HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD COVER SHEET

Name of Site: Southeastern Wood Preserving 

EPA ID No.: MSD000828558 

Contact Persons 

Documentation Record: Cathy Amoroso, National Priorities List Coordinator 

 (404) 562-8637 

 Ralph Howard, Remedial Project Manager 

 (404) 562-8829 

 U.S. Environmental Protection Agency, Region 4 

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

 Atlanta, Georgia 30303 

 

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 pathway is sufficient to qualify 

the site for the National Priorities List (NPL). These pathways are of concern to EPA and may be 

considered during future evaluation. 

Ground Water Migration Pathway: Canton Municipal Utilities (CMU) operates six municipal drinking 

water wells within a 4-mile radius of the Southeastern Wood Preserving (SWP) property, serving about 

15,000 customers (Ref. 28). The nearest CMU well is located within 0.25 mile of SWP (Ref. 27). CMU 

maintains two water treatment facilities where the water is mixed in distribution lines (Ref. 28). All six 

CMU wells are completed in the Sparta aquifer and range in depth from 892 feet below ground surface 

(bgs) to 1,075 feet bgs (Refs. 28; 29, p. 87; 30, p. 57). Hazardous substances were not detected in the 

CMU wells that were sampled during the September 2008 expanded site inspection (Ref. 5, Appendix B, 

Table 15, pp. B-32, B-33). There are 46 in use domestic wells that obtain water from the Cockfield 

aquifer (from 54 feet to 550 feet bgs) within a 4-mile radius of SWP (the nearest domestic well is located 

0.5 to 1 mile from SWP) (Refs. 5, p. 13; 32, pp. 2 through 8). These wells are about 200 feet deep and 

serve approximately 131 people (Refs. 31, p. 1; 32). The surficial and Cockfield aquifers are separated by 

a Yazoo clay layer that is approximately 40 feet thick. The Cockfield and Sparta aquifers are separated 

by the Cook Mountain confining unit, which is encountered at a depth of about 450 feet bgs and is 60 to 

200 feet thick in the vicinity of the SWP property (Ref. 5, pp. 13, 14). One temporary monitoring well 

installed in the surficial aquifer on the SWP property during the 2008 expanded site inspection contained 

concentrations of semivolatile organic compounds (Ref. 5, p. 15; 5, Appendix A, Figure 4, p. A-4; 5, 

Appendix B, Table 15, pp. B-32, B-33; 5, Appendix E, pp. E-72, E-73, E-74). 

Soil Exposure Pathway: One surface soil (0 to 6 inches bgs) sample and one subsurface soil (12 to 24 

inches bgs) sample were collected from each of six residential properties located southwest of SWP (Ref. 

5, Appendix A, Figure 4, p. A-4; 5, Appendix B, Table 2, pp. B-3, B-4). Two of these properties are 

located within the original footprint of King Lumber, which operated a saw mill, lumber yard, and wood 

treating facility from 1928 to 1961 (Refs. 5, Appendix A, Figure 3, p. A-3; 7, p. i; 8, p. 1). Residential 

soil samples contained carcinogenic polycyclic aromatic hydrocarbons as well as dioxins and furans (Ref. 

5, Appendix B, Tables 24, 25, and 26, pp. B-51 through B-62). About 3,951 people reside within 1 mile 

of SWP (Ref. 33, p. i). No residences are located on the SWP areas of observed contamination. Several 

federally designated endangered and threatened species inhabit Madison County, Mississippi; however, 

specific habitat locations have not been identified (Ref. 34, p. 5). 

Air Migration Pathway: No air samples have been collected at SWP. The residential population within 

4 radial miles of SWP is about 14,923 people (Ref. 33, p. i). Several federally designated endangered and 

threatened species inhabit Madison County, Mississippi; however, specific habitat locations have not 

been identified (Ref. 34, p. 5).
HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD

Name of Site: Southeastern Wood Preserving 

EPA Region: 4 

Date Prepared: September 2011 

Street Address of Site*: Northern side of Covington Drive (Ref. 5, Appendix A, Figure 2, p. A-2) 

City, County, State, Zip: Canton, Madison County, Mississippi, 39046 

General Location in the State: Central portion of state 

Topographic Map: Canton, MS (1989) 

Latitude: 32° 37′ 5.019′′ North 

Longitude: 90° 1′ 5.4804′′ West 

The coordinates above for Southeastern Wood Preserving were measured from the center of the stockpile 

(Source No. 1) of partially treated waste material (Refs. 3; 5, Appendix A, Figure 2, p. A-2; 18, 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 the U.S. 

Environmental Protection Agency (EPA) considers part of the site based on the screening information 

EPA used to evaluate the site for National Priorities List (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 
2 

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 9227.5236

Soil Exposure Pathway Score (Ss) NS NS

Air Migration Pathway Score (Sa) NS NS

S2

gw + S2sw + S2s + S2a 9227.5236

(S2

gw + S2sw + S2s + S2a) / 4 2306.8809

√ (S2

gw + S2sw + S2s + S2a) / 4 48.03

Note: 

NS = Not scored
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 550 550 550 

2. Potential to Release by Overland Flow: 

2a. Containment 10 

2b. Runoff 25 

2c. Distance to Surface Water 25 

2d. Potential to Release by Overland Flow [lines 

2a(2b + 2c)] 

500 

3.Potential to Release by Flood: 

3a. Containment (Flood) 10 

3b. Flood Frequency 50 

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

4. Potential to Release (lines 2d + 3c, subject to a 

maximum of 500) 

500 

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 

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 

3 
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) 

0.0003

19d. Population (lines 19a + 19b + 19c) (b) 0.0303 

20. Targets (lines 18 + 19d) (b) 45.0303 

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 

c

 Do not round to nearest integer 

NS Not scored

4 
I 

P

Un

SOUTH

T

MADI

M

SOUTHEASTERN WOOD PRESERVING

LEG
D D D D D D D D D

D D D D D

B a t c h e l o r C r e e k

Tribu tary 1

Tribu tary 3

PENICK

ORGANICS

LEGEN

ApBaBaApDrRaApApPr

D D

D

D D St

0 

Notes:Aerial Google Refere67, pp. 

CUR

SOUT
#*

!(

!(

!( !(

!(

!(

!(

!( !( !(

!( !( !(

") ") ") B a t c h e l o r C r e e k

Tribu

tary

1

Tribu

tary

3

SWP-WS-02

SWP-WS-02D

SWP09

SWP-WS-03

SWP-WS-01

SWP14

SWP13 SWP12

SWP11

SWP10

SWP05

SWP04

SWP03

SWP02

SWP08

SWP07

SWP06

SWPB01

LEGEN

") S!( S

#* B

PDRASTE(C

0 

Notes:Aerial PDigitalGReferen6, pp. 1

B -D -SWP -WS -

SW

SOUT
REFERENCES 

1. U.S. Environmental Protection Agency (EPA). Hazard Ranking System, 55 Federal Register 51532. 

December 14, 1990. 138 Pages. 

2. EPA. Superfund Chemical Data Matrix (SCDM). January 2004. Excerpt, 53 Pages. A complete 

copy of SCDM is available at: http://epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm. 

3. Tetra Tech EM Inc. (Tetra Tech). Project Note to File with Attachment. Subject: Coordinates at the 

Center of the Waste Stockpile. Attachment: Google Earth Map. October 26, 2009. 2 Pages. 

4. Tetra Tech. 15-Mile Surface Water Pathway. U.S. Geological Survey (USGS) 7.5 Minute Series 

Topographic Map Quadrangles: Berryville, MS 1989; Way, MS 1989; Charlton, MS 1988; Canton, 

MS 1989. 1 Map. 

5. Tetra Tech. Final Expanded Site Inspection Report. Southeastern Wood Preserving, Canton, 

Madison County, Mississippi. July 17, 2009. 429 Pages. 

6. Tetra Tech. Project Note to File with Attachment. Subject: Parcel Information for the Southeastern 

Wood Preserving Site in Madison County, Mississippi. Attachment: Madison County, Mississippi 

Property Parcel Details. October 27, 2009. 3 Pages. 

7. Tetra Tech. Record of Telephone Conversation with Attachment. Subject: Current Conditions at the 

Southeastern Wood Preserving Site in Canton, Madison County, MS. Between Quinn Kelley, 

Environmental Scientist, and Richard V. Ball, Environmental Scientist, Mississippi Department of 

Environmental Quality (MDEQ), Office of Pollution Control. Attachment: Photographs. March 5, 

2010. 8 Pages. 

8. Mississippi Department of Environmental Quality (MDEQ), Office of Pollution Control. Letter with 

Attachments. Subject: Southeastern Woods Creosoting Site, Madison County, Mississippi. From 

Richard V. Ball, MDEQ, to Sandra Harrigan, Tetra Tech. May 21, 2009. 6 Pages. 

9. Roy F. Weston, Inc. Bioremediation at the Southeastern Wood Preserving Site. Prepared for Rita 

Ford, U.S. EPA, Region IV. March 1991. 14 Pages. 

10. MDEQ, Office of Pollution Control. Site Inspection Prioritization, Final Report. Southeastern 

Wood Preserving, Canton, Madison County, Mississippi, MSD000828558. March 11, 1994. 373 

Pages. 

11. EPA. Pollution Report No. 1, Southeastern Wood Preserving, Removal Site Evaluation. Prepared 

by Alyssa Hughes, On-Scene Coordinator. October 23, 2007. 3 Pages. 

12. Mississippi Bureau of Pollution Control (MBPC). Potential Hazardous Waste Site, Preliminary 

Assessment of Southeastern Wood Preserving, Inc. September 21, 1985. 7 Pages. 

13. MBPC. Potential Hazardous Waste Site, Site Inspection Report (EPA Form 2070-13) for 

Southeastern Wood Preserving, Inc. December 9, 1985. 33 Pages. 

14. EPA. Action Memorandum. Subject: Request for $2 Million Exemption and Ceiling Increase at the 

SWP Site, Canton, Mississippi. July 5, 1990. 21 Pages.

15. NUS Corporation. Listing Site Inspection, Phase I for Southeastern Wood Preserving, Inc., Canton, 

Madison County, Mississippi, EPA ID No. MSD000828558. Prepared for A.R. Hanke, Waste 

Programs Branch, Waste Management Division, EPA. August 29, 1990. 65 Pages. 

8
16. OHM Remediation Services Corp. (OHM). Final Report, Volume I of II. Southeastern Wood 

Preserving Site Canton, Mississippi. May 16, 1995. 648 Pages. 

17. EPA. Memorandum to File. Subject: Southeastern Wood Preserving Company Site, Canton, MS, 

Site Regulatory History 1995-2007. Prepared by Ralph O. Howard, Jr., EPA Remedial Project 

Manager, Site Evaluation Coordinator, Superfund Remedial & Site Evaluation Branch, Superfund 

Division. June 16, 2009. 2 Pages. 

18. EPA, Region 4 Science and Ecosystem Support Division (SESD). Final Soil Boring Investigation 

Report for the Southeastern Wood Preserving Site, Project Number: 07-079. October 30, 2007. 30 

Pages. 

19. Tetra Tech. Final Removal Site Evaluation Letter Report, Southeastern Wood Preserving, Canton, 

Madison County, Mississippi. May 21, 2008. 67 Pages. 

20. Tetra Tech. Project Note to File with Attachment. Subject: September 2008 Chain-of-Custody 

Records. Attachment: EPA Forms II Lite Traffic Reports for Case No. 37871. October 29, 2009. 

14 Pages. 

21. Tetra Tech. Expanded Site Inspection Final Site-Specific Sampling Plan. Southeastern Wood 

Preserving, Canton, Madison County, Mississippi. August 7, 2008. 97 Pages. 

22. EPA, Region 4 SESD. Field Branches Quality System and Technical Procedure for Soil Sampling, 

Number SESDPROC-300-R1. November 1, 2007. 22 Pages. Accessed on-line at 

http://www.epa.gov/region4/sesd/fbqstp/Soil-Sampling.pdf. 

23. Tetra Tech. Record of Telephone Conversation. Subject: Definitions of Minimum Reporting Limit, 

Minimum Quantitation Limit, Contract Required Quantitation Limit, and Sample Quantitation Limit. 

Between Shanna Davis, Environmental Scientist, and Charlie Appleby, Quality Assurance Section, 

SESD, Management and Technical Services Branch, EPA Region 4. July 9, 2008. 1 Page. 

24. EPA. Envirofacts Warehouse, Comprehensive Environmental Response, Compensation, and 

Liability Information System (CERCLIS). Site Name: Southeastern Wood Preserving. Data 

Extracted on October 9, 2009. Accessed on October 26, 2009. 3 Pages. Accessed On-line at 

http://oaspub.epa.gov/enviro/cerclis_web.report?pgm_sys_id=MSD000828558. 

25. Tetra Tech. Project Note to File. Subject: September 2008 Sampling Event Observations Regarding 

Liners and Run-On/Runoff Control Systems. November 13, 2009. 1 Page. 

26. Tetra Tech. Project Note to File with Attachment. Subject: Soil Map for the Southeastern Wood 

Preserving Property and Surrounding Areas. Attachment: Madison County, MS Web Soil Survey 

from the Natural Resources Conservation Service. November 13, 2009. 4 Pages. 

27. Tetra Tech. 4-Mile Radius Map for the SWP Site. USGS Series Topographic Map Quadrangles: 

Way, MS 1989; Sharon, MS 1988; Canton, MS 1989; Shoccoe, MS 1989. 1 Map. 

28. Tetra Tech. Record of Telephone Conversation. Subject: Canton Municipal Utilities Water Survey. 

Between Quinn Kelley, Environmental Scientist, and Mark Snow, Operations Manager with Canton 

Municipal Utilities. December 15, 2008. 1 Page. 

29. MDEQ, Office of Land and Water Resources, Groundwater Planning and Protection Division. 

Records of Public-Supply Wells in Mississippi, 2009. May 22, 2009. 147 Pages. 

9
30. Environmental Data Resources Inc. (EDR). Southeastern Wood Preserving, Near Miller Street and 

Covington Drive Canton, MS 39046. The EDR Radius MapTM Report with GeoCheck®; The EDR 

Historical Topographic Map Report; The EDR Aerial Photo Decade Package; Certified Sanborn® 

Map Report; The EDR-City Directory Abstract. June 17, 2008. 97 Pages. 

31. U.S. Census Bureau. State and County QuickFacts, Madison, County, Mississippi from the 2000 

Census. Accessed December 10, 2009. 2 Pages. Accessed On-line at 

http://quickfacts.census.gov/qfd/states/28/28089.html. 

32. MDEQ, Groundwater Assessment and Remediation Division. Southeastern Woods, Canton, 

Mississippi, Radial Well Search Results Report. January 14, 2009. 8 Pages. 

33. Tetra Tech. Project Note to File with Attachment. Subject: Population within 4 Miles of the SWP 

Property. Attachment: Bureau of the Census 2000 Population Data within a 4-Mile Radius of 

Armstrong World Industries. January 20, 2009. 7 Pages. 

34. U.S. Fish and Wildlife Service. Mississippi List of Threatened and Endangered Species by County. 

June 2008. 8 Pages. 

35. USGS, National Water Information System. Flow Rate for USGS 07289730 Big Black River near 

Bentonia, MS. Accessed February 18, 2009. 2 Pages. Accessed on-line at 

http://waterdata.usgs.gov/nwis/. 

