HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD COVER SHEET
 

Name of Site: Clinch River Corporation 

EPA ID No.: TND987768587 

Contact Persons 

Documentation Record: Jennifer Wendel, National Priorities List Coordinator 

U.S. Environmental Protection Agency, Region 4 

61 Forsyth Street, S.W., 11th Floor 

Atlanta, Georgia 30303 

(404) 562-8799 

John Nolen, Remedial Project Manager 

U.S. Environmental Protection Agency, Region 4 

61 Forsyth Street, S.W., 11th Floor 

Atlanta, Georgia 30303 

(404) 562-8750 

Wendy Robinson, Ecologist 

Tetra Tech EM, Inc. 

1955 Evergreen Boulevard, Ste. 300 

Duluth, Georgia 30096 

(678) 775-3082 

Pathways, Components, or Threats Not Scored 

The ground water migration, soil exposure, and air migration pathways were not scored in this Hazard 

Ranking System (HRS) documentation record because the surface water migration pathway is sufficient 

to qualify the site for the National Priorities List (NPL). These pathways are of concern to the U.S. 

Environmental Protection Agency (EPA), and may be considered during a future evaluation. 
 

 

 

 

HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD
 

Name of Site: Clinch River Corporation 

EPA Region: 4 

Date Prepared: September 2012 

Street Address of Site*: 728 Emory Drive 

City, County, State, Zip: Harriman, Roane County, Tennessee, 37748 

General Location in the State: Eastern portion of state 

Topographic Map: Bacon Gap, TN 1980; Cave Creek, TN 1989; Elverton, TN 1990; 

Harriman, TN 1980 

Latitude: 35° 55' 55.02" North 

Longitude:	 84° 32' 21.77" West 

The coordinates above for Clinch River Corporation (CRC) were measured from soil sample CR09 

0709SF, collected west of the former paper and pulp mill building and within Source No. 1 of this HRS 

documentation record (Refs. 4; 8, p. 30; 16, p. 4). 

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

record identify the general area where the site is located. They represent one or more locations EPA 

considers part of the site based on the screening information EPA used to evaluate the site for NPL 

listing. EPA lists national priorities among the known “releases or threatened releases” of hazardous 

substances; thus, the focus is on the release, and not on precisely delineated boundaries. A site is defined 

as an area 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 represent the initial 

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

Response, Compensation, and Liability 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 about where the contamination has come to be located. 

Pathway	 Pathway Score 

Ground Water Migration NS 

Surface Water Migration 96.06 

Soil Exposure NS 

Air Migration NS 

HRS SITE SCORE	 48.03 

Note: 

NS Not scored 

1 
 

WORKSHEET FOR COMPUTING HRS SITE SCORE 

S Pathway S2

 Pathway 

Ground Water Migration Pathway Score (Sgw) NS NS 

Surface Water Migration Pathway Score (Ssw) 96.06 9,227.5236 

Soil Exposure Pathway Score (Ss) NS NS 

Air Migration Pathway Score (Sa) NS NS 

S2 

gw + S2 sw + S2 s + S2 a 9,227.5236 

(S2 

gw + S2 sw + S2 s + S2 a) / 4 2,306.8809 

√ (S2 

gw + S2 sw + S2 s + S2 a) / 4 48.03 

Note: 

NS = Not scored 

2 
3 

Table 4-1 –Surface Water Overland/Flood Migration Component Scoresheet

Factor Categories and Factors Maximum Value Value Assigned

Drinking Water Threat

Likelihood of Release:

1. Observed Release 550 550

2. Potential to Release by Overland Flow:

2a. Containment 10 NS

2b. Runoff 10 NS

2c. Distance to Surface Water 5 NS

2d. Potential to Release by 

2a(2b + 2c)] 

Overland Flow [lines 150 NS

3.Potential to Release by Flood:

3a. Containment (Flood) 10 NS

3b. Flood Frequency 50 NS

3c. Potential to Release by Flood (lines 3a x 3b) 500 NS

4. Potential to Release 

maximum of 500)

(lines 2d + 3c, subject to a 500 NS

5. Likelihood of Release (higher of lines 1 and 4) 550 550

Waste Characteristics:

6. Toxicity/Persistence (a) NS

7. Hazardous Waste Quantity (a) NS

8. Waste Characteristics 100 NS

Targets:

9. Nearest Intake 50 NS

10. Population:

10a. Level I Concentrations (b) NS

10b. Level II Concentrations (b) NS

10c. Potential Contamination (b) NS

10d. Population (lines 10a + 10b + 10c) (b) NS

11. Resources 5 NS

12. Targets (lines 9 + 10d + 11) (b) NS

Drinking Water Threat Score:

13. Drinking Water Threat Score [(lines 

5x8x12)/82,500, subject to a maximum of 100] 100 NS

Human Food Chain Threat

Likelihood of Release:

14. Likelihood of Release (same value as line 5) 550 550

Waste Characteristics:

15. Toxicity/Persistence/Bioaccumulation (a) 500,000,000

16. Hazardous Waste Quantity (a) 100

17. Waste Characteristics 1,000 320

Targets:

18. Food Chain Individual 50 45
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 4-1 –Surface Water Overland/Flood Migration Component Scoresheet (Continued) 

Factor Categories and Factors Maximum Value Value Assigned 

19. Population 

19a. Level I Concentrations (b) 0 

19b. Level II Concentrations (b) 0.03 

19c. Potential Human Food Chain 

Contamination 

(b) 

NS 

19d. Population (lines 19a + 19b + 19c) (b) 0.03 

20. Targets (lines 18 + 19d) (b) 45.03 

Human Food Chain Threat Score: 

21. Human Food Chain Threat Score [(lines 

14x17x20)/82500, subject to maximum of 100] 100 96.06 

Environmental Threat 

Likelihood of Release: 

22. Likelihood of Release (same value as line 5) 550 550 

Waste Characteristics: 

23. Ecosystem Toxicity/Persistence/Bioaccumulation (a) NS 

24. Hazardous Waste Quantity (a) NS 

25. Waste Characteristics 1,000 NS 

Targets:

 26. Sensitive Environments 

26a. Level I Concentrations (b) NS 

26b. Level II Concentrations (b) NS 

26c. Potential Contamination (b) NS 

26d. Sensitive Environments (lines 26a + 26b + 

26c) (b) NS 

27. Targets (value from line 26d) (b) NS 

Environmental Threat Score: 

28. Environmental Threat Score [(lines 

22x25x27)/82,500 subject to a maximum of 60] 60 NS 

Surface Water Overland/Flood Migration Component 

Score for a Watershed 

29. Watershed Scorec

 (lines 13+21+28, subject to a 

maximum of 100) 100 96.06 

Surface Water Overland/Flood Migration Component Score 

30. Component Score (Ssw)

c

 (highest score from line 

29 for all watersheds evaluated; subject to a maximum 

of 100) 100 96.06 

Notes: 

a Maximum value applies to waste characteristics category b Maximum value not applicable 

Do not round to nearest integer 

NS Not scored 

4 

c 
Emory River

Clinch River Corporation

Emory River

TDD No.:

TDD Name:

United States

Environmental Protection Agency

Region 4

City: County: State:

8/6/2012

Date:

ray.yeager

Analyst:

Legend

Clinch River Corporation

property boundary

Map Source:

USGS 7.5 Minute Topographic Quadrangle Map:

Harriman, TN 1980.

File: C:\GIS_Workspace\TTEMI-05-003-0128_Clinch_River_Corporation\GIS\MXDs\Site Location\Fig1_Facility_Location 6-29-12 RY.mxd

FIGURE 1

TTEMI-05-003-0128

Clinch River Corporation

Facility Location

Harriman Roane Tennessee

Roane County

KY

MS AL GA

NC

SC

IL

MO VA

TENNESSEE

/

0 1,000 2,000

Feet

1:24,000
L

egend 

CD Main office 


@ Training building 


® Clarifier 


@ Time keeping building 


Former location of

Lt boiler house 

Steam generation and ® turbine building 

Former location of 

the paper 

A 

and pulp mill 

building 

Former 

location of chipper 

~ shed 

(drum storage) 

® 600

,000-gallon AST 

@ Black 

liquor pond 

Former location of

A coal tar pond 

@ Scale house 

[!] Waste paper 

pile 

Railroad 

I•:::::J I Clinch 

River Corporation 

property boundary 

_.,.. 

