86-93, 116, 121, 123, 125, 127, 129, 131, 133, 135, 160).

All drinking water in the study area comes from ground water sources. A major 

municipal drinking water supplier in the area is the Clarksdale Public Utilities, 

which operates 10 wells ranging from approximately 667 to 760 feet deep in the 

Sparta aquifer and 1,122 to 1,299 deep in the Meridian-Upper Wilcox aquifer (Ref. 

22, pp. 1-5 ). All of the Clarksdale Public Utilities wells contribute equally to 

the municipal water supply and no one well supplies more than 40% to the total water 

supply (Ref. 35, p. 1). Seven of the wells draw water from the Sparta Aquifer, and 

three wells draw water from the deeper Meridian-Upper Wilcox Aquifer. The municipal 

wells completed in the Sparta aquifer within the 4-mile TDL of the sources at the 

site are all owned by the Clarksdale Public Utilities and are distributed as 

follows: 0- to 0.25-mile, 1 well; 0.25- to 0.5-mile, 0 wells; 0.5- to 1-mile, 4

wells; 1- to 2-miles, 2 wells; 2- to 3-miles, 0 wells; 3- to 4-miles, 0 wells (Refs.

3; 22, pp. 1-5; 24, p. 1). 

According to the U.S. Census Bureau, the average number of persons per household in 

Coahoma County based on the 2004-2009 Census population estimates is 2.69 (Ref. 24, 

p. 1). Clarksdale Public Utilities serves a total of 7,355 connections in the water 

system; therefore, the total population served by the entire water system of the 

Clarksdale Public Utilities is approximately 19,784.95 persons served by 10 wells

(Refs. 22, pp. 1-5; 35, p. 1). Therefore, the number of persons served per well in 

the Clarksdale Public Utilities water system is 1,978.495 persons. The population 

served by the seven wells completed in the Sparta aquifer within the 4-mile TDL of 

the source are distributed as follows: 0- to 0.25-mile, 1,978.495 persons; 0.25- to 

0.5-mile, 0 persons; 0.5- to 1-mile, 7,913.98 persons; 1- to 2-miles, 3,956.99

persons; 2- to 3-miles, 0 persons; 3- to 4-miles, 0 persons (Refs. 3; 22, pp. 1-5; 

24, p. 1; 35, p. 1). All municipal wells in Mississippi are located in designated 

Wellhead Protection Areas(WPA); however, no source associated with the site is 

within a WPA (Refs. 22, pp. 1-5; 34, p. 9). 

No documented private wells that draw water from the Sparta Aquifer are located 

within the 4-mile TDL of the Red Panther property 

3.3.1 NEAREST WELL

The nearest well completed in the Sparta Aquifer, Well 140002-4, is owned by the 

Clarksdale Public Utilities and is located within 0 to 0.25-mile distance category,

south of the Red Panther sources (Refs. 3; 22, pp. 1-5). 

Level of Contamination (I, II, or potential): Potential

Nearest Well Factor Value (Sparta Aquifer): 20

(Ref. 1, Table 3-11)
GW-Targets

51

3.3.2 POPULATION

3.3.2.1 Level of Contamination

3.3.2.2 Level I Concentrations

No Level I wells have been documented within the 4-mile TDL of the property.

Population Served by Level I Wells: 0

Level I Concentration Factor Value: 0

3.3.2.3 Level II Concentrations

No Level II wells have been documented within the 4-mile TDL of the property.

Population Served by Level II Wells: 0

Level II Concentrations Factor Value: 0

3.3.2.4 Potential Contamination

An observed release of site-attributable constituents has been documented in the 

surficial aquifer beneath the facility (See Section 3.1.1 of this Documentation 

Record). No municipal wells completed in the interconnected Mississippi River 

Valley Alluvial Aquifer and Sparta Sands aquifer have indicated elevated levels of 

site-attributable constituents (See Section 3.1.1 of this Documentation Record). 

The municipal wells completed in the Sparta aquifer within the 4-mile TDL of the 

sources at the site are all owned by the Clarksdale Public Utilities and are 

distributed as follows: 0- to 0.25-mile, 1 well; 0.25- to 0.5-mile, 0 wells; 0.5- to 

1-mile, 4 wells; 1- to 2-miles, 2 wells; 2- to 3-miles, 0 wells; 3- to 4-miles, 0 

wells (Refs. 3; 22, pp. 1-5; 24, p. 1). According to the U.S. Census Bureau, the 

average number of persons per household in Coahoma County based on the 2005 to 2009 

Census estimates is 2.69 (Ref. 24, p. 1). Clarksdale Public Utilities serves a 

total of 7,355 connections; therefore, the total population served by the 10 wells 

in the Clarksdale Public Utilities system is approximately 19,784.95 persons (Refs. 

22, pp. 1-5; 24, p. 1; 35, p. 1). Therefore, the population served by wells 

completed in the Sparta aquifer within the 4-mile TDL of the property are 

distributed as follows: 0- to 0.25-mile, 1,978.495 persons; 0.25- to 0.5-mile, 0 

persons; 0.5- to 1-mile, 7,913.98 persons; 1- to 2-miles, 3,956.99 persons; 2- to 3-

miles, 0 persons; 3- to 4-miles, 0 persons (Refs. 3; 22, pp. 1-5; 24, p. 1; 35, p. 

1; Figures 2 to 4 of this HRS documentation record). 
 

52

Municipal Wells within 4 Miles of the 

Red Panther Sources

Distance 

Category 

(miles)

Number of 

Municipal

Wells

(Sparta 

Aquifer) Well ID

Population per 

Distance Ring

Distance 

Weighted 

Population 

Value References

0 - 0.25 1 140002-4 1,978.495 1,633

1, Table 3-12;

3; 22, pp. 1-

5; 24, p. 1; 

35 p. 1; 

Figures 2 to 4

of the HRS 

documentation 

record

0.25 - 0.5 0 0 0

0.5 - 1

4

140002-1

140002-5

140002-6 

140002-7 7,913.98 1,669

1 - 2 2

140002-2

140002-8 3,956.99 939

2 - 3 0 0 0

3 - 4 0 0 0

Sum of Distance-Weighted Population Values: 1,633 + 1,669 + 939 = 4,241

(as applied to Reference 1 Section 3.3.2.4) = 4,241 ÷ 10 = 424.1

Potential Contamination Factor Value: 424.1

3.3.3 RESOURCES

Resources were not scored. 

 Resources Factor Value: 0

3.3.4 WELLHEAD PROTECTION AREA

All municipal wells in Mississippi are located within wellhead protection areas 

(WPA) (Refs. 22, pp. 1-5; 34, p. 9). No source lies above or within a WPA. 

Therefore, a factor value of 5 was assigned for WPA.

 Wellhead Protection Area Factor Value: 5
 

53

5.0 SOIL EXPOSURE PATHWAY

The Soil Exposure Pathway is being scored based on two areas of observed 

contamination (AOCs), AOC A (located on the Red Panther property) and AOC B 

(located in the residential area surrounding the Red Panther property) (see 

Figures 3 and 4 of this Documentation Record). The targets associated with the 

Soil Exposure Pathway include Level I and Level II populations residing in single 

family dwellings in the area surrounding the Red Panther property (Refs. 18, pp. 

49-77; 40, pp. 28-31, 50-87, 89-180). 

5.0.1 GENERAL CONSIDERATIONS

Letter by which this AOC is to be identified: A

Name of area: Red Panther property (Source 1)

Location and description of area (with reference to a map of the site):

The Red Panther property is located at 1201 Normandy Avenue in Clarksdale, 

Coahoma County, Mississippi (Refs. 3; 4, p. 4). The geographic coordinates of 

the property are 34° 11' 14.67" North latitude and 90° 33' 41.85" West longitude

as calculated from the north corner of the office and labs building on the 

property (Ref. 3). The former Red Panther facility is comprised of approximately 

6.5 acres (Refs. 5, p. 4; 6, p. 8; 7, p. 2). All of the samples listed below, 

except DGC-15, DGC-16, and DGC-17 were collected from within 200 feet of a 

workplace area (Ref. 17, pp. 184, 186-187). See Figure 1 of this Documentation 

Record for the location of the Red Panther Property.

Background Concentrations

Sample ID Sample Medium Depth Date Reference

SN-01-SS Soil 0-3 inches 8/10/05 18, pp. 40-41, 166

Sample ID Hazardous Substance

Concentration

(ug/kg)

Sample 

Quantitation 

Limit

(ug/kg)

Reference

SN-01-SS

Heptachlor epoxide 1.8U 1.8

18, pp. 85, 

125, 166; 

43, p. 93; 

45

Endosulfan II 3.5U 3.5

4,4’-DDD 3.5U 3.5

Endrin 3.5U 3.5

Dieldrin 3.5U 3.5

4,4-DDE 15 3.5

Toxaphene 180U 180

Gamma-chlordane 1.8U 1.8

Alpha-chlordane 1.8U 1.8

Arsenic 20,000 1,000*

Notes:

ug/kg – Micrograms per kilogram

U - Constituent analyzed for but not detected above reporting limit. DDD - 4,4’-dichloro-2,2-bis(p-chlorophenyl)ethylene

DDE - 4,4’-dichloro-2,2-bis(p-chlorophenyl)ethane

* - Contract Required Quantitation Limit (CRQL) (Ref. 43, p. 93)
 

54

Contaminated Samples

Area Letter: A

Sample ID Sample 

Medium

Depth

(inches bgs) Date Reference

BGC-1 Soil 24 5/11/05 17, pp. 184, 203, 

209

BGC-15 Soil 24 6/20/05 17, pp. 184, 205, 

212

CGC-2 Soil 24 5/11/05 17, pp. 186, 203, 

213

DGC-1 Soil 24 5/24/05 17, pp. 187, 201, 

214

DGC-15 Soil 24 6/6/05 17, pp. 187, 202, 

215

DGC-16 Soil 24 6/2/05 17, pp. 187, 208, 

216

DGC-17 Soil 24 6/6/05 17, pp. 187, 202, 

217

The composite surface soil samples listed below were collected during the Phase 

II Soil Removal activities conducted at Red Panther by URS and Newfields on 

behalf of Red Panther (Ref. 17, pp. 22-25, 184, 186-187). All surface soil 

samples were collected from 2 feet bls (Ref. 17, pp. 20-25, 184, 186-187). No 

background surface soil sample was collected; however, the samples listed were 

collected as confirmation samples after removal activities at the property based 

on the requirements of the 2001 Administrative Order on Consent (Ref. 17, pp. 7-

8, 20-25, 184, 186-187). All constituents listed in this section were included 

in the 2001 Administrative Order on Consent and agreed by the performing PRP to 

be remediated (Ref. 7, pp. 1, 3-7, 48). 