36. EPA, Region 4 SESD. Field Branches Quality System and Technical Procedure for Sediment 

Sampling, Number SESDPROC-200-R1. November 1, 2007. 22 Pages. Accessed on-line at 

http://www.epa.gov/region4/sesd/fbqstp/Sediment-Sampling.pdf. 

37. Tetra Tech. Record of Telephone Conversation with Attachment. Subject: Fishing on Batchelor 

Creek, Bear Creek, and the Big Black River. Between Quinn Kelley, Environmental Scientist, and 

Greg Walters, Master Sergeant, Mississippi Department of Wildlife, Fisheries, and Parks, Bureau of 

Fisheries, Central Region. Attachment: One GoogleTM Earth Map. March 10, 2010. 2 Pages. 

38. Tetra Tech. Record of Telephone Conversation. Subject: Fish Advisories for the Big Black River, 

Bear Creek, and Batchelor Creek. Between Quinn Kelley, Environmental Scientist, and Dennis 

Reicke, Fisheries Coordinator, Mississippi Department of Wildlife, Fisheries, and Parks. January 9, 

2009. 1 Page. 

39. EPA, Office of Emergency and Remedial Response. Using Qualified Data to Document an 

Observed Release and Observed Contamination. Quick Reference Fact Sheet EPA-540-F-94-028. 

November 1996. 18 Pages. 

40. Tetra Tech. Project Note to File with Attachment. Subject: Rationales for Data Qualifiers. March 

26, 2008. 4 Pages. 

41. Tetra Tech. Project Note to File with Attachment. Subject: Summary of J-Qualified Data. July 21, 

2011. 5 Pages. 

42. Tetra Tech. Project Note to File. Subject: Data Review, Validation, and Verification Conducted at 

the Science and Ecosystem Support Division (SESD), Analytical Support Branch. January 6, 2008. 

1 Page. 

43. EPA. Memorandum to File. Subject: Amendment to Removal Action Memoranda for the 

Southeastern Wood Treating Site – Request for Treatability Variance. From: Donald J. Guinyard, 

Director, Waste Management Division. To: Greer C. Tidwell, Regional Administrator. February 5, 

1992. 14 Pages. 

10
44. Tetra Tech. Project Note to File with Attachments. Subject: EPA Time-Critical Removal Action 

Pollution Reports (POLREPS) 2009-2010. Attachments: EPA POLREP Nos. 3 through 13. August 

15, 2011. 44 Pages. 

45. Pace Analytical Services, Inc. Report of Laboratory Analysis for Semivolatile Organic Compounds. 

Southeastern Wood Preserving, Project No. 2079316. March 17, 2008. 333 Pages. 

46. Pace Analytical Services, Inc. Report of Laboratory Analysis for PCDD/PCDF. Southeastern Wood 

Preserving, Project No. 1069279. April 1, 2008. 279 Pages. 

47. Tetra Tech. Borehole Logs Report. Southeastern Wood Preserving, Canton, Madison County, 

Mississippi. February 17, 2009. 34 Pages. 

48. Printable Metric Conversion Charts and Tables. Accessed on November 11, 2009. 1 Page. 

Accessed on-line at http://metricconversioncharts.org/. 

49. Karen H. Brown, Pace Analytical Services, Inc. Subject: The Definition of RL. Correspondence 

with Jessica Vickers, Tetra Tech, Quality Assurance Manager. February 18, 2010. 2 Pages. 

50. Federal Emergency Management Agency. Flood Insurance Rate Map for Madison County, 

Mississippi (and Incorporated Areas). Panel 410 of 625. Map Number 28089C0410F. Revised 

March 17, 2010. 3 Pages. 

51. EPA, Office of Solid Waste and Emergency Response, Technology Innovation Office. Cost and 

Performance Report, Southeastern Wood Preserving Superfund Site. December 10, 2002. 28 Pages. 

52. U.S. Office of the Federal Register National Archives and Records Administration. Code of Federal 

Regulations (CFR). Protection of Environment. CFR Title 40, Part 261. Revised as of July 1, 2003. 

Excerpt, 130 Pages. Accessed on-line at http://www.access.gpo.gov/cgibin/cfrassemble.cgi?title=200340. 

53. OHM. Request for Contract Reformation, Southeastern Wood Preserving Site, Canton, Mississippi. 

Submitted to Sharyn Erickson, EPA Region 4, Contracting Officer. June 22, 1993. 249 Pages. 

54. Tetra Tech. Sediment Sampling Locations. Aerial Photograph: DigitalGlobe/GlobeXplorer. 2007. 

1 Map. 

55. EPA. Contract Laboratory Program (CLP), SOW for Organics Analysis, Multi-Media, MultiConcentration, SOM01.1, May 2005, and Summary of Changes SOM01.1 to SOM01.2, April 2007. 

747 Pages. Accessed on-line at http://www.epa.gov/superfund/programs/clp/som1.htm. 

56. EPA. CLP, SOW for Dioxins and Furans Analysis, Multi-Media, Multi-Concentration, DLM02.0, 

May 2005. 186 Pages. Accessed on-line at http://www.epa.gov/superfund/programs/clp/dlm2.htm. 

57. EPA. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. SW-846 Method 

8270C, Revision 3, December 1996. 54 Pages. Accessed on-line at http://www.caslab.com/EPAMethods/PDF/8270c.pdf

58. EPA. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. SW-846 Method 

8290, Revision 0, September 1994. 71 Pages. Accessed on-line at http://www.caslab.com/EPAMethods/PDF/8290.pdf. 

59. Tetra Tech. Record of Telephone Conversation. Subject: Estimated Flow Rate of Batchelor Creek 

in Canton, Mississippi. Between Quinn Kelley, Environmental Scientist, and Mark Syracuse, 

Project Manager, WRScompass. March 8, 2010. 1 Page. 

11
60. Tetra Tech. Project Note to File with Attachment. Subject: Conversion of Gallons per Minute to 

Cubic Feet per Second. Attachment: Conversion Chart. March 8, 2010. 4 Pages. 

61. EPA. Ten Point Settlement Analysis (Redacted Copy). Southeastern Wood Preserving Superfund 

Site, Canton, Madison County, Mississippi, The Industrial Development Authority of Madison 

County Settlement. No Date. 9 Pages. 

62. Tetra Tech. Project Note to File. Subject: 2009-2010 Removal Action Sediment Stockpile. July 8, 

2011. 1 Page. 

63. EPA, Region 4, SESD. Environmental Investigations Standard Operating Procedures and Quality 

Assurance Manual. November 2001. 413 Pages. 

64. Tetra Tech. Project Note to File. Subject: September 2008 Boring Investigation. June 28, 2010. 1 

Page. 

65. Research Triangle Institute, Center for Environmental Analysis. Draft Risk Assessment for Cement 

Kiln Dust Used as an Agricultural Soil Amendment. Prepared for EPA, Office of Solid Waste. June 

16, 1998. 324 Pages. 

66. U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic 

Substances and Disease Registry. Toxicological Profile for Wood Creosote, Coal Tar Creosote, 

Coal Tar, Coal Tar Pitch, and Coal Tar Pitch Volatiles. September 2002. 392 Pages. 

67. Tetra Tech. Project Note to File with Attachments. Subject: Extent of Batchelor Creek Removal. 

Attachment: Google Earth Maps. June 29, 2010. 3 Pages. 

68. Tetra Tech. Project Note to File. Subject: Creosote Sludge Storage Tanks Formerly Located on the 

Southeastern Wood Preserving Property. June 30, 2010. 1 Page. 

69. Tetra Tech. Project Note to File. Subject: King Lumber Operations. July 14, 2010. 1 Page. 

70. Tetra Tech. Record of Telephone Conversation. Subject: Current Removal Activities. Between 

Quinn Kelley, Environmental Scientist, and Mark Syracuse, Project Manager, WRScompass. July 

14, 2010. 1 Page. 

71. EPA. Superfund Site Information, Archived Sites. Canton Plating & Bumper Works, Inc. Accessed 

July 14, 2010. 2 Pages. Accessed On-line at 

http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0402307. 

72. EPA. Envirofacts Warehouse, Facility Registry System (FRS) and Air Facility System (AFS). Van 

Leer Containers. Accessed July 14, 2010. 4 Pages. FRS Accessed On-line at 

http://iaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility. AFS Accessed On-line at 

http://oaspub.epa.gov/enviro/afs_reports.detail_plt_view?p_state_county_compliance_src=28089000

48&p_plant_id=. 

73. Tetra Tech. Project Note to File with Attachment. Subject: Logbook Notes for Batchelor Creek 

Removal Action at Southeastern Wood Preserving. Attachment: Logbook Notes. July 20, 2010. 8 

Pages. 

74. EPA, Region 4 SESD. Final Analytical Report for Semivolatile Organic Compounds. Project 

Number 10-0287, Southeastern Wood Preserving. April 14, 2010. 34 Pages. 

75. Tetra Tech. Final Comprehensive Environmental Response, Compensation and Liability Act 

Removal Action Report. March 14, 2011. 327 Pages. 

12
13

76. EPA. Envirofacts Warehouse, FRS, Resource Conservation and Recovery Act Information 

(RCRAInfo), and Toxics Release Inventory (TRI). Greif Industrial Packaging & Services, LLC. 

Accessed July 14, 2011. 20 Pages. FRS Accessed On-line at 

http://iaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?p_registry_id=110000766270. 

RCRAInfo Accessed On-line at 

http://iaspub.epa.gov/enviro/efsystemquery.rcrainfo?fac_search=handler_id&fac_search_type=Begi

nning+With&postal_code=&location_address=&add_search_type=Beginning+With&city_name=&

county_name=&state_code=&naics_type=Equal+to&naics_to=&univ_search=0&univA=FULL_EN

FORCEMENT&univB=LQG&LIBS=&proc_group=0&procname=&program_search=2&report=1&

page_no=1&output_sql_switch=TRUE&database_type=RCRAINFO&fac_value=MSD082008921. 

TRI Accessed On-line at 

http://iaspub.epa.gov/enviro/tris_control.tris_print?tris_id=39046VNLRC100IN. 

77. Tetra Tech. Project Note to File. Subject: September 2008 EPA Expanded Site Inspection Sediment 

Sample Distances. July 14, 2011. 1 Page. 

78. Tetra Tech. Electronic Mail Correspondence. Between Sandra Harrigan, Environmental Scientist, 

and Carter Williamson, Federal On-Scene Coordinator, Emergency Response and Removal Branch, 

EPA Region 4. Subject: Southeastern Wood Preserving Batchelor Creek Excavation. Attachment: 

Google Earth Map. August 19, 2011. 2 Pages. 
SITE DESCRIPTION

The Southeastern Wood Preserving (SWP) facility is located along Covington Drive in Canton, Madison 

County, Mississippi (Ref. 5, Appendix A, Figure 2, p. A-2) (see Figure 1 of this HRS documentation 

record). More specifically, the geographic coordinates as measured from the center of the partially 

treated waste material stockpile are 32° 37′ 5.019′′ north latitude and 90° 1′ 5.4804′′ west longitude (Ref. 

3). The U.S. Environmental Protection Agency (EPA) identification number, as recorded in the 

Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) 

database, is MSD000828558 (Ref. 24). 

The SWP property covers about 25 acres of land and includes an abandoned scale house, a silo which 

housed wood chips used for boiler fuel, and a large stockpile of partially treated waste material (Refs. 5, 

Appendix A, Figure 2, p. A-2; 6, p. 2; 7, p. i; 18, p. 4). A wood chipping operation (Penick Organics) 

currently leases the SWP property from the owner, the Madison County Economic Development 

Authority (formerly the Madison County Industrial Development Authority), and operates on the eastern 

portion of the SWP property (Refs. 6, p. 2; 7, pp. i, 4, 5) (see Figure 2 of this HRS documentation record). 

This operation grinds scrap wood into mulch for landscaping and sells the mulch in bulk. A scale house 

and an office were built for this operation and the old silo is used for storage (Ref. 7, pp. i, 5). 

Land uses surrounding the property are predominantly agricultural, residential, and light industrial (Refs. 

5, p. 2, Appendix A, Figure 2, p. A-2; 6, pp. 2, 3) (see Figures 1 and 2 of this HRS documentation 

record). The SWP property is bounded to the north by Batchelor Creek and the Illinois Central Gulf 

Railroad, which is no longer in operation; to the east by a residential and industrial area; to the south by 

Covington Drive; and to the west by residential and agricultural properties (Ref. 5, p. 2, Appendix A, 

Figure 2, p. A-2). 

For HRS scoring, the site consists of two sources and associated releases. Source No. 1 is a stockpile of 

partially treated waste material located in the central portion of the property (Refs. 14, p. 3; 16, pp. 1, 2; 

18, p. 4). This area will be referred to as the stockpile throughout this HRS documentation record. 

Source No. 2 is contaminated soil located on the SWP property in areas surrounding Source No. 1 (Ref. 5, 

Appendix A, Figure 2, p. A-2; 5, Appendix B, Tables 8 through 14, pp. B-11 through B-31) (see Figure 3 

of this HRS documentation record). Source Nos. 1 and 2 contain semivolatile organic compounds 

(SVOC) and dioxins and furans (see Section 2.2 of this HRS documentation record). These hazardous 

substances have also been documented in sediment samples collected from Batchelor Creek, which 

receives runoff from Source Nos. 1 and 2, 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 

The current SWP property was originally part of a larger property owned by King Lumber, which 

operated the facility as a saw mill, lumber yard, and wood treating operation beginning in 1928 (Refs. 7, 

p. i; 8, p. 1; 69). Canton Treating Company leased the wood treating operation portion of the King 

Lumber property (currently the SWP property) in 1961 and later purchased the property in 1964 (Ref. 8, 

p. 5). In 1965, Dickson Treating Company (Dickson) began operations on the SWP property. Dickson 

operated the facility until it filed for bankruptcy in late 1979. The assets were held by bankruptcy court 

from 1979 until 1982, when SWP purchased the property. In 1984, SWP defaulted on its small business 

administration loan without ever operating the facility (Ref. 9, p. 1). During the foreclosure auction in 

1984, White Pole and Timber Company of Kennedy, Alabama, purchased the physical assets of the SWP 

operation and the Madison County Economic Development Authority (formerly the Madison County 

Industrial Development Authority) purchased the property and remains the current owner (Refs. 5, p. 3; 6, 

p. 2; 8, p. 2; 9, p. 1). 

During former operations, southern yellow pine timbers were stripped of bark and placed in retort 

cylinders for drying. Wood preservatives, hot creosote or pentachlorophenol (PCP), were pumped into 

the cylinders. The cylinders were pressurized to force the liquid into the wood until it was saturated. The 

wood was then removed and allowed to drip dry in the central portion of the SWP property, and the 

14 Site Description 
residual liquid was drained (Refs. 8, p. 2; 10, p. 2; 11, p. 1; 12, p. 1). Three unlined wastewater treatment 

surface impoundments were constructed on the SWP property for disposal of wood preserving treatment 

sludges and process wastewater (Refs. 9, p. 1; 10, pp. 1, 2; 13, p. 5; 14, p. 2). During the 1970s, the 

facility received several notices of violation and fines from the Mississippi Pollution Control Commission 

(currently the Mississippi Office of Pollution Control) for gross contamination of the process area; 

releases of hazardous substances to Batchelor Creek; and inadequate treatment of process wastewater 

before it was discharged into the city sewage treatment facility (Ref. 10, pp. 1, 2). Before 1977, when the 

Clean Water Act was enacted, the facility reportedly discharged approximately 50,000 gallons of 

wastewater per day directly into Batchelor Creek, which flows through a city park, a residential area, and 

downtown Canton before it enters Bear Creek (Refs. 11, p. 1; 15, p. 1). The State of Mississippi received 

complaints of children, who had been playing in the creek near the city park, suffering from creosote 

burns (Ref. 14, p. 4). When operations ceased in 1979, the property included large areas of contamination 

in the treatment and storage areas, as well as piles of contaminated soil, creosote sludge storage tanks, and 

three unlined wastewater surface impoundments that had been filled by a previous owner at an 

unspecified time (Ref. 9, p. 1). 