Flow direction 

Approximate location of south 

m~u 

waste paper impoundment 

CJ Parcel bou

ndary 

[I] 	Process 

area 

15ft X 30ft X 6in 1M! Excavated Area 

0 125 250 

~~~~~ Feet 

13,000 

Notes: 

AST- Aboveground storage tank 

structure numbers have been reVised for this 

HRS documentation record. 

Map Source: 

Bing Maps Aerial 

imagery, 2012; 

References 7, pp. 

2, 5, 10. 12; 8, pp. 28, 29; 

10, 

p. 6; 14, pp. 13, 14; 45, p. 2; 61, pp. 2, 3. 

® United States 

• Envirormenta! Protection Agency 

ot Region4 

FIGURE 2 

Facility Layout 

TOO Name: Clinch River Corporation 

TOO No.: TTEM I 05-00~ 1 28 

City: County: State: 

Harriman Roane Tennessee 

Date

(1\:) TETRA TECH Analyst 

ray.yeager 

File: C:\GlS_Wortsp.ac:e\TTEMl-05~~ 28 Clnch ver_Corporabon GIS\MXOs\Si1e layout\F~~g2 Faciity layoutl>29- 2 RY 11x17 .mxd 

71512012 
Map Source:

Bing Maps Aerial Imagery, 2012;

Refs. 3; 8, pp. 30; 11, pp. 15, 21, 22, 116, 118, 120; 

16, pp. 3, 4, 6, 7, 8; 57, p. 2; 61, pp. 2, 3. 

File: C:\GIS_Workspace\TTEMI-05-003-0128_Clinch_River_Corporation\GIS\MXDs\Source and Observed Release Maps\Fig3_Source_and_Observed_Release_Samples 8-14-12 RY.mxd

FIGURE 3

TTEMI-05-003-0128

Clinch River Corporation

Source and Observed

Release Samples

TDD No.:

TDD Name:

Harriman Roane Tennessee

Sample Identification Notes:

0 to 1 foot below ground surface

Sample number

Area number

Clinch River

Clinch River Corporation Brownfields

Sediment

Sediment duplicate

Surface soil

Surface soil duplicate

Surface soil

00-01

##

A#

CR

CRCB

SD

SDD

SF

SFD

SS

USACE

TDEC

8/14/2012

Date:

ray.yeager

Analyst:

City: County: State:

United States

Environmental Protection Agency

Region 4

0 150 300

/

Feet

Legend

2009 TDEC Site Reassessment

!( Observed Release Sediment Sample

!(!( Background Sediment Sample

") Source Sample

")") Background Soil Sample

2005 USACE Phase II Investigation

#* Source Sample

#*#* Background Soil Sample

")

Emory River Mile Marker

Process Area

Flow direction

Source No. 1

Tennessee Department of

Environment and Conservation

U.S. Army Corps of Engineers

#*

#*

#*

#*

#*

#*#*

!(!( CR02 0709SD

River Mile

")

11.4

15ft x 30ft x 6in 

Excavated Area

Emory Dr

Clify St ￿

Sewanee St

Queen Ave

Clinch St

Crescent Ave

Cumberland St

Clinton St

Virginia St

Tennessee St

Walden Ave

Trenton St

Morgan Ave

Georgia St

Carter St

Emory Heights Rd

Carter Ave

CR13 0709SF

CR09 0709SF

CR08 0709SF

CR06 0709SD

CR03 0709SD

CR06 0709SDD

SS-CRCB-A9-39-00-01

SS-CRCB-A2-05-00-01

SS-CRCB-A4-27-00-01

SS-CRCB-A2-34-00-01

SS-CRCB-A2-03-00-01

SS-CRCB-A4-26-00-01

")")

")

")

!(

!(

Clinch River Corporation

Property Boundary

Probable Point of Entry (PPE)

Area of Fishing for 

Human Consumption

15ft x 30ft x 6in 

Excavated Area
8

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9

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10

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11

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12

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ALS Environmental analytical data sheets for sample PKL05. June 6, 2012. 8 pages.

62. EPA. Environmental Protection Agency – Region 4, Fiscal Year 2002 Enforcement and Compliance 

Assurance Report. Accessed on-line June 25, 2012, at 

http://www.epa.gov/region4/ead/attachments/2002_accomplishments_report.pdf. 20 pages.

63. Tetra Tech. Electronic Correspondence Between Sandra Harrigan, Tetra Tech, and Brad Bingham, 

State Private Lands Coordinator, U. S. Fish and Wildlife Service, Tennessee Ecological Services 

Field Office. Subject: Fishing on the Emory River in Harriman, TN, - River Mile 12 downstream to 

River Mile 10 (also addresses endangered mussel species that inhabit the Emory River in Harriman, 

Tennessee). October 4, 2011, through July 5, 2012. 4 pages. 

64. TDEC. Contract Laboratory Program, Organic Traffic Report and Chain of Custody Record for 2009 

TDEC Sampling Event. July 2009. 5 pages.

65. TDEC. Contract Laboratory Program, Generic Chain of Custody for 2009 TDEC Sampling Event.

July 2009. 3 pages.

66. TDEC. Contract Laboratory Program. Inorganic Traffic Report and Chain of Custody Record for 

2009 TDEC Sampling Event. July 2009. 3 pages.

67. Tetra Tech. Electronic Correspondence Between Sandra Harrigan, Tetra Tech, and Erin Sutton, 

Project Manager, TDEC DOR. Subject: Sample CR03 0709SD. July 22-23, 2012. 2 pages. 
SITE DESCRIPTION
 

Clinch River Corporation (CRC) is located at 728 Emory Drive in Harriman, Roane County, Tennessee 

(References [Refs.] 5; 6, p. 1; see Figure 1 of this HRS documentation record). More specifically, the 

geographical coordinates, as measured at sample CR09 0709SF, collected within Source No. 1 and west 

of the former paper and pulp mill building, are latitude 35° 55' 55.02" north and longitude 84° 32' 21.77" 

west (Refs. 4; 8, p. 30; 16, p. 4). The EPA identification number, as recorded in the Comprehensive 

Environmental Response, Compensation, and Liability Information System (CERCLIS) database, is 

TND987768587 (Ref. 5). 

The CRC property is an inactive paper and pulp mill with several entrances along Emory Drive at Walden 

Street, Queen Street, and Tennessee Street (Ref. 8, p. 1). The CRC property consists of four parcels of 

land covering an area of about 29 acres (Refs. 7, pp. 1, 2, 3, 5, 6, 10, 11, 12; 8, pp. 1, 28). Several 

railroad tracks and easements traverse the CRC property from north to south (Ref. 8, p. 1; see Figures 1 

and 2 of this HRS documentation record). 

Parcel 001.00, located in the southwestern portion of the property, covers 1.3 acres and includes a scale 

house (Refs. 7, pp. 1, 2; 8, pp. 28, 29; 45, p. 2). Parcel 002.00, located in the northwestern portion of the 

property, covers 5.3 acres and includes a clarifier, a main office building, a training building (also referred 

to as a bath house), and a waste paper pile (referred to as “waste paper pile 4” in this HRS documentation 

record) (Refs. 7, pp. 3, 5; 8, pp. 28, 29; 10, pp. 6, 28; 45, p. 2; see Figure 2 of this HRS documentation 

record). 

Parcel 003.00, located in the northeastern portion of the property, covers 10.48 acres and includes the 

former location of the paper and pulp mill building, the former location of an unlined surface 

impoundment (coal tar pond [ash pond]), a chipper shed and associated drum storage area, a steam 

generation and turbine building, a time keeping building, several aboveground storage tanks (AST), 

including a 15,000-gallon AST, a waste paper pile (referred to as “waste paper pile 1” in this HRS 

documentation record) located about 525 feet north of the former paper and pulp mill building, a waste 

paper pile (referred to as “waste paper pile 3” in this HRS documentation record) located about 100 feet 

northwest of the former paper and pulp mill building, and a concrete surface located north of the former 

paper and pulp mill building and near waste paper pile 1 (Refs. 7, pp. 6, 10; 8, pp. 28, 29, 34, 39; 10, pp. 

5, 6, 51, 52, 55, 60; 45, pp. 2, 5, 8, 9, 10, 11; 61). The area where the former paper and pulp mill 

operations occurred will be referred to as the “process area” throughout this HRS documentation record 

(see Figure 2 of this HRS documentation record). 

Parcel 003.01, located in the southeastern portion of the property, covers at least 12 acres and includes the 

former location of the boiler house, the former location of a south waste paper impoundment, a 600,000­

gallon AST, an unlined surface impoundment (black liquor pond), and a waste paper pile (referred to as 

“waste paper pile 2” in this HRS documentation record) located adjacent to the black liquor pond (Refs. 

7, pp. 11, 12; 8, pp. 28, 29; 10, p. 6; 45, p. 2; see Figures 1 and 2 of this HRS documentation record). 

The CRC property is overgrown with dense vegetation in some locations and is not secure (Refs. 8, p. 1; 

10, p. 8). Land uses surrounding the CRC property are predominantly residential and light industrial 

(Refs. 8, p. 28). The CRC property is bordered to the north by industrial properties, to the east and south 

by the Emory River, and to the west by Emory Drive and residential properties beyond (Ref. 8, pp. 1, 28; 

see Figure 2 of this HRS documentation record). 

For HRS scoring purposes, the site consists of one source and associated releases to the surface water 

migration pathway. Source No. 1 consists of contaminated soil from discrete operations (e.g., disposal 

practices) around the process area (Refs. 8, pp. 2, 14 through 21, 28, 29; 10, p. 6; 11, pp. 33, 38 through 

42, 47, 48, 49; see Figure 3 of this HRS documentation record). Hazardous substances including 

anthracene; benzo(a)anthracene; benzo(a)pyrene; benzo(k)fluoranthene; carbazole; chrysene; 

dibenzo(a,h)anthracene; fluoranthene; fluorene; indeno(1,2,3-cd)pyrene; 2-methlynaphthalene; 

naphthalene; phenanthrene; pyrene; 1,2,3,4,6,7,8-heptachlorodibenzodioxin (HpCDD); 1,2,3,4,6,7,8­

heptachlorodibenzofuran (HpCDF); 1,2,3,4,7,8-hexachlorodibenzodioxin (HxCDD); 1,2,3,6,7,8-HxCDD; 

13 Site Description 
1,2,3,7,8,9-HxCDD; cadmium; chromium; copper; lead; manganese; mercury; nickel; silver; and zinc 

have been detected in Source No. 1 (see Section 2.2.1 of this HRS documentation record). 

These hazardous substances have also been documented in sediment samples collected from the Emory 

River, which receives runoff from Source No. 1, indicating that a release has occurred to the surface water 

migration pathway (see Section 4.0 of this HRS documentation record). 

OPERATIONAL AND REGULATORY HISTORY 

From 1929 to 2002, a paper and pulp mill operated on the CRC property (Refs. 8, p. 2; 10, pp. 4, 5; 14, 

pp. 22, 315). The following companies owned and/or operated the paper and pulp mill throughout its 

operational history: the Mead Corporation, Inc.; the Harriman Paperboard Corporation; the Clinch River 

Corporation; the Gibson Group; Mid-South Cogeneration, Inc.; Power Paper, Inc.; Power Paper, Limited; 

Power Paper Recycling, Inc.; and American Kraft Mills of Tennessee, LLC (Refs. 10, pp. 4, 5, 6, 7, 286 

through 298; 14, pp. 190, 196, 200). Of the four parcels that make up the CRC property, three are 

currently owned by the Gibson Group and one is currently owned by Dr. Clary P. Foote (Ref. 7, pp. 1, 2, 

3, 5, 6, 10, 11, 12). 

Former operations on the CRC property included manufacturing nonbleached corrugated containers using 

paperboard from pulp production (Ref. 14, pp. 8, 256, 280, 315). The manufacturing process included 

partially digesting raw hardwood chips with sodium sulfite, sodium carbonate, and live steam. The wood 

chips were further refined using a mechanical pulping process (Refs. 10, p. 6; 14, pp. 8, 211, 280, 400; 

44, p. 10). The virgin paper stock was then mixed with recycled paper stock at a rate of 75 percent virgin 

to 25 percent recycled. The blended paper stock was allowed to dry in mats that were cut into customerspecific widths (Ref. 14, p. 211). 

By-products of the paper manufacturing process included paper waste, black liquor (spent processing 

waste), and coal tar constituents (Refs. 10, p. 6; 11, p. 6; 14, p. 8). The treatment of the paper waste 

consisted of primary clarification after the material was screened through a 3-millimeter mesh screen. 

One half of the waste stream (sludge) generated by the clarifier was recycled back into the plant, while 

the other half (mill effluent) was discharged to the Tennessee River through the Harriman Sewage 

Treatment Plant system. Skimmer waste from the clarifier was disposed of on the CRC property (Ref. 14, 

pp. 211, 216). Waste paper was also disposed of in piles throughout the CRC property (Refs. 10, p. 6; 11, 

p. 7; 14, pp. 8, 169 through 178, 182, 183, 185). 

Black liquor can be composed of phenols, sodium hydroxide, sodium oxide, and sulfur; as well as metals, 

such as calcium and magnesium (Refs. 10, p. 6; 14, p. 8). Coal tar consists of polynuclear aromatic 

hydrocarbons (PAH), phenols, heterocyclic oxygen, sulfur, and nitrogen compounds (Refs. 9, p. 220; 14, 

p. 8; 30, pp. 9, 21). Dioxins, furans, PAHs, and metals, such as chromium, copper, and manganese, can 

also be produced as by-products of the paper manufacturing process (Refs. 49, p. 7; 51, p. 10; 54, pp. 1-1, 

3-3, 3-4, 3-7, 3-8, 3-11; 55, pp. 1, 2). Black liquor and coal tar wastes were disposed of on the CRC 

property in two unlined surface impoundments (the black liquor pond and the former coal tar pond) and in 

drums (Refs. 10, p. 31; 11, pp. 7, 11; 14, pp. 8, 155). 

Paper and pulp mill processes generated effluents from pulp operations, paper board operations, and 

supporting auxiliaries. The pulp operations waste stream received only the dilute solutions of constituents 

extracted from the wood that could be reused in the pulping operations. The paper board operation waste 

stream consisted of excess white water (filtrate) from the paper machine water slurry. The supporting 

auxiliary waste stream consisted of chemicals used for conditioning boiler feed water by the ion exchange 

method (Ref. 14, p. 316). 

Wastes from paper mill operations were disposed of on the CRC property (Refs. 10, p. 6; 14, pp. 155, 