Sample 

ID

Date 

Collected

RL

(mg/kg)

Hazardous 

Substance

Hazardous 

Substance 

Concentration

(mg/kg) 

Background 

Concentration

(SN-01-SS)

(mg/kg) References

BGC-1 5/11/05

17, pp. 184, 

203, 209; 18, 

pp. 125, 166; 

26, p. 1; 27, 

p. 1 

3 Toxaphene 3.5 0.18

BGC-15 6/20/05

2 Arsenic 420 20 17, pp. 184, 

205, 212; 18, 

pp. 85, 125, 

166; 26, p. 1; 

27, p. 1 

0.1 Dieldrin 2.6 0.0035U

3 Toxaphene 7.4 0.18

CGC-2 5/11/05

2 Arsenic 210 20 17, pp. 186, 

203, 213; 18, 

pp. 85, 125, 

166; 26, p. 1; 

27, p. 1 

0.1 Dieldrin 0.89 0.0035U

3 Toxaphene 7.0 0.18
 

55

Sample 

ID

Date 

Collected

RL

(mg/kg)

Hazardous 

Substance

Hazardous 

Substance 

Concentration

(mg/kg) 

Background 

Concentration

(SN-01-SS)

(mg/kg) References

DGC-1 5/24/05

0.1 Dieldrin 0.54 0.0035U 17, pp. 187, 

201, 214; 18, 

pp. 125, 166; 

26, p. 1; 27, 

p. 1

3 Toxaphene 7.5 0.18

DGC-15 6/6/05

0.1 Dieldrin 11 0.0035U

17, pp. 187, 

202, 215; 18, 

pp. 125, 166; 

26, p. 1; 27, 

p. 1

3 Toxaphene 14 0.18U

DGC-16 6/2/05

0.1 Dieldrin 2.9 0.0035U 17, pp. 187, 

208, 216; 18, 

pp. 125, 166; 

26, p. 1; 27, 

p. 1

3 Toxaphene 220 0.18U

DGC-17 6/6/05

0.1 Dieldrin 0.83 0.0035U 17, pp. 187, 

202, 217; 18, 

pp. 125, 166; 

26, p. 1; 27, 

p. 1

3 Toxaphene 3.1 0.18U

Notes:

 mg/kg - Milligrams per kilogram

 RL - Reporting Limit
 

56

5.1.2.2 AREA HAZARDOUS WASTE QUANTITY

Hazardous Constituent Quantity

Insufficient data is available to calculate the hazardous constituent quantity.

Hazardous Constituent Quantity Value (S): Not Scored

Hazardous Wastestream Quantity

Insufficient data is available to calculate the hazardous wastestream quantity.

Hazardous Wastestream Quantity Value (W): Not Scored

Volume

This tier cannot be used for contaminated soil.

Volume Value (V): Not scored

Area

The area of observed contamination is formed by a perimeter of composite 

confirmation sample locations CGC-2, BGC-1, BGC-15, DGC-1, DGC-15, DGC-16, and 

DGC-17 collected during the Phase II Soil Removal by URS and Newfields for Red 

Panther (Ref. 17, pp. 184, 186-187). Removal activities were conducted by the 

PRP; insufficient sampling has been performed to determine the extent of 

contaminated soil remaining. Therefore, the area of observed contamination for 

AOC A was determined to be >0 ft2 (Ref. 17, pp. 184, 186-187).

Equation for hazardous waste quantity evaluation for the contaminated soil is 

A/34,000. Therefore, >0 ft2 /34,000 = >0

Area Assigned Value: >0

Area Hazardous Waste Quantity Value

Area Hazardous Waste Quantity Value: >0
 

57

Letter by which this AOC is to be identified: B

Name of AOC: Area Surrounding Red Panther (Source 2)

Location and description of area (with reference to a map of the site):

AOC B (Source 2) consists of contaminated soil in the area to the north, south, 

east, and west of the Red Panther facility (Ref. 3). The area north, east, and 

south of the facility is a mix of commercial and industrial properties, with 

residential properties farther east (Refs. 3; 40, p. 7). The 18th Street 

Neighborhood is located west of the Red Panther property and consists of single 

family dwellings on approximately 0.25 acre lots (Refs. 3; 18, p. 4, 13; 31). 

According to a 1935 USGS Quadrangle map and a 1938 aerial photograph, this area 

has been historically used as a residential neighborhood. The area has not been 

used for agricultural purposes, at least since 1935 (Ref. 40, p. 7). See Figures

3 and 4 of this Documentation Record for the location of Source 2.

Elevated concentrations of pesticides in Area B are a result of air deposition 

from the Red Panther facility during facility operations (Refs. 40, p. 20; 46, 

pp. 2, 5, 7, 21, 22). A citizen complaint of dead vegetation, including 

evergreen trees, tomato and pepper plants, and shrubs resulted in an inspection 

by the Mississippi Department of Air and Water Pollution Control in 1975 (Ref. 

32, p. 1). The inspector noted highly dusty conditions inside the plant and open 

doors during product formulation (Ref. 32, pp. 1-2). Residents had historically 

been financially reimbursed by the Riverside Chemical Company for damage to

gardens (Ref. 32, p. 2).

The Removal Assessment of the 18th Street Neighborhood was conducted in August 

2005 by Weston for EPA to characterize the nature and extent of contaminated soil 

on residential properties in the neighborhood (Ref. 18, p. 4). Composite samples 

using three to five aliquots per sample collected from 30 residential properties 

in the neighborhood indicated the presence of contaminated soil at a depth of 

less than 1 foot bgs on several of the properties sampled (Ref. 18, pp. 7, 9, 16-

21, 29-47, 85-117, 125-157, 159-171). The background sample (SN-01-SS) was 

collected from the B.F. McLaurin Park as a reference to determine what direct 

impact Red Panther operations might have had on the soils in the nearby 

neighborhood (Ref. 18, pp. 7, 40-41). All samples collected during the 

investigation were analyzed for pesticides, aluminum, arsenic, iron, and other 

metals (Ref. 18, pp. 16-22, 78-171). Soil samples were elevated above background 

concentrations for pesticides, including dieldrin; toxaphene; 4,4’-DDD; alphachlordane; gamma-chlordane; endosulfan sulfate; and endrin (Ref. 18, pp. 16-22). 

No metals were detected at elevated concentrations in any samples (Ref. 18, pp. 

78-171). 

From June 29 to July 1, 2010, OTIE conducted an ADS on behalf of EPA in the area 

of the former Red Panther facility (Refs. 40, pp. 5, 14, 182-287; 41, pp. 1, 5). 

The purpose of the ADS was to evaluate the presence of pesticides in the surface 

soils surrounding the former Red Panther facility (Ref. 40, p. 5). Field 

investigation activities included the collection of surface soil samples in every 

direction from the facility to determine if contaminant concentrations previously 

identified in the residential neighborhood to the west of the facility (18th

Street Neighborhood) were a result of the pesticide formulation activities at the 

facility or if the presence of the agricultural fields nearby contributed to the 

pesticide contamination (Ref. 40, p. 5). A total of 81 nine-point composite 

surface soil samples were collected from 73 locations in a 1⁄4-mile area 

surrounding the facility, including 8 duplicate samples (Refs. 40, pp. 14-18; 41, 

pp. 31-32). Four background composite samples, including one duplicate, were 

collected north and northeast of the facility from areas 0.7- to 1.1-mile distant 

from the facility to ensure an adequate background for comparison purposes (Refs. 

40, pp. 15, 19-20; 41, pp. 31-32). The 73 composite soil samples were collected 
 

58

in a grid pattern with 300-foot centers in all directions from the facility. At 

each 300-foot center, composite soil samples were collected from the 0- to 3-inch 

bgs interval; each sample consisted of nine aliquots within a 25-by-25 foot 

sampling sub-grid (Ref. 40, p. 15). All aliquots of the composite were collected 

from within the respective property boundary and, for residential grids, less 

than 200 feet from the residential structure (Ref. 40, p. 15; 42, p. 1). Each 

25-by-25 foot grid was approximately 300 feet apart. The background samples 

were collected in the same manner from three residential properties located in 

neighborhoods of approximately the same age as the 18th Street Neighborhood (Ref. 

40, pp. 15-16). 

Elevated concentrations of 4,4’-DDD; 4,4’-DDE; 4,4’-DDT; aldrin; alpha-BHC; betaBHC; delta-BHC; dieldrin; endosulfan sulfate; endrin; endrin aldehyde; lindane; 

gamma-chlordane; heptachlor; heptachlor epoxide; and toxaphene were detected in 

the composite surface soil samples when compared to the highest concentration of 

the pesticide in all background samples (Ref. 40, pp. 35-48, 88-180). Although 

pesticide constituents were detected in the background samples, toxaphene was not 

detected in any of the background samples (Ref. 40, pp. 18-20, 35). Higher 

concentrations of DDT, DDD, and DDE were detected in areas closer to the facility 

(Ref. 40, pp. 18-20, 28-30, 35-48). Toxaphene was identified in eight samples 

collected near the facility, with concentrations increasing closer to the 

facility (Ref. 40, pp. 19-20, 30, 35-48). Modeling of the toxaphene contaminant 

concentrations suggests the facility is the source of toxaphene (Ref. 40, pp. 19-

20, 30). Dieldrin was identified in half of the samples collected, generally in 

higher concentrations nearest the facility and declining to non-detect 

concentrations in the outlying samples (Ref. 40, pp. 19-20, 35-48). The highest 

dieldrin concentration (3,800 ug/kg) was identified in the sample collected 

closest to the facility (Ref. 40, pp. 19-20, 31, 35-48). According to the ADS, 

the absence of dieldrin in samples adjacent to agricultural fields and the 

presence of higher concentrations near the facility indicate that Red Panther is 

the source of an increase in dieldrin contamination in the area (Ref. 40, pp. 19-

20, 31, 35-48). In general, the ADS concluded that the higher contaminant 

concentrations near the facility resulted from historic Red Panther facility 

activities (Ref. 40, p. 20-21, 31, 35-48). 