PREVIOUS INVESTIGATIONS 

In September 1985, the Mississippi Bureau of Pollution Control (MBPC) conducted a preliminary 

assessment (PA) of the SWP property (Ref. 12, p. 1). MBPC observed several piles of creosotecontaminated soil on the SWP property that had been left by the previous owner (Dickson) after 

operations ceased in 1979 (Refs. 9, p. 1; 12, p. 2). MBPC also spoke with a former Dickson employee 

who reported that, in 1977, wastes were loaded into tanker trucks and disposed of in the city dump. After 

an investigation of the city dump, it was discovered that the waste was discharged into a bed of sawdust 

near a creek bank. In addition, there was evidence that PCP was leaking from the sawdust pile into the 

creek (Ref. 12, p. 3). The name of the creek was not provided in the PA (Ref. 12, p. 3). Based on 

observations made during the PA and the history of the property, MBPC concluded that a site 

investigation of the SWP property was warranted (Ref. 12, p. 6). 

In December 1985, MBPC conducted a site inspection at the SWP property, which included collection of 

one composite soil sample from the process area, one collocated surface water and sediment sample from 

Batchelor Creek upstream of the SWP property, and one collocated surface water and sediment sample 

from Batchelor Creek downstream of the SWP property (Ref. 13, pp. 1, 3, 8, 11, 13). The samples were 

analyzed for SVOCs (Ref. 13, pp. 11 through 19). The soil sample (SW-3) contained anthracene, 

benzo(a)anthracene, phenanthrene, and pyrene (Ref. 13, p. 19). No contaminants were detected in the 

upstream surface water sample (SW-1), and bis(2-ethylhexyl)phthalate was the only contaminant that was 

detected in the upstream sediment sample (SW-1, Sediment) (Ref. 13, pp. 10, 11, 15, 17). The 

downstream surface water sample (SW-2) contained PCP and pyrene among others (Ref. 13, p. 16). The 

downstream sediment sample (SW-2, Sediment) contained anthracene, naphthalene, phenanthrene, and 

pyrene (Ref. 13, p. 18). 

In 1986, EPA initiated an emergency response action at the SWP property to stabilize three unlined 

surface impoundments that contained creosote sludge and water. Approximately 8,000 cubic yards, or 

12,000 tons, of sludge were excavated from the impoundments and stabilized with approximately 70 

cubic yards of lime (or concrete) kiln dust (Refs. 14, p. 2; 51, p. 1; 61, p. 3). Bottom sediment sludge 

from the impoundments contained total polycyclic aromatic hydrocarbons (PAH) at a concentration of 

3,815 milligrams per kilogram (mg/kg) and was, therefore, classified as a Resource Conservation and 

Recovery Act (RCRA) K001-listed hazardous waste (Ref. 51, pp. i, 2). RCRA K001 hazardous waste is 

defined as bottom sediment sludge from the treatment of wastewaters from wood preserving processes 

that use creosote or PCP (Ref. 52, p. 63). The stabilized sludge was then stockpiled on the property to 

await treatment or disposal (Refs. 14, pp. 3, 5; 61, p. 3). 

In 1988, the U.S. Department of Agriculture (USDA) Soil Conservation Service (SCS) (currently known 

as the Natural Resources Conservation Service) designed a soil erosion prevention plan that included 

excavating and widening Batchelor Creek. While surveying the creek, SCS personnel observed oily 

waste leaching into the creek from the SWP property. SCS requested EPA’s assistance and, in response, 

15 Site Description 
EPA excavated contaminated soil from the creek bank observed to be leaching contaminants into 

Batchelor Creek to facilitate the SCS stream widening project (Refs. 14, p. 3; 61, p. 3). EPA sampled the 

excavated soils. The soils contained PAHs at concentrations ranging from 199 mg/kg to 865 mg/kg 

(Refs. 9, p. 4; 14, p. 3; 61, p. 3). EPA also installed a geofabric liner in the bed of the creek, and the 

banks were lined with rip-rap to prevent erosion (Ref. 9, p. 4). The visibly contaminated soil that was 

excavated from the creek bank was added to the stockpile of bottom sediment sludge excavated from the 

impoundments. The remaining excavated soil was spread over the property (Ref. 61, p. 3).

From 1991 to 1994, OHM Remediation Services Corp., under contract with EPA, treated the stockpile 

using a slurry phase bioremediation system that was constructed on the SWP property (Refs. 16, pp. 1, 2; 

51, p. i). This system consisted of a power screen, a slurry mix tank, four slurry phase bioremediation 

reactors (bioreactors), and a slurry dewatering unit. The bioreactors were operated on a batch basis, and 

each batch was monitored during treatment to evaluate performance with respect to cleanup goals (Ref. 

51, pp. i, 5). Initially, the goal was to reach the K001 (wood preserving waste) treatment standard for 

each individual PAH. However, after several failed attempts to reach K001 land disposal restriction 

standards — specifically with respect to phenanthrene and pyrene — a treatability variance was requested 

and approved (Refs. 16, pp. 1, 2; 43, pp. 3, 4, 7; 51, p. 7). The treatability variance involved modifying 

the K001 cleanup standards to be based on total PAH concentrations instead of individual PAHs (Ref. 51, 

p. 7). As a result, the cleanup goals were modified to 950 mg/kg total PAHs dry weight soil solids and 

180 mg/kg benzo(a)pyrene-equivalent carcinogenic PAHs dry weight soil solids. In addition, the 

modified cleanup goals allowed 15 percent of the treated soil to contain a total PAH concentration less 

than 1,100 mg/kg, and 25 percent of the treated soil to contain a benzo(a)pyrene-equivalent concentration 

less than 230 mg/kg (Refs. 16, p. 3; 51, pp. 7, 10). With the variance in place, EPA was able to meet the 

cleanup goals (Ref. 51, p. 11). A containment cell consisting of earthen berms lined with 40-mil highdensity polyethylene was constructed to contain the partially treated waste. The treated soil and debris 

were placed within the containment cell, with a visqueen layer segregating the treated soils and debris. 

The containment cell was capped with a 12-inch-thick compacted layer of clay. The clay cap was then 

covered with 4 inches of topsoil and subsequently fertilized and seeded. The entire containment cell was 

enclosed with a chain link fence. Remediation was completed in 1995 (Refs. 16, p. 4; 53, pp. 219 through 

223). The containment cell with the partially treated waste is evaluated as Source No. 1 in this HRS 

documentation record. 

In March 1994, the Mississippi Department of Environmental Quality (MDEQ) prepared a site inspection 

prioritization (SIP) report using existing sampling data and file information (Ref. 10, p. 1). MDEQ 

confirmed that the contaminated soils, sediments, and surface water on and adjacent to the SWP property 

contained hazardous substances associated with the wood treating process (Ref. 10, p. 2). MDEQ also 

updated target data, which included identifying 41 private residential wells within a 4-mile radius of SWP 

and fishing in Batchelor Creek, Bear Creek, and the Big Black River (Ref. 10, pp. 3, 4). 

From 1997 to 2002, site inspections were conducted at the SWP property and EPA communicated with 

Scott Penn Inc. regarding a Brownfields prospective purchaser agreement (PPA); however, available 

information does not indicate that the PPA was finalized (Ref. 17, pp. 1, 2). In October 2002, MDEQ 

related to EPA the results of an investigation of Batchelor Creek, when PAHs (creosote-component 

compounds) were detected. In response to MDEQ concerns, on February 26, 2003, EPA and MDEQ 

conducted a site reconnaissance at the SWP facility. Based on this visit, EPA concluded that the surface 

water pathway was of concern and agreed that contamination was present in Batchelor Creek (Ref. 17, 

p. 2). 

In 2006, MDEQ discovered new historical information during research on the SWP property at the 

Mississippi Archives and History facility. An aerial photograph taken in 1965 revealed the approximate 

location of a PCP wood treating area on the eastern portion of the SWP property. MDEQ also found an 

old legal property description, which indicated a larger property “footprint.” With the addition of this 

new information and the recent population growth in Canton, Mississippi, EPA agreed that further 

investigation of the SWP property was warranted (Ref. 17, p. 2). 

16 Site Description 
In 2007, EPA Science and Ecosystem Support Division (SESD) personnel advanced soil borings along 

the northern boundary of the property, between the stockpile, former lagoons, and Batchelor Creek, to 

evaluate whether pathways for free-phase creosote to enter Batchelor Creek exist and, if so, where they 

enter the creek. Visible and odorous impacts (believed to be organic contamination) to the soil were 

observed in several of the borings adjacent to and west of the stockpile. In addition, free-phase creosote 

was observed in at least one boring at a depth of 6 to 10 feet bgs located adjacent to the stockpile (Ref. 18, 

pp. 4, 6, 12, 19). 

On February 28, 2008, Tetra Tech, on behalf of EPA, conducted a removal site evaluation (RSE) to assess 

whether a removal action would be appropriate in accordance with Title 40 of the Code of Federal 

Regulations (CFR), Part 300, Section 300.415, as well as to estimate the volume of waste present on the 

property (Ref. 19, pp. 1, 2). Tetra Tech collected four five-point composite waste samples, including one 

duplicate sample, from the stockpile to identify disposal requirements. Two grab sediment samples were 

also collected from Batchelor Creek downstream of the stockpile to evaluate whether hazardous 

substances were migrating from the stockpile into the adjacent Batchelor Creek (Ref. 19, p. 2). The 

sediment and waste samples contained anthracene, benzo(a)anthracene, benzo(a)pyrene, 

benzo(k)fluoranthene, chrysene, naphthalene, phenanthrene, pyrene, and dioxins and furans. 

In September 2008, Tetra Tech, on behalf of EPA, conducted an expanded site inspection (ESI) at the 

SWP property (Ref. 5, pp. 1, 7). Surface and subsurface soil and waste samples were collected 

throughout the SWP property (Ref. 5, p. 7). In addition, sediment samples were collected from Batchelor 

Creek and unnamed tributaries of Batchelor Creek (Ref. 5, p. 7). Surface and subsurface soil and waste 

samples contained anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(k)fluoranthene, chrysene, 

dibenzo(a,h)anthracene, dibenzofuran, indeno(1,2,3-cd)pyrene, pentachlorophenol, phenanthrene, pyrene, 

and dioxins and furans (Ref. 5, p. 11, Appendix B, Tables 8 through 14, pp. B-11 through B-31). 

Sediment samples collected from Batchelor Creek contained anthracene, naphthalene, phenanthrene, and 

pyrene (Ref. 5, Appendix B, Tables 21 through 23, pp. B-44 through B-50). 

Also in September 2008, the EPA advanced 29 borings between 0 and 36 feet bgs throughout the SWP 

property and within the stockpile. Two borings, PILE01 and PILE02, were collected from the center of 

the stockpile (Ref. 47, p. 1, Enclosure 1, p. E1-1, Enclosure 2, pp. E2-27, E2-28). According to borehole 

logs for these two samples, solidified lagoon sludge was encountered between 4 and 9 feet bgs (Ref. 47, 

Enclosure 1, p. E1-1, Enclosure 2, pp. E2-27, E2-28). Borings advanced between the stockpile and 

Batchelor Creek, as well as west of the stockpile along Batchelor Creek, contained free product (creosote) 

weeps. Free product was noted in 14 of the 29 boreholes (Ref. 47, p. 1, Enclosure 1, p. E1-1, Enclosure 2, 

pp. E2-1 through E2-29). Boring P3 located west of the stockpile contained free product weeps as deep 

as 33 to 36 feet bgs (Ref. 47, Enclosure 1, p. E1-1, Enclosure 2, p. E2-20). 

From August 2009 to November 2010, EPA conducted a time-critical removal action at the SWP property 

under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (Ref. 

75, p. 1). Because of the creosote contamination in Batchelor Creek, EPA excavated between 1,500 and 

1,800 linear feet of Batchelor Creek adjacent to the SWP property at depths ranging from 5 to 15 feet 

below the creek bed and stockpiled the creosote-contaminated sediment (approximately 45,000 to 50,000 

tons) on the western portion of the property (Refs. 44, p. 1; 62; 70; 78) (see Figure 2 of this HRS 

documentation record). Post-excavation sediment samples were collected during four sampling events 

from November 2009 to March 2010. Twelve sediment samples (including one duplicate) were collected 

from 11 locations along the excavated bottom of Batchelor Creek (Ref. 75, p. 3). SVOCs detected in 

these samples included anthracene (up to 5,600J μg/kg), benzo(a)anthracene (up to 5,100J μg/kg), 

benzo(a)pyrene (up to 1,300 μg/kg), benzo(k)fluoranthene (up to 1,400 μg/kg), chrysene (up to 5,100J 

μg/kg), dibenzo(a,h)anthracene (up to 170J μg/kg), dibenzofuran (up to 17,000 μg/kg), fluoranthene (up 

to 37,000 μg/kg), indeno(1,2,3-cd)pyrene (up to 470 μg/kg), naphthalene (up to 11,000 μg/kg), 

phenanthrene (up to 69,000 μg/kg), and pyrene (up to 19,000 μg/kg) (Ref. 75, Appendix B, p. B-1). 

On March 11, 2010, EPA collected six sediment samples (including 1 duplicate) from the creosotecontaminated sediment stockpile. SVOCs detected in these samples included anthracene (up to 5,600 

μg/kg), benzo(a)anthracene (up to 3,200J μg/kg), benzo(a)pyrene (up to 1,200 μg/kg), 

17 Site Description 
18 Site Description 

benzo(k)fluoranthene (up to 1,200 μg/kg), chrysene (up to 2,800J μg/kg), dibenzo(a,h)anthracene (up to 

170J μg/kg), dibenzofuran (up to 14,000J μg/kg), fluoranthene (up to 22,000 μg/kg), indeno(1,2,3-

cd)pyrene (up to 440 μg/kg), naphthalene (up to 45,000 μg/kg), phenanthrene (up to 47,000 μg/kg), and 

pyrene (up to 12,000 μg/kg) (Ref. 75, Appendix B, p. B-4). In addition to SVOCs, EPA analyzed the 

creosote-contaminated sediment stockpile samples for Toxicity Characteristic Leaching Procedure 

(TCLP) SVOCs and metals. No contaminants were detected at concentrations exceeding TCLP criteria; 

therefore, EPA classified the creosote-contaminated sediment pile as Non-RCRA hazardous waste and 

removed the pile to an off-site Class B waste management facility in Lake, MS (Refs. 44, p. 42; 70; 75, p. 

6, Appendix B, p. B-6). The removal of the entire creosote-contaminated sediment stockpile was 

completed on September 24, 2010 (Ref. 75, p. 6). EPA also constructed a slurry wall measuring 1,500 

feet long, three feet wide, and 30 feet below land surface between the SWP property and the southern 

bank of Batchelor Creek to prevent further migration of hazardous substances from the SWP property to 

Batchelor Creek (Refs. 70; 73, p. 6; 75, pp. 4, 5) (see Figure 2 of this HRS documentation record). 