156, 157, 169 through 183, 185). Multiple waste areas have been identified on the CRC property. These 

areas include: (1) an unlined surface impoundment (black liquor pond), located on the southern portion of 

the property; (2) an unlined surface impoundment (former coal tar pond), located on the northeastern side 

of the property; (3) waste paper pile 1, located about 525 feet north of the former paper and pulp mill 

14 Site Description 
 

 

 

building; (4) waste paper pile 2, located adjacent to the black liquor pond; (5) waste paper pile 3, located 

about 100 feet northwest of the former paper and pulp mill building; and (6) waste paper pile 4, located 

on a concrete slab inside a fenced enclosure on the southern portion of Parcel 002.00 (Refs. 8, p. 29; 10, 

p. 6; 14, pp. 155, 169 through 183, 185). Waste paper pile 3 was removed in the 1990s and its former 

location was subsequently paved with concrete. The fencing around waste paper pile 4 was removed and 

the pile was covered with soil (Ref. 10, p. 6). 

The Emory River was the source of fresh water for mill operations. The receiving streams were the 

Emory and Tennessee Rivers (Ref. 14, pp. 315, 337, 338). In 1957, Mead Corporation began discharging 

effluent through the City of Harriman’s sewer system (Ref. 14, pp. 278, 400). In 1971, Mead Corporation 

maintained 12 outfalls into the Emory River and one outfall into the Tennessee River (Ref. 14, pp. 303 

through 306). Outfall 001 received process effluent that was mixed with the Harriman’s Utility Board 

Waste Treatment Plant effluent and discharged through a diffuser into the Tennessee River, 

approximately 15.7 miles downstream of the CRC property (Refs. 3; 14, p. 304). Outfall 002 (surface 

drains in debarking area), Outfall 003 (drain from small laboratory), Outfall 004 (septic tank outfall), 

Outfall 005 (drain from chemical storage area), Outfall 006 (bearing and machine cooling water), Outfall 

007 (emergency overflow from mill process water), Outfall 008 (storm water runoff from the mill area), 

Outfall 009 (turbine room roof drainage), Outfall 010 (boiler feed water conditioning area), Outfall 011 

(sand filter backwash), Outfall 012 (boiler house area), and Outfall 013 (boiler mud drum) discharged into 

the Emory River (Ref. 14, pp. 304, 305, 306). 

In June 1974, Mead Corporation was issued National Pollutant Discharge Elimination System (NPDES) 

permit TN0001627 from EPA as well as a temporary discharge permit from the State; however, the 

details of the permits are not known (Ref. 14, p. 277). In June 1974, just prior to receiving this permit, 

Mead Corporation stated that it had already tied Outfalls 002, 003, 004, 005, and 006 to Outfall 001, and 

planned to tie Outfalls 010, 011, 012, and 013 to Outfall 001 by 1976. Furthermore, Outfall 007 was no 

longer in use, and Outfalls 008 and 009 were storm drains that Mead did not intend to connect to Outfall 

001. Mead also stated its intention to install a primary clarifier on the CRC property by 1976, in advance 

of the date on which the City of Harriman’s secondary treatment system would be completed (Ref. 14, pp. 

300, 301). 

The NPDES permit was renewed in 1983 and allowed sanitary and process wastewater from Outfall 001 

to be discharged to the City of Harriman sewage treatment plant system (Ref. 14, pp. 268, 270, 337, 338). 

In 1988, CRC was issued NPDES permit TN0062383 authorizing discharge of noncontact cooling water 

and storm water runoff to the Emory River at mile 11.4, which is about 250 feet from Source No. 1, and 

about 211 feet from the observed release (Ref. 14, pp. 236, 237, 250, 257, 261; see Figure 3 and Section 

4.1.2.1.1 of this HRS documentation record). An estimated 400,000 gallons of effluent was discharged 

into the Emory River per day (Ref. 14, p. 259). Previously, process wastewater was discharged to the 

Tennessee River through NPDES permit TN0001627; however, NPDES permit application TN0062383 

stated that the process wastewater would be recycled (Ref. 14, pp. 249, 250, 261, 268, 270). The permit 

did not require monitoring of specific constituents (Ref. 14, pp. 237, 238). 

Several spills, releases, and NPDES permit violations have been documented throughout the facility’s 

operational history. Between 1988 and 1989, the facility illegally discharged process water, cooling 

water, and waste paper wash runoff into the Emory River (Ref. 14, pp. 345, 354, 357, 359, 361, 367). 

Discoloration (black and gray) of the Emory River directly adjacent to and downstream of the CRC 

property was also documented during this period (Ref. 14, pp. 354, 360, 362). The CRC property flooded 

in 1990, and as a result, waste paper, black liquor, and coal tar wastewater were deposited into the Emory 

River (Ref. 14, pp. 8, 159 through 161, 164 through 166, 186, 187). During the 1991 TDHE site 

inspection, TDHE observed (1) black liquor and coal tar leaching into the Emory River from the CRC 

property below the water line, and (2) that the south waste paper impoundment had partially collapsed 

into the Emory River, dumping waste paper and waste paper rolls into the river (Ref. 14, pp. 8, 14, 16, 

165 through 168, 186, 187). In June 2002, the owner of Parcel 003.01 was convicted of intentionally 

releasing approximately 500,000 gallons of process liquid containing black liquor and solids, the contents 

of an AST, onto the ground and into the Emory River on February 14, 1999, during a period of heavy 

rains (Refs. 7, p. 11; 46, p. 1; 47, p. 11; 62, p. 17). 

15 Site Description 
Paper and pulp mill effluent can contain PAHs; dioxins and furans; and metals (Refs. 49, p. 7; 51, p. 10; 

54, pp. 1-1, 3-7, 3-8, 3-11). PAHs are contained in coal tar (Refs. 9, p. 220; 14, p. 8; 30, pp. 9, 21). 

Dioxins and furans accumulate in the pulp and are chemicals of concern in wastewater treatment sludge 

and in liquid (re-pulped) effluent (Ref. 50, pp. 6, 10). Metals, such as cadmium, chromium, copper, lead, 

mercury, nickel, and zinc can be contained in effluent and in pulp mill sludge (Refs. 50, p. 10; 51, pp. 1, 

2, 3; 54, pp. 1-1, 3-11). 

PREVIOUS INVESTIGATIONS 

From 1984 to 2012, numerous investigations were conducted at the CRC property. Table 1 lists some of 

the previous sampling investigations, including the paper and pulp mill-related hazardous substances 

detected in the samples collected. 

TABLE 1: Summary of Previous Investigations 

Agency Investigation Date 

Samples 

Collected 

Chemicals of Concern 

Detected References 

TDHE 

Acute 

Toxicity 

Study 

1984 

Process 

waste water 

discharge 

Phenols 14, pp. 9, 211 

through 214, 218 

TDHE Site 

Investigation 1991 

Soil, surface 

water, and 

sediment 

Chromium 

Copper 

Lead 

Manganese 

Mercury 

Nickel 

Zinc 

14, pp. 6, 16, 63, 

64, 80, 81 

Halliburton 

NUS 

Corporation 

for EPA 

Expanded 

Site 

Inspection 

1993 

Surface and 

subsurface 

soil, 

sediment 

Anthracene 

Benzo(a)anthracene 

Benzo(a)pyrene 

Benzo(b,k)fluoranthene 

Carbazole 

Chrysene 

Dibenzo(a,h)anthracene 

Fluoranthene 

Fluorene 

Indeno(1,2,3-cd)pyrene 

2-Methylnaphthalene 

Naphthalene 

Phenanthrene 

Pyrene 

Cadmium 

Chromium 

Copper 

Lead 

Manganese 

Mercury 

Nickel 

Zinc 

13, pp. 1, 8, 10, 

11, 12, 16 through 

20, 22, 24, 25 

Shaw 

Environmental 

for TDEC 

DOR 

Phase I ESA 2005 None None 10, pp. 1, 38 

through 41 

16 Site Description 
 

TABLE 1: Summary of Previous Investigations 

Agency Investigation Date 

Samples 

Collected 

Chemicals of Concern 

Detected References 

USACE TBA Phase II 

Investigation 2005 

Surface and 

subsurface 

soil 

Cadmium 

Chromium 

Copper 

Manganese 

Mercury 

Nickel 

Silver 

Zinc 

11, pp. 4, 13, 14, 

38, 39, 47 

TDEC DOR Site 

Reassessment 2009 

Soil, surface 

water, and 

sediment 

Anthracene 

Benzo(a)anthracene 

Benzo(a)pyrene 

Benzo(k)fluoranthene 

Carbazole 

Chrysene 

Dibenzo(a,h)anthracene 

Fluoranthene 

Fluorene 

Indeno(1,2,3-cd)pyrene 

2-Methylnaphthalene 

Naphthalene 

Phenanthrene 

Pyrene 

1,2,3,4,6,7,8-HpCDD 

1,2,3,4,6,7,8-HpCDF 

1,2,3,4,7,8-HxCDD 

1,2,3,6,7,8-HxCDD 

1,2,3,7,8,9-HxCDD 

Cadmium 

Chromium 

Copper 

Lead 

Mercury 

Nickel 

Zinc 

8, pp. i, ii, 3, 14, 

15, 17 through 21 

TDEC DOR 

Expanded 

Site 

Investigation 

2010 Fish tissue 

Chromium 

Copper 

Zinc 

12, pp. i, 1, 3, 6, 7, 

15 

OTIE for EPA Emergency 

Response 2011 Waste Benzo(a)pyrene Naphthalene 

52, p. 3; 59, pp. 1, 

4, 5, 6 

OTIE for EPA Removal 

Assessment 2012 

Surface and 

subsurface 

soil 

Benzo(a)anthracene 

Benzo(a)pyrene 

Dibenzo(a,h)anthracene 

60, pp. 1, 3, 4 

17 Site Description 
 

 

 

 

 

Notes: 

CRC Clinch River Corporation 

DOR Division of Remediation 

ESA Environmental Site Assessment 

HpCDD Heptachlorodibenzodioxin 

HpCDF Heptachlorodibenzofuran 

HxCDD Hexachlorodibenzodioxin 

OTIE Oneida Total Integrated Enterprises 

PAH Polynuclear aromatic hydrocarbon 

SVOC Semivolatile Organic Compounds 

TBA Targeted Brownfield Assessment 

TDEC Tennessee Department of Environment and Conservation 

TDHE Tennessee Department of Health and Environment 

USACE U.S. Army Corps of Engineers 

VOC Volatile Organic Compounds 

In 2005, the Tennessee Department of Environment and Conservation (TDEC, previously TDHE) 

Division of Remediation (DOR) tasked Shaw Environmental, Inc. (Shaw) with conducting a Phase I 

Environmental Site Assessment (ESA) at CRC (Ref. 10, p. ES-1). During site reconnaissance activities, 

about 106 damaged, leaking, or open containers (55-gallon drums and two 250-gallon totes) containing 

various oily liquid wastes were observed in and around the chipper shed. The oily liquid wastes were 

suspected to contain lubricant oils, white paper and black paper liquor waste, water, and other waste. 

Notable dark staining was observed in the area near the leaking containers (Ref. 10, pp. 39, 51, 52). 

Erosion of the concrete surface near waste paper pile 1 revealed layers of dark staining in the soils 

underneath the concrete surface. This area of concrete erosion and staining borders the Emory River and 

is prone to flooding (Refs. 10, p. 39; 23; 24, p. 1). In addition, distressed vegetation was observed near 

waste paper pile 1 (Ref. 10, pp. 40, 59; see Figure 2 of this HRS documentation record). Shaw 

recommended that a Phase II ESA be conducted (Ref. 10, p. 40). 

In 2005, the U.S. Army Corps of Engineers (USACE) was tasked by EPA to conduct a Targeted 

Brownfield Assessment (TBA) Phase II Investigation at the CRC property (Ref. 11, p. 4). Surface and 

subsurface soil samples were collected throughout the CRC property (Ref. 11, pp. 11, 13, 14). The 

samples contained semivolatile organic compounds (SVOCs), including PAHs; dioxins and furans; and 

metals (Refs. 11, pp. 38 through 42, 47, 48, 49; 54, pp. 3-7, 3-8). 

In 2009, TDEC DOR conducted a site reassessment at the CRC property (Ref. 8, p. i). Surface soil, 

surface water, and sediment samples were collected during the reassessment (Ref. 8, p. 3). Surface soil 

samples contained dioxins and furans; PAHs; and arsenic at concentrations above background levels (Ref. 

8, pp. 9, 15, 18, 20, 21). The same constituents were also detected in sediment samples collected from the 

Emory River directly adjacent to the CRC property (Ref. 8, pp. 6, 7, 8, 14, 15, 17, 19, 20). 

In September 2010, TDEC DOR conducted an expanded site investigation (ESI), which involved 

collection of 32 fish (four largemouth bass, 25 sunfish, and three carp) from the Emory River at three 

locations downstream of the CRC property (Ref. 12, pp. i, 3). A fish tissue sample was not collected 

upstream of the CRC property; however, analytical data from the fish tissue samples were compared to 

average concentrations from the Watts Bar Reservoir, obtained from a biological database maintained by 

the Division of Water Pollution Control within TDEC (Ref. 12, pp. 4, 6). The fish tissue samples 

contained polychlorinated biphenyls, benzaldehyde, chromium, copper, and zinc (Ref. 12, pp. 6, 15). 

Copper and chromium levels in the collected fish tissue both exceeded the historical average background 

levels, with copper exceeding three times the historical average background concentration (Ref. 12, pp. 6, 

7). 

In August 2011, EPA conducted an assessment of the leaking drums in the drum storage area and of the 

600,000-gallon AST located on parcel 003.01 (Ref. 52, pp. 2, 3). Field testing indicated that the drums 

contained liquid acids, liquid and solid bases, flammable liquids, and natural liquids (Refs. 52, p. 3; 59, 

pp. 3, 4). Approximately 20 cubic yards of spilled material were observed in the drum storage area (Ref. 

52, p. 3). 

18 Site Description 
 

In September 2011, EPA initiated an emergency removal action to stabilize the leaking drums located in 

the drum storage area. The drums were stabilized and disposed of in February 2012 (Refs. 45, p. 22; 52, 

p. 3; 53, p. 1; 59, p. 5). Stained surface soil directly surrounding the drums located in the drum storage 

area was removed (Refs. 53, p. 1; 59, pp. 5, 28; 61, p. 1). No other areas on the CRC property were 

excavated (Ref. 61, p. 1). 

EPA removal activities continued in February 2012 and included removing all drums and containers, 