Contaminants associated with AOC B include 4,4’-DDD; 4,4’-DDE; 4,4’-DDT; aldrin; 

alpha-BHC; alpha-chlordane; beta-BHC; delta-BHC; dieldrin; endosulfan sulfate; 

endrin; endrin aldehyde; gamma chlordane; lindane; heptachlor; heptachlor 

epoxide; and toxaphene (Refs. 18, pp. 16-21, 29-47, 85-117, 125-157, 159-171; 40, 

pp. 89-180).
 

59

-Background samples

One background sample was collected during the 2005 Weston Removal Assessment 

(Ref. 18, pp. 4, 7). The background surface soil sample was collected from BF 

McLaurin Park located on Sunflower Avenue, near 6th Street, approximately 0.5 

mile north of the 18th Street Neighborhood (Ref. 18, pp. 7, 40-41, 49). The 

background sample was a composite sample collected between 0 and 12 inches bgs

(Ref. 18, pp. 29-47).

The four background composite surface soil samples collected during the 2010 ADS, 

including one duplicate, were collected from residential properties located 0.7-

to 1.1-mile distant from the facility to ensure an adequate background for 

comparison purposes (Ref. 40, pp. 14-15; 41, pp. 31-32). All samples were 

collected in accordance with the guidance presented in the EPA-approved sitespecific QAPP/SSP and in accordance with the EPA SESD FBQSTP (Refs. 40, pp. 6, 

14; 41). Each aliquot of the composite was collected from the same property, 

within 200 feet of the home (Ref. 40, p. 15). The neighborhoods selected for the 

background samples were of approximately the same age as the 18th Street 

Neighborhood; the background composite soil samples consisted of similar soil 

types (Ref. 40, pp. 14-15). Soil contamination in the area is largely a result 

of air deposition of particulates from the Red Panther facility. There is no one 

prevailing wind direction in the area (Ref. 40, p. 17). In addition, some 

pesticide presence in the background is to be expected due to use on agricultural 

fields in the area (Ref. 40, pp. 19-20).

Sample ID Sample Medium Depth Date Reference

SN-01-SS Soil 0-3 inches 8/10/05 18, pp. 40-41, 85, 

125, 162, 166

RP-CS-01

RP-CS-77 

(duplicate)

Soil 0-3 inches 6/29/10

40, pp. 15-16, 25, 

33, 194, 210, 295, 

297

RP-CS-02 Soil 0-3 inches 7/1/10

40, pp. 15-16, 25, 

33, 194, 230, 288

RP-CS-03 Soil 0-3 inches 7/1/10

40, pp. 15-16, 25, 

33, 194, 229, 288

Sample ID Hazardous Substance

Concentration

(ug/kg)

Sample 

Quantitation 

Limit

(ug/kg)

Reference

SN-01-SS

Heptachlor epoxide 1.8U 1.8

18, pp. 

125, 166

Endosulfan II 3.5U 3.5

4,4’-DDD 3.5U 3.5

Endrin 3.5U 3.5

Dieldrin 3.5U 3.5

4,4-DDE 15 3.5

Toxaphene 180U 180

Gamma-chlordane 1.8U 1.8

Alpha-chlordane 1.8U 1.8

Notes:

ug/kg – Micrograms per kilogram

U - Constituent analyzed for but was not detected at or above 
 

60

reporting limit. DDD - 4,4’-dichloro-2,2-bis(p-chlorophenyl)ethylene

DDE - 4,4’-dichloro-2,2-bis(p-chlorophenyl)ethane

The highest hazardous substance concentration or highest sample quantitation 

limit of a substance if it is not detected in background samples RP-CS-01 and its 

duplicate RP-CS-77, RP-CS-02 or RP-CS-03 is listed below as the background level.

Sample 

ID

Hazardous Substance Concentration

(ug/kg)

Minimum 

Reporting 

Limit 

(ug/kg)a

Reference

RP-CS-77 4,4’-DDD

34 10

40, pp. 91, 94, 

97

RP-CS-77 4,4’-DDE

22 5.1

40, pp. 91, 94,

97

RP-CS-77 4,4’-DDT

34 13

40, pp. 91, 94, 

97

RP-CS-03 Aldrin

3.1U 3.1

40, pp. 92, 94, 

160

RP-CS-03 Alpha-BHC

1.6U 1.6

40, pp. 92, 94, 

160

RP-CS-03 Beta-BHC

3.1U

3.1 40, pp. 92, 94, 

160

RP-CS-03 Dieldrin

52 7.8

40, pp. 92, 94, 

160

RP-CS-02 Endosulfan sulfate

7.9U 7.9

40, pp. 91, 94, 

159

RP-CS-01 Endrin

29U, D-4 29

40, pp. 91, 94, 

96

RP-CS-02 Endrin aldehyde

7.9U 7.9

40, pp. 91, 94, 

159

RP-CS-77 Gamma-chlordane

27 5.1

40, pp. 91, 94, 

97

RP-CS-01 Heptachlor 2.4 0.76 40, pp. 91, 96

RP-CS-03 Heptachlor epoxide

3.2 3.1

40, PP. 92, 94, 

160

RP-CS-01 Toxaphene

350U, D-4 350

40, pp. 91, 94, 

96

Notes:

a - Minimum reporting limit is equivalent to the Sample Quantitation 

limit (Ref. 45).

D-4 - MRL elevated due to interference.

J - Constituent was detected, value is an estimate.

ug/kg - Micrograms per kilogram

U - Constituent was analyzed for but was not detected at or above the

 reporting limit.

The concentrations for background samples are also presented in the same table 

with the contaminated samples. 
 

61

Contaminated Samples

The composite surface soil samples listed below were collected by Weston for EPA 

during the Removal Assessment conducted at the 18th Street Neighborhood and by 

OTIE for EPA during the Air Deposition Study (Ref. 18, pp. 1-171; 41). 

For the 2005 Weston Removal Assessment, all composite surface soil samples were 

collected between 0 to 12 inches bgs from locations within 200 feet of the 

residences or play grounds located on the properties (see Figure 3)(Refs. 18, pp. 

29-47). Generally, the soil samples were comprised of light brown sandy silt 

(Ref. 18, pp. 29-31). For the 2010 OTIE ADS, the composite surface soil samples 

listed below were collected by OTIE from locations in a 1⁄4-mile area surrounding 

the Red Panther facility (Ref. 40, pp. 14, 15, 18). All composite surface soil 

samples were collected from 0-to 3-inches bgs and were comprised of a nine 

aliquots collected from a 25-by-25 foot grid (Ref. 40, pp. 14-15). The centers 

of the 25-foot grids were located 300 feet apart (Ref. 40, pp. 14-15). All 

aliquots of the individual sample were collected from within the legal property 

boundary and, in the case of residential samples, within 200 feet of the building 

(Ref. 40, pp. 14-15). See Figures 3 and 4 of this Documentation Record for 

sample locations.

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(ug/kg)

Contract 

Required 

Quantitation 

Limit (ug/kg)

Background 

Concentration

(ug/kg) References

SN-03-SS 4,4-DDE 58 3.3 15

18, pp. 127, 

162; 44, p. 3

SN-04-SS 4,4-DDE 58 3.3 15

18, pp. 128, 

166; 44, p. 3

SN-05-SS

4,4-DDE 78 3.3 15 18, pp. 129, 

166; 44, p. 3

Dieldrin 42 3.3 3.5U

SN-06-SS

4,4-DDE 190 3.3 15 18, pp. 130, 

166; 44, p. 3

Dieldrin 58 3.3 3.5U

SN-07-SS

4,4-DDE 540 3.3 15

18, pp. 131, 

Dieldrin 200 3.3 3.5U 166; 44, p. 3

Alpha 

Chlordane 5.2 1.7 1.8U

SN-08-SS

4,4-DDE 500 3.3 15

18, pp. 132, 

166; 44, p. 3

4,4-DDD 64 3.3 3.5U

Dieldrin 360 3.3 3.5U

Endosulfan 

II 570 3.3 3.5U

SN-11-SS

4,4-DDE 160 3.3 15 18, pp. 136, 

166-167; 44, 

p. 3 4,4-DDD 19 3.3 3.5U
 

62

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(ug/kg)

Contract 

Required 

Quantitation 

Limit (ug/kg)

Background 

Concentration

(ug/kg) References

Dieldrin 77 3.3 3.5U

Alpha 

Chlordane 100 1.7 1.8U

Gamma 

Chlordane 110 1.7 1.8U

SN-12-SS

4,4-DDE 170 3.3 15 18, pp. 137, 

167; 44, p. 3

Toxaphene 4,500 170 180U

SN-13-SS

4,4-DDE 320 3.3 15

18, pp. 138, 

167; 44, p. 3

Alpha 

Chlordane 53 1.7 1.8U

Gamma 

Chlordane 44 1.7 1.8U

SN-14-SS 4,4-DDE 170 3.3 15 18, pp. 139, 

167; 44, p. 3

SN-16-SS 4,4-DDE 73 3.3 15 18, pp. 141, 

167; 44, p. 3

SN-18-SS

4,4-DDE 280 3.3 15

18, pp. 143, 

167; 44, p. 3

4,4-DDD 19 3.3 3.5U

Gamma 

Chlordane 29 1.7 1.8U

Endrin 7.2 3.3 3.5U

SN-19-SS Gamma 

Chlordane

62J*

(6.2)