Concurrent with the sediment stockpile disposal activities, EPA conducted site restoration activities. 

Along the 1,100-foot removal area, Batchelor Creek was graded and an erosion control fabric was 

installed along the southern bank of the creek. Limestone rip-rap was also installed along the northern 

and southern banks and the bottom of the creek. Sod was placed along the top of the southern bank of 

Batchelor Creek. Site restoration activities were completed on September 24, 2010 and on November 30, 

2010 final site conditions were documented (Refs. 70; 75, p. 6). 
Source No: 1 

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Number of source: 1 

Name of source: Stockpile of Partially Treated Waste Material 

Source Type: Pile 

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

Source No. 1 is a stockpile of partially treated waste material located in the central portion of the SWP 

property (Refs. 14, pp. 2, 5; 16, pp. 1, 2; 18, p. 4) (see Figure 3 of this HRS documentation record). The 

estimated volume of sludge originally excavated from three unlined wastewater treatment surface 

impoundments at the facility and placed in the stockpile is about 8,000 cubic yards (Refs. 14, pp. 2, 3, 5; 

51, p. 1; 61, p. 3). 

During operations, three unlined wastewater treatment surface impoundments were constructed for 

disposal of wood preserving treatment sludges and process wastewater (Refs. 9, p. 1; 10, pp. 1, 2; 13, p. 

5). In 1986, EPA initiated an emergency response action at SWP to stabilize the three unlined surface 

impoundments. Approximately 8,000 cubic yards, or 12,000 tons, of bottom sediment sludge were 

excavated from the impoundments, and the contaminated sludge was stabilized with 70 cubic yards of 

lime kiln dust. The stabilized sludge was then stockpiled on the property to await treatment or disposal 

(Refs. 14, pp. 2, 3, 5; 51, pp. 1 through 3; 61, p. 3). Lime kiln dust, or cement kiln dust, can contain 

various metals and dioxins and furans (Ref. 65, pp. 12, 13). According to a risk assessment study 

conducted by the Research Triangle Institute on behalf of EPA, the concentrations of dioxins and furans 

detected in the sampled cement kiln dust are generally well below the concentrations of dioxins and 

furans scored in this HRS documentation record, some being an order of magnitude below (Refs. 5, 

Appendix B, Table 14, pp. B-29, B-30, B-31; 19, Table 4, pp. B-4, B-5; 65, pp. 1, 11, 12, 13; see also 

Tables 2 and 5 of this HRS documentation record). From 1991 to 1994, EPA treated the stockpiled 

sludge using a slurry phase bioremediation system. A treatability variance was approved and the cleanup 

goals were modified after several failed attempts to reach land disposal restriction standards for wood 

preserving waste (K001) (Refs. 16, pp. 1, 2; 43, pp. 3, 4). 

After bioremediation was completed in 1994, a containment cell consisting of earthen berms lined with 

40-mil high-density polyethylene was constructed in the central portion of the SWP property to contain 

the partially treated waste. The partially treated waste and debris were placed within the containment cell, 

with a visqueen layer segregating the treated waste and debris. The containment cell was capped with a 

12-inch-thick compacted layer of clay. The clay cap was then covered with 4 inches of topsoil and 

subsequently fertilized and seeded. The entire containment cell was enclosed with a chain link fence. 

This remedial action was completed in 1995 (Refs. 16, p. 4; 53, pp. 219 through 223). 

Since 1995, Source No. 1 has sunken into the ground and "the surface has weathered" (Refs. 7, p. i; 44, p. 

2). In September 2008, borings were advanced throughout the SWP property and within Source No. 1 at 

depths ranging from 0 and 36 feet bgs. Two boreholes, PILE01 and PILE02, were collected from the 

center of Source No. 1 (Ref. 47, p. 1, Enclosure 1, p. E1-1, Enclosure 2, pp. E2-1 through E2-29). 

According to the logs for these two boreholes, solidified lagoon sludge was encountered down to 9 feet 

bgs. Borehole NWPile, collected from the northwestern corner of Source No. 1, contained free-product 

weeps from 8 to 10 feet bgs (Ref. 47, Enclosure 1, p. E1-1; 47, Enclosure 2, pp. E2-17, E2-27, E2-28). 

Samples were not collected from any of the borings (Ref. 64). 

Source No. 1 samples collected from 6 inches to 3 feet below the surface of the stockpile during the EPA 

February 2008 RSE contained anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(k)fluoranthene, 

naphthalene, phenanthrene, pyrene, and dioxins and furans (Ref. 19, p. 2; 19, Appendix B, Tables 3 and 4, 

pp. B-3, B-4, B-5) (also see Table 2 of this HRS documentation record). 

19 Source Characterization
Source No: 1 

20 Source Characterization

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

EPA September 2008 Expanded Site Inspection 

Background Concentrations 

The background samples listed in Table 1 were collected during the EPA September 2008 ESI (Ref. 5, p. 

7, Appendix A, Figure 4, p. A-4; 5, Appendix B, Table 1, p. B-1). The background soil samples were 

collected from a location about 1,000 feet northwest of the center of the SWP property (Ref. 5, Appendix 

A, Figure 4, p. A-4). The background surface soil sample was collected at a depth of 0 to 1 foot bgs and 

the background subsurface soil sample was collected at a depth of 1 to 4 feet bgs (Ref. 5, Appendix A, 

Figure 4, p. A-4; 5, Appendix B, Table 1, p. B-1). 

Although not required by the HRS, Source No. 1 samples were compared to background samples and 

estimated concentrations were adjusted to demonstrate the relative increase of source concentrations 

above background levels. A background soil sample was not collected during the EPA February 2008 

RSE; therefore, samples collected from Source No. 1 during the EPA February 2008 RSE were compared 

with background soil samples collected during the EPA September 2008 ESI. Samples collected during 

both investigations were collected using similar sampling procedures (Refs. 5, pp. 7, 8; 5, Appendix C, 

Logbook 3, p. 1; 19, pp. 2, 3; 19, Appendix C, p. C-2; 22; 63). The background samples were collected in 

accordance with the EPA Region 4 SESD Field Branch Quality System and Technical Procedures for Soil 

Sampling, SESDPROC-300-R1 (Refs. 5, pp. 7, 8; 21, p. 5; 22). 

The samples were analyzed under the EPA Contract Laboratory Program (CLP) for SVOCs in accordance 

with EPA CLP Statement of Work (SOW) SOM01.2 and for dioxins and furans in accordance with CLP 

SOW DLM02.0 (Refs. 5, p. 8, Appendix E, pp. E-1, E-2, E-249, E-250; 21, Appendix B, Table 7, p. B10; 21, Appendix C, p. C-12; 55; 56). EPA Region 4 SESD reviewed all data according to the contract 

SOW and EPA guidelines (Ref. 5, Appendix E, pp. E-2, E-250; 42). The minimum reporting limits 

(MRL) are listed on the analytical data sheets in Reference 5, Appendix E. Each MRL is sample-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 MRLs are equivalent 

to sample quantitation limits (SQL) (Ref. 23). The chain-of-custody records are provided in Reference 

20. Logbook notes are available in Reference 5, Appendix C. The location of the background samples is 

depicted in Reference 5, Appendix A, Figure 4, page A-4, and is described in Reference 5, Appendix B, 

Table 1, page B-1. 

TABLE 1: Analytical Results for Background Samples – September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

Background Sample (0 to 1 foot bgs) 

SWPB01 SWP-SS-01A1 Anthracene 2.1J (21) μg/kg 3.9 μg/kg 

5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-118; 20, p. 1; 39, 

pp. 8, 14; 41, pp. i, 1 

SWPB01 SWP-SS-01A1 Benzo(a)anthracene 11 μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-118; 20, p. 1 

SWPB01 SWP-SS-01A1 Benzo(a)pyrene 12 μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-118; 20, p. 1 

SWPB01 SWP-SS-01A1 Benzo(k)fluoranthene 11J (11) μg/kg 3.9 μg/kg 

5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-118; 20, p. 1; 39, 

p. 8; 40, p. 2; 41, p. 1 
Source No: 1 

21 Source Characterization

TABLE 1: Analytical Results for Background Samples – September 2008 

Station 

ID Sample ID

Hazardous 

Hazardous Substance 

Substance Concentration MRL References

SWPB01 SWP-SS-01A1 Chrysene 13 μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-118; 20, p. 1 

SWPB01 SWP-SS-01A1 Naphthalene 3.1J (31) μg/kg 3.9 μg/kg 

5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-118; 20, p. 1; 39, 

pp. 8, 15; 41, pp. i, 1 

SWPB01 SWP-SS-01A1 Phenanthrene 6.8 μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-119; 20, p. 1 

SWPB01 SWP-SS-01A1 Pyrene 23 μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-119; 20, p. 1 

SWPB01 SWP-SS-01A1 1,2,3,4,6,7,8-HpCDD 81 ng/kg 4.8 ng/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-260; 20, p. 11 

SWPB01 SWP-SS-01A1 1,2,3,4,6,7,8-HpCDF 170 ng/kg 4.8 ng/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-260; 20, p. 11 

SWPB01 SWP-SS-01A1 1,2,3,4,7,8-HxCDF 6.8 ng/kg 4.8 ng/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-260; 20, p. 11 

SWPB01 SWP-SS-01A1 1,2,3,6,7,8-HxCDD 7.0 ng/kg 4.8 ng/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-260; 20, p. 11 

Background Sample (1 to 4 feet bgs)

SWPB01 SWP-SS-01A2 Anthracene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-103; 20, p. 1 

SWPB01 SWP-SS-01A2 Benzo(a)anthracene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-103; 20, p. 1 

SWPB01 SWP-SS-01A2 Benzo(a)pyrene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-103; 20, p. 1 

SWPB01 SWP-SS-01A2 Benzo(k)fluoranthene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-103; 20, p. 1 

SWPB01 SWP-SS-01A2 Chrysene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-103; 20, p. 1 

SWPB01 SWP-SS-01A2 Naphthalene 4.0J (40) μg/kg 4.2 μg/kg 

5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-103; 20, p. 1; 39, 

pp. 8, 15; 41, pp. i, 1 

SWPB01 SWP-SS-01A2 Phenanthrene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-104; 20, p. 1 

SWPB01 SWP-SS-01A2 Pyrene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 5, 

Appendix E, p. E-104; 20, p. 1 
Source No: 1 

22 Source Characterization

Notes: 

( ) Concentrations shown in parentheses were adjusted in accordance with References 39, 40, and 41. 

A1 Sample collected at a depth of 0 to 1 foot bgs 

A2 Sample collected at a depth of 1 to 4 feet bgs 

B Background 

bgs Below ground surface 

HpCDD Heptachlorodibenzodioxin 

HpCDF Heptachlorodibenzofuran 

HxCDD Hexachlorodibenzodioxin 

HxCDF Hexachlorodibenzofuran 

ID Identification number 

J Identification of the analyte is acceptable; the reported value is an estimate 

μg/kg Microgram per kilogram 

MRL Minimum reporting limit 

ng/kg Nanogram per kilogram 

SS Surface sample 

SWP Southeastern Wood Preserving
Source No: 1 

23 Source Characterization

EPA February 2008 Removal Site Evaluation 

Source Concentrations 

The Source No. 1 samples listed in Table 2 were collected during the EPA February 2008 RSE (Ref. 19, 

p. 2; 19, Appendix B, Table 1, p. B-1). Source No. 1 (stockpile of partially treated waste material) was 

divided into three equal sections, and a composite sample was collected from each section (Ref. 19, 

Appendix A, Figure 2, p. A-2). Source samples were collected from a depth of 6 inches to 3 feet below 

the surface of the stockpile (Ref. 19, Appendix B, Table 1, p. B-1). 

Source No. 1 samples were collected in accordance with the EPA SESD Environmental Investigations 

Standard Operating Procedures and Quality Assurance Manual, November 2001 (Ref. 19, p. 2; 63, pp. 13-

1 through 13-6, 13-11). The samples were analyzed by Pace Analytical Services, Inc., for SVOCs in 

accordance with SW-846 Method 8270C and for dioxins and furans in accordance with SW-846 Method 

8290 (Refs. 19, p. 3, Appendix D, pp. D-1, D-15; 45, p. 4; 46, p. 2; 57; 58). Tetra Tech reviewed all data 

according to the National Functional Guidelines for Superfund Organic Methods Data Review and 

Chlorinated Dioxin/Furan Data Review (Ref. 19, p. 2, Appendix D, pp. D-1, D-15). The reporting limits 

(RL) are listed on the analytical data sheets in References 45 and 46. Each RL is sample-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 (Ref. 49). The data validation reports are provided in Reference 19, Appendix D. The chain-ofcustody records are provided in References 45 and 46. Logbook notes are available in Reference 19, 

Appendix C. The locations of Source No. 1 samples are depicted in Reference 19, Appendix A, Figure 2, 

page A-2, and are described in Reference 19, Appendix B, Table 1, page B-1. 

TABLE 2: Analytical Results for Source No. 1 – February 2008 

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration RL* References

Source Samples (6 to 24 inches bps) 

SWP-WS-02 Benzo(a)anthracene 459 μg/kg 435 μg/kg 19, Appendix C, p. 3; 45, pp. 5, 332

SWP-WS-02 Benzo(a)pyrene 714 μg/kg 435 μg/kg 19, Appendix C, p. 3; 45, pp. 5, 332

SWP-WS-02 Benzo(k)fluoranthene 467 μg/kg 435 μg/kg 19, Appendix C, p. 3; 45, pp. 5, 332

SWP-WS-02 Chrysene 829 μg/kg 435 μg/kg 19, Appendix C, p. 3; 45, pp. 5, 332

SWP-WS-02 Naphthalene 883 μg/kg 435 μg/kg 19, Appendix C, p. 3; 45, pp. 6, 332

SWP-WS-02 Phenanthrene 681 μg/kg 435 μg/kg 19, Appendix C, p. 3; 45, pp. 7, 332

SWP-WS-02 Pyrene 774 μg/kg 435 μg/kg 19, Appendix C, p. 3; 45, pp. 7, 332

SWP-WS-02 1,2,3,4,6,7,8-HpCDD 1,600J (160) 

ng/kg 1.90 ng/kg 

19, Appendix C, p. 3; 19, Appendix 

D, pp. D-5, D-10; 41, p. 2; 46, pp. 7, 

38 

SWP-WS-02D Benzo(a)anthracene 455 μg/kg 423 μg/kg 19, Appendix C, p. 3; 45, pp. 8, 332

SWP-WS-02D Benzo(a)pyrene 639 μg/kg 423 μg/kg 19, Appendix C, p. 3; 45, pp. 8, 332

SWP-WS-02D Benzo(k)fluoranthene 497 μg/kg 423 μg/kg 19, Appendix C, p. 3; 45, pp. 8, 332

SWP-WS-02D Chrysene 792 μg/kg 423 μg/kg 19, Appendix C, p. 3; 45, pp. 8, 332

SWP-WS-02D Naphthalene 723 μg/kg 423 μg/kg 19, Appendix C, p. 3; 45, pp. 9, 332
Source No: 1 