excavating an underground storage tank (UST), collecting surface and subsurface soil samples, and 

advancing borings to install temporary monitoring wells (Refs. 45, pp. 19, 22, 26; 53, pp. 1, 2; 60, p. 3; 

61, p. 1). The UST, located southeast of the former paper and pulp mill building, contained 

approximately 38,500 gallons of black liquor. Once the UST was removed, black liquor and associated 

sludge were observed in the tank pit. This material was removed; however, about 6 inches of water 

containing black liquor was noted seeping into the excavated tank pit (Refs. 45, pp. 19, 21, 22, 24, 26; 53, 

pp. 1, 2). Surface soil samples were collected from 21 locations throughout the CRC property. 

Specifically, samples were collected near waste paper pile 1, north and southeast of the former mill 

building, near the chipper shed, near the black liquor pond, near waste paper pile 2, and in the wooded 

area of parcel 003.01 (Ref. 53, pp. 1, 2; 60, p. 9; see Figure 2 of this HRS documentation record). A soil 

boring was advanced through the concrete at the former location of the coal tar pond to a depth of 35 feet 

bgs. Black liquor was observed in the boring (Ref. 45, pp. 1, 19, 21). The surface and subsurface soil 

samples contained PAHs and arsenic. More specifically, benzo(a)anthracene was detected up to 2,300 

μg/kg (micrograms per kilogram); benzo(a)pyrene was detected up to 2,000 μg/kg; benzo(b)fluoranthene 

was detected at 2,200 μg/kg; dibenzo(a,h)anthracene was detected up to 440 μg/kg; and arsenic was 

detected at 54 mg/kg (milligrams per kilograms) (Ref. 60, pp. 4, 10). 

As of June 2012, the emergency response actions are complete; however, the removal action is on-going. 

No drums containing waste remain on the CRC property. The chipper shed is no longer standing. Three 

empty ASTs remain on the CRC property. EPA is in the process of working with Dr. Foote and other 

potentially responsible parties to empty and dismantle the 600,000-gallon AST and to conduct further soil 

testing. An expected completion date has not been established (Ref. 61, p. 1). Samples evaluated for 

Source No. 1 were not impacted by EPA removal activities (Refs. 53, p. 1; 61, pp. 1, 2, 3), and no 

removal has occurred at the zone of contamination in the Emory River (see Section 4.1.2.1.1 of this HRS 

documentation record). At the time this HRS documentation record submittal, the status of the removal 

action remained unchanged. 

19 Site Description 
Source No: 1 

2.2 SOURCE CHARACTERIZATION

 2.2.1 SOURCE IDENTIFICATION 

Number of source: 1 

Name of source: Contaminated soil resulting from discrete operations (e.g., disposal practices) around 

the process area 

Source Type: Contaminated Soil 

Description and Location of Source (with reference to a map of site): 

Source No. 1 is an area of contaminated soil resulting from paper manufacturing operations (e.g., disposal 

practices) around the process area. Specifically, composite samples used to characterize Source No. 1 

were collected in the vicinity of (1) waste paper pile 1 (north of the former paper and pulp mill building), 

(2) waste paper pile 3 (northwest of the former paper and pulp mill building), and (3) the western wall of 

the steam generation and turbine building (Refs. 8, pp. 9, 14 through 21, 29, 30; 10, pp. 6, 47; 11, pp. 15, 

16, 21, 38 through 42, 47, 48, 49; see Figures 2 and 3 of this HRS documentation record). Soil samples 

contained overlapping hazardous substances related to facility processes, each sample was collected from 

within the paper manufacturing operations process area and from the same source type (contaminated 

soil) and containment features, and each sample drains into the same surface water pathway (Refs. 8, p. 6; 

8, pp. 1, 2, 6, 30, 33, 34, 35; 10, pp. 6, 33, 39, 40; 14, pp. 164 through 174, 186, 187; 39; see Figure 3 and 

Sections 2.2.2 and 2.2.3 of this HRS documentation record). 

From 1929 to 2002, a paper and pulp mill facility operated on the CRC property (Refs. 8, p. 2; 10, pp. 4, 

5; 14, pp. 22, 315). By-products of the paper manufacturing process included black liquor (spent 

processing waste), coal tar constituents, and waste paper (Refs. 10, p. 6; 11, p. 6; 14, p. 8). Black liquor 

can be composed of phenols, sodium hydroxide, sodium oxide, and sulfur; as well as metals, such as 

calcium and magnesium (Refs. 10, p. 6; 14, p. 8; 29, p. 19). Coal tar consists of PAHs, phenols, 

heterocyclic oxygen, sulfur, and nitrogen compounds (Refs. 9, p. 220; 14, p. 8; 30, pp. 9, 21). Dioxins, 

furans, PAHs, and metals, such as chromium, copper, and manganese, can also be produced as byproducts of the paper manufacturing process (Refs. 49, p. 7; 51, p. 10; 54, pp. 1-1, 3-3, 3-4, 3-7 through 

3-11; 55, pp. 1, 2). These by-products were disposed of on the CRC property (Refs. 10, p. 31; 14, pp. 8, 

155, 169 through 181). 

Surface and subsurface soil samples were collected from Source No. 1 during the 2005 USACE TBA 

Phase II investigation and the 2009 TDEC site reassessment (Refs. 8, pp. 9, 29, 30; 11, pp. 4, 13, 14). 

The samples contained PAHs; dioxins and furans; and metals at concentrations greater than background 

levels (Ref. 8, pp. 15, 18, 20, 21; 11, pp. 38 through 42, 47, 48, 49; 40, p. 3-8) (see Tables 2 and 3 of this 

HRS documentation record). Samples evaluated for Source No. 1 were not impacted by EPA removal 

activities (Refs. 53, p. 1; 61, pp. 1, 2, 3). 

20 Source Characterization 
Source No: 1 

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE 

2005 USACE TBA Phase II Investigation 

USACE collected the surface soil samples listed in Table 2 during the 2005 TBA Phase II Investigation 

(Ref. 11, pp. 15, 16, 17). Composite surface soil sample SS-CRCB-A9-39-00-01 was chosen to represent 

background conditions because (1) the soil type at sample location SS-CRCB-A9-39-00-01 (loam) was 

similar to the soil types at the locations of samples collected from Source No. 1 (loam), and (2) this 

sampling location (a community center) appeared to be minimally affected by past facility operations 

(Refs. 11, pp. 17, 22; 20, pp. 1, 4; 28, pp. 1, 4; see Figure 3 of this HRS documentation record). Source 

No. 1 samples were collected from the process area (Ref. 11, pp. 15, 16, 21). Specifically, three 

composite surface soil samples (SS-CRCB-A2-03-00-01, SS-CRCB-A2-05-00-01, and SS-CRCB-A2-34­

00-01) were collected adjacent to waste paper pile 3 located northwest of the former paper and pulp mill 

building, and two composite surface soil samples (SS-CRCB-A4-26-00-01 and SS-CRCB-A4-27-00-01) 

were collected near the western wall of the steam generation and turbine building (Refs. 10, p. 47; 11, pp. 

15, 16, 21). The samples were collected using stainless steel hand augers (Refs. 11, p. 13; 25, pp. 28, 34). 

The background and contaminated composite surface soil samples were collected at a depth of 0 to 1 foot 

below ground surface (bgs) (Refs. 11, p. 13; 25, p. 40). 

Background and Source No. 1 surface soil samples were collected during the same sampling event, from 

the same depth (0 to 1 foot bgs), from similar soil types (loam), and in accordance with the same 

sampling procedures (Refs. 11, pp. 4, 13, 15, 16, 17; 20, pp. 1, 4; 25, pp. 28, 31, 40; 28, pp. 1, 4). The 

surface soil samples were collected in accordance with the EPA Region 4 Environmental Investigations 

Standard Operating Procedures and Quality Assurance Manual (EISOPQAM), May 1996, including 1997 

revisions and the EPA approved the quality assurance project plan (QAPP) (Refs. 11, pp. 4, 12; 25, p. 37; 

26, p. 3). 

The samples were analyzed for trace inductively coupled plasma (ICP) metals (EPA Method 6010B) and 

mercury (EPA Method 7470/7471) by Severn Trent Laboratories, Inc. (STL) (Refs. 11, pp. 130, 131, 132, 

141; 25, p. 32; 27, pp. 1, 1A, 2, 3; 40, pp. 1, 2, 3). Bhate Environmental, subcontractor for USACE, 

reviewed all data in accordance with the EPA National Functional Guidelines for Inorganic Data Review, 

EPA 540/R-99/013 (Refs. 11, pp. 12, 18). 

The reporting limits (RLs) are listed on the analytical data sheets in References 27 and 40. Each RL is 

sample-specific and analyte-specific and corresponds to the lowest quantitative point on the calibration 

curve; it is adjusted for the amount of sample prepared and any dilutions performed, as well as for percent 

moisture. The RLs are equivalent to SQLs as defined in HRS Section 1.1, Definitions (Refs. 1, Section 

1.1; 58). Logbook notes are provided in Reference 11, Appendix B. The chain-of-custody records are 

provided in Reference 11, Appendix C. The locations of the samples are depicted in Reference 11, pages 

21and 22, and are described in Reference 11, pages 15, 16, and 17 (see Figure 3 of this HRS 

documentation record). 

TABLE 2: Analytical Results for Source No. 1 Samples – 2005 

Sample ID 

Hazardous 

Substance 

Hazardous 

Substance 

Concentration RL References 

Background Surface Soil Sample 

SS-CRCB-A9-39-00-01 Chromium 34.7 mg/kg 1.2 mg/kg 11, pp. 114, 132; 40, p. 1299 

SS-CRCB-A9-39-00-01 Copper 22.2 mg/kg 3.1 mg/kg 11, pp. 114, 132; 40, p. 1299 

SS-CRCB-A9-39-00-01 Manganese 836 mg/kg 1.8 mg/kg 11, pp. 114, 132; 40, p. 1300 

SS-CRCB-A9-39-00-01 Mercury 0.37 mg/kg 0.041 mg/kg 11, pp. 114, 132; 40, p. 1300 

21 Source Characterization 
 

 

 

Source No: 1 

TABLE 2: Analytical Results for Source No. 1 Samples – 2005 

Sample ID 

Hazardous 

Substance 

Hazardous 

Substance 

Concentration RL References 

SS-CRCB-A9-39-00-01 Silver ND 1.2 mg/kg 11, pp. 114, 132; 40, p. 1300 

Contaminated Surface Soil Samples 

SS-CRCB-A2-03-00-01 Chromium 988 mg/kg 1.7 mg/kg 11, pp. 106, 131; 27, p. 1195 

SS-CRCB-A2-03-00-01 Copper 131 mg/kg 4.2 mg/kg 11, pp. 106, 131; 27, p. 1195 

SS-CRCB-A2-03-00-01 Manganese 9,400 mg/kg 25.1 mg/kg 

11, pp. 106, 131; 17, pp. 8, 

18; 18, pp. i, 1; 27, p. 1196; 

56, p. 17 

SS-CRCB-A2-03-00-01 Silver 18.6 mg/kg 1.7 mg/kg 11, pp. 106, 131; 27, p. 1196 

SS-CRCB-A2-05-00-01 Silver 9.3 mg/kg 1.5 mg/kg 11, pp. 106, 130; 27, p. 1192 

SS-CRCB-A2-34-00-01 Copper 122 mg/kg 6.2 mg/kg 11, pp. 106, 130; 27, p. 1189 

SS-CRCB-A4-26-00-01 Copper 126 mg/kg 3.0 mg/kg 11, pp. 109, 130; 27, p. 1173 

SS-CRCB-A4-26-00-01 Mercury 1.4 mg/kg 0.039 mg/kg 11, pp. 109, 130; 27, p. 1174 

SS-CRCB-A4-27-00-01 Copper 131 mg/kg 6.1 mg/kg 11, pp. 109, 130; 27, p. 1171 

Notes: 

00-01 0 to 1 foot below ground surface (Ref. 11, p. 13) 

## Sample Number 

A# Area Number 

CRCB Clinch River Corporation Brownfields 

ID Identification 

mg/kg Milligrams per kilogram 

ND The analyte was not detected at or above the reporting limit (Ref. 40, p. 3) 

SS Surface soil 

RL Reporting limit 

22 Source Characterization 
 

Source No: 1 

2009 TDEC Site Reassessment 

The surface soil samples listed in Table 3 were collected by TDEC during the 2009 site reassessment 

(Ref. 8, p. 9). Composite surface soil sample CR08 0709SF was chosen to represent background 

conditions because (1) the soil type at sample location CR08 0709SF (loam) was similar to the soil types 

at the locations of samples collected from Source No. 1 (loam), and (2) the sampling location (a baseball 

field) appeared minimally affected by past facility operations (Refs. 8, pp. 9, 30, 36, 359; 28, pp. 1, 4; 41, 

pp. 1, 4; see Figure 3 of this HRS documentation record). Source No. 1 samples were collected from the 

process area (Ref. 8, pp. 28, 30, 359). Specifically, one composite surface soil sample (CR09 0709SF) 

was collected west of the former paper and pulp mill building near waste paper pile 3; and one composite 

surface soil sample (CR13 0709SF) was collected near waste paper pile 1 (Refs. 8, pp. 9, 29, 30). The 

background and contaminated composite surface soil samples were collected at a depth of 0 to 2 inches 

bgs (Ref. 39). In September 2011, EPA initiated an emergency removal action. Stained surface soil 

directly surrounding the drums located in the drum storage area was removed, which affected sampling 

location CR11 0709SF from the 2009 TDEC site reassessment (Refs. 53, p. 1; 59, pp. 5, 28; 61, p. 1). 

This sampling location is not used in this HRS documentation record. 

Background and Source No. 1 composite surface soil samples were collected during the same sampling 

event, from the same depth (0 to 2 inches bgs), from similar soil types (loam), and in accordance with the 

same sampling procedures (Refs. 8, pp. 9, 27, 359; 28, pp. 1, 4; 39; 41, pp. 1, 4). The background and 

contaminated composite surface soil samples were collected in accordance with the EPA approved TDEC 

sampling and analysis plan (SAP) and QAPP, specifically the EPA Region 4 Science and Ecosystem 

Support Division (SESD) Field Branches Quality System and Technical Procedures (FBQSTP) for Soil 

Sampling, SESDPROC-300-R1 (Refs. 8, pp. 327, 346, 359; 39). 

The background and source samples were analyzed for SVOCs, dioxins, and metals (Ref. 8, p. 3). SVOC 

analysis (EPA Methods 8270D and 8270SIM) was conducted by the EPA Region 4 SESD Analytical 

Support Branch (ASB) in accordance with the ASB Laboratory Operations and Quality Assurance 

Manual (LOQAM) (Ref. 8, pp. 3, 95). EPA Region 4 SESD reviewed SVOC data in accordance with the 

ASB LOQAM, EPA methods and guidelines (Refs. 8, p. 95). Dioxins were analyzed by SGS 