1.7 1.8U

18, pp. 144, 

167; 44, p.3

SN-20-SS Dieldrin 10 3.3 3.5U

18, pp. 146,

168, 170; 44, 

p. 3

SN-21-SS

4,4-DDE 270 3.3 15

18, pp. 147, 

168, 170; 44, 

p. 3

4,4-DDD 20 3.3 3.5U

Dieldrin 380 3.3 3.5U

Heptachlor 

Epoxide 4.6 1.7 1.8U

Alpha 

Chlordane 6.1 1.7 1.8U

SN-24-SS

4,4-DDE 150 3.3 15 18, pp. 150, 

168, 170; 44, 

Toxaphene 4,700 170 180U p. 3

SN-25-SS 4,4-DDE 82 3.3 15 18, pp. 151, 

168, 170; 

44, p. 3 Toxaphene 1,900 170 180U
 

63

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(ug/kg)

Contract 

Required 

Quantitation 

Limit (ug/kg)

Background 

Concentration

(ug/kg) References

Gamma 

Chlordane 7.2 1.7 1.8U

SN-26-SS

4,4-DDE 180 3.3 15

18, pp. 152, 

168, 170; 44, 

p. 3

Endosulfan 

II 12 3.3 3.5U

Toxaphene 810 170 180U

SN-27-SS

4,4-DDE 110 3.3 15 18, pp. 153, 

168, 170; 44, 

4,4-DDD 7.2 3.3 3.5U p. 3

SN-29-SS

4,4-DDE 90 3.3 25

18, pp. 155, 

169, 171; 44, 

p. 3

Dieldrin 36 3.3 3.5U

Alpha 

Chlordane 3.5 1.7 1.8U

SN-30-SS

4,4-DDE 250 3.3 15

18, pp. 156, 

169, 171; 44, 

p. 3

Dieldrin 42 3.3 3.5U

Alpha 

Chlordane 6.6 1.7 1.8U

SN-31-SS

4,4-DDE 130 3.3 15 18, pp. 157, 

169, 171; 44, 

Dieldrin 32 3.3 3.5U p. 3

RP-CS-05

4,4’-DDD 220 95 34

40, pp. 91-

92, 96-97, 

99, 159, 160; 

44, p. 3

4,4’-DDE 220 48 22

4,4’-DDT 310 120 34

Aldrin 12 4.8 3.1U

Dieldrin 230 48 52

Gammachlordane 530 48 27

Heptachlor 210 36 2.4

Heptachlor 

epoxide 290 48 3.2

RP-CS-06 Dieldrin 160 4.5 7.9U

40, pp. 91-

92, 96-97, 

100, 159, 160

RP-CS-08 Endrin 

aldehyde 11 7.8 7.9U

40, pp. 91-

92, 96-97,, 

159, 160

RP-CS-09 4,4’-DDE 84 7.7 22

40, pp. 91-

92, 96-97, 

159, 160-161

RP-CS-11 4,4’-DDE 94 7.4 22 40, pp. 91-
 

64

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(ug/kg)

Contract 

Required 

Quantitation 

Limit (ug/kg)

Background 

Concentration

(ug/kg) References

4,4’-DDT 110 19 34

92, 94, 96-

97, 130, 159, 

160

RP-CS-12 Alpha-BHC 3.4 1.7 1.6U

40, pp. 91-

92, 96-97, 

131, 159, 160

RP-CS-18

Aldrin 34 4.7 3.1U 40, pp. 91-

92, 96-97, 

Dieldrin 840 93 52 104, 159, 160

RP-CS-19 4,4’-DDE 68 4.7 22

40, pp. 91-

92, 96-97, 

105, 159, 160

RP-CS-20 Endrin 

aldehyde 8 7.6 7.9U

40, pp. 91-

92, 96-97, 

135, 159, 160

RP-CS-23 4,4’-DDE 82 7.7 22

40, pp. 91-

92, 96-97, 

159, 160, 164

RP-CS-24

4,4’-DDD 120 15 34

40, pp. 91-

92, 96-97, 

159, 160, 

165

4,4’-DDE 260 76 22

4,4’-DDT 240 19 34

Dieldrin 2200 380 52

Toxaphene 5300 1500 350U

RP-CS-28 4,4’-DDE 110 42 22

40, pp. 91-

92, 96-97, 

106, 159, 160

RP-CS-29 4,4’-DDE 99 8.8 22

40, pp. 91-

92, 96-97, 

107, 159, 160

RP-CS-32 4,4’-DDT 110 12 34

40, pp. 91-

92, 96-97, 

111, 159, 160

RP-CS-38

4,4’-DDT 330 120 34 40, pp. 91-

92, 96-97, 

114, 159, 160 Heptachlor 

epoxide 51 4.7 3.2

RP-CS-39 4,4’-DDT 130 13 34

40, pp. 91-

92, 96-97, 

115, 159, 160

RP-CS-47

4,4’-DDT 170 27 34 40, pp. 91-

92, 96-97, 

Beta-BHC 9.7 1.1 3.1U 117, 159, 160

RP-CS-50 4,4’-DDE 90 9.6 22

40, pp. 91-

92, 96-97, 

120, 159, 160

RP-CS-57 4,4’-DDE 88 9.6 22 40, pp. 91-

92, 96-97, 
 

65

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(ug/kg)

Contract 

Required 

Quantitation 

Limit (ug/kg)

Background 

Concentration

(ug/kg) References

122, 159, 160

RP-CS-60

4,4’-DDE 180 19 22 40, pp. 91-

92, 96-97, 

4,4’-DDT 280 48 34 125, 159, 160 

RP-CS-61

4,4’-DDE 1100 140 22

40, pp. 91-

92, 93, 96-

97, 116, 159, 

160, 171

4,4’-DDT 950 180 34

Beta-BHC 56 7.2 3.1U

Dieldrin 3800 360 52

Endosulfan 

sulfate 80 18 7.9U

Endrin 110 14 29U

Toxaphene 5900 2900 350U

RP-CS-62

4,4’-DDD 80 16 34

40, pp. 91-

92, 96-97, 

159, 160, 

172

4,4’-DDE 390 79 22

4,4’-DDT 140 20 34

Dieldrin 1700 320 52

Toxaphene 2400 790 350U

RP-CS-66 4,4’-DDT 120 16 34

40, pp. 91-

92, 96-97, 

159, 156, 160

RP-CS-75

4,4’-DDE 87 7.2 22 40, pp. 91-

92, 94, 96-

97, 159, 160 

180 Dieldrin 210 29 52

Notes:

ug/kg - Micrograms per kilogram

U - Constituent was analyzed for but not detected above the reporting

 limit.

J - Constituent was detected, value is an estimate

* - Identification of analyte is acceptable; bias unknown. Value adjusted 

 (62/10 = 6.2J) (Ref. 33, pp. 8, 17).
 

66

5.1.2.2 AREA HAZARDOUS WASTE QUANTITY

Hazardous Constituent Quantity

Insufficient data is available to calculate the hazardous constituent quantity.

Hazardous Constituent Quantity Value (S): Not Scored

Hazardous Wastestream Quantity

Insufficient data is available to calculate the hazardous wastestream quantity.

Hazardous Wastestream Quantity Value (W): Not Scored

Volume

This tier cannot be used for contaminated soil.

Volume Value (V): Not scored

2.4.2.1.4 Area

All soil samples were collected within the legal property boundaries of each 

property; soil contamination between the samples was inferred unless sampling 

data indicated no presence of significant levels of contamination. The area of 

soil contamination was estimated to be >0 ft2

. 

Equation for hazardous waste quantity evaluation for the contaminated soil is 

A/34,000. Therefore, >0 ft2 /34,000 = >0

Area Assigned Value: >0

Reference: 1, Table 2-5

Area Hazardous Waste Quantity Value

Area Hazardous Waste Quantity Value: >0

Reference: 1, Section 2.4.2.2

Attribution:

Red Panther operated as a pesticide formulation plant between 1949 and 1996

formulating liquid and dry herbicide, insecticide, and fungicide products (Refs. 

4, p. 4; 5, p. 3; 6, p. 8; 7, p. 2). Chemicals used in the formulation process 

included toxaphene; aldrin; arsenic; 4,4’-DDT; methyl parathion; chlorpyrifos;

2,4-D; malathion; carbaryl; diazinon; methoxychlor; DSMA; MSMA; chlorothalonil;

and parathion (Refs. 6, p. 8; 7, p. 3; 9, p. 2). Air permits allowing for the 

operation of emission equipment and emit air contaminants for the formulation of 

pesticides and herbicides were issued to Red Panther from 1979 through 1991 (Ref. 

46, pp. 1-46). Four stacks were part of the manufacturing process, with heights 

between 20 and 30 feet (Ref. 46, p. 29). According to air permit records, 

arsenic; 2,4-D; methanol; xylene; and ethylene glycol were emitted at the 

facility from the four stacks (Ref. 46, pp. 28-31, 42). Wastewater and solvents 

containing pesticide and solvent residues were generated from equipment cleaning 

(Refs. 5, p. 3; 6, p. 8). Prior to obtaining interim status, wastewater 

containing pesticide and solvent residues were generated during equipment

cleaning at the facility and discharged either directly to a drainage ditch or 

into an underground septic tank and drain field on the facility property (Refs. 

5, p. 5; 6, pp. 8-9). Contamination on the Red Panther property is also believed 
 

67

to have originated from numerous spills during loading and unloading operations, 

contaminated wastewater releases, from spills and leaking underground piping in 

the tank farm area, and poor housekeeping practices during production including 

allowing the doors to the stack house to remain open during processing activities 

(Refs. 9, p. 2; 32, pp. 1, 2). 

There is no prevailing wind direction data for the area of the facility (Ref. 40, 

p. 18). Wind direction data from 1961 to 1990 in Memphis indicates widely varying 

wind direction throughout the year with slightly dominant wind directions varying 

from month to month (Refs. 40, p. 18; 47, pp. 1-15).