24 Source Characterization

TABLE 2: Analytical Results for Source No. 1 – February 2008 

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration RL* References

SWP-WS-02D Phenanthrene 1,110 μg/kg 423 μg/kg 19, Appendix C, p. 3; 45, pp. 10, 

332 

SWP-WS-02D Pyrene 891 μg/kg 423 μg/kg 19, Appendix C, p. 3; 45, pp. 10, 

332 

SWP-WS-02D 1,2,3,4,6,7,8-HpCDD 13,000J 

(1,300) ng/kg 6.30 ng/kg 

19, Appendix C, p. 3; 19, Appendix 

D, pp. D-5, D-11; 41, p. 2; 46, pp. 7, 

39 

SWP-WS-02D 1,2,3,4,6,7,8-HpCDF 4,700J (470) 

ng/kg 2.80 ng/kg 

19, Appendix C, p. 3; 19, Appendix 

D, pp. D-5, D-11; 41, p. 2; 46, pp. 7, 

39 

Source Sample (20 to 24 inches bps) 

SWP-WS-03 Anthracene 4,830 μg/kg 1,990 μg/kg 19, Appendix C, p. 4; 45, pp. 11, 

332 

SWP-WS-03 Benzo(a)pyrene 5,440 μg/kg 1,990 μg/kg 19, Appendix C, p. 4; 45, pp. 11, 

332 

SWP-WS-03 Benzo(k)fluoranthene 4,340 μg/kg 1,990 μg/kg 19, Appendix C, p. 4; 45, pp. 11, 

332 

SWP-WS-03 Chrysene 3,760 μg/kg 1,990 μg/kg 19, Appendix C, p. 4; 45, pp. 11, 

332 

SWP-WS-03 Pyrene 3,090 μg/kg 1,990 μg/kg 19, Appendix C, p. 4; 45, pp. 13, 

332 

SWP-WS-03 1,2,3,4,6,7,8-HpCDD 13,000 ng/kg 5.70 ng/kg 19, Appendix C, p. 4; 46, pp. 7, 40 

SWP-WS-03 1,2,3,4,6,7,8-HpCDF 4,700 ng/kg 3.60 ng/kg 19, Appendix C, p. 4; 46, pp. 7, 40 

SWP-WS-03 1,2,3,4,7,8-HxCDF 140 ng/kg 1.20 ng/kg 19, Appendix C, p. 4; 46, pp. 7, 40 

SWP-WS-03 1,2,3,6,7,8-HxCDD 360 ng/kg 1.40 ng/kg 19, Appendix C, p. 4; 46, pp. 7, 40 

Source Sample (3 feet bps) 

SWP-WS-01 Benzo(a)pyrene 452 μg/kg 423 μg/kg 19, Appendix C, p. 2; 45, pp. 20, 

332 

Notes: 

* The February 2008 RLs are equivalent to sample quantitation limits (Ref. 49). 

( ) Concentrations shown in parentheses were adjusted in accordance with References 39, 40, and 41. 

bps Below pile surface 

D Duplicate 

HpCDD Heptachlorodibenzodioxin 

HpCDF Heptachlorodibenzofuran 

HxCDD Hexachlorodibenzodioxin 

HxCDF Hexachlorodibenzofuran 

ID Identification number 

J Identification of the analyte is acceptable; the reported value is an estimate 

μg/kg Microgram per kilogram 

ng/kg Nanogram per kilogram 

RL Reporting limit 

SWP Southeastern Wood Preserving

WS Waste sample
Source No: 1 

25 Source Characterization

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Source samples collected from Source No. 1 contained SVOCs and dioxins and furans (Ref. 19, 

Appendix A, Figure 2, p. A-2; 19, Appendix D, pp. D-1, D-14, D-15 D-46, D-47) (also see Table 1 of this 

HRS documentation record). Source No. 1 is a stockpile of partially treated waste material (Refs. 18, p. 

4; 14, pp. 2, 5; 16, pp. 1, 2; 19, Appendix B, Table 3, p. B-3). Analytical results for sediment samples 

collected from Batchelor Creek, 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. While a section of Batchelor Creek has been remediated, a release of 

hazardous substances from the site has been documented downstream from the remediated section (Refs. 

5, Appendix A, Figure 4, p. A-4, Appendix B, Table 23, pp. B-48, B-49; 62; 75, p. 3) (see also Figure 2 of 

this HRS documentation record). Although Source No. 1 is located within a containment cell, free-phase 

creosote has been observed leaching into Batchelor Creek in the area downgradient from Source No. 1 

(Refs. 5, Appendix C, Logbook 1, p. 47, Logbook 2, p. 4; 5, Appendix D, p. D-8; 7, pp. 1, 2; 14, p. 5; 19, 

Appendix C, p. 5). Staining was observed in borings advanced in Source No. 1 during the 2008 EPA 

boring investigation (Ref. 47, Enclosure 2, pp. E2-27, E2-28). Furthermore, no run-on or runoff control 

systems were observed during the EPA September 2008 ESI sampling event (Refs. 5, Appendix C, pp. C1 through C-5; 25). The removal action conducted by EPA from 2009 to 2010 included the placement of 

a slurry wall between the SWP source areas and Batchelor Creek to prevent further migration of creosote; 

it did not, however, include actual removal of Source No. 1 or construction of any run-on control or 

runoff management features (Refs. 62; 75, pp. 4, 5). Therefore, a containment factor value of 10 as noted 

in Table 3 was assigned for the surface water migration pathway (Ref. 1, Section 4.1.2.1.2.1.1). 

TABLE 3: 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 

maintained engineered cover; no functioning and 

maintained run-on control system or runoff 

management system. 

10 

1, Section 4.1.2.1.2.1.1; 5, 

Appendix B, Tables 8 through 14, 

pp. B-11 through B-31; 5, 

Appendix C, Logbook 1, p. 47; 5, 

Appendix C, Logbook 2, p. 4; 5, 

Appendix D, p. D-8; 7, pp. i, 1, 2; 

14, pp. 2, 5; 16, pp. 1, 2; 19, 

Appendix C, p. 5; 25; 62 

Notes: 

NA Not applicable 

NS Not scored
Source No: 1 

26 Source Characterization

2.4.2.1 SOURCE HAZARDOUS WASTE QUANTITY

2.4.2.1.1 Hazardous Constituent Quantity

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

About 8,000 cubic yards (cy) of bottom sediment sludge were excavated from the three surface 

impoundments (Refs. 14, pp. 3, 5; 51, p. 1; 61, p. 3). However, an unquantified amount of contaminated 

soil excavated from Batchelor Creek during the 1989 SCS creek widening project was added to this 

wastestream while it was stockpiled onsite (Ref. 9, p. 4). Therefore, the Hazardous Wastestream Quantity 

is not adequately determined for the source; a value for hazardous wastestream quantity is assigned based 

on the available data and the evaluation proceeds to section 2.4.2.1.3 (Ref. 1, Section 2.4.2.1.2). 

8,000 cy x 2,000 pounds/cy (Ref. 1, Table 2-5) = 16,000,000 pounds 

Equation for Assigning Value (Ref. 1, Table 2-5): Wastestream Quantity (W) / 5,000 

 Hazardous Wastestream Quantity Assigned Value: 3,200 

2.4.2.1.3 Volume

Volume information is not available to evaluate Tier C. 

 

Volume Assigned Value: 0 

2.4.2.1.4 Area

During the February 2008 RSE, the area of Source No. 1 was measured using global positioning system 

coordinates. The area is 79,549.6 square feet, or 1.82 acres (Refs. 19, p. 3; 48). 

Area (ft2

): 79,549.60 (Ref. 19, p. 3) 

Equation for Assigning Value (Ref. 1, Table 2-5): Area (A) / 13 

Area Assigned Value: 6,119.2 

2.4.2.1.5 Calculation of Source Hazardous Waste Quantity Value

A source hazardous waste quantity (HWQ) value of 6,119.2 is assigned for Source No. 1 (Ref. 1, Section 

2.4.2.1.5). 

Source HWQ Value: 6,119.2 
Source No: 2 

27 Source Characterization 

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Number of source: 2 

Name of source: Contaminated soil located on the SWP property 

Source Type: Contaminated soil 

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

Source No. 2 is an area of contaminated soil located on the SWP property (see Figure 3 of this HRS 

documentation record). From 1928 to 1979, wood treating operations occurred on the SWP property 

(Refs. 8, p. 5; 9, p. 1). During former operations, southern yellow pine timbers were stripped of bark and 

placed in retort cylinders for drying. Wood preservatives, hot creosote or PCP, were pumped into the 

cylinders. The cylinders were pressurized to force the liquid into the wood until saturation. The wood 

was then removed to drip dry on the western portion of the property, and the residual liquid was drained 

(Ref. 10, p. 2; 11, p. 1; 12, p. 1). When operations ceased, the property included large areas of 

contamination in the treatment and storage areas, as well as piles of contaminated soil, creosote sludge 

storage tanks, and three unlined wastewater surface impoundments that had been filled by a previous 

owner at an unspecified time (Ref. 9, p. 1). 

In 2007, EPA SESD personnel advanced soil borings from 0 to 32 feet bgs along the northern border of 

the property, between the stockpile, former lagoons, and Batchelor Creek, to evaluate whether free-phase 

creosote was entering Batchelor Creek (Ref. 18, pp. 4, 5, 15 through 30). Visible and odorous impacts 

(believed to be organic contamination) to the soil were observed in several of the borings adjacent to and 

west of the stockpile. In addition, free-phase creosote was observed at 6 feet bgs in at least one boring 

located adjacent to the stockpile (Ref. 18, pp. 6, 12, 19). 

In September 2008, EPA advanced 29 boreholes between 0 and 36 feet bgs throughout the SWP property 

and within the stockpile. Free product (creosote) was noted in 14 of the 29 boreholes (Ref. 47, p. 1, 

Enclosure 1, p. E1-1, Enclosure 2, pp. E2-1 through E2-29). 

Hazardous substances detected in Source No. 2 include SVOCs and dioxins and furans (see Table 5 of 

this HRS documentation record). The same hazardous substances detected in Source No. 2 were also 

detected in the stockpile (Source No. 1) (Refs. 5, Appendix B, Table 8, pp. B-11 through B-16; 5, 

Appendix B, Tables 10 through 13, pp. B-19 through B-28; 5, Appendix B, Table 14, pp. B-29, B-30, B31; 5, Appendix E; 19, Appendix B, Table 3, p. B-3; 45, pp. 5 through 11, 13, 20; 46, pp. 38, 39, 40, 43) 

(see Table 2 of this HRS documentation record). 

Soil samples collected from Source No. 2 contained elevated concentrations of anthracene; 

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

dibenzofuran; indeno(1,2,3-cd)pyrene; pentachlorophenol; phenanthrene; pyrene; 1,2,3,4,6,7,8-HpCDD; 

1,2,3,4,6,7,8-HpCDF; 1,2,3,4,7,8-HxCDF; and 1,2,3,6,7,8-HxCDD (Ref. 5, Appendix B, Table 8, pp. B11 through B-16; 5, Appendix B, Tables 10 through 13, pp. B-19 through B-28; 5, Appendix B, Table 14, 

pp. B-29, B-30, B-31; 5, Appendix E) (see Table 5 of this HRS documentation record). Hazardous 

substance concentrations in samples that are greater than or equal to three times the background 

concentration or that are greater than or equal to the sample-specific and analyte-specific MRL if not 

detected in the background sample are considered elevated. 
Source No: 2 

28 Source Characterization 

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

EPA September 2008 Expanded Site Inspection 

Background Concentrations 

Although not required by the HRS, the Source No. 2 samples were compared to background samples and 

estimated concentrations were adjusted to show the relative increase of source concentrations over 

background levels. The background soil samples listed in Table 4 were collected during the EPA 

September 2008 ESI (Ref. 5, p. 7, Appendix A, Figure 4, p. A-4; 5, Appendix B, Table 1, pp. B-1, B-2). 

The background soil samples were collected from a location about 1,000 feet north-northwest of the 

center of the SWP property (Ref. 5, Appendix A, Figure 4, p. A-4). The background surface soil sample 

was collected at a depth of 0 to 1 foot bgs (Ref. 5, Appendix A, Figure 4, p. A-4; 5, Appendix B, Table 1, 

pp. B-1, B-2). Background subsurface soil samples were collected at multiple depth intervals: 1 to 4 feet, 

4 to 8 feet, 8 to 12 feet, 12 to 16 feet, and 16 to 20 feet bgs (Refs. 5, Appendix B, Table 1, pp. B-1, B-2). 

The background samples will be compared with Source No. 2 samples collected at corresponding depths. 

Background and Source No. 2 surface and subsurface soil samples were collected during the same 

sampling event and in accordance with the same sampling procedures (Refs. 5, pp. 7, 8, Appendix A, 

Figure 4, p. A-4; 5, Appendix B, Table 1, pp. B-1, B-2; 21, p. 5). Surface and subsurface soil samples 

were collected in accordance with the EPA Region 4 SESD Field Branch Quality System and Technical 

Procedures for Soil Sampling, SESDPROC-300-R1 (Refs. 5, p. 10; 21, p. 5; 22). 

The samples were analyzed under the EPA CLP for SVOCs in accordance with EPA CLP SOW 

SOM01.2 and for dioxins and furans in accordance with CLP SOW DLM02.0 (Refs. 5, p. 8, Appendix E, 

pp. E-1, E-2, E-249, E-250; 21, Appendix B, Table 7, p. B-10; 21, Appendix C, p. C-12; 55; 56). EPA 

Region 4 SESD reviewed all data according to the contract SOW and EPA guidelines (Ref. 5, Appendix 

E, pp. E-2, E-250; 42). The MRLs are listed on the analytical data sheets in Reference 5, Appendix E. 

Each MRL is sample-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 MRLs are equivalent to SQLs (Ref. 23). The chain-of-custody records are provided in 

Reference 20. Logbook notes are available in Reference 5, Appendix C. The location of the background 

samples are depicted in Reference 5, Appendix A, Figure 4, page A-4, and described in Reference 5, 

Appendix B, Table 1, page B-1. 