Environmental Services in accordance with the EPA Contract Laboratory Program (CLP) Statement of 

Work (SOW) DLM02.0 (Ref. 8, pp. 3, 50, 51). Total metals were analyzed by CompuChem, currently 

known as Liberty Analytical Corporation (Liberty), in accordance with the EPA CLP SOW ILM05.3 

(Ref. 8, pp. 272, 273, 304, 306, 316). EPA Region 4 SESD reviewed dioxin and total metals data in 

accordance with the contract SOW and EPA guidelines (Refs. 8, pp. 3, 50, 51, 272, 273). 

The minimum reporting limits (MRLs) are listed on the analytical data sheets in Reference 8, Appendix 1. 

Each MRL is sample-specific and analyte-specific and corresponds to the lowest quantitative point on the 

calibration curve; it is adjusted for the amount of sample prepared and any dilutions performed, as well as 

for percent moisture (Ref. 15). The MRLs are equivalent to SQLs as defined in HRS Section 1.1, 

Definitions (Refs. 1, Section 1.1; 8, pp. 53, 98, 277; 15). Logbook notes are provided in Reference 16. 

The chain-of-custody records are provided in References 64, 65, and 66. The locations of the samples 

listed in Table 3 are depicted in Reference 8, page 30, and are described in Reference 8, page 9 (also see 

Figure 3 of this HRS documentation record). 

TABLE 3: Analytical Results for Source No. 1 Samples –2009 

Sample ID 

Hazardous 

Substance 

Hazardous 

Substance 

Concentration MRL References 

Background Surface Soil Sample 

CR08 0709SF Anthracene 3.8U μg/kg 3.8 μg/kg 8, p. 120; 16, p. 3; 64, p. 2 

CR08 0709SF Benzo(a)anthracene 7.3 μg/kg 3.8 μg/kg 8, p. 121; 16, p. 3; 64, p. 2 

23 Source Characterization 
Source No: 1 

TABLE 3: Analytical Results for Source No. 1 Samples –2009 

Sample ID 

Hazardous 

Substance 

Hazardous 

Substance 

Concentration MRL References 

CR08 0709SF Benzo(a)pyrene 6.6 μg/kg 3.8 μg/kg 8, p. 121; 16, p. 3; 64, p. 2 

CR08 0709SF Benzo(k)fluoranthene 4.2 μg/kg 3.8 μg/kg 8, p. 121; 16, p. 3; 64, p. 2 

CR08 0709SF Carbazole 3.8U μg/kg 3.8 μg/kg 8, p. 121; 16, p. 3; 64, p. 2 

CR08 0709SF Chrysene 8.9 μg/kg 3.8 μg/kg 8, p. 121; 16, p. 3; 64, p. 2 

CR08 0709SF Dibenzo(a,h)anthracene 3.8U μg/kg 3.8 μg/kg 8, p. 121; 16, p. 3; 64, p. 2 

CR08 0709SF Fluoranthene 12 μg/kg 3.8 μg/kg 8, p. 121; 16, p. 3; 64, p. 2 

CR08 0709SF Fluorene 3.8U μg/kg 3.8 μg/kg 8, p. 121; 16, p. 3; 64, p. 2 

CR08 0709SF Indeno(1,2,3-cd)pyrene 3.8U μg/kg 3.8 μg/kg 8, p. 121; 16, p. 3; 64, p. 2 

CR08 0709SF 2-Methylnaphthalene 17 μg/kg 3.8 μg/kg 8, p. 120; 16, p. 3; 64, p. 2 

CR08 0709SF Naphthalene 11 μg/kg 3.8 μg/kg 8, p. 121; 16, p. 3; 64, p. 2 

CR08 0709SF Phenanthrene 11 μg/kg 3.8 μg/kg 8, p. 122; 16, p. 3; 64, p. 2 

CR08 0709SF Pyrene 11 μg/kg 3.8 μg/kg 8, p. 122; 16, p. 3; 64, p. 2 

CR08 0709SF 1,2,3,4,6,7,8-HpCDD 52 ng/kg 4.3 ng/kg 8, p. 66; 16, p. 3; 65, p. 1 

CR08 0709SF 1,2,3,4,6,7,8-HpCDF 6.6 ng/kg 4.3 ng/kg 8, p. 66; 16, p. 3; 65, p. 1 

CR08 0709SF 1,2,3,4,7,8-HxCDD 0.57J (5.7) 

ng/kg 4.3 ng/kg 8, p. 66; 16, p. 3; 17, pp.8, 9; 

18, pp. i, 1; 65, p. 1 

CR08 0709SF 1,2,3,6,7,8-HxCDD 1.4J (14) ng/kg 4.3 ng/kg 8, p. 66; 16, p. 3; 17, pp. 8, 

9; 18, pp. i, 1; 65, p. 1 

CR08 0709SF 1,2,3,7,8,9-HxCDD 1.4J (14) ng/kg 4.3 ng/kg 8, p. 66; 16, p. 3; 17, pp. 8, 

9; 18, pp. i, 1; 65, p. 1 

CR08 0709SF Cadmium 0.52J (0.73) 

mg/kg 0.57 mg/kg 8, p. 304; 16, p. 3; 17, p. 8, 18; 18, pp. i, 1; 66, p. 1 

CR08 0709SF Chromium 15 mg/kg 1.1 mg/kg 8, p. 304; 16, p. 3; 66, p. 1 

CR08 0709SF Copper 12 mg/kg 2.9 mg/kg 8, p. 304; 16, p. 3; 66, p. 1 

CR08 0709SF Lead 30 mg/kg 1.1 mg/kg 8, p. 304; 16, p. 3; 66, p. 1 

CR08 0709SF Mercury 0.11U mg/kg 0.11 mg/kg 8, p. 304; 16, p. 3; 66, p. 1 

CR08 0709SF Nickel 8.7 mg/kg 4.6 mg/kg 8, p. 304; 16, p. 3; 66, p. 1 

CR08 0709SF Zinc 50 mg/kg 6.9 mg/kg 8, p. 304; 16, p. 3; 66, p. 1 

Contaminated Surface Soil Samples 

CR09 0709SF Benzo(a)anthracene 100 μg/kg 43 μg/kg 8, p. 124; 16, p. 4; 64, p. 2 

CR09 0709SF Benzo(a)pyrene 110 μg/kg 43 μg/kg 8, p. 124; 16, p. 4; 64, p. 2 

CR09 0709SF Benzo(k)fluoranthene 110 μg/kg 43 μg/kg 8, p. 124; 16, p. 4; 64, p. 2 

CR09 0709SF Carbazole 37 μg/kg 4.3 μg/kg 8, p. 124; 16, p. 4; 64, p. 2 

CR09 0709SF Chrysene 140 μg/kg 43 μg/kg 8, p. 124; 16, p. 4; 64, p. 2 

24 Source Characterization 
Source No: 1 

TABLE 3: Analytical Results for Source No. 1 Samples –2009 

Sample ID 

Hazardous 

Substance 

Hazardous 

Substance 

Concentration MRL References 

CR09 0709SF Dibenzo(a,h)anthracene 26J (26) μg/kg 4.3 μg/kg 8, p. 124; 16, p. 4; 17, pp. 8, 

14; 18, pp. i, 1; 64, p. 2 

CR09 0709SF Fluoranthene 140 μg/kg 43 μg/kg 8, p. 124; 16, p. 4; 64, p. 2 

CR09 0709SF Fluorene 5.2 μg/kg 4.3 μg/kg 8, p. 124; 16, p. 4; 64, p. 2 

CR09 0709SF Indeno(1,2,3-cd)pyrene 83 μg/kg 4.3 μg/kg 8, p. 124; 16, p. 4; 64, p. 2 

CR09 0709SF 2-Methylnaphthalene 110 μg/kg 43 μg/kg 8, p. 123; 16, p. 4; 64, p. 2 

CR09 0709SF Naphthalene 84 μg/kg 43 μg/kg 8, p. 124; 16, p. 4; 64, p. 2 

CR09 0709SF Phenanthrene 94 μg/kg 43 μg/kg 8, p. 125; 16, p. 4; 64, p. 2 

CR09 0709SF Pyrene 150 μg/kg 43 μg/kg 8, p. 125; 16, p. 4; 64, p. 2 

CR09 0709SF 1,2,3,4,6,7,8-HpCDD 710 ng/kg 3.9 ng/kg 8, p. 67; 16, p. 4; 65, p. 1 

CR09 0709SF 1,2,3,4,6,7,8-HpCDF 150 ng/kg 3.9 ng/kg 8, p. 67; 16, p. 4; 65, p. 1 

CR09 0709SF Copper 45 mg/kg 3.2 mg/kg 8, p. 306; 16, p. 4; 66, p. 2 

CR09 0709SF Lead 290 mg/kg 1.3 mg/kg 8, p. 306; 16, p. 4; 66, p. 2 

CR09 0709SF Mercury 0.37 mg/kg 0.14 mg/kg 8, p. 306; 16, p. 4; 66, p. 2 

CR09 0709SF Zinc 760 mg/kg 7.7 mg/kg 8, p. 306; 16, p. 4; 66, p. 2 

CR13 0709SF Anthracene 290J (290) 

μg/kg 25 μg/kg 8, p. 135; 16, p. 3; 17, pp. 8, 

14; 18, pp. i, 2; 64, p. 3 

CR13 0709SF Benzo(a)anthracene 530 μg/kg 250 μg/kg 8, p. 136; 16, p. 3; 64, p. 3 

CR13 0709SF Benzo(a)pyrene 560 μg/kg 250 μg/kg 8, p. 136; 16, p. 3; 64, p. 3 

CR13 0709SF Benzo(k)fluoranthene 780 μg/kg 250 μg/kg 8, p. 136; 16, p. 3; 64, p. 3 

CR13 0709SF Carbazole 68 μg/kg 25 μg/kg 8, p. 136; 16, p. 3; 64, p. 3 

CR13 0709SF Chrysene 800 μg/kg 250 μg/kg 8, p. 136; 16, p. 3; 64, p. 3 

CR13 0709SF Dibenzo(a,h)anthracene 98 μg/kg 25 μg/kg 8, p. 136; 16, p. 3; 64, p. 3 

CR13 0709SF Fluoranthene 730 μg/kg 250 μg/kg 8, p. 136; 16, p. 3; 64, p. 3 

CR13 0709SF Fluorene 25 μg/kg 25 μg/kg 8, p. 136; 16, p. 3; 64, p. 3 

CR13 0709SF Indeno(1,2,3-cd)pyrene 330 μg/kg 25 μg/kg 8, p. 136; 16, p. 3; 64, p. 3 

CR13 0709SF 2-Methylnaphthalene 520 μg/kg 250 μg/kg 8, p. 135; 16, p. 3; 64, p. 3 

CR13 0709SF Naphthalene 270 μg/kg 25 μg/kg 8, p. 136; 16, p. 3; 64, p. 3 

CR13 0709SF Phenanthrene 210 μg/kg 25 μg/kg 8, p. 137; 16, p. 3; 64, p. 3 

CR13 0709SF Pyrene 780 μg/kg 250 μg/kg 8, p. 137; 16, p. 3; 64, p. 3 

CR13 0709SF 1,2,3,4,6,7,8-HpCDD 1,000 ng/kg 4.7 ng/kg 8, p. 72; 16, p. 3; 65, p. 2 

CR13 0709SF 1,2,3,4,6,7,8-HpCDF 180 ng/kg 4.7 ng/kg 8, p. 72; 16, p. 3; 65, p. 2 

CR13 0709SF Copper 57 mg/kg 4.6 mg/kg 8, p. 316; 16, p. 3; 66, p. 2 

25 Source Characterization 
 

 

 

 

Source No: 1 

TABLE 3: Analytical Results for Source No. 1 Samples –2009 

Sample ID 

Hazardous 

Substance 

Hazardous 

Substance 

Concentration MRL References 

CR13 0709SF Zinc 160 mg/kg 11 mg/kg 8, p. 316; 16, p. 3; 66, p. 2 

Notes: 

( ) Although not required by the HRS for source data, concentration shown in parentheses was adjusted based on 

bias in accordance with References 17, p. 8, and 18, pp. i, 1, 2, to show the relative increase over the 

background level. 

CR Clinch River 

ID Identification 

HpCDD Heptachlorodibenzodioxin 

HpCDF Heptachlorodibenzofuran 

HxCDD Hexachlorodibenzodioxin 

J The identification of the analyte is acceptable; the reported value is an estimate (Ref. 8, pp. 53, 98, 277) 

MRL Minimum reporting limit 

μg/kg Micrograms per kilogram 

mg/kg Milligrams per kilogram 

ng/kg Nanograms per kilogram 

SF Surface soil 

SFD Surface soil duplicate 

U The analyte was not detected at or above the reporting limit (Ref. 8, pp. 98, 277) 

26 Source Characterization 
Source No: 1 

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY 

Source No. 1 is an area of contaminated soil resulting from discrete operations (e.g., disposal practices) 

around the process area (Refs. 8, pp. 9, 14 through 21, 29, 30; 10, pp. 6, 47; 11, pp. 21, 38 through 42, 47, 

48, 49; see Figure 3 of this HRS documentation record). Source No. 1 samples contain anthracene; 

benzo(a)anthracene; benzo(a)pyrene; benzo(k)fluoranthene; carbazole; chrysene; dibenzo(a,h)anthracene; 

fluoranthene; fluorene; indeno(1,2,3-cd)pyrene; 2-methlynaphthalene; naphthalene; phenanthrene; 

pyrene; 1,2,3,4,6,7,8-HpCDD; 1,2,3,4,6,7,8-HpCDF; 1,2,3,4,7,8-HxCDD; 1,2,3,6,7,8-HxCDD; 

1,2,3,7,8,9-HxCDD; cadmium; chromium; copper; lead; manganese; mercury; nickel; silver; and zinc (see 

Tables 2 and 3 of this HRS documentation record). 

During the 2009 TDEC site reassessment, no examined portion of the CRC property, including Source 1, 

contained a functioning and maintained run-on control or runoff management system (Ref. 39). 

Therefore, a containment factor value of 10, as noted below in Table 4, was assigned for the surface water 

migration pathway (Ref. 1, Section 4.1.2.1.2.1.1, and Table 4-2). 

Analytical results for sediment samples collected from the Emory River, which receives runoff from 

Source No. 1, indicate that a release of hazardous substances has occurred to the surface water migration 

pathway, as documented in Section 4.0 of this HRS documentation record. 

TABLE 4: Containment Factors for Source No. 1 

Containment Description 

Containment 

Factor Value References 

Gas release to air NS NA 

Particulate release to air NS NA 

Release to ground water NS NA 

Release via overland migration or flood: no 

engineered maintained cover or functioning and 

maintained run-on control system or runoff 

management system is present. 

10 

1, Section 4.1.2.1.2.1.1; 8, pp. 1, 2, 

30, 33, 34, 35; 10, pp. 6, 33, 39, 40; 

14, pp. 164 through 174, 186, 187; 

39 

Notes: 

NA Not applicable 

NS Not scored 

27 Source Characterization 
Source No: 1 

2.4.2.1 HAZARDOUS WASTE QUANTITY 

2.4.2.1.1 Hazardous Constituent Quantity 

The mass of CERCLA hazardous substances contained in Source No. 1 is not known. The information 

available is not sufficient to evaluate Tier A, hazardous constituent quantity, as required by Reference 1, 

Section 2.4.2.1.1. 

Hazardous Constituent Quantity Assigned Value: NS 

2.4.2.1.2 Hazardous Wastestream Quantity 

The mass of CERCLA hazardous substances, pollutants, and contaminants contained in Source No. 1 

cannot be adequately quantified or verified. The information available is not sufficient to evaluate Tier B, 

hazardous wastestream quantity, as required by Reference 1, Section 2.4.2.1.2. 

Hazardous Wastestream Quantity Assigned Value: NS 

2.4.2.1.3 Volume 

The depth of the contaminated soil source is not known and the extent of the source has not been 

determined. The information available is not sufficient to evaluate Tier C, volume, as required by 

Reference 1, Table 2-5. 

Volume Assigned Value: 0 

2.4.2.1.4 Area 

Source No. 1 contains multiple discrete areas of contaminated soil where facility operations and/or 

disposal occurred; however, the extent and continuity of contamination between discrete areas in Source 

No. 1 is not known (Refs. 8, pp. 15, 18, 20, 21, 30; 11, pp. 21, 38 through 42, 47 through 49; see Figure 3 

of this HRS documentation record). Therefore, the area of Source No. 1 is undetermined, but greater than 

zero. 

Sum (square feet [ft2

]): >0 

Equation for Assigning Value (Ref. 1, Table 2-5): Area (A)/34,000 

Area Assigned Value: >0 

2.4.2.1.5 Source Hazardous Waste Quantity Value 

Source No. 1 is assigned a source HWQ value that is undetermined, but greater than zero (Ref. 1, Section 

2.4.2.1.5). 

Source HWQ Value: >0 

28 Source Characterization 
 

 

 

SUMMARY OF SOURCE DESCRIPTIONS
 

TABLE 5: Summary of Source Descriptions 

Source 

No. 

Source 

Hazardous 

Waste 

Quantity 

Value 

Source 

Hazardous 

Constituent 

Quantity 

Complete? 

(Yes/No) 

Containment Factor Value by Pathway 

Ground 

Water 

(Ref. 1, 

Table 3-2) 

Surface 

Water 

Overland/ 

Flood 

(Ref. 1, 

Table 4-2) 

Air 

Gas 

(Ref. 1, 

Table 6-3) 

Particulate 

(Ref. 1, 

Table 6-9) 

1 >0 No NS 10 NS NS 

Notes: 

NS Not scored 

Also see Table 4 and Section 2.4.2.1.5 of this HRS documentation record. 

Sum of Source Hazard Waste Quantity Values: >0 

Other Possible Sources 

Black Liquor Pond: Wastes from paper mill operations were dumped on the CRC property into an 

unlined surface impoundment (black liquor pond), located on the southern portion of the property (Refs. 

8, p. 29; 10, p. 6; 14, p. 155). The CRC property flooded in the fall of 1990 and washed black liquor and 

coal tar waste water into the Emory River (Ref. 14, p. 8). From May 1990 to March 1991, TDHE 

collected surface water samples from the surface impoundment (black liquor pond). The samples 

contained arsenic, acetone, toluene, and xylenes (Refs. 8, p. 29; 14, pp. 13, 16, 63, 64, 113, 114). In 

2011, TDEC observed liquid in the pond; however, it is not known if this liquid is black liquor (Ref. 45, 

p. 1). 

Former Coal Tar Pond: Wastes from paper mill operations were also dumped on the CRC property into 

an unlined surface impoundment (former coal tar pond), located on the northwestern side of the property 