The Mississippi Department of Air and Water Pollution Control Commission filed a 

Report of Field Investigation on May 6, 1975 (Ref. 32, p. 1). The report was a 

result of a citizen complaint of dead vegetation from the actions of the 

Riverside Chemical Company (Ref. 32, p. 1). The inspector visited the residence 

and noted dead plant life including evergreen trees, tomato and pepper plants, 

and shrubs (Ref. 32, p. 1). After visiting the residence, the inspector visited 

the chemical plant (the current Red Panther property) and noted baghouse dust 

collectors; however, he also observed highly dusty conditions inside the plant 

and open doors during product formulation, which led him to determine that 

compounds could be escaping the plant through the open doors (Ref. 32, pp. 1-2). 

The inspector collected samples of the dead vegetation at the residence for 

analysis and noted dead vegetation in additional areas adjacent to the facility 

(Ref. 32, p. 2). The inspector noted in his report that residents had been 

financially reimbursed by Riverside Chemical Company in 1974 for a damaged garden 

(Ref. 32, p. 1). 

A fire in 1985 at the facility occurred in a warehouse where 382 old fiber drums 

were discovered in the crawlspace beneath the warehouse (Ref. 11, p. 5). No air 

samples were collected during the fire; however, 95 of the drums contained trace 

residues of technical grade dieldrin (Ref. 11, p. 5). Contaminated water was 

contained on the property and later shipped to a commercial hazardous waste 

disposal facility (Ref. 11, p. 5). 

During the 1991 SSI, a soil sample collected near the wastewater collection pit 

near the south tank farm indicated the presence of analytes including 1,130 parts 

per million (ppm) toxaphene, 245 ppm DDT, 1,650,000 ug/kg xyles, and 250,000 

ug/kg ethylbenzene (Ref. 11, p. 11). 

In 1999, EPA tasked Tetra Tech EM, Inc., under the START contract to conduct 

surface and subsurface soil sampling of the drainage ditches east of the Red 

Panther property, the former facility leaching field and septic tank on the north 

side of the property, and the rail spur in front of the loading dock that runs 

along the west side of the property (Ref. 13, pp. 4, 5, 13-26). Samples were 

analyzed for RCRA metals and pesticides (Ref. 13, p. 10). The results from the 

sampling event indicated that the facility was contaminated with arsenic, 

organochlorinated pesticides, and degradation by-products including, but not 

limited to, aldrin; chlordane; dieldrin; 4,4’-DDT; endrin; endosulfan II; and 

toxaphene (Ref. 13, pp. 10, 27-41). 

On September 4, 2001, the Administrative Order on Consent for the Red Panther 

property between the PRPs and EPA Region 4 was finalized (Ref. 7, pp. 25-48). 

The Administrative Order on Consent identified four COCs for surface soil 

criteria and three COCs for subsurface soil criteria (Ref. 7, pp. 6-7, 21-24). 

The surface COCs were identified as arsenic, toxaphene, dieldrin, and total 

chlorinated pesticides (Ref. 7, p. 6). The subsurface COCs were identified as 

arsenic, toxaphene, and dieldrin (Ref. 7, p. 7). The Administrative Order on 

Consent required the PRPs to perform two phases of removal activities and 
 

68

disposal of excavated materials under all requirements of the Administrative 

Order on Consent (Ref. 7, pp. 5-9). EPA subsequently submitted the Action 

Memorandum documenting approval of the proposed removal action (Ref. 9).

On March 18, 2003, URS submitted the Phase I Removal Action Report and the Phase 

I Soil Characterization Report (Refs. 6, p. 1; 15, p. 1). Based on the results, 

URS recommended addressing the soils exceeding performance standards and 

addressing disposal options for the stockpiled soils in Ditch 1 in the Phase II 

Work Plan (Ref. 6, p. 17). The report was approved by EPA on April 10, 2003 

(Ref. 16, p. 8). During the Interim Removal, the contents of eight ASTs ranging 

in size from 200 gallons up to 15,000 gallons in the Tank Farm were cleaned out 

and the solids and/or liquids impacted with arsenic and/or pesticides were 

disposed of off the property (Ref. 17, p. 7). During the Phase II Removal, a 

total of 5,341.27 tons of arsenic-impacted soils and 200 tons of pesticideimpacted soils were removed from the AST storage area; 1,903.73 tons of hazardous 

pesticide-impacted soils were removed from the loading dock and railroad spur 

area. Additional soils were removed from the AST storage area, loading dock and 

railroad spur area, silo area and property ditches, but was not characterized as 

hazardous or pesticide-impacted soils (Ref. 17, p. 8).

Surface soil concentrations of pesticides and arsenic remain beneath the Red 

Panther property and sampling of nearby residences in the 18th Street 

Neighborhood has indicated elevated levels of pesticides in the surface soils of 

the residential properties (Refs. 17, pp. 7-8, 22-25, 184, 186, 187; 18, pp. 7-9, 

16-19, 28-47, 120-171). Based on historical aerial photographs and Sanborn® 

maps, portions of the 18th Street Neighborhood (13th through 16th Street) were 

present as a residential area in the current location as early as 1918 and the 

area has remained a residential neighborhood (Refs. 28, p. 1; 29, pp. 1-10).

During the week of June 28, 2010, OTIE conducted an ADS on behalf of EPA in the 

area of the former Red Panther facility (Refs. 40, pp. 5, 14; 41, pp. 1, 5). The 

purpose of the ADS was to evaluate the presence of pesticides in the surface 

soils surrounding the former Red Panther facility and to identify background soil 

samples outside the area of the influence for the Red Panther facility (Refs. 40, 

p. 5; 41, pp. 24-25). Field investigation activities included the collection of 

surface soil samples in every direction from the facility to determine if 

contaminant concentrations previously identified in the residential neighborhood 

to the west of the facility (18th Street Neighborhood) were a result of the 

pesticide formulation activities at the facility or if the presence of the 

operation of agricultural fields in the vicinity contributed to the pesticide 

contamination (Ref. 40, p. 5). A total of 76 composite surface soil samples were 

collected in a 0.25-mile area surrounding the facility (Refs. 40, pp. 14-17; 41, 

pp. 31-32). Three background composite samples were collected north and 

northeast of the facility from areas 0.7- to 1.1-mile distant from the facility 

to ensure an adequate background for comparison purposes (Refs. 40, pp. 14-17; 

41, pp. 31-32). Although several other pesticide constituents were detected in 

the background samples, toxaphene was not detected in any of the three background 

samples (Ref. 40, p. 18-20). Concentrations of DDT, DDD, and DDE were detected 

in several samples and analysis indicated a trend for increased concentrations as 

distance to the Red Panther facility decreased (Ref. 40, p. 18-20). Toxaphene 

was identified in eight samples collected near the Red Panther facility, with 

concentrations again increasing with decreased distance to the facility (Ref. 40, 

p. 20). Modeling of the toxaphene contaminant concentrations suggests the 

facility is the source of toxaphene (Ref. 40, p. 19). Dieldrin was identified in 

half of the samples collected, again in generally higher concentrations near the 

facility and declining to non-detect concentrations in the outlying samples (Ref. 

40, p. 19). The highest dieldrin concentration (3,800 ug/kg) was identified in 

the sample collected closest to the Red Panther facility (Ref. 40, p. 20). The 
 

69

absence of dieldrin in samples adjacent to the nearby agricultural fields 

combined with the presence of higher concentrations near the Red Panther facility 

indicates that Red Panther is the source of toxaphene and dieldrin contamination 

in the area (Ref. 40, pp. 19-20). In general, the ADS concluded that the higher 

contaminant concentrations near the facility suggest that the pesticide 

contamination in the vicinity is the result of historic Red Panther facility 

activities and not the result of legal application on nearby agricultural fields 

(Ref. 40, pp. 20-21). 

MDEQ personnel conducted a search in the City Directories of Clarksdale, 

Mississippi to identify any additional businesses in the area specializing in the 

manufacture or distribution of pesticides, herbicides, or insecticides (Ref. 30, 

pp. 1-20). The City Directory search covered the years 1949, 1953, 1963, 1973, 

1983, and 1996-1997 (Ref. 30, p. 1). The results of the search determined that 

Red Panther and the previous owners of the facility have historically been the 

only pesticide, insecticide, and herbicide manufacturers/distributors in the City 

of Clarksdale (Ref. 30, pp. 1-20). 

A radial search for businesses within 2 miles of the Red Panther was conducted by 

EDR (Ref. 25, pp. 1-315). The EDR radial report searched multiple databases 

including, but not limited to, federal, state, tribal, local land records, 

emergency release reports, and EDR proprietary records (Ref. 25, pp. 4-6, 227-

243). Additionally, properties that could not be mapped (orphaned) are listed; 

however, their exact location in relation to the Red Panther property is unknown 

(Ref. 25, p. 226). No NPL sites, Indian Reservations, DOD sites, or manufactured 

gas plants are located within a 2-mile radius of the Red Panther property (Ref. 

25, p. 16). 

The EDR report identified a USS Agri-Chemicals facility located to the northwest 

within the 0.25- to 0.5-mile radius of the Red Panther property (Ref. 25, pp. 12, 

16, 77-78). USS Agri-Chemicals, EPA ID No. MSD000798850, is a private company 

listed as a RCRA-Non Generator (Ref. 25, p. 78). The facility is listed as 

having one waste, dimethoate, associated with the business and does not generate 

or transport hazardous waste (Ref. 25, p. 78). No additional information for the 

facility was available.
 

70

Several of the insecticides/pesticides formulated or distributed during the 

operational history at the Red Panther property, including toxaphene, dieldrin, 

and DDT are currently banned from production and use in the United States (Refs. 

26, p. 1; 27, p. 1; 36, p. 2). Toxaphene was one of the most heavily used 

insecticides in the United States until it was banned in 1982 (Ref. 26, p. 1). 