TABLE 4: Analytical Results for Background Samples – September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

Background Sample (0 to 1 foot bgs) 

SWPB01 SWP-SS-01A1 Benzo(a)anthracene 11 μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-118; 20, p. 1 

SWPB01 SWP-SS-01A1 Benzo(a)pyrene 12 μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-118; 20, p. 1 

SWPB01 SWP-SS-01A1 Benzo(k)fluoranthene 11J (11) μg/kg 3.9 μg/kg 

5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-118; 20, p. 1; 

39, p. 8; 40, p. 2; 41, p. 1 

SWPB01 SWP-SS-01A1 Chrysene 13 μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-118; 20, p. 1 

SWPB01 SWP-SS-01A1 Dibenzofuran 200U μg/kg 200 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-118; 20, p. 1 
Source No: 2 

29 Source Characterization 

TABLE 4: Analytical Results for Background Samples – September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWPB01 SWP-SS-01A1 Indeno(1,2,3-cd)pyrene 7.3J (73) μg/kg 3.9 μg/kg 

5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-118; 20, p. 1; 

39, pp. 8, 15; 40, p. 2; 41, p. 1 

SWPB01 SWP-SS-01A1 Phenanthrene 6.8 μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-119; 20, p. 1 

SWPB01 SWP-SS-01A1 Pyrene 23 μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-119; 20, p. 1 

SWPB01 SWP-SS-01A1 1,2,3,4,6,7,8-HpCDD 81 ng/kg 4.8 ng/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-260; 20, p. 11

SWPB01 SWP-SS-01A1 1,2,3,4,6,7,8-HpCDF 170 ng/kg 4.8 ng/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-260; 20, p. 11

SWPB01 SWP-SS-01A1 1,2,3,4,7,8-HxCDF 6.8 ng/kg 4.8 ng/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-260; 20, p. 11

SWPB01 SWP-SS-01A1 1,2,3,6,7,8-HxCDD 7.0 ng/kg 4.8 ng/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-260; 20, p. 11

Background Sample (1 to 4 feet bgs) 

SWPB01 SWP-SB-01A2 Anthracene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-103; 20, p. 1 

SWPB01 SWP-SB-01A2 Benzo(a)anthracene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-103; 20, p. 1 

SWPB01 SWP-SB-01A2 Benzo(a)pyrene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-103; 20, p. 1 

SWPB01 SWP-SB-01A2 Benzo(k)fluoranthene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-103; 20, p. 1 

SWPB01 SWP-SB-01A2 Chrysene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-103; 20, p. 1 

SWPB01 SWP-SB-01A2 Dibenzofuran 210U μg/kg 210 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-103; 20, p. 1 

SWPB01 SWP-SB-01A2 Phenanthrene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-104; 20, p. 1 

SWPB01 SWP-SB-01A2 Pyrene 4.2U μg/kg 4.2 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-104; 20, p. 1 

Background Sample (4 to 8 feet bgs) 

SWPB01 SWP-SB-01B Anthracene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-106; 20, p. 1 

SWPB01 SWP-SB-01B Benzo(a)anthracene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-106; 20, p. 1 
Source No: 2 

30 Source Characterization 

TABLE 4: Analytical Results for Background Samples – September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWPB01 SWP-SB-01B Benzo(a)pyrene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-106; 20, p. 1 

SWPB01 SWP-SB-01B Benzo(k)fluoranthene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-106; 20, p. 1 

SWPB01 SWP-SB-01B Chrysene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-106; 20, p. 1 

SWPB01 SWP-SB-01B Dibenzofuran 210U μg/kg 210 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-106; 20, p. 1 

SWPB01 SWP-SB-01B Phenanthrene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-107; 20, p. 1 

SWPB01 SWP-SB-01B Pyrene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-107; 20, p. 1 

Background Sample (8 to 12 feet bgs) 

SWPB01 SWP-SB-01C Anthracene 3.9U μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-109; 20, p. 1 

SWPB01 SWP-SB-01C Benzo(a)anthracene 3.9U μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-109; 20, p. 1 

SWPB01 SWP-SB-01C Benzo(a)pyrene 3.9U μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-109; 20, p. 1 

SWPB01 SWP-SB-01C Benzo(k)fluoranthene 3.9U μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-109; 20, p. 1 

SWPB01 SWP-SB-01C Chrysene 3.9U μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-109; 20, p. 1 

SWPB01 SWP-SB-01C Dibenzofuran 200U μg/kg 200 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-109; 20, p. 1 

SWPB01 SWP-SB-01C Phenanthrene 3.9U μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-110; 20, p. 1 

SWPB01 SWP-SB-01C Pyrene 3.9U μg/kg 3.9 μg/kg 5, Appendix C, Logbook 1, p. 5; 

5, Appendix E, p. E-110; 20, p. 1 

Background Sample (12 to 16 feet bgs) 

SWPB01 SWP-SB-01D Anthracene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 7; 

5, Appendix E, p. E-112; 20, p. 1 

SWPB01 SWP-SB-01D Benzo(a)anthracene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 7; 

5, Appendix E, p. E-112; 20, p. 1 

SWPB01 SWP-SB-01D Benzo(a)pyrene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 7; 

5, Appendix E, p. E-112; 20, p. 1 

SWPB01 SWP-SB-01D Benzo(k)fluoranthene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 7; 

5, Appendix E, p. E-112; 20, p. 1 
Source No: 2 

31 Source Characterization 

TABLE 4: Analytical Results for Background Samples – September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWPB01 SWP-SB-01D Chrysene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 7; 

5, Appendix E, p. E-112; 20, p. 1 

SWPB01 SWP-SB-01D Phenanthrene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 7; 

5, Appendix E, p. E-113; 20, p. 1 

Background Sample (16 to 20 feet bgs) 

SWPB01 SWP-SB-01E Benzo(a)pyrene 110U μg/kg 110 μg/kg 5, Appendix C, Logbook 1, p. 7; 

5, Appendix E, p. E-115; 20, p. 4 

SWPB01 SWP-SB-01E Dibenzo(a,h)anthracene 110U μg/kg 110 μg/kg 5, Appendix C, Logbook 1, p. 7; 

5, Appendix E, p. E-115; 20, p. 4 

SWPB01 SWP-SB-01E Dibenzofuran 2,600U μg/kg 2,600 

μg/kg 

5, Appendix C, Logbook 1, p. 7; 

5, Appendix E, p. E-115; 20, p. 4 

SWPB01 SWP-SB-01E Pentachlorophenol 210U μg/kg 210 μg/kg 5, Appendix C, Logbook 1, p. 7; 

5, Appendix E, p. E-116; 20, p. 4 

SWPB01 SWP-SB-01E Phenanthrene 640 μg/kg 110 μg/kg 5, Appendix C, Logbook 1, p. 7; 

5, Appendix E, p. E-116; 20, p. 4 

SWPB01 SWP-SB-01E Pyrene 330 μg/kg 110 μg/kg 5, Appendix C, Logbook 1, p. 7; 

5, Appendix E, p. E-116; 20, p. 4 

Notes: 

( ) Concentrations shown in parentheses were adjusted in accordance with References 39, 40, and 41. 

A1 Sample collected at a depth of 0 to 1 foot bgs 

A2 Sample collected at a depth of 1 to 4 feet bgs 

B Sample collected at a depth of 4 to 8 feet bgs 

bgs Below ground surface 

C Sample collected at a depth of 8 to 12 feet bgs 

D Sample collected at a depth of 12 to 16 feet bgs 

E Sample collected at a depth of 16 to 20 feet bgs 

HpCDD Heptachlorodibenzodioxin 

HpCDF Heptachlorodibenzofuran 

HxCDD Hexachlorodibenzodioxin 

HxCDF Hexachlorodibenzofuran 

ID Identification number 

J Identification of the analyte is acceptable; the reported value is an estimate. 

μg/kg Microgram per kilogram 

MRL Minimum reporting limit 

ng/kg Nanogram per kilogram 

SB Subsurface sample 

SS Surface sample 

SWP Southeastern Wood Preserving 

SWPB Southeastern Wood Preserving background 

U The analyte was not detected at or above the reporting limit. 
Source No: 2 

32 Source Characterization 

Source Concentrations 

The Source No. 2 samples listed in Table 5 were collected during the EPA September 2008 ESI (Ref. 5, 

pp. 7, 10, Appendix A, Figure 4, p. A-4; 5, Appendix B, Table 1, pp. B-1, B-2). The samples were 

collected on the SWP property (Ref. 21, p. 6). A surface soil sample was collected from each location at 

a depth of 0 to 1 foot bgs (Ref. 5, Appendix A, Figure 4, p. A-4; 5, Appendix B, Table 1, pp. B-1, B-2). 

Subsurface soil samples were collected from one or more of the following depth intervals: 1 to 4 feet, 4 to 

8 feet, 8 to 12 feet, 12 to 16 feet, and 16 to 20 feet bgs (Ref. 5, Appendix B, Table 1, pp. B-1, B-2). 

Source No. 2 samples were collected in accordance with the EPA Region 4 SESD Field Branch Quality 

System and Technical Procedures, Soil Sampling (Refs. 5, p. 10; 21, p. 5; 22). Samples collected from 

Source No. 2 were analyzed under the EPA CLP for SVOCs in accordance with CLP SOW SOM01.2. In 

addition, selected samples were also analyzed for dioxins and furans in accordance with the CLP SOW 

DLM02.0 (Refs. 5, p. 8; 5, Appendix E, pp. E-1, E-2, E-249, E-250; 21, Appendix B, Table 7, p. B-10; 

21, Appendix C, p. C-12; 55; 56). EPA Region 4 SESD reviewed all data according to the contract SOW 

and EPA guidelines (Ref. 5, Appendix E, pp. E-2, E-250; 42). The MRLs are listed on the analytical data 

sheets in Reference 5, Appendix E. Each MRL is sample-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 MRLs are equivalent to SQLs (Ref. 23). The 

chain-of-custody records are provided in Reference 20. Logbook notes are available in Reference 5, 

Appendix C. The locations of Source No. 2 samples are depicted in Reference 5, Appendix A, Figure 4, 

page A-4 and are described in Reference 5, Appendix B, Table 1, pages B-1 and B-2. 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

Source Samples (0 to 1 foot bgs)

SWP02 SWP-SS-02-A1 Benzo(a)anthracene 220 μg/kg 180 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-16; 20, 

p. 9 

SWP02 SWP-SS-02-A1 Benzo(a)pyrene 360 μg/kg 180 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-16; 20, 

p. 9 

SWP02 SWP-SS-02-A1 Benzo(k)fluoranthene 520 μg/kg 180 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-16; 20, 

p. 9 

SWP02 SWP-SS-02-A1 Chrysene 390 μg/kg 180 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-16; 20, 

p. 9 

SWP02 SWP-SS-02-A1 Indeno(1,2,3-cd)pyrene 870 μg/kg 180 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-16; 20, 

p. 9 

SWP02 SWP-SS-02-A1 Phenanthrene 460 μg/kg 180 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-17; 20, 

p. 9 

SWP02 SWP-SS-02-A1 Pyrene 670 μg/kg 180 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-17; 20, 

p. 9 

SWP03 SWP-SS-03A1 Benzo(a)anthracene 3,200 μg/kg 1,200 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-22; 20, 

p. 8 
Source No: 2 

33 Source Characterization 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWP03 SWP-SS-03A1 Benzo(a)pyrene 2,200 μg/kg 1,200 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-22; 20, 

p. 8 

SWP03 SWP-SS-03A1 Benzo(k)fluoranthene 2,500 μg/kg 1,200 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-22; 20, 

p. 8 

SWP03 SWP-SS-03A1 Chrysene 4,500 μg/kg 1,200 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-22; 20, 

p. 8 

SWP03 SWP-SS-03A1 Indeno(1,2,3-cd)pyrene 1,800 μg/kg 1,200 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-22; 20, 

p. 8 

SWP03 SWP-SS-03A1 Phenanthrene 7,400 μg/kg 1,200 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-23; 20, 

p. 8 

SWP03 SWP-SS-03A1 Pyrene 7,900 μg/kg 1,200 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-23; 20, 

p. 8 

SWP04 SWP-SS-04A1 Benzo(a)anthracene 19,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-31; 20, 

p. 7 

SWP04 SWP-SS-04A1 Benzo(a)pyrene 27,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-31; 20, 

p. 7 

SWP04 SWP-SS-04A1 Benzo(k)fluoranthene 30,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-31; 20, 

p. 7 

SWP04 SWP-SS-04A1 Chrysene 23,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-31; 20, 

p. 7 

SWP04 SWP-SS-04A1 Indeno(1,2,3-cd)pyrene 24,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-31; 20, 

p. 7 

SWP04 SWP-SS-04A1 Phenanthrene 3,100 μg/kg 500 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-32; 20, 

p. 7 

SWP04 SWP-SS-04A1 Pyrene 27,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-32; 20, 

p. 7 

SWP04 SWP-SS-04A1 1,2,3,4,6,7,8-HpCDD 9,500 ng/kg 240 ng/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-254; 

20, p. 11 

SWP04 SWP-SS-04A1 1,2,3,4,6,7,8-HpCDF 14,000 ng/kg 47 ng/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-254; 

20, p. 11 

SWP04 SWP-SS-04A1 1,2,3,4,7,8-HxCDF 240 ng/kg 47 ng/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-254; 

20, p. 11 
Source No: 2 

34 Source Characterization 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWP04 SWP-SS-04A1 1,2,3,6,7,8-HxCDD 650 ng/kg 47 ng/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-254; 

20, p. 11 

SWP05 SWP-SS-05A1 Benzo(a)anthracene 2,000 μg/kg 550 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-37; 20, 

p. 5 

SWP05 SWP-SS-05A1 Benzo(a)pyrene 1,800 μg/kg 550 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-37; 20, 

p. 5 

SWP05 SWP-SS-05A1 Benzo(k)fluoranthene 2,200 μg/kg 550 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-37; 20, 

p. 5 

SWP05 SWP-SS-05A1 Chrysene 3,300 μg/kg 550 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-37; 20, 

p. 5 

SWP05 SWP-SS-05A1 Indeno(1,2,3-cd)pyrene 1,500 μg/kg 550 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-38; 20, 

p. 5 

SWP05 SWP-SS-05A1 Phenanthrene 790 μg/kg 110 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-38; 20, 

p. 5 

SWP05 SWP-SS-05A1 Pyrene 5,000 μg/kg 550 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-38; 20, 

p. 5 

SWP06 SWP-SS-06A1 Benzo(a)anthracene 14,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-43; 20, 

p. 5 

SWP06 SWP-SS-06A1 Benzo(a)pyrene 7,900 μg/kg 2,600μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-43; 20, 

p. 5 

SWP06 SWP-SS-06A1 Benzo(k)fluoranthene 9,900 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-43; 20, 

p. 5 

SWP06 SWP-SS-06A1 Chrysene 19,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-43; 20, 

p. 5 

SWP06 SWP-SS-06A1 Dibenzofuran 3,300 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-43; 20, 

p. 5 

SWP06 SWP-SS-06A1 Indeno(1,2,3-cd)pyrene 5,400 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-43; 20, 

p. 5 

SWP06 SWP-SS-06A1 Phenanthrene 33,000 μg/kg 10,000 μg/kg

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-44; 20, 

p. 5 

SWP06 SWP-SS-06A1 Pyrene 69,000 μg/kg 10,000 μg/kg

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-44; 20, 

p. 5 
Source No: 2 

35 Source Characterization 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWP07 SWP-SS-07A1 Benzo(a)anthracene 10,000 μg/kg 2,900 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-52; 20, 

p. 4 

SWP07 SWP-SS-07A1 Benzo(a)pyrene 13,000 μg/kg 2,900 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-52; 20, 

p. 4 

SWP07 SWP-SS-07A1 Benzo(k)fluoranthene 13,000 μg/kg 2,200 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-52; 20, 

p. 4 

SWP07 SWP-SS-07A1 Chrysene 15,000 μg/kg 2,200 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-52; 20, 

p. 4 

SWP07 SWP-SS-07A1 Indeno(1,2,3-cd)pyrene 7,800 μg/kg 2,200 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-52; 20, 

p. 4 

SWP07 SWP-SS-07A1 Pyrene 10,000 μg/kg 2,900 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-53; 20, 

p. 4 

SWP08 SWP-SS-08A1 Benzo(a)anthracene 1,400 μg/kg 930 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-58; 20, 

p. 8 

SWP08 SWP-SS-08A1 Benzo(a)pyrene 610 μg/kg 93 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-58; 20, 

p. 8 

SWP08 SWP-SS-08A1 Benzo(k)fluoranthene 690 μg/kg 93 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-58; 20, 

p. 8 

SWP08 SWP-SS-08A1 Chrysene 1,900 μg/kg 930 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-58; 20, 

p. 8 

SWP08 SWP-SS-08A1 Dibenzofuran 4,100 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-58; 20, 

p. 8 

SWP08 SWP-SS-08A1 Indeno(1,2,3-cd)pyrene 780 μg/kg 93 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-58; 20, 