(Refs. 10, p. 6; 11, pp. 7, 11). The CRC property flooded in the fall of 1990 and washed black liquor and 

coal tar waste water into the Emory River (Ref. 14, p. 8). From May 1990 to March 1991, TDHE 

collected surface water samples from the surface impoundment (former coal tar pond). The samples 

contained arsenic, cadmium, chromium, copper, lead, manganese, mercury, nickel, selenium, zinc, 

acetone and phenols (Refs. 14, pp. 14, 16, 63, 64, 113, 114). In the late 1990s, the property owner 

(owner’s name unknown) paved the northern portion of the CRC property, including the coal tar pond 

(Refs. 10, p. 6; 39; 45, p. 1). In 2012, during the EPA removal action, a soil boring was advanced through 

the concrete at the former location of the coal tar pond to a depth of 35 feet bgs. Black liquor was 

observed in the boring (Ref. 45, pp. 1, 19, 21). 

Waste Paper Piles: Wastes from paper mill operations were dumped on the CRC property in multiple 

waste paper piles, including: (1) waste paper pile 1, located about 525 feet north of the former paper and 

pulp mill building; (2) waste paper pile 2, located adjacent to the black liquor pond; (3) waste paper pile 

3, located about 100 feet northwest of the former paper and pulp mill building, and (4) waste paper pile 4, 

located on a concrete slab inside a fenced enclosure on the southern portion of Parcel 002.00 (Refs. 8, p. 

29; 10, p. 6; 14, pp. 169 through 183, 185). From May 1990 to March 1991, TDHE collected surface soil 

samples from waste paper pile 1 and waste paper pile 2. The samples contained arsenic, cadmium, 

chromium, copper, lead, manganese, nickel, silver, zinc, aldrin, acetone, benzene, methylene chloride, 

MEK, and xylenes (Ref. 14, pp. 16, 63, 64, 80, 81, 113, 114). 

Residual Releases from Tanks and Containers: In 2005, Shaw observed about 106 damaged, leaking, or 

open containers (55-gallon drums and two 250-gallon totes) containing various oily liquid wastes in and 

29 Source Characterization 
 

 

around the chipper shed. The oily liquid wastes were suspected to contain lubricant oils, white paper and 

black paper liquor waste, water, and other waste. Notable dark staining was observed in the area near the 

leaking containers (Ref. 10, pp. 39, 51, 52). In 2009, TDEC personnel observed the same drums observed 

by Shaw in 2005 as well as several large tanks, including a 600,000-gallon AST, on the CRC property 

(Ref. 8, pp. 1, 3, 29, 37). In September 2011, a waste sample was collected of the liquid within a 15,000­

gallon AST located southeast of the former paper and pulp mill building. This sample contained PAHs, 

specifically benzo(a)pyrene, which exceeded its National Recommended Water Quality Criteria value 

(Refs. 59, pp. 3, 5, 6, 11; 61, p. 1). In February 2012, EPA removed all drums and containers from the 

CRC property and excavated a UST, which contained approximately 38,500 gallons of black liquor that 

was located southeast of the former paper and pulp mill building. Once the UST was removed, black 

liquor and associated sludge were observed in the tank pit. This material was removed; however, about 6 

inches of water containing black liquor was noted seeping into the excavated tank pit (Refs. 45, pp. 19, 

21, 22, 24, 26). 

Mill By-product: During the 2005 TBA Phase II investigation, two samples were collected from the 

interior of the paper and pulp mill building (Ref. 11, p. 16). One composite sample (SS-CRCB-A5-21­

00-01) was collected from material located on the floor of the paper and pulp mill building, and one 

composite sample (SS-CRCB-A5-22-00-01) was collected from a sump (Ref. 11, pp. 16, 21, 83 through 

86). These samples contained arsenic, beryllium, cadmium, chromium, copper, lead, manganese, nickel, 

selenium, and zinc (Ref. 11, pp. 26, 27, 50). 

In 2009, TDEC observed a by-product from facility operations, which appeared to be a dry, powdery, 

dark brown to gray, extremely fine-grained material that was approximately 3 inches thick, overlying the 

concrete floor of the paper and pulp mill building (Ref. 39). This same by-product was observed within 1 

to 2 feet outside the paper and pulp mill building along the eastern side of the building, adjacent to the 

Emory River (Ref. 45, p. 1). A composite sample (CR10 0709SF) was collected and contained PAHs; 

dioxins and furans; PCBs; and metals including anthracene; benzo(a)anthracene; benzo(a)pyrene; 

benzo(k)fluoranthene; carbazole; chrysene; dibenzo(a,h)anthracene; fluoranthene; fluorene; indeno(1,2,3­

cd)pyrene; 2-methlynaphthalene; naphthalene; phenanthrene; pyrene; 1,2,3,4,6,7,8-HpCDD; 1,2,3,4,6,7,8­

HpCDF; 1,2,3,6,7,8-HxCDD; PCB-1242; PCB-1254; cadmium; chromium; copper; lead; mercury; 

nickel; and zinc (Refs. 8, pp. 9, 68, 87, 126, 127, 128, 308; 39). The paper and pulp mill building was 

demolished in 2010 (Ref. 45, p. 1). The demolition debris was not removed from the property but was 

pushed into vats inside the former paper and pulp mill building (Ref. 45, pp. 1, 4, 6, 7, 10). By-product 

on the floor inside the building was not removed before demolition (Ref. 45, p. 1). By-product is still 

present on the ground surface at the location of the former paper and pulp mill building and in 

surrounding areas (Refs. 8, pp. 36, 39; 45, p. 1). No functioning and maintained run-on control or runoff 

management system was observed in the vicinity of the former paper and pulp mill building during the 

2009 TDEC site reassessment (Refs. 39; 45, p. 1). 

30 Source Characterization 
4.0 SURFACE WATER MIGRATION PATHWAY 

4.1 OVERLAND/FLOOD MIGRATION COMPONENT – Emory/Clinch Rivers 

4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood Component 

The hazardous substance migration pathway includes both the overland segment and the in-water segment 

that hazardous substances would take as they migrate away from sources. The overland segment begins 

at the source and proceeds downgradient to the probable point of entry (PPE) to surface water. The inwater segment at the PPE continues in the direction of flow (Ref. 1, Section 4.1.1.1). 

Surface water runoff from Source No. 1 follows land topography, which slopes east and south, and enters 

the Emory River along the CRC property’s eastern boundary between the two observed release samples 

(CR03 0709SD and CR06 0709SD); this area generally corresponds to the area of the property described 

as the “drainage” area (Refs. 8, p. 6; 11, pp. 11, 17, 88; see Figure 3 of this HRS documentation record). 

From the southern corner of Source No. 1 (SS-CRCB-A4-27-00-01), surface water runoff flows about 

230 feet southeast to the western bank of the Emory River. From the central portion of Source No. 1 

(CR09 0709SF), surface water runoff flows about 270 feet southeast to the western bank of the Emory 

River. From the northern corner of Source No. 1 (CR13 0709SF), surface water runoff flows about 90 

feet east to the western bank of the Emory River (see Figures 1 and 3 of this HRS documentation record). 

The PPE extends about 250 feet along Emory River between the two observed release samples (CR03 

0709SD and CR06 0709SD) (see Figures 1 and 3 of this HRS documentation record). Samples CR06 

0709SD/CR06 0709SDD and CR03 0709SD were each collected at the confluence of drainage ditches 

originating on the Clinch River Corporation property and the Emory River, and are located within the 

PPE (Ref. 8, p. 7; 67, p. 1). 

The surface water migration pathway target distance limit (TDL) begins at sample location CR03 

0709SD, which is the downstream boundary of the PPE. From this portion of the PPE, flow continues in 

a northerly, then southeasterly direction for about 11 miles and empties into the Clinch River. Flow 

continues in the Clinch River for about 4 miles, where the 15-mile surface water migration pathway TDL 

is completed (Refs. 3; 19; 21; see Figure 3 of this HRS documentation record). The Emory River and the 

Clinch River are part of the Watts Bar Reservoir, which was constructed in 1942 (Refs. 34, p. 1; 48, p. i). 

The flow rate for the Emory River at Oakdale, Tennessee, located about 6.9 miles upstream of the CRC 

property, is 1,469 cubic feet per second (cfs) (Refs. 22, pp. 1, 3; 35). The CRC property is located within 

the 100-year floodplain of the Emory River (Refs. 23; 24, p. 1). 

31 SW-Overland/Flood Migration Component 
 

 

4.1.2.1.1 OBSERVED RELEASE 

Direct Observation 

Evidence of observed release by direct observation includes: 

	 Several spills, releases, and NPDES permit violations have been documented throughout the 

facility’s operational history. Between 1988 and 1989, the facility illegally discharged process 

water, cooling water, and waste paper wash runoff into the Emory River (Ref. 14, pp. 345, 354, 

357, 359, 361, 367). Discoloration (black and gray) of the Emory River directly adjacent to and 

downstream of the CRC property was also documented during this period (Ref. 14, pp. 354, 360, 

362). 

	 The CRC property flooded in 1990, and as a result, waste paper, black liquor, and coal tar 

wastewater were deposited into the Emory River (Ref. 14, pp. 8, 159 through 161, 164 through 

166, 186, 187). 

	 During the 1991 TDHE site inspection, TDHE observed (1) black liquor and coal tar leaching 

into the Emory River from the CRC property below the water line, and (2) that the south waste 

paper impoundment had partially collapsed into the Emory River, dumping waste paper and 

waste paper rolls into the river (Ref. 14, pp. 8, 14, 16, 165 through 168, 186, 187). 

	 In June 2002, the owner of Parcel 003.01 was convicted of intentionally releasing approximately 

500,000 gallons of process liquid containing black liquor and solids, the contents of an AST, onto 

the ground and into the Emory River on February 14, 1999, during a period of heavy rains (Refs. 

7, p. 11; 46, p. 1; 47, p. 11; 62, p. 17). 

Paper and pulp mill effluent can contain PAHs; dioxins and furans; and metals (Refs. 49, p. 7; 51, p. 10; 

54, pp. 1-1, 3-7, 3-8, 3-11). PAHs are contained in coal tar (Refs. 9, p. 220; 14, p. 8; 30, pp. 9, 21). 

Dioxins and furans accumulate in the pulp and are chemicals of concern in wastewater treatment sludge 

and in liquid (re-pulped) effluent (Ref. 50, pp. 6, 10). Metals, such as cadmium, chromium, copper, lead, 

mercury, nickel, and zinc can be contained in effluent and in pulp mill sludge (Refs. 50, p. 10; 51, pp. 1, 

2, 3; 54, pp. 1-1, 3-11). 

Chemical Analysis 

Background Sample 

The background sediment sample listed in Table 6 (CR02 0709SD) was collected during the 2009 TDEC 

site reassessment (Ref. 8, pp. 3, 7). Background sediment sample CR02 0709SD was collected from the 

Emory River adjacent to the CRC property at a depth of 0 to 4 inches below the surface water-sediment 

interface (bsw), upstream and outside the influence of Source No. 1 (Refs. 8, pp. 7, 30, 32, 358; 39; see 

Figure 3 of this HRS documentation record). The sample was collected using a ponar dredge device 

(Refs. 8, p. 358; 39). 

Background and observed release sediment samples were collected during the same sampling event, at the 

same depths, from similar soil types (silty sand with gravel and organics), and in accordance with the 

same sampling procedures (Refs. 8, p. 358; 16, p. 6; 39; 57, p. 1; see Figure 3 of this HRS documentation 

record). 

The background sediment sample was collected in accordance with the EPA approved TDEC SAP and 

QAPP, specifically the EPA Region 4 SESD FBQSTP for Soil Sampling, SESDPROC-300-R1 (Refs. 8, 

pp. 327, 346, 359; 39). Logbook notes are provided in Reference 16. The chain-of-custody records are 

provided in References 64 and 66. The location of the sediment sample presented in Table 6 is depicted 

in Reference 8, page 30 (see Figure 3 of this HRS documentation record). 

32 SW-Observed Release 
 

 

 

TABLE 6: Background Sediment Sample – 2009 

Sample ID Sample Location 

Distance from 

PPE 

Depth 

(inches bsw) 

Date 

Sampled References 

CR02 0709SD 

Along the western 

bank of the Emory 

River, and south 

of Source No. 1 

600 feet 

upstream of 

PPE 

0 to 4 07/21/2009 

3; 8, pp. 6, 7, 30; 

16, p. 7; 39; see 

Figure 3 of this 

HRS 

documentation 

record 

Notes: 

bsw Below the surface water-sediment interface 

CR Clinch River 

ID Identification 

PPE Probable point of entry 

SD Sediment 

33 SW-Observed Release 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Background Concentrations 

The background sediment sample listed in Table 7 was collected during the 2009 TDEC site reassessment 

(Ref. 8, pp. 3, 7). The background sediment sample was analyzed for SVOCs and metals (Ref. 8, p. 3). 

SVOC analysis (EPA Methods 8270D and 8270SIM) was conducted by the EPA Region 4 SESD ASB in 

accordance with the ASB LOQAM (Ref. 8, pp. 3, 95). EPA Region 4 SESD verified SVOC data in 

accordance with the ASB LOQAM, EPA methods and guidelines (Refs. 8, pp. 95, 98). Total metals were 

analyzed by CompuChem, currently known as Liberty, in accordance with EPA CLP SOW ILM05.3 

(Ref. 8, pp. 272, 273, 284). EPA Region 4 SESD reviewed the total metals data in accordance with the 

CLP SOW and EPA guidelines (Refs. 8, pp. 3, 273). 

The MRLs are listed on the analytical data sheets in Reference 8, Appendix 1. Each MRL is samplespecific and analyte-specific and corresponds to the lowest quantitative point on the calibration curve; it is 