Toxaphene was used to control insect pests on cotton and other crops, to control 

insect pests on livestock, and to kill unwanted fish species in lakes (Ref. 26, 

p. 1). It is a man-made mixture of over 670 chemicals that is yellow-to-amber in 

color and is a waxy solid that smells like turpentine (Ref. 26, p. 1). Dieldrin 

was widely used in the United States from the 1950s to the early 1970s (Ref. 27, 

p. 1). Dieldrin was used in agriculture for soil and seed treatment and in 

public health to control disease vectors such as mosquitoes and testes flies 

(Ref. 27, p. 1). Dieldrin was also used as a sheep dip and in the treatment of 

wood and mothproofing woolen products (Ref. 27, p. 1). Dieldrin is persistent in 

soil; however, environmental background levels are known to be decreasing slowly 

(Ref. 27, p. 1). Residual contamination may be present at waste sites from the 

disposal of used stocks (Ref. 27, p. 1). DDT was banned from use in the United 

States in 1972 (Ref. 36, p. 2). DDT was used in the 1940s and 1950s to control 

mosquitoes and the typhus carried by lice (Ref. 36, p. 2). It was extensively 

used as an agricultural insecticide after 1945 (Ref. 36, p. 2). DDT is 

persistent in the environment with a reported half-life of 26 days in river water 

to 15 years and is immobile in most soils (Ref. 36, p. 1). It breaks down in the 

environment into DDE and DDD, which are also persistent and have similar physical 

and chemical properties (Ref. 36, p. 1). 

Chlordane residues include heptachlor epoxide, heptachlor, alpha chlordane, gamma 

chlordane, nonachlor, photo-alpha-chlordane, and “compounds C and E” which are 

two isomers of chlordane (Ref. 39, p. 1). Root crops contain the highest 

residues of chlordane; however, they are also present in other vegetables 

including grains (Ref. 39, p. 1). 

The documented dusty conditions at the Red Panther facility during its 

operational period posed the threat of airborne particulates migrating to 

surrounding areas and endangering the public (Ref. 9, p. 3). Additionally, the 

uses of these pesticides are primarily agricultural (crops and livestock) 

products; as such, the elevated levels of the pesticides present in AOC B are not 

likely a result of pesticide application because the neighborhood has 

consistently been residential during the operational period of the Red Panther

facility (Refs. 26, p. 1; 27, p. 1; 28, p. 1; 48, p. 2). Although some residents 

have applied pesticides to the immediate area around the house, several other 

residents have stated that they have never applied pesticides, insecticides, or 

herbicides to their properties during their residence at the property (Ref. 18, 

pp. 42-44).

The collection of the three background composite soil samples during the 2010 ADS 

was specifically designed to obtain a baseline concentration of pesticide 

contamination in the area. The samples were collected outside the immediate area 

of influence of the Red Panther facility. Although the samples contained 

detectable concentrations of pesticides, the concentrations indicate levels 

indicative of usage of pesticides in a residential and/or agricultural setting. 

Pesticide concentrations in AOC B are significantly elevated when compared to the 

highest of all of the background concentrations (Ref. 40, pp. 14-21). 
 

71

5.1 RESIDENT POPULATION THREAT

5.1.1 LIKELIHOOD OF EXPOSURE

Sample ID Sample Date

Distance of 

Population/Resource

from Area of 

Observed 

Contamination

Reference

SN-03-SS 8/9/05 0 feet 18, pp. 30, 162; 31

SN-04-SS 8/9/05 0 feet 18, pp. 31, 162; 31

SN-05-SS 8/9/05 0 feet 18, pp. 31, 162; 31

SN-06-SS

RP-CS-60

8/10/05

6/28/10 0 feet 18, pp.32, 54, 159; 31; 40, pp. 14-15, 26, 33-34, 194, 259

SN-07-SS 8/9/05 0 feet 18, pp. 36, 159; 31

SN-08-SS 8/9/05 0 feet 18, pp. 37, 159; 31

SN-11-SS 8/9/05 0 feet 18, pp. 38, 159; 31

SN-12-SS 8/9/05 0 feet 18, pp. 38, 159; 31

SN-13-SS 8/9/05 0 feet 18, pp. 39, 159; 31

SN-14-SS 8/9/05 0 feet 18, pp. 39, 160; 31

SN-16-SS 8/9/05 0 feet 18, pp. 39, 160; 31

SN-18-SS 8/10/05 0 feet 18, pp.44, 160; 31

SN-19-SS 8/10/05 0 feet 18, pp. 44, 160; 31

SN-20-SS 8/10/05 0 feet 18, pp. 43, 160; 31

SN-21-SS 8/10/05 0 feet 18, pp. 44, 162; 31

SN-24-SS 8/10/05 0 feet 18, pp. 34, 161; 31

SN-25-SS 8/10/05 0 feet 18, pp. 43, 165; 31

SN-26-SS 8/10/05 0 feet 18, pp. 35, 161; 31

SN-27-SS 8/10/05 0 feet 18, pp. 47, 161; 31

SN-29-SS

RP-CS-19

8/10/05

6/29/10 0 feet 18, pp. 46, 161; 31; 40, pp. 14-15, 26, 33-34, 194, 199

SN-30-SS 8/10/05 0 feet 18, pp. 42-43, 161; 31

SN-31-SS 8/10/05 0 feet 18, pp. 35, 161; 31

RP-CS-05 6/29/10 0 feet 40, pp. 14-15, 26, 33-34, 194, 

197

RP-CS-06 6/29/10 0 feet 40, pp. 14-15, 26, 33-34, 194, 

247

RP-CS-18 6/29/10 0 feet 40, pp. 14-15, 26, 33-34, 194, 

248

RP-CS-29 6/29/10 0 feet 40, pp. 14-15, 26, 33-34, 194, 

202

RP-CS-32 6/29/10 0 feet 40, pp. 14-15, 26, 33-34, 194, 

255

RP-CS-38 6/29/10 0 feet 40, pp. 14-15, 26, 33-34, 194, 

254

RP-CS-39 6/29/10 0 feet 40, pp. 14-15, 26, 33-34, 194, 

204

RP-CS-47 6/29/10 0 feet 40, pp. 14-15, 26, 33-34, 194, 

206

RP-CS-57 6/29/10 0 feet 40, pp. 14-15, 26, 33-34, 194, 

208

Resident Population Threat Likelihood of 

Exposure Factor Category Value: 550
 

72

5.1.2 WASTE CHARACTERISTICS

5.1.2.1 Toxicity

Hazardous Substance Toxicity Factor Value Reference

4,4’-DDD 100 2, p. BI-4

4,4’-DDE 100 2, p. BI-4

4,4’-DDT 1,000 2, p. BI-4

Aldrin 10,000 2, p. BI-1

Aldrin 10,000 2, p. BI-1

Alpha-Chlordane 10,000 2, p. BI-3

AlphaHexachlorocyclohexane

(Alpha-BHC)

10,000

2, p. BI-7

Arsenic 10,000 2, p. BI-1

Gamma-Chlordane 10 2, p. BI-3

Dieldrin 10,000 2, p. BI-5

Endrin 10,000 2, p. BI-6

Endrin aldehyde 0 2, p. BI-6

Endosulfan II 100 2, p. BI-6

Heptachlor 10,000 2, p. BI-6

Heptachlor epoxide 10,000 2, p. BI-6

Toxaphene 1,000 2, p. BI-11

Toxicity Factor Value: 10,000
 

73

5.1.2.2 Hazardous Waste Quantity

Area Letter Source Type Area Hazardous Waste Quantity

A Contaminated Soil >0

B Contaminated Soil >0

Sum of Values: >0

Hazardous Waste Quantity Factor Value: 10* 

*The hazardous constituent quantity is not adequately established for the source. 

The value assigned from Table 2-6 without consideration of the removal action 

would be less than 100. Therefore, a value of 10 has been assigned for the 

Hazardous Waste Quantity value (Ref. 1, Section 2.4.2.2 and Table 2-6).

5.1.2.3 Calculation of Waste Characteristics Factor Category Value

Toxicity Factor Value: 10,000

Hazardous Waste Quantity Factor Value: 10

Toxicity Factor Value x Hazardous Waste Quantity Factor Value: 100,000

Waste Characteristics Factor Category Value: 18

(Ref. 1, Table 2-7) 
 

74

5.1.3 TARGETS

Surface soil samples were collected during the August 2005 investigation of the 

18th Street Neighborhood and the 2010 ADS (Refs. 18; 40). The below samples were 

collected during those sampling events.

Level I Concentrations

The below samples were collected during the August 2005 investigation of the 18th

Street Neighborhood by Weston for EPA (Ref. 18, pp. 4-9, 16-19, 29-39, 126-157). 

All samples were collected as 3-, 4-, or 5-point composite samples from 0 to 6 

inches bgs from the residential yards (Ref. 18, pp. 29-47). Generally, the soil 

samples were comprised of light brown sandy silt (Ref. 18, pp. 29-31). All 

aliquots of the samples were collected from within 200 feet of the residential 

dwelling as evidenced by the size of the properties (Ref. 18, pp. 29-47; 31). 

All samples were analyzed by a CLP laboratory and validated by the EPA SESD (Ref. 

18, pp. 8-9, 79-175). See Figure 3 of this Documentation Record for sample 

locations.