p. 8 

SWP08 SWP-SS-08A1 Phenanthrene 17,000 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-59; 20, 

p. 8 

SWP08 SWP-SS-08A1 Pyrene 6,800 μg/kg 930 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-59; 20, 

p. 8 

SWP09 SWP-SS-09A1 Benzo(a)anthracene 22,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-64; 20, 

p. 8 

SWP09 SWP-SS-09A1 Benzo(a)pyrene 17,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-64; 20, 

p. 8 
Source No: 2 

36 Source Characterization 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWP09 SWP-SS-09A1 Benzo(k)fluoranthene 24,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-64; 20, 

p. 8 

SWP09 SWP-SS-09A1 Chrysene 30,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-64; 20, 

p. 8 

SWP09 SWP-SS-09A1 Indeno(1,2,3-cd)pyrene 12,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-64; 20, 

p. 8 

SWP09 SWP-SS-09A1 Phenanthrene 6,600 μg/kg 1,000 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-65; 20, 

p. 8 

SWP09 SWP-SS-09A1 Pyrene 14,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-65; 20, 

p. 8 

SWP10 SWP-SS-10A1 Benzo(a)anthracene 35,000 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-70; 20, 

p. 12 

SWP10 SWP-SS-10A1 Benzo(a)pyrene 9,500 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-70; 20, 

p. 12 

SWP10 SWP-SS-10A1 Benzo(k)fluoranthene 11,000 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-70; 20, 

p. 12 

SWP10 SWP-SS-10A1 Chrysene 33,000 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-70; 20, 

p. 12 

SWP10 SWP-SS-10A1 Dibenzofuran 64,000 μg/kg 23,000 μg/kg

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-70; 20, 

p. 12 

SWP10 SWP-SS-10A1 Indeno(1,2,3-cd)pyrene 4,300 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-70; 20, 

p. 12 

SWP10 SWP-SS-10A1 Phenanthrene 210,000 μg/kg 23,000 μg/kg

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-71; 20, 

p. 12 

SWP10 SWP-SS-10A1 Pyrene 82,000 μg/kg 23,000 μg/kg

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-71; 20, 

p. 12 

SWP11 SWP-SS-11A1 Benzo(a)anthracene 7,100 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-79; 20, 

p. 8 

SWP11 SWP-SS-11A1 Benzo(a)pyrene 6,900 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-79; 20, 

p. 8 

SWP11 SWP-SS-11A1 Benzo(k)fluoranthene 7,500 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-79; 20, 

p. 8 
Source No: 2 

37 Source Characterization 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWP11 SWP-SS-11A1 Chrysene 9,600 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-79; 20, 

p. 8 

SWP11 SWP-SS-11A1 Indeno(1,2,3-cd)pyrene 5,800 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-79; 20, 

p. 8 

SWP11 SWP-SS-11A1 Phenanthrene 8,000 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-80; 20, 

p. 8 

SWP11 SWP-SS-11A1 Pyrene 13,000 μg/kg 2,300 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-80; 20, 

p. 8 

SWP11 SWP-SS-11A1 1,2,3,4,6,7,8-HpCDD 2,600 ng/kg 24 ng/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-258; 

20, p. 11 

SWP11 SWP-SS-11A1 1,2,3,4,6,7,8-HpCDF 1,500 ng/kg 4.9 ng/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-258; 

20, p. 11 

SWP11 SWP-SS-11A1 1,2,3,4,7,8-HxCDF 33 ng/kg 4.9 ng/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-258; 

20, p. 11 

SWP11 SWP-SS-11A1 1,2,3,6,7,8-HxCDD 94 ng/kg 4.9 ng/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-258; 

20, p. 11 

SWP12 SWP-SS-12A1 Benzo(a)anthracene 120 μg/kg 89 μg/kg 

5, Appendix C, Logbook 1, p. 

9; 5, Appendix E, p. E-85; 20, 

p. 1 

SWP12 SWP-SS-12A1 Benzo(a)pyrene 100 μg/kg 89 μg/kg 

5, Appendix C, Logbook 1, p. 

9; 5, Appendix E, p. E-85; 20, 

p. 1 

SWP12 SWP-SS-12A1 Benzo(k)fluoranthene 160 μg/kg 89 μg/kg 

5, Appendix C, Logbook 1, p. 

9; 5, Appendix E, p. E-85; 20, 

p. 1 

SWP12 SWP-SS-12A1 Chrysene 290 μg/kg 89 μg/kg 

5, Appendix C, Logbook 1, p. 

9; 5, Appendix E, p. E-85; 20, 

p. 1 

SWP12 SWP-SS-12A1 Phenanthrene 190 μg/kg 89 μg/kg 

5, Appendix C, Logbook 1, p. 

9; 5, Appendix E, p. E-86; 20, 

p. 1 

SWP12 SWP-SS-12A1 Pyrene 300 μg/kg 89 μg/kg 

5, Appendix C, Logbook 1, p. 

9; 5, Appendix E, p. E-86; 20, 

p. 1 

SWP13 SWP-SS-13A1 Benzo(a)anthracene 700 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

7; 5, Appendix E, p. E-91; 20, 

p. 1 

SWP13 SWP-SS-13A1 Benzo(a)pyrene 510 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

7; 5, Appendix E, p. E-91; 20, 

p. 1 
Source No: 2 

38 Source Characterization 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWP13 SWP-SS-13A1 Benzo(k)fluoranthene 780 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

7; 5, Appendix E, p. E-91; 20, 

p. 1 

SWP13 SWP-SS-13A1 Chrysene 1,400 μg/kg 240 μg/kg 

5, Appendix C, Logbook 1, p. 

7; 5, Appendix E, p. E-91; 20, 

p. 1 

SWP13 SWP-SS-13A1 Indeno(1,2,3-cd)pyrene 730 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

7; 5, Appendix E, p. E-91; 20, 

p. 1 

SWP13 SWP-SS-13A1 Phenanthrene 290 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

7; 5, Appendix E, p. E-92; 20, 

p. 1 

SWP13 SWP-SS-13A1 Pyrene 1,500 μg/kg 240 μg/kg 

5, Appendix C, Logbook 1, p. 

7; 5, Appendix E, p. E-92; 20, 

p. 1 

SWP13 SWP-SS-13A1 1,2,3,4,6,7,8-HpCDD 6,600 ng/kg 49 ng/kg 

5, Appendix C, Logbook 1, p. 

7; 5, Appendix E, p. E-259; 20, 

p. 11 

SWP13 SWP-SS-13A1 1,2,3,4,6,7,8-HpCDF 4,500 ng/kg 49 ng/kg 

5, Appendix C, Logbook 1, p. 

7; 5, Appendix E, p. E-259; 20, 

p. 11 

SWP13 SWP-SS-13A1 1,2,3,4,7,8-HxCDF 170 ng/kg 4.9 ng/kg 

5, Appendix C, Logbook 1, p. 

7; 5, Appendix E, p. E-259; 20, 

p. 11 

SWP13 SWP-SS-13A1 1,2,3,6,7,8-HxCDD 250 ng/kg 4.9 ng/kg 

5, Appendix C, Logbook 1, p. 

7; 5, Appendix E, p. E-259; 20, 

p. 11 

SWP14 SWP-SS-14A1 Benzo(a)anthracene 360 μg/kg 130 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-97; 20, 

p. 5 

SWP14 SWP-SS-14A1 Benzo(a)pyrene 560 μg/kg 130 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-97; 20, 

p. 5 

SWP14 SWP-SS-14A1 Benzo(k)fluoranthene 690 μg/kg 130 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-97; 20, 

p. 5 

SWP14 SWP-SS-14A1 Chrysene 620 μg/kg 130 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-97; 20, 

p. 5 

SWP14 SWP-SS-14A1 Indeno(1,2,3-cd)pyrene 460 μg/kg 130 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-97; 20, 

p. 5 

SWP14 SWP-SS-14A1 Phenanthrene 180 μg/kg 130 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-98; 20, 

p. 5 

SWP14 SWP-SS-14A1 Pyrene 590 μg/kg 130 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-98; 20, 

p. 5 
Source No: 2 

39 Source Characterization 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

Source Samples (1 to 4 feet bgs)

SWP07 SWP-SB-07A2 Anthracene 8,900 μg/kg 2,800 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-46; 20, 

p. 4 

SWP07 SWP-SB-07A2 Benzo(a)anthracene 14,000 μg/kg 2,800 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-46; 20, 

p. 4 

SWP07 SWP-SB-07A2 Benzo(a)pyrene 10,000 μg/kg 2,800 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-46; 20, 

p. 4 

SWP07 SWP-SB-07A2 Benzo(k)fluoranthene 14,000 μg/kg 4,600 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-46; 20, 

p. 4 

SWP07 SWP-SB-07A2 Chrysene 19,000 μg/kg 4,600 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-46; 20, 

p. 4 

SWP07 SWP-SB-07A2 Dibenzofuran 7,000 μg/kg 2,800 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-46; 20, 

p. 4 

SWP07 SWP-SB-07A2 Phenanthrene 23,000 μg/kg 2,800 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-47; 20, 

p. 4 

SWP07 SWP-SB-07A2 Pyrene 33,000 μg/kg 2,800 μg/kg 

5, Appendix C, Logbook 1, p. 

11; 5, Appendix E, p. E-47; 20, 

p. 4 

SWP07 SWP-SB-07A2-

DUP Anthracene 46,000 μg/kg 4,800 μg/kg 

5, Appendix C, Logbook 1, p. 

13; 5, Appendix E, p. E-49; 20, 

p. 4 

SWP07 SWP-SB-07A2-

DUP Benzo(a)anthracene 3,500 μg/kg 2,400 μg/kg 

5, Appendix C, Logbook 1, p. 

13; 5, Appendix E, p. E-49; 20, 

p. 4 

SWP07 SWP-SB-07A2-

DUP Benzo(a)pyrene 3,500 μg/kg 2,400 μg/kg 

5, Appendix C, Logbook 1, p. 

13; 5, Appendix E, p. E-49; 20, 

p. 4 

SWP07 SWP-SB-07A2-

DUP Benzo(k)fluoranthene 5,300 μg/kg 2,400 μg/kg 

5, Appendix C, Logbook 1, p. 

13; 5, Appendix E, p. E-49; 20, 

p. 4 

SWP07 SWP-SB-07A2-

DUP Chrysene 7,100 μg/kg 2,400 μg/kg 

5, Appendix C, Logbook 1, p. 

13; 5, Appendix E, p. E-49; 20, 

p. 4 

SWP07 SWP-SB-07A2-

DUP Phenanthrene 7,700 μg/kg 2,400 μg/kg 

5, Appendix C, Logbook 1, p. 

13; 5, Appendix E, p. E-50; 20, 

p. 4 

SWP07 SWP-SB-07A2-

DUP Pyrene 5,100 μg/kg 2,400 μg/kg 

5, Appendix C, Logbook 1, p. 

13; 5, Appendix E, p. E-50; 20, 

p. 4 
Source No: 2 

40 Source Characterization 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

Source Samples (4 to 8 feet bgs)

SWP02 SWP-SB-02B Anthracene 12,000 μg/kg 2,800 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-13; 20, 

p. 9 

SWP02 SWP-SB-02B Benzo(a)anthracene 10,000 μg/kg 2,800 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-13; 20, 

p. 9 

SWP02 SWP-SB-02B Benzo(a)pyrene 2,000 μg/kg 220 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-13; 20, 

p. 9 

SWP02 SWP-SB-02B Benzo(k)fluoranthene 2,000 μg/kg 220 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-13; 20, 

p. 9 

SWP02 SWP-SB-02B Chrysene 8,500 μg/kg 2,800 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-13; 20, 

p. 9 

SWP02 SWP-SB-02B Dibenzofuran 25,000 μg/kg 2,800 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-13; 20, 

p. 9 

SWP02 SWP-SB-02B Phenanthrene 88,000 μg/kg 2,800 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-14; 20, 

p. 9 

SWP02 SWP-SB-02B Pyrene 32,000 μg/kg 2,800 μg/kg 

5, Appendix C, Logbook 1, p. 

31; 5, Appendix E, p. E-14; 20, 

p. 9 

SWP03 SWP-SB-03B Anthracene 210 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-19; 20, 

p. 8 

SWP03 SWP-SB-03B Benzo(a)anthracene 420 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-19; 20, 

p. 8 

SWP03 SWP-SB-03B Benzo(a)pyrene 290 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-19; 20, 

p. 8 

SWP03 SWP-SB-03B Benzo(k)fluoranthene 270 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-19; 20, 

p. 8 

SWP03 SWP-SB-03B Chrysene 480 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-19; 20, 

p. 8 

SWP03 SWP-SB-03B Phenanthrene 580 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-20; 20, 

p. 8 

SWP03 SWP-SB-03B Pyrene 4,600 μg/kg 3,100 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-20; 20, 

p. 8 
Source No: 2 

41 Source Characterization 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWP06 SWP-SB-06B Benzo(a)anthracene 320 μg/kg 100 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-40; 20, 

p. 5 

SWP06 SWP-SB-06B Benzo(a)pyrene 220 μg/kg 100 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-40; 20, 

p. 5 

SWP06 SWP-SB-06B Benzo(k)fluoranthene 240 μg/kg 100 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-40; 20, 

p. 5 

SWP06 SWP-SB-06B Chrysene 350 μg/kg 100 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-40; 20, 

p. 5 

SWP06 SWP-SB-06B Pyrene 150 μg/kg 100 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-41; 20, 

p. 5 

SWP10 SWP-SB-10B Anthracene 100,000 μg/kg 54,000 μg/kg

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-67; 20, 

p. 12 

SWP10 SWP-SB-10B Benzo(a)anthracene 66,000 μg/kg 54,000 μg/kg

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-67; 20, 

p. 12 

SWP10 SWP-SB-10B Benzo(a)pyrene 11,000 μg/kg 2,700 μg/kg 

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-67; 20, 

p. 12 

SWP10 SWP-SB-10B Benzo(k)fluoranthene 33,000 μg/kg 2,700 μg/kg 

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-67; 20, 

p. 12 

SWP10 SWP-SB-10B Chrysene 100,000 μg/kg 54,000 μg/kg

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-67; 20, 

p. 12 

SWP10 SWP-SB-10B Dibenzofuran 79,000 μg/kg 54,000 μg/kg

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-67; 20, 

p. 12 

SWP10 SWP-SB-10B Phenanthrene 700,000 μg/kg 54,000 μg/kg

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-68; 20, 

p. 12 

SWP10 SWP-SB-10B Pyrene 320,000 μg/kg 54,000 μg/kg

5, Appendix C, Logbook 2, p. 