adjusted for the amount of sample prepared and any dilutions performed, as well as for percent moisture 

(Ref. 15). The MRLs are equivalent to SQLs as defined in HRS Section 1.1, Definitions (Refs. 1, Section 

1.1; 8, pp. 53, 98; 15). The analytical data sheets are provided in Reference 8, Appendix 1. 

TABLE 7: Analytical Results for Background Sediment Sample – 2009 

Sample ID Hazardous Substance 

Hazardous 

Substance 

Concentration MRL References 

CR02 0709SD Benzo(a)anthracene 5.9 μg/kg 4.2 μg/kg 8, p. 100; 64, p. 1 

CR02 0709SD Benzo(k)fluoranthene 4.2U μg/kg 4.2 μg/kg 8, p. 100; 64, p. 1 

CR02 0709SD Carbazole 4.2U μg/kg 4.2 μg/kg 8, p. 100; 64, p. 1 

CR02 0709SD Chrysene 9.7 μg/kg 4.2 μg/kg 8, p. 100; 64, p. 1 

CR02 0709SD Dibenzo(a,h)anthracene 4.2U μg/kg 4.2 μg/kg 8, p. 100; 64, p. 1 

CR02 0709SD Fluoranthene 16 μg/kg 4.2 μg/kg 8, p. 100; 64, p. 1 

CR02 0709SD Fluorene 5.1 μg/kg 4.2 μg/kg 8, p. 100; 64, p. 1 

CR02 0709SD Indeno (1,2,3-cd)pyrene 4.2U μg/kg 4.2 μg/kg 8, p. 100; 64, p. 1 

CR02 0709SD 2-Methylnaphthalene 56 μg/kg 4.2 μg/kg 8, p. 99; 64, p. 1 

CR02 0709SD Naphthalene 27 μg/kg 4.2 μg/kg 8, p. 100; 64, p. 1 

CR02 0709SD Phenanthrene 28 μg/kg 4.2 μg/kg 8, p. 101; 64, p. 1 

CR02 0709SD Pyrene 12 μg/kg 4.2 μg/kg 8, p. 101; 64, p. 1 

CR02 0709SD Chromium 4.4 mg/kg 1.3 mg/kg 8, p. 284; 66, p. 1 

CR02 0709SD Copper 3.5 mg/kg 3.3 mg/kg 8, p. 284; 66, p. 1 

CR02 0709SD Manganese 54 mg/kg 2.0 mg/kg 8, p. 284; 66, p. 1 

Notes: 

CR Clinch River 

ID Identification 

μg/kg Micrograms per kilogram 

mg/kg Milligrams per kilogram 

MRL Minimum reporting limit 

SD Sediment 

34 SW-Observed Release 
 

Contaminated Samples 

Sediment samples listed in Table 8 were collected during the 2009 TDEC site reassessment (Ref. 8, pp. 3, 

7). The samples were collected at a depth of 0 to 4 inches bsw along the western bank of the Emory 

River (Refs. 8, pp. 7, 30, 358; 39; see Figure 4 of this HRS documentation record). 

The samples were collected in accordance with the EPA Region 4 SESD FBQSTP for Sediment 

Sampling, SESDPROC-200-R1 (Ref. 8, p. 358; 39). Logbook notes are provided in Reference 16. The 

chain-of-custody records are provided in References 64 and 66. The locations of the sediment samples 

presented in Table 8 are depicted in Reference 8, page 30 (see Figure 4 of this HRS documentation 

record). 

TABLE 8: Contaminated Sediment Samples – 2009 

Sample ID Sample Location 

Distance 

from PPE 

Depth 

(inches 

bsw) 

Date 

Sampled References 

CR06 0709SD 

Along the western 

bank of the Emory 

River, east of the 

former paper and pulp 

mill building 

0 feet from 

the PPE 0 to 4 07/21/2009 

3; 8, pp. 29, 30; 16, 

p. 8; 39; see Figure 3 

of this HRS 

documentation 

record 

CR06 0709SDD 

Along the western 

bank of the Emory 

River, east of the 

former paper and pulp 

mill building 

0 feet from 

the PPE 0 to 4 07/21/2009 

3; 8, pp. 29, 30; 16, 

p. 8; 39; see Figure 3 

of this HRS 

documentation 

record 

CR03 0709SD 

Along the western 

bank of the Emory 

River, northeast of the 

former paper and pulp 

mill building, about 

250 feet downstream 

from CR06 0709SD 

and CR06 0709SDD 

0 feet from 

the PPE 0 to 4 07/20/2009 

3; 8, pp. 29, 30; 16, 

p. 6; 39; see Figure 3 

of this HRS 

documentation 

record 

Notes: 

bsw Below the surface water-sediment interface 

CR Clinch River 

ID Identification 

PPE Probable point of entry 

SD Sediment 

SDD Sediment duplicate 

35 SW-Observed Release 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Contaminated Concentrations 

The sediment samples listed in Table 9 were collected during the 2009 TDEC site reassessment (Ref. 8, 

pp. 3, 7). The sediment samples were analyzed for SVOCs and total metals (Ref. 8, p. 3). SVOC analysis 

(EPA Methods 8270D and 8270SIM) was conducted by the EPA Region 4 SESD ASB in accordance 

with the ASB LOQAM (Ref. 8, pp. 3, 95). EPA Region 4 SESD verified SVOC data in accordance with 

the ASB LOQAM, EPA methods and guidelines (Refs. 8, pp. 95, 98). Total metals were analyzed by 

CompuChem, currently known as Liberty, in accordance with EPA CLP SOW ILM05.3 (Ref. 8, pp. 3, 

272, 273, 290, 298, 300). EPA Region 4 SESD reviewed the total metals data in accordance with the 

CLP SOW and EPA guidelines (Refs. 8, pp. 3, 273). 

The MRLs are listed on the analytical data sheets in Reference 8, Appendix 1. Each MRL is samplespecific and analyte-specific and corresponds to the lowest quantitative point on the calibration curve; it is 

adjusted for the amount of sample prepared and any dilutions performed, as well as for percent moisture 

(Ref. 15). The MRLs are equivalent to SQL as defined in HRS Section 1.1, Definitions (Ref. 15). The 

analytical data sheets are provided in Reference 8, Appendix 1 (Refs. 1, Section 1.1; 8, pp. 53, 98). 

TABLE 9: Analytical Results for Contaminated Sediment Samples – 2009 

Sample ID Hazardous Substance 

Hazardous 

Substance 

Concentration MRL References 

CR03 0709SD Benzo(a)anthracene 38 μg/kg 4.3 μg/kg 8, p. 109; 64, p. 1 

CR03 0709SD Benzo(k)fluoranthene 10 μg/kg 4.3 μg/kg 8, p. 109; 64, p. 1 

CR03 0709SD Carbazole 35 μg/kg 4.3 μg/kg 8, p. 109; 64, p. 1 

CR03 0709SD Chrysene 110 μg/kg 43 μg/kg 8, p. 109; 64, p. 1 

CR03 0709SD Dibenzo(a,h)anthracene 5.7 μg/kg 4.3 μg/kg 8, p. 109; 64, p. 1 

CR03 0709SD Fluoranthene 120 μg/kg 43 μg/kg 8, p. 109; 64, p. 1 

CR03 0709SD Fluorene 40 μg/kg 4.3 μg/kg 8, p. 109; 64, p. 1 

CR03 0709SD 2-Methylnaphthalene 1,600 μg/kg 43 μg/kg 8, p. 108; 64, p. 1 

CR03 0709SD Naphthalene 1,100 μg/kg 43 μg/kg 8, p. 109; 64, p. 1 

CR03 0709SD Phenanthrene 690 μg/kg 43 μg/kg 8, p. 110; 64, p. 1 

CR03 0709SD Pyrene 110 μg/kg 43 μg/kg 8, p. 110; 64, p. 1 

CR03 0709SD Chromium 18 mg/kg 1.4 mg/kg 8, p. 290; 66, p. 1 

CR03 0709SD Copper 14 mg/kg 3.4 mg/kg 8, p. 290; 66, p. 1 

CR03 0709SD Manganese 200 mg/kg 2.0 mg/kg 8, p. 290; 66, p. 1 

CR06 0709SD Benzo(a)anthracene 38 μg/kg 4.4 μg/kg 8, p. 148; 64, p. 4 

CR06 0709SD Benzo(k)fluoranthene 15 μg/kg 4.4 μg/kg 8, p. 148; 64, p. 4 

CR06 0709SD Carbazole 31 μg/kg 4.4 μg/kg 8, p. 148; 64, p. 4 

CR06 0709SD Chrysene 110 μg/kg 44 μg/kg 8, p. 148; 64, p. 4 

CR06 0709SD Dibenzo(a,h)anthracene 5.7 μg/kg 4.4 μg/kg 8, p. 148; 64, p. 4 

36 SW-Observed Release 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

TABLE 9: Analytical Results for Contaminated Sediment Samples – 2009 

Sample ID Hazardous Substance 

Hazardous 

Substance 

Concentration MRL References 

CR06 0709SD Fluoranthene 130 μg/kg 44 μg/kg 8, p. 148; 64, p. 4 

CR06 0709SD Fluorene 37 μg/kg 4.4 μg/kg 8, p. 148; 64, p. 4 

CR06 0709SD Indeno(1,2,3-cd)pyrene 14 μg/kg 4.4 μg/kg 8, p. 148; 64, p. 4 

CR06 0709SD 2-Methylnaphthalene 1,400 μg/kg 44 μg/kg 8, p. 147; 64, p. 4 

CR06 0709SD Naphthalene 980 μg/kg 44 μg/kg 8, p. 148; 64, p. 4 

CR06 0709SD Phenanthrene 590 μg/kg 44 μg/kg 8, p. 149; 64, p. 4 

CR06 0709SD Pyrene 110 μg/kg 44 μg/kg 8, p. 149; 64, p. 4 

CR06 0709SD Manganese 210 mg/kg 2.0 mg/kg 8, p. 298; 66, p. 3 

CR06 0709SDD Benzo(a)anthracene 39 μg/kg 4.3 μg/kg 8, p. 151; 64, p. 5 

CR06 0709SDD Benzo(k)fluoranthene 8.6 μg/kg 4.3 μg/kg 8, p. 151; 64, p. 5 

CR06 0709SDD Carbazole 33 μg/kg 4.3 μg/kg 8, p. 151; 64, p. 5 

CR06 0709SDD Chrysene 120 μg/kg 43 μg/kg 8, p. 151; 64, p. 5 

CR06 0709SDD Dibenzo(a,h)anthracene 6.0 μg/kg 4.3 μg/kg 8, p. 151; 64, p. 5 

CR06 0709SDD Fluoranthene 110 μg/kg 43 μg/kg 8, p. 151; 64, p. 5 

CR06 0709SDD Fluorene 43 μg/kg 4.3 μg/kg 8, p. 151; 64, p. 5 

CR06 0709SDD Indeno(1,2,3-cd)pyrene 9.5 μg/kg 4.3 μg/kg 8, p. 151; 64, p. 5 

CR06 0709SDD 2-Methylnaphthalene 1,700 μg/kg 43 μg/kg 8, p. 150; 64, p. 5 

CR06 0709SDD Naphthalene 1,100 μg/kg 43 μg/kg 8, p. 151; 64, p. 5 

CR06 0709SDD Phenanthrene 720 μg/kg 43 μg/kg 8, p. 152; 64, p. 5 

CR06 0709SDD Pyrene 110 μg/kg 43 μg/kg 8, p. 152; 64, p. 5 

CR06 0709SDD Manganese 250 mg/kg 2.0 mg/kg 8, p. 300; 66, p. 3 

Notes: 

CR Clinch River 

ID Identification 

MRL Minimum reporting limit 

mg/kg Milligrams per kilogram 

μg/kg Micrograms per kilogram 

SD Sediment 

SDD Sediment duplicate 

37 SW-Observed Release 
 

Attribution 

From 1929 to 2002, a paper and pulp mill operated on the CRC property (Refs. 8, p. 2; 10, pp. 4, 5; 14, 

pp. 22, 315). Former operations included manufacturing corrugated containers using paperboard from 

pulp production (Ref. 14, pp. 256, 280, 315). The manufacturing process included partially digesting raw 

hardwood chips with sodium sulfite, sodium carbonate, and live steam. The wood chips were further 

refined using a mechanical pulping process (Refs. 10, p. 6; 14, pp. 8, 211, 280, 400; 44, p. 10). 

By-products of the paper manufacturing process included paper waste, black liquor (spent processing 

waste), and coal tar constituents (Refs. 10, p. 6; 11, p. 6; 14, p. 8). Black liquor can be composed of 

phenols, sodium hydroxide, sodium oxide, and sulfur; as well as metals, such as calcium and magnesium 

(Refs. 10, p. 6; 14, p. 8; 29, p. 19). Coal tar consists of PAHs, phenols, heterocyclic oxygen, sulfur, and 

nitrogen compounds (Refs. 9, p. 220; 14, p. 8; 30, p. 9). Dioxins, furans, PAHs, and metals were also 

produced as by-products of the paper manufacturing process (Refs. 49, p. 7; 51, p. 10; 54, pp. 1-1, 3-3, 3­

4, 3-7, 3-8, 3-10, 3-11; 55, pp. 1, 2). 

Waste paper, black liquor, and coal tar wastes were disposed of on the CRC property (Refs. 10, p. 6; 11, 

p. 7; 14, pp. 8, 155, 156, 157, 169 through 183, 185). The black liquor and coal tar wastes were placed in 

two unlined surface impoundments (the black liquor pond and the former coal tar pond) and in drums 

(Refs. 10, p. 31; 11, pp. 7, 11; 14, pp. 8, 155). Waste paper was placed in piles located in various places 

around the process area (Refs. 10, p. 6; 14, pp. 169 through 181, 185). 

Paper and pulp mill effluent can contain PAHs; dioxins and furans; and metals (Refs. 49, p. 7; 51, p. 10; 

54, pp. 1-1, 3-3, 3-4, 3-7, 3-8, 3-10, 3-11; 55, pp. 1, 2). PAHs, such as fluoranthene, fluorene, 

phenanthrene, and pyrene are contained in coal tar (Refs. 49, p. 7; 51, pp. 6, 10). Dioxins and furans 

accumulate in the pulp and are chemicals of concern in wastewater treatment sludge and in liquid (repulped) effluent (Ref. 50, pp. 6, 10). Metals, such as cadmium, chromium, copper, lead, mercury, nickel, 

and zinc can be contained in effluent and in pulp mill sludge (Refs. 50, p. 10; 51, pp. 1, 2, 3; 54, pp. 1-1, 

3-10, 3-11). 

Several spills, releases, and NPDES permit violations have been documented throughout the facility’s 

operational history. Between 1988 and 1989, the facility illegally discharged process water, cooling 

water, and waste paper wash runoff into the Emory River (Ref. 14, pp. 345, 354, 359, 361, 367). 

Discoloration (black and gray) of the Emory River directly adjacent to and downstream of the CRC 

property was also documented during this period (Ref. 14, pp. 354, 357, 360, 362). In 2011, pipes and 

seeps that discharge into the Emory River were observed along the eastern boundary of the CRC property 

(Ref. 45, pp. 12 through 18). The northern portion of the CRC property (near waste paper pile 1) flooded 

in 1990, and as a result, waste paper, black liquor, and coal tar waste water were deposited into the Emory 

River (Ref. 14, pp. 8, 159 through 161, 164 through 166, 186, 187). During the 1991 TDHE site 

inspection, TDHE observed (1) black liquor and coal tar leaching into the Emory River from the CRC 

property below the water line, and (2) that the south waste paper impoundment had partially collapsed 

into the Emory River, dumping waste paper and waste paper rolls into the river (Ref. 14, pp. 8, 14, 16, 

165 through 168, 186, 187). In June 2002, the owner of Parcel 003.01 was convicted of intentionally 

releasing approximately 500,000 gallons of process liquid containing black liquor and solids, the contents 

of an AST, onto the ground and into the Emory River on February 14, 1999, during a period of heavy 

rains (Refs. 7, p. 11; 46, p. 1; 47, p. 11; 62, p. 17). 

Surface water runoff from Source No. 1 follows land topography, which slopes east and south, and enters 

the Emory River along the CRC property’s eastern boundary between observed release samples CR03 

0709SD and CR06 0709SD, which is the PPE for the surface water migration pathway (Refs. 8, p. 6; 11, 

pp. 11, 17, 88; see Figure 3 of this HRS documentation record). 

Surface and subsurface soil samples collected from Source No. 1 (contaminated soil resulting from 

discrete operations (e.g., disposal practices) around the process area) contained PAHs; dioxin and furans; 

and metals (Refs. 8, pp. 67, 72, 123, 124, 125, 135, 136, 137, 306, 316; 27, pp. 1171, 1173, 1174, 1189, 

38 SW-Observed Release 
 

1192, 1195, 1196; see also Figure 3 of this HRS documentation record). Specifically, the samples 

contained benzo(a)pyrene, dibenzo(a,h)anthracene, naphthalene, 1,2,3,4,6,7,8-HpCDD; 1,2,3,4,6,7,8­

HpCDF, cadmium, chromium, copper, manganese, and mercury, among others (see Tables 2 and 3 of this 

HRS documentation record). Analyses of sediment samples collected from the western bank of the 

Emory River (which abuts the CRC property) within and downstream of the PPE contained 