Sample ID: SN-05-SS

Area Letter: B

References: 2, p. BII-17; 18, pp. 125, 129, 166

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

(SN-05-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Dieldrin 42 3.5U 40 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-06-SS

Area Letter: B

References: 2, pp. BII-17; 18, pp. 125, 130, 166

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

(SN-06-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Dieldrin 58 3.5U 40 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration
 

75

Sample ID: SN-07-SS

Area Letter: B

References: 2, p. BII-17; 18, pp. 125, 131, 166

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

(SN-07-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Dieldrin 200 3.5U 40 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-08-SS

Area Letter: B

References: 2, p. BII-17; 18, pp. 125, 132, 166

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

(SN-08-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Dieldrin 360 3.5U 40 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-11-SS

Area Letter: B

References: 2, p. BII-17; 18, pp. 125, 136, 166-167

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

(SN-11-SS)

Background 

Concentration

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Dieldrin 77 3.5U 40 CRSC

Notes: 

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration
 

76

Sample ID: SN-12-SS

Area Letter: B

References: 2, p. BII-23; 18, pp. 125, 137, 166-167

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

(SN-12-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Toxaphene 4,500 180U 580 CRSC

Notes: 

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram 

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-21-SS

Area Letter: B

References: 2, p. BII-17; 18, pp. 125, 147, 166, 168

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

(SN-21-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Dieldrin 380 3.5U 40 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-24-SS

Area Letter: B

References: 2, p. BII-23; 18, pp. 125, 150, 166, 168

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

(SN-24-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Toxaphene 4,700 180U 580 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration
 

77

Sample ID: SN-25-SS

Area Letter: B

References: 2, p. BII-23; 18, pp. 125, 151, 166, 168

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

(SN-25-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Toxaphene 1,900 180U 580 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-26-SS

Area Letter: B

References: 2, p. BII-23; 18, pp. 125, 152, 166, 168

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

(SN-26-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Toxaphene 810 180U 580 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-30-SS

Area Letter: B

References: 2, p. BII-17; 18, pp. 125, 156, 166, 169

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

(SN-30-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Dieldrin 42 3.5U 40 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

 

The samples below were collected during the 2010 OTIE ADS (Ref. 40, pp. 1, 5). 

All of the soil samples listed below were nine-point composite surface soil 

samples collected from 0-to 3-inches bgs. The composite samples were collected 

from a 25-by-25-foot grid (Ref. 40, pp. 14-15). All aliquots of each individual 

sample was collected from within the legal property boundary and within 200 feet 

of the building (Ref. 40, pp. 14-15). The four background composite surface soil 

samples, including one duplicate, were collected from residential properties 

located 0.7- to 1.1-mile distant from the facility to ensure an adequate 

background for comparison purposes (Ref. 40, pp. 14-15; 41, pp. 31-32). The 

neighborhoods selected for the background samples were of approximately the same 
 

78

age; the background composite soil samples consisted of similar soil types (Ref. 

40, pp. 14-15). The highest concentration of each constituent in all four 

background samples was used for comparison purposes. All samples were collected 

in accordance with the guidance presented in the EPA-approved site-specific 

QAPP/SSP and in accordance with the EPA SESD FBQSTP (Refs. 40, pp. 6, 14; 41).

All samples collected during the investigation were submitted to the EPA SESD 

laboratory for routine TCL pesticide analytical services using EPA Method 8080 

(Ref. 40, pp. 16, 89). Results were validated by EPA SESD; the data validation 

report is included in Reference 40. See Figure 4 of this Documentation Record 

for sample locations.

Sample ID: RP-CS-05

Area Letter: B

References: 2, p. BII-17; 40, pp. 27, 33, 91-92, 96-97, 99, 151, 160

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

Background 

Concentration 

(μg/kg)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Dieldrin 230 52 40 CRSC

Heptachlor 210 2.4 140 CRSC

Heptachlor 

epoxide 290 3.2 70 CRSC

Notes:

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: RP-CS-06

Area Letter: B

References: 2, p. BII-17; 40, pp. 27, 33, 91-92, 96-97, 100, 151, 160

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

Background 

Concentration 

(μg/kg)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Dieldrin 160 52 40 CRSC

Notes:

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: RP-CS-18

Area Letter: B

References: 2, p. BII-17; 40, pp. 27, 33, 91-92, 96-97, 104, 151, 160 

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

Background 

Concentration 

(μg/kg)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Dieldrin 840 52 40 CRSC

Notes:

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration
 

79

5.1.3.1 Resident Individual

Area Letter: B

Level of Contamination (Level I/Level II): I

Reference: 2, pp. BII-16, BII-17, BII-18, BII-24; 18, pp. 9-10, 21-44, 76-168;

40, pp. 27, 33, 91-180

Resident Individual Factor Value: 50
 

80

5.1.3.2 Resident Population

The below listed samples were collected during the August 2005 investigation of 

the 18th Street Neighborhood by Weston for EPA and during the 2010 ADS by OTIE 

for EPA (Ref. 18, pp. 4-9, 16-19, 29-39, 126-157; 40, pp. 1, 5). During the 2005 

Weston investigation, a total of 30 single home properties were sampled and of 

those properties sampled, 11 properties were determined to contain Level I 

concentrations of pesticides (Refs. 2, pp. BII-17, BII-23; 18, pp. 7, 49-77, 125-

171). During the 2010 ADS, samples were collected from 32 residential 

properties, not including three background residential locations, of those 

properties, three properties were determined to contain Level I concentrations of 

pesticides (Refs. 2, pp. BII-17, BII-23; 40, pp. 33-34, 91-180). 

5.1.3.2.1 Level I Concentrations

Level I Resident Population Targets

Area 

Letter Sample ID

Number of 

Residences

County 

Multiplier

Total No.

of Residents Reference

B SN-05-SS 1 2.69 2.69 18, p. 53; 24, 

p. 1; 31, p. 1

B SN-06-SS 1 2.69 2.69 18, p. 54; 24, 

p. 1; 31, p. 1

B SN-07-SS 1 2.69 2.69 18, p. 55; 24, 

p. 1; 31, p. 1

B SN-08-SS 1 2.69 2.69 18, p. 56; 24, 

p. 1; 31, p. 1

B SN-11-SS 1 2.69 2.69 18, p. 59; 24, 

p. 1; 31, p. 1

B SN-12-SS 1 2.69 2.69 18, p. 60; 24, 

p. 1; 31, p. 1

B SN-21-SS 1 2.69 2.69 18, p. 68; 24, 

p. 1; 31, p. 1

B SN-24-SS 1 2.69 2.69 18, p. 71; 24, 

p. 1; 31, p. 1

B SN-25-SS 1 2.69 2.69 18, p. 64; 24, 

p. 1; 31, p. 1

B SN-26-SS 1 2.69 2.69 18, p. 72; 24, 

p. 1; 31, p. 1

B SN-30-SS 1 2.69 2.69 18, p. 76; 24, 

p. 1; 31, p. 1

B RP-CS-05 1 2.69 2.69

24, p. 1; 31, 

p. 1; 

40, p. 50

B RP-CS-06 1 2.69 2.69

24, p. 1; 31, 

p. 1; 

40, p. 57

B RP-CS-18 1 2.69 2.69

24, p. 1; 31, 

p. 1; 

40, p. 58

Sum of individuals subject to Level I concentrations: 37.66

Sum of individuals subject to Level I concentrations x 10: 376.6

Level I Concentrations Factor Value: 376.6
 

81

5.1.3.2.2 Level II Concentrations

Surface soil samples were collected during the August 2005 investigation of 

the 18th Street Neighborhood and the 2010 ADS (Refs. 18; 40). The below 

samples were collected during those sampling events.

Level II Samples

The below samples were collected during the August 2005 investigation of the 18th

Street Neighborhood by Weston for EPA (Ref. 18, pp. 4-9, 16-19, 19-39, 126-157). 

All samples were collected as 3-, 4-, or 5-point composite samples from 0 to 6 

inches bgs from the residential yards (Ref. 18, pp. 29-47). All aliquots of the 

samples were collected from within 200 feet of the residential dwelling as 

evidenced by the size of the properties (Ref. 18, pp. 29-47; 31). All samples 

were analyzed by a CLP laboratory and validated by the EPA SESD (Ref. 18, pp. 8-

9, 79-175). Generally, the soil samples were comprised of light brown sandy silt 

(Ref. 18, pp. 29-31). See Figure 3 of this Documentation Record for sample 

locations.

Sample ID: SN-03-SS

Area Letter: B

References: 2, p. BII-16; 18, pp. 125, 127, 166

Hazardous 

Substance

Hazardous Substance 

Concentration (μg/kg)

(SN-03-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4’-DDE 58 15 1,900 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-04-SS

Area Letter: B

References: 2, p. BII-16; 18, pp. 125, 128, 166

Hazardous 

Substance

Hazardous Substance 

Concentration (μg/kg)

(SN-04-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4’-DDE 58 15 1,900 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration
 

82

Sample ID: SN-13-SS

Area Letter: B

References: 2, pp. BII-15, BII-16; 18, pp. 125, 138, 166-167

Hazardous 

Substance

Hazardous Substance 

Concentration (μg/kg)

(SN-13-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4’-DDE 320 15 1,900 CRSC

Gamma Chlordane/2 44 1.8U 1,800 CRSC

Alpha Chlordane/2 53 1.8U 1,800 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

U – Constituent was analyzed for but not detected

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-14-SS

Area Letter: B

References: 2, pp. BII-16; 18, pp. 125, 139, 166-167

Hazardous 

Substance

Hazardous Substance 

Concentration (μg/kg)

(SN-14-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4’-DDE 170 15 1,900 CRSC

Notes: 

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram 

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-16-SS

Area Letter: B

References: 2, p. BII-16; 18, pp. 125, 141, 166-167

Hazardous 

Substance

Hazardous Substance 

Concentration (μg/kg)

(SN-16-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4’-DDE 73 15 1,900 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration
 

83

Sample ID: SN-18-SS

Area Letter: B

References: 2, pp. BII-15, BII-16, BII-18; 18, pp. 125, 143, 166-167

Hazardous 

Substance

Hazardous Substance 

Concentration (μg/kg)

(SN-18-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4’-DDE 280 15 1,900 CRSC

4,4’-DDD 19 3.5U 2,700 CRSC

Gamma 

Chlordane/2 29 1.8U 1,800 CRSC

Endrin 7.2 3.5U 23,000 RDSC

Notes:

SN – Street Neighborhood

SS – Surface soil

U – Constituent analyzed for but not detected

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

RDSC – Reference Dose Screening Concentration

Sample ID: SN-19-SS

Area Letter: B

References: 2, p. BII-15; 18, pp. 125, 144, 166-167

Hazardous 

Substance

Hazardous Substance 

Concentration (μg/kg)

(SN-19-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Gamma 

Chlordane/2 6.2 J* 1.8U 1,800 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

J* – Identification of analyte is acceptable; bias unknown. Value adjusted 

(62/10 = 6.2J) (Ref. 33, pp. 8, 17).

U – Constituent analyzed for but not detected

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-20-SS

Area Letter: B

References: 2, p. BII-17; 18, pp. 125, 146, 166, 168

Hazardous 

Substance

Hazardous Substance 

Concentration (μg/kg)

(SN-20-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

Dieldrin 10 3.5U 40 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

U – Constituent analyzed for but not detected

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration
 

84

Sample ID: SN-27-SS

Area Letter: B

References: 2, p. BII-16; 18, pp. 125, 153, 166, 168

Hazardous 

Substance

Hazardous Substance 

Concentration (μg/kg)

(SN-27-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4’-DDE 110 15 1,900 CRSC

4,4’-DDD 7.2 3.5U 2,700 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

U – Constituent analyzed for but not detected

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-29-SS

Area Letter: B

References: 2, pp. BII-15, BII-16, BII-17; 18, pp. 125, 155, 166, 169

Hazardous 

Substance

Hazardous Substance 

Concentration (μg/kg)

(SN-29-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4’-DDE 90 15 1,900 CRSC

Dieldrin 36 3.5U 40 CRSC

Alpha 

Chlordane/2 3.5 1.8U 1,800 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

U – Constituent analyzed for but not detected

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: SN-31-SS

Area Letter: B

References: 2, pp. BII-16, BII-17; 18, pp. 125, 157, 166, 169

Hazardous 

Substance

Hazardous Substance 

Concentration (μg/kg)

(SN-31-SS)

Background 

Concentration 

(μg/kg)

(SN-01-SS)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4’-DDE 130 15 1,900 CRSC

Dieldrin 32 3.5U 40 CRSC

Notes:

SN – Street Neighborhood

SS – Surface soil

U – Constituent analyzed for but not detected

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration
 

85

The samples below were collected during the 2010 OTIE ADS (Ref. 40, pp. 1, 5).

All of the soil samples listed below were nine-point composite surface soil 

samples collected from 0-to 3-inches bgs. The composite samples were 

collected from a 25-by-25-foot grid (Ref. 40, pp. 14-15). All aliquots of 

each individual sample was collected from within the legal property boundary

and within 200 feet of the building (Ref. 40, pp. 14-15). The four background 

composite surface soil samples, including one duplicate, were collected from 

residential properties located 0.7- to 1.1-mile distant from the facility to 

ensure an adequate background for comparison purposes (Ref. 40, pp. 14-15; 41,

pp. 31-32). The neighborhoods selected for the background samples were of 

approximately the same age; the background composite soil samples consisted of

similar soil types (Ref. 40, pp. 14-15). The highest concentration of each 

constituent in all four background samples was used for comparison purposes. 

All samples were collected in accordance with the guidance presented in the 

EPA-approved site-specific QAPP/SSP and in accordance with the EPA SESD FBQSTP

(Refs. 40, pp. 6, 14; 41).

All samples collected during the investigation were submitted to the EPA SESD 

laboratory for routine TCL pesticide analytical services using EPA Method 8080 

(Ref. 40, pp. 16, 89). Results were validated by EPA SESD; the data validation 

report is included in Reference 40. See Figure 4 of this Documentation Record 

for sample locations.

Sample ID: RP-CS-29

Area Letter: B

References: 2, p. BII-17; 40, pp. 27, 33, 91-92, 96-97, 107, 151, 160 

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

Background 

Concentration 

(μg/kg)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4-DDE 99 22 1900 CRSC

Notes:

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: RP-CS-32

Area Letter: B

References: 2, p. BII-17; 40, pp. 27, 33, 91-92, 96-97, 111, 151, 160 

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

Background 

Concentration 

(μg/kg)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4-DDT 110 34 1900 CRSC

Notes:

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration
 

86

Sample ID: RP-CS-38

Area Letter: B

References: 2, p. BII-17; 40, pp. 27, 33, 91-92, 96-97, 114, 151, 160 

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

Background 

Concentration 

(μg/kg)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4-DDT 330 34 1900 CRSC

Heptachlor 

epoxide 51 3.2 70 CRSC

Notes:

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: RP-CS-39

Area Letter: B

References: 2, p. BII-17; 40, pp. 27, 33, 91-92, 96-97, 115, 151, 160 

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

Background 

Concentration 

(μg/kg)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4-DDT 330 34 1900 CRSC

Notes:

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: RP-CS-47

Area Letter: B

References: 2, p. BII-17; 40, pp. 27, 33, 91-92, 96-97, 117, 151, 160 

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

Background 

Concentration 

(μg/kg)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4-DDT 170 34 1900 CRSC

Notes:

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Sample ID: RP-CS-50

Area Letter: B

References: 2, p. BII-17; 40, pp. 27, 33, 91-92, 96-97, 120, 151, 160 

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

Background 

Concentration 

(μg/kg)

Benchmark

Concentration 

(μg/kg)

Benchmark

4,4-DDE 90 22 1900 CRSC

Notes:

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration
 

87

Sample ID: RP-CS-57

Area Letter: B

References: 2, p. BII-17; 40, pp. 27, 33, 91-92, 96-97, 122, 151, 160 

Hazardous 

Substance

Hazardous Substance 

Concentration 

(μg/kg)

Background 

Concentration 

(μg/kg)

Benchmark 

Concentration 

(μg/kg)

Benchmark

4,4-DDE 88 22 1900 CRSC

Notes:

μg/kg – Micrograms per kilogram

CRSC – Cancer Risk Screening Concentration

Level II Resident Population Targets

The below listed samples were collected during the August 2005 investigation of 

the 18th Street Neighborhood by Weston for EPA and during the 2010 ADS by OTIE 

for EPA (Ref. 18, pp. 4-9, 16-19, 29-39, 126-157; 40, pp. 1, 5). During the 2005 

investigation, a total of 30 single home properties were sampled and of those 

properties sampled, 11 properties were determined to contain Level II 

concentrations of pesticides (Refs. 2, pp. BII-15, BII-16, BII-17; 18, pp. 7, 49-

77, 125-171). During the 2010 ADS, samples were collected from 32 residential 

properties, not including three background residential locations, of those 

properties, nine properties were determined to contain Level II concentrations of 

pesticides (Refs. 2, pp. BII-17, BII-23; 40, pp. 33-34, 91-180). 

Area 

Letter Sample ID

Number of 

Residences

County 

Multiplier

Total No. of 

Residents Reference

B SN-03-SS 1 2.69 2.69 18, p. 51; 24, 

p. 1; 31, p. 1

B SN-04-SS 1 2.69 2.69 18, p. 52; 24, 

p. 1; 31, p. 1

B SN-13-SS 1 2.69 2.69 18, p. 61; 24, 

p. 1; 31, p. 1

B SN-14-SS 1 2.69 2.69 18, p. 62; 24, 

p. 1; 31, p. 1

B SN-16-SS 1 2.69 2.69 18, p. 62; 24, 

p. 1; 31, p. 1

B SN-18-SS 1 2.69 2.69 18, p. 62; 24, 

p. 1; 31, p. 1

B SN-19-SS 1 2.69 2.69

18, p. 66; 24, 

p. 1; 31, p. 1

B SN-20-SS 1 2.69 2.69 18, p. 67; 24, 

p. 1; 31, p. 1

B SN-27-SS 1 2.69 2.69 18, p. 73; 24, 

p. 1; 31, p. 1

B SN-29-SS 1 2.69 2.69 18, p. 75; 24, 

p. 1; 31, p. 1

B SN-31-SS 1 2.69 2.69 18, p. 77; 24, 

p. 1; 31, p. 1

B RP-CS-29 1 2.69 2.69

24, p. 1; 31, 

p. 1; 40, p. 

52

B RP-CS-32 1 2.69 2.69

24, p. 1; 31, 

p. 1; 40, p. 

61
 

88

Area 

Letter Sample ID

Number of 

Residences

County 

Multiplier

Total No. of 

Residents Reference

B RP-CS-38 1 2.69 2.69

24, p. 1; 31, 

p. 1; 40, p. 

61

B RP-CS-39 1 2.69 2.69

24, p. 1; 31, 

p. 1; 40, p. 

53

B RP-CS-47 1 2.69 2.69

24, p. 1; 31, 

p. 1; 40, p. 

54

B RP-CS-50 1 2.69 2.69

24, p. 1; 31, 

p. 1; 40, p. 

62

B RP-CS-57 1 2.69 2.69

24, p. 1; 31, 

p. 1; 40, p. 

55

Sum of individuals subject to Level II concentrations: 2.69 x 18 = 48.42

Level II Concentrations Factor Value: 48.42
 

89

5.1.3.3 Workers

Area Letter Number of Workers Reference

A 1 8, p. 1

Total workers: 1

Workers Factor Value: 5

(Ref. 1, Table 5-4) 

5.1.3.4 Resources

Description of Resource(s): No resources are documented on the Red Panther 

property (AOC A) or the surrounding area (AOC B).

Resources Factor Value: 0

5.1.3.5 Terrestrial Sensitive Environments

No Terrestrial Sensitive Environments have been documented within the vicinity

of the Red Panther property.

Likelihood of exposure factor category value (LE): 550

Waste characteristics factor category value (WC): 18

Terrestrial sensitive environments value (ES): 0

Product (LE x WC x ES): 0

(LE x WC x ES)/82,500 (EC):0 

If EC is >60, Value of EC:

Terrestrial Sensitive Environments Factor Value: 0 
 

90

5.2 NEARBY POPULATION THREAT

The Nearby Population Threat was not scored because the Attractiveness/ 

Accessibility factor value is zero. The facility is physically inaccessible to 

the public with no signs of public recreation use, resulting in an 

attractiveness/accessibility factor value of zero for the property. Therefore, 

the threat does not significantly change the Soil Exposure Pathway score (Ref. 1, 

Table 5-6).