dibenzo(a,h)anthracene, naphthalene, chromium, copper, and manganese, among others, at concentrations 

above background levels (see Tables 8 and 9 of this HRS documentation record). The presence of these 

hazardous substances in Source No. 1 and in sediment samples collected from the western bank of the 

Emory River, and the lack of a functioning and maintained run-or control and runoff management system 

indicate that Source No. 1 is not contained (Refs. 1, Table 4-2; 39). 

Current property uses do not suggest another source of contamination to the Emory River in the vicinity 

of the Clinch River Corporation property (Ref. 57, p. 1). No NPL sites are located within a one-mile 

radius of the CRC property (Ref. 31, pp. i, 3). Master Wood Products (MWP), also known as the 

Christmas Lumber Company Truss Shop, is located approximately 0.91 mile upstream of the CRC 

property and the CRC PPE and background sediment samples (Ref. 31, pp. i, 5, 9, 10, 11). MWP 

produces non-upholstered wooden household furniture (Ref. 31, p. 4). As of September 2, 2000, MWP 

was listed as an inactive RCRA facility (Ref. 31, p. 4). 

The hazardous substances listed below have been documented in Source No. 1 as well as in sediments of 

the Emory River, indicating that a release has occurred or is occurring at the CRC property (see Tables 2 

and 3 in Section 2.2.2 for Source No. 1, and Table 9 in Section 4.1.2.1.1, Observed Release, of this HRS 

documentation record). 

Hazardous Substances in the Release: 

Benzo(a)anthracene 

Benzo(k)fluoranthene 

Carbazole 

Chrysene 

Dibenzo(a,h)anthracene 

Fluoranthene 

Fluorene 

Indeno(1,2,3-cd)pyrene 

2-Methylnaphthalene 

Naphthalene 

Phenanthrene 

Pyrene 

Chromium 

Copper 

Manganese 

Surface Water Observed Release Factor Value: 550 

39 SW-Observed Release 
4.1.2 DRINKING WATER THREAT WASTE CHARACTERISTICS 

No drinking water intakes are located on the Emory River or on the Clinch River within the 15-mile 

downstream TDL (Refs. 3; 32, pp. i, 4). The City of Harriman provides municipal water to area residents 

from a surface water intake located on the Emory River about 1.33 miles upstream of the CRC property 

(Refs. 3; 32, pp. i, 1, 2, 4). The drinking water threat was not scored because it is not expected to 

contribute significantly to the overall site score. 

40 SW-Drinking Water Threat 
 

 

 

 

4.1.3.2 HUMAN FOOD CHAIN THREAT WASTE CHARACTERISTICS 

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation 

Table 10 lists toxicity, persistence, and bioaccumulation factor values for hazardous substances that were 

detected in the source samples and have containment factor values exceeding 0. The combined toxicity, 

persistence, and bioaccumulation factor values are assigned in accordance with Reference 1, Section 

4.1.3.2.1. Table 9 of this HRS documentation record previously identified those hazardous substances 

associated with observed release. 

TABLE 10: Toxicity/Persistence/Bioaccumulation 

Hazardous 

Substance 

Source 

No. 

Observed 

Release? 

(Yes/No) 

Toxicity 

Factor 

Value 

Persistence 

Factor 

Value1 

Bioaccumulation 

Value2 

Toxicity/ 

Persistence/ 

Bioaccumulation 

Factor 

Value (Ref. 

1, Table 4-

16) Reference 

Anthracene 1 No 10 0.4000 50,000 2E+5 2, p. BI-1 

Benzo(a)anthracene 1 Yes 1,000 1 50,000 5E+7 2, p. BI-2 

Benzo(a)pyrene 1 No 10,000 1 50,000 5E+8 2, p. BI-2 

Benzo(k)fluoranthene 1 Yes 100 1 50,000 5E+6 2, p. BI-2 

Carbazole 1 Yes 10 0.4000 500 2,000 2, p. BI-2 

Chrysene 1 Yes 10 1 5.0 50 2, p. BI-3 

Dibenzo(a,h)anthracene 1 Yes 10,000 1 50,000 5E+8 2, p. BI-4 

Fluoranthene 1 Yes 100 1 500 5E+4 2, p. BI-2 

Fluorene 1 Yes 100 1 500 5E+4 2, p. BI-6 

Indeno(1,2,3-cd)pyrene 1 Yes 1,000 1 50,000 5E+7 2, p. BI-8 

2-Methlynaphthalene 1 Yes 1,000 0.4000 50,000 2E+7 2, p. BI-9 

Naphthalene 1 Yes 1,000 0.4000 50,000 2E+7 2, p. BI-9 

Phenanthrene 1 Yes 0 0.4000 5,000 0 2, p. BI-9 

Pyrene 1 Yes 100 1 50,000 5E+6 2, p. BI-10 

1,2,3,4,6,7,8-HpCDD 1 No 10,000 1 50,000 5E+8 2, p. BI-6 

1,2,3,4,6,7,8-HpCDF 1 No 10,000 1 50,000 5E+8 2, p. BI-7 

1,2,3,4,7,8-HxCDD 1 No 10,000 1 50,000 5E+8 2, p. BI-7 

1,2,3,6,7,8-HxCDD 1 No 10,000 1 5,000 5E+7 2, p. BI-7 

1,2,3,7,8,9-HxCDD 1 No 10,000 1 50,000 5E+8 2, p. BI-7 

Cadmium 1 No 10,000 1 5,000 5E+7 2, p. BI-2 

41 SW-Human Food Chain Threat 
TABLE 10: Toxicity/Persistence/Bioaccumulation 

Hazardous 

Substance 

Source 

No. 

Observed 

Release? 

(Yes/No) 

Toxicity 

Factor 

Value 

Persistence 

Factor 

Value1 

Bioaccumulation 

Value2 

Toxicity/ 

Persistence/ 

Bioaccumulation 

Factor 

Value (Ref. 

1, Table 4-

16) Reference 

Chromium 1 Yes 10,000 1 500 5E+6 2, p. BI-3 

Copper 1 Yes 0 1 500 0 2, p. BI-3 

Lead 1 No 10,000 1 5.0 50,000 2, p. BI-8 

Manganese 1 Yes 10,000 1 50,000 5E+8 2, p. BI-8 

Mercury 1 No 10,000 0.4000 50,000 2E+8 2, p. BI-8 

Nickel 1 No 10,000 1 0.5 5,000 2, p. BI-9 

Silver 1 No 100 1 50 5,000 2, p. BI-10 

Zinc 1 No 10 1 5.0 50 2, p. BI-12 

Notes: 

1 Persistence factor value for rivers 2 Bioaccumulation factor value for fresh water 

HpCDD Heptachlorodibenzodioxin 

HpCDF Heptachlorodibenzofuran 

HxCDD Hexachlorodibenzodioxin 

Toxicity/Persistence/Bioaccumulation Factor Value: 5E+8 

(Ref. 1, Section 4.1.3.2.1.4) 

42 SW-Human Food Chain Threat 
 

4.1.3.2.2 HAZARDOUS WASTE QUANTITY 

TABLE 11: Hazardous Waste Quantity 

Source No. Source Type Source Hazardous Waste Quantity 

1 

Contaminated soil resulting from 

discrete operations (e.g., disposal 

practices) around the process 

area 

Undetermined, but greater than zero 

Source No. 1 contains multiple discrete areas of contaminated soil where facility operations and/or 

disposal occurred; however, the extent and continuity of contamination between discrete areas in Source 

No. 1 is not known (Refs. 8, pp. 15, 18, 20, 21, 30; 11, pp. 21, 38 through 42, 47 through 49; see Figure 3 

of this HRS documentation record). Therefore, the area of Source No. 1 is undetermined, but greater than 

zero. 

The Source HWQ value for Source No. 1 is undetermined but greater than zero. Because actual 

contamination at Level II concentrations is present in a fishery, and the hazardous constituent quantity is 

not adequately determined, the hazardous waste quantity receives a minimum factor value of 100 for the 

surface water migration pathway (Ref. 1, Section 2.4.2.2). 

Sum of Source Hazardous Waste Quantity Values: >0 

Hazardous Waste Quantity Factor Value: 100 

(Ref. 1, Section 2.4.2.2) 

4.1.3.2.3 CALCULATION OF HUMAN FOOD CHAIN THREAT 

WASTE CHARACTERISTICS FACTOR CATEGORY VALUE 

The waste characteristics factor category was obtained by multiplying the toxicity/persistence and HWQ 

factor values, subject to a maximum product of 1 x 108

. Then, this product was multiplied by the 

bioaccumulation potential factor value, subject to a maximum product of 1 x 1012. Based on this product, 

a value was assigned in accordance with Reference 1, Table 2-7. 

Toxicity/Persistence Factor Value: 10,000 

Hazardous Waste Quantity Factor Value: 100 

Toxicity/Persistence Factor Value × 

Hazardous Waste Quantity Factor Value: 1 x 106 

Toxicity/Persistence Factor Value × 

Hazardous Waste Quantity Factor Value × Bioaccumulation Factor Value (50,000): 5 x 1010 

Waste Characteristics Factor Category Value: 320 

(Ref. 1, Table 2-7) 

43 SW-Human Food Chain Threat 
 

 

 

4.1.3.3 HUMAN FOOD CHAIN THREAT TARGETS 

Level I Concentrations 

No Level I concentrations have been documented. 

Level II Concentrations 

Level II concentrations have been documented in the Emory River. According to the U.S. Fish and 

Wildlife Service (USFWS), TDEC, and the Tennessee Wildlife Resources Agency (TWRA), the Emory 

River is fished adjacent to the CRC property and within the PPE. This area receives runoff from Source 

No. 1, and the fish are consumed (Refs. 33, p. 1; 42, pp. 1, 2; 57, p. 1; 63, p. 1). During the 2010 TDEC 

ESI, several fishermen were observed fishing on the Emory River adjacent to the facility (Refs. 33, pp. 1, 

2, 3; 63, p. 1). Sediment samples CR03 0709SD, CR06 0709SD, and CR06 0709SDD were collected 

within the extent of the PPE which is within the fishery (Refs. 8, p. 7; 57, pp. 1, 2). The sampling 

locations are shown in Reference 8, page 30 (see Figure 3 of this HRS documentation record). 

Most Distant Level II Sample 

Investigation: 2009 Site Reassessment 

Sample ID: CR03 0709SD 

Sample Medium: Sediment 

Hazardous Substances: Benzo(a)anthracene, Benzo(k)fluoranthene, Carbazole, Chrysene, 

Dibenzo(a,h)anthracene, Fluoranthene, Fluorene, 

2-Methylnaphthalene, Naphthalene, Phenanthrene, Pyrene, Chromium, 

Copper, and Manganese 

Location: Emory River, 0 feet from the PPE 

References: 3; 8, pp. 30, 109, 290; see Tables 8 and 9 of this HRS documentation 

record 

TABLE 12: Level II Fishery 

Identity of Fishery 

Extent of Level II Fishery 

(Relative to PPE) References 

Emory River 

The extent of the Level II fishery is about 250 feet 

as measured from CR03 0709SD to CR06 

0709SD; both samples were collected within the 

extent of the PPE 

3; 8, pp. 30; 33, p. 1; 42, 

pp. i, 1; 57, pp. 1, 2; 63, 

p. 1 (see Figure 3 of this 

HRS documentation 

record) 

4.1.3.3.1 Food Chain Individual 

As noted in Section 4.1.2.1.1, an observed release of hazardous substances having a bioaccumulation 

factor value of 500 or greater is documented in perennial surface water body within a fishery (Emory 

River) (see Tables 9 and 11 and Figure 3 of this HRS documentation record). The Emory River (Watts 

Bar Reservoir) is used for recreational and subsistence fishing, and recreational activities such as boating 

and swimming (Refs. 21; 33, p .1; 42, pp. 1, 2; 48; 57, pp. 1, 2; 63, p. 1). According to the USFWS, 

TDEC, and TWRA, the Emory River is fished in the vicinity of the CRC property, which receives runoff 

from Source No. 1, and the fish are consumed (Refs. 33, p. 1; 42, pp. i, 1; 57, pp. 1, 2; 63, p. 1; see Figure 

3 of this HRS documentation record). During the 2009 and 2010 TDEC sampling events, several 

fishermen were observed fishing on the Emory River between the observed release samples (Refs. 33, pp. 

1, 2; 57, pp. 1, 2). The types of fish caught and consumed from the Emory River include catfish, crappie 

(black, blacknose, and white), and bass (largemouth, rock, smallmouth, striped, spotted, white, and 

yellow), bluegill, redear, and redbreast (Refs. 42, pp. 1, 2, 3; 57, p. 1). A fish consumption advisory for 

mercury is currently in effect for the Emory River; however, the limits of this advisory (upstream of river 

44 SW-Human Food Chain Threat 
 

 

mile 12.4) are located upstream from the CRC property (at approximately river mile 11.5) (Refs. 19; 37, 

p. 2). 

Sample ID: CR03 0709SD 

Level I/Level II/Potential: Level II 

Hazardous Substances: Benzo(a)anthracene, Benzo(k)fluoranthene, Carbazole, Chrysene, 

Dibenzo(a,h)anthracene, Fluoranthene, Fluorene, 2-Methylnaphthalene, Naphthalene, 

Phenanthrene, Pyrene, Chromium, Copper, Manganese 

Bioaccumulation Potential: 50,000 

Sample ID: CR06 0709SD 

Level I/Level II/Potential: Level II 

Hazardous Substances: Benzo(a)anthracene, Benzo(k)fluoranthene, Carbazole, Chrysene, 

Dibenzo(a,h)anthracene, Fluoranthene, Fluorene, Indeno(1,2,3-cd)pyrene, 

2-Methylnaphthalene, Naphthalene, Phenanthrene, Pyrene, Manganese 

Bioaccumulation Potential: 50,000 

Sample ID: CR06 0709SDD 

Level I/Level II/Potential: Level II 

Hazardous Substances: Benzo(a)anthracene, Benzo(k)fluoranthene, Carbazole, Chrysene, 

Dibenzo(a,h)anthracene, Fluoranthene, Fluorene, Indeno(1,2,3-cd)pyrene, 2-Methylnaphthalene, 

Naphthalene, Phenanthrene, Pyrene, Manganese 

Bioaccumulation Potential: 50,000 

Food Chain Individual Factor Value: 45 

(Ref. 1, Section 4.1.3.3.1) 

4.1.3.3.2 Population 

4.1.3.3.2.1 Level I Concentrations 

No Level I concentrations have been documented. 

4.1.3.3.2.2 Level II Concentrations 

The Emory River is evaluated as a Level II fishery. According to the USFWS, TDEC, and TWRA, the 

Emory River is fished adjacent to the CRC property and within the PPE. This area receives runoff from 

Source No. 1, and the fish are consumed (Refs. 33, p. 3; 42, pp. i, 1; 57, pp. 1, 2; 63, p. 1; see Figure 3 of 

this HRS documentation record). Information is not available on the annual production of fish caught in 

the Emory River within the TDL. Therefore, the annual production for the water body is undetermined 

but greater than zero because the Emory River is a fishery (Refs. 33, p. 1; 42, pp. i, 1; 63, p. 1). 

Identity 

of Fishery 

Annual Production 

(pounds) 

Population Value (Pi) 

(Ref. 1, Table 4-18) References 

Emory River >0 0.03 

3; 22, pp. 1, 3; 33, 

pp. 1, 2, 3; 57, pp. 

1, 2; 63 p. 1 

Level II Concentrations Factor Value: 0.03

 (Ref. 1, Section 4.1.3.3.2.2) 

45 SW-Human Food Chain Threat 
4.1.4.2 ENVIRONMENTAL THREAT WASTE CHARACTERISTICS 

No wetlands are located in the immediate vicinity of the CRC property (Ref. 43, p. 1). No sensitive 

environments or sensitive species are located on the Emory River within the 15-mile downstream TDL 

(Refs. 38, p. 1; 63, p. 1). The environmental threat was not scored because it is not expected to 

significantly contribute to the overall site score. 

46 SW-Environmental Threat