10; 5, Appendix E, p. E-68; 20, 

p. 12 

Source Samples (8 to 12 feet bgs)

SWP04 SWP-SB-04C Anthracene 24,000 μg/kg 16,000 μg/kg

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-25; 20, 

p. 7 

SWP04 SWP-SB-04C Benzo(a)anthracene 16,000 μg/kg 3,100 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-25; 20, 

p. 7 
Source No: 2 

42 Source Characterization 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWP04 SWP-SB-04C Benzo(a)pyrene 4,500 μg/kg 600 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-25; 20, 

p. 7 

SWP04 SWP-SB-04C Benzo(k)fluoranthene 4,900 μg/kg 600 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-25; 20, 

p. 7 

SWP04 SWP-SB-04C Chrysene 13,000 μg/kg 3,100 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-25; 20, 

p. 7 

SWP04 SWP-SB-04C Dibenzofuran 65,000 μg/kg 16,000 μg/kg

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-25; 20, 

p. 7 

SWP04 SWP-SB-04C Phenanthrene 230,000 μg/kg 16,000 μg/kg

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-26; 20, 

p. 7 

SWP04 SWP-SB-04C Pyrene 80,000 μg/kg 16,000 μg/kg

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-26; 20, 

p. 7 

SWP04 SWP-SB-04CDUP Anthracene 26,000 μg/kg 16,000 μg/kg

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-28; 20, 

p. 7 

SWP04 SWP-SB-04CDUP Benzo(a)anthracene 13,000 μg/kg 3,100 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-28; 20, 

p. 7 

SWP04 SWP-SB-04CDUP Benzo(a)pyrene 4,200 μg/kg 600 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-28; 20, 

p. 7 

SWP04 SWP-SB-04CDUP Benzo(k)fluoranthene 4,500 μg/kg 600 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-28; 20, 

p. 7 

SWP04 SWP-SB-04CDUP Chrysene 12,000 μg/kg 3,100 μg/kg 

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-28; 20, 

p. 7 

SWP04 SWP-SB-04CDUP Dibenzofuran 60,000 μg/kg 16,000 μg/kg

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-28; 20, 

p. 7 

SWP04 SWP-SB-04CDUP Phenanthrene 220,000 μg/kg 16,000 μg/kg

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-29; 20, 

p. 7 

SWP04 SWP-SB-04CDUP Pyrene 69,000 μg/kg 16,000 μg/kg

5, Appendix C, Logbook 1, p. 

26; 5, Appendix E, p. E-29; 20, 

p. 7 

SWP08 SWP-SB-08C Anthracene 380 μg/kg 100 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-55; 20, 

p. 8 

SWP08 SWP-SB-08C Benzo(a)anthracene 290 μg/kg 100 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-55; 20, 

p. 8 
Source No: 2 

43 Source Characterization 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWP08 SWP-SB-08C Benzo(a)pyrene 110 μg/kg 100 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-55; 20, 

p. 8 

SWP08 SWP-SB-08C Benzo(k)fluoranthene 150 μg/kg 100 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-55; 20, 

p. 8 

SWP08 SWP-SB-08C Chrysene 270 μg/kg 100 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-55; 20, 

p. 8 

SWP08 SWP-SB-08C Phenanthrene 3,300 μg/kg 500 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-56; 20, 

p. 8 

SWP08 SWP-SB-08C Pyrene 1,100 μg/kg 500 μg/kg 

5, Appendix C, Logbook 1, p. 

18; 5, Appendix E, p. E-56; 20, 

p. 8 

SWP09 SWP-SB-09C Anthracene 970,000 μg/kg 610,000 

μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-61; 20, 

p. 8 

SWP09 SWP-SB-09C Dibenzofuran 

1,600,000J 

(1,600,000) 

μg/kg 

610,000 

μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-61; 20, 

p. 8; 39, p. 8; 40, p. 1; 41, p. 2 

SWP09 SWP-SB-09C Phenanthrene 5,600,000 

μg/kg 

610,000 

μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-62; 20, 

p. 8 

SWP09 SWP-SB-09C Pyrene 1,800,000 

μg/kg 

610,000 

μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-62; 20, 

p. 8 

Source Samples (12 to 16 feet bgs)

SWP05 SWP-SB-05D Anthracene 200 μg/kg 110 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-34; 20, 

p. 5 

SWP05 SWP-SB-05D Benzo(a)anthracene 520 μg/kg 220 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-34; 20, 

p. 5 

SWP05 SWP-SB-05D Benzo(a)pyrene 460 μg/kg 110 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-34; 20, 

p. 5 

SWP05 SWP-SB-05D Benzo(k)fluoranthene 560 μg/kg 110 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-34; 20, 

p. 5 

SWP05 SWP-SB-05D Chrysene 670 μg/kg 220 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-34; 20, 

p. 5 

SWP05 SWP-SB-05D Phenanthrene 320 μg/kg 110 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-35; 20, 

p. 5 
Source No: 2 

44 Source Characterization 

TABLE 5: Analytical Results for Source No. 2– September 2008 

Station 

ID Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWP14 SWP-SB-14D Benzo(a)anthracene 270 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-94; 20, 

p. 5 

SWP14 SWP-SB-14D Benzo(a)pyrene 330 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-94; 20, 

p. 5 

SWP14 SWP-SB-14D Benzo(k)fluoranthene 400 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-94; 20, 

p. 5 

SWP14 SWP-SB-14D Chrysene 290 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-94; 20, 

p. 5 

SWP14 SWP-SB-14D Phenanthrene 150 μg/kg 120 μg/kg 

5, Appendix C, Logbook 1, p. 

20; 5, Appendix E, p. E-95; 20, 

p. 5 

Source Sample (16 to 20 feet bgs)

SWP11 SWP-SB-11E Benzo(a)pyrene 42,000 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-76; 20, 

p. 8 

SWP11 SWP-SB-11E Dibenzo(a,h)anthracene 4,300 μg/kg 2,600 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-76; 20, 

p. 8 

SWP11 SWP-SB-11E Dibenzofuran 530,000 μg/kg 100,000 

μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-76; 20, 

p. 8 

SWP11 SWP-SB-11E Pentachlorophenol 1,800 μg/kg 500 μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-77; 20, 

p. 8 

SWP11 SWP-SB-11E Phenanthrene 1,500,000 

μg/kg 

100,000 

μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-77; 20, 

p. 8 

SWP11 SWP-SB-11E Pyrene 400,000 μg/kg 100,000 

μg/kg 

5, Appendix C, Logbook 1, p. 

14; 5, Appendix E, p. E-77; 20, 

p. 8 
Source No: 2 

45 Source Characterization 

Notes: 

( ) Concentrations shown in parentheses were adjusted in accordance with References 39, 40, and 41. 

A1 Sample collected at a depth of 0 to 1 foot bgs 

A2 Sample collected at a depth of 1 to 4 feet bgs 

B Sample collected at a depth of 4 to 8 feet bgs 

bgs Below ground surface 

C Sample collected at a depth of 8 to 12 feet bgs 

D Sample collected at a depth of 12 to 16 feet bgs 

DUP Duplicate 

E Sample collected at a depth of 16 to 20 feet bgs 

HpCDD Heptachlorodibenzodioxin 

HpCDF Heptachlorodibenzofuran 

HxCDD Hexachlorodibenzodioxin 

HxCDF Hexachlorodibenzofuran 

ID Identification number 

J Identification of the analyte is acceptable; the reported value is an estimate 

μg/kg Microgram per kilogram 

MRL Minimum reporting limit 

ng/kg Nanogram per kilogram 

SB Subsurface sample 

SS Surface sample 

SWP Southeastern Wood Preserving
Source No: 2 

46 Source Characterization 

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

The source samples collected from Source No. 2 (contaminated soil located on the SWP property) 

contained elevated concentrations of SVOCs and dioxins and furans (Ref. 5, Appendix B, Table 8, pp. B11 through B-16; 5, Appendix B, Tables 10 through 13, pp. B-19 through B-28; 5, Appendix B, Table 14, 

pp. B-29, B-30, B-31; 5, Appendix E) (also see Table 5 of this HRS documentation record) (see Figure 3 

of this HRS documentation record). Analytical results for sediment samples collected from Batchelor 

Creek, which receives runoff from Source No. 2, 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. No run-on or runoff control systems were observed during the EPA September 

2008 ESI sampling (Refs. 5, Appendix C, Logbook 1; 25; 62). The removal action conducted by EPA 

from 2009 to 2010 included the placement of a slurry wall between the SWP source areas and Batchelor 

Creek to prevent further migration of creosote; it did not, however, include the construction of any run-on 

control or runoff management features (Refs. 62; 75, pp. 4, 5). At the end of the removal action, clean 

soil was placed over areas impacted by removal activities, such as the former location of the stockpile of 

sediments from Batchelor Creek (Ref. 44, p. 1). However, this location overlaps only a portion of the area 

comprising Source No. 2 (see Figures 2 and 3 of this HRS documentation record). As such, and 

considering the surface and near subsurface depths at which contamination was found in Source No. 2 

(see Table 5 of this HRS documentation record), the source is considered to have no maintained 

engineered cover. Based on the information provided above, a containment factor value of 10, as noted in 

Table 6, was assigned for Source No. 2 for the surface water migration pathway (Ref. 1, Section 

4.1.2.1.2.1.1). 

TABLE 6: Containment Factors for Source No. 2 

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 

maintained engineered cover; No functioning and 

maintained run-on control system or runoff 

management system. 

10 

1, Section 4.1.2.1.2.1.1; 5, 

Appendix B, Tables 8 through 14, 

pp. B-11 through B-31; 5, 

Appendix C, Logbook 1, p. 47; 5, 

Appendix C, Logbook 2, p. 4; 5, 

Appendix D, p. D-8; 7, pp. 1, 2; 14, 

pp. 2, 5; 16, pp. 1, 2; 25; 44, p. 1; 

62 

Notes: 

NA Not applicable 

NS Not scored
Source No: 2 

47 Source Characterization 

2.4.2.1 HAZARDOUS WASTE QUANTITY

2.4.2.1.1 Hazardous Constituent Quantity

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 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 information available is not sufficient to evaluate Tier C, volume, as required by Reference 1, Section 

2.4.2.1.3. 

 Volume Assigned Value: 0 

2.4.2.1.4 Area

It is not known whether contamination in Source No. 2 is continuous between sampling locations (Ref. 5, 

Appendix B, Table 1, pp. B-1, B-2). Therefore, the area of Source No. 2 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. 2 is assigned a source HWQ value of undetermined, but greater than zero (Ref. 1, Section 

2.4.2.1.5). 

Source HWQ Value: >0 
48 Source Characterization 

SUMMARY OF SOURCE DESCRIPTIONS

TABLE 7: Summary of Source Descriptions 

Containment Factor Value by Pathway

Air

Source 

No.

Source 

Hazardous 

Waste 

Quantity 

Value

Source 

Hazardous 

Constituent 

Quantity 

Complete? 

(Yes/No)

Ground 

Water 

(Ref. 1, 

Table 3-2)

Surface 

Water 

Overland/ 

Flood 

(Ref. 1, 

Table 4-2)

Gas 

(Ref. 1, 

Table 6-3)

Particulate 

(Ref. 1, 

Table 6-9)

1 6,119.2 No NS 10 NS NS 

2 >0 No NS 10 NS NS 

Notes: 

NS Not scored

Sum of Source Hazard Waste Quantity Values: 6,119 

Other Possible Sources

King Lumber: The current SWP property was originally part of a larger property owned by King 

Lumber, which operated the facility as a saw mill, lumber yard, and wood treating operation from 1928 to 

1964 (Refs. 7; 8, pp. 1, 5; 69). King Lumber also owned the railroad that runs along the northern bank of 

Batchelor Creek, north of the SWP property. There has been visual observation of creosote 

contamination along the northern bank of Batchelor Creek, which may be a result of King Lumber 

operations (Ref. 44, p. 43). Because King Lumber’s operations included wood treating, site operations 

and the types of hazardous substances (SVOCs) used are expected to be similar (Refs. 7; 8, p. 5). In 

addition, King Lumber constructed a mill pond north of the SWP property to store its lumber. This pond 

is currently being operated by CMU as a wastewater treatment pond (Ref. 69). Several residential 

properties located along the southern side of Covington Drive were reportedly located within the original 

footprint of King Lumber. Soil samples collected at these properties during the September 2008 EPA ESI 

contained site-related contaminants, including anthracene, benzo(a)anthracene, benzo(a)pyrene, 

benzo(k)fluoranthene, chrysene, dibenzo(a,h)anthracene, indeno(1,2,3-cd)pyrene, naphthalene, 

pentachlorophenol, phenanthrene, and pyrene (Ref. 5, pp. 18, 19; 5, Appendix A, p. A-4, Appendix B, pp. 

B-51, B-52, B-53). Specific details of operations, waste management, and disposal procedures employed 

by King Lumber are not known. 

 
49 SW-Overland/Flood Migration Component 

4.0 SURFACE WATER MIGRATION PATHWAY

4.1 OVERLAND/FLOOD MIGRATION COMPONENT – Batchelor Creek 

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). 

Overland flow from Source Nos. 1 and 2 (the stockpile and contaminated soil on the SWP property, 

respectively) generally follows land topography, which slopes north toward Batchelor Creek (Ref. 62). 

The southern portion of the SWP property has an elevation of 240 feet above mean sea level and the 

elevation of Batchelor Creek is 230 feet above mean sea level (see Figure 1 of this HRS documentation 

record). EPA constructed a slurry wall measuring 1,500 feet long, three feet wide, and 30 feet below land 

surface between the SWP property and the southern bank of Batchelor Creek to prevent further migration 

of hazardous substances to Batchelor Creek (Refs. 70; 73, p. 6; 75, pp. 4, 5) (see Figure 2 of this HRS 

documentation record). It did not, however, include the construction of any run-on control or runoff 

management features (Refs. 62; 75, p. 3) 

PPE 1 may be delineated by the downgradient intersection of the overland path with Batchelor Creek 

between sample stations SWP14 and SWP02. PPE 1 covers 2,370 feet along the northern boundary of the 

SWP property, which is Batchelor Creek (Refs. 4; 54; 77) (see Figure 3 of this HRS documentation 

record). The 15-mile target distance limit (TDL) of the surface water migration pathway begins at the 

most downstream point of PPE 1 (Refs. 4; 54). Batchelor Creek flows to the northwest approximately 8.5 

miles before it merges with Bear Creek, which continues in a northwest direction for about 4.25 miles to 

the Big Black River. Flow continues in the Big Black River for the remainder of the 15-mile surface 

water migration pathway TDL near Ross Lake in Yazoo County, Mississippi (Ref. 4). According to the 

U.S. Geological Survey (USGS), the average annual flow rate for the Big Black River is approximately 

6,079 cubic feet per second (cfs) (Ref. 35). USGS flow rate data are not available for Batchelor Creek or 

Bear Creek. Water level observations made during the EPA time-critical removal action September 2009 

to March 2010 indicate that the flow rate for Batchelor Creek is estimated to be from 0.13 to 22 cfs. 

Batchelor Creek is prone to flooding during rain events (Refs. 7, p. i; 50, p. 1; 59; 60). 
50 SW-Observed Release 

4.1.2.1 LIKELIHOOD OF RELEASE 

4.1.2.1.1 OBSERVED RELEASE – Direct Observation 

During the 1970s, the SWP facility received several notices of violation and fines from the Mississippi 

Pollution Control Commission (currently the Mississippi Office of Pollution Control) for gross 

contamination of the process area; releases of hazardous substances to Batchelor Creek; and inadequate 

treatment of process wastewater before it was discharged into the city sewage treatment facility (Ref. 10, 

pp. 1, 2). Before 1977, when the Clean Water Act was enacted, the facility reportedly discharged 

approximately 50,000 gallons of wastewater per day directly into Batchelor Creek, which flows through a 

city park, a residential area, and downtown Canton before it enters Bear Creek (Refs. 11, p. 1; 15, p. 1). 

The State of Mississippi received complaints of children, who had been playing in Batchelor Creek near 

the city park, suffering from creosote burns (Ref. 14, p. 4). 

In 1988, SCS designed a soil erosion prevention plan that included excavating and widening Batchelor 

Creek. While surveying the creek, SCS personnel observed oily waste leaching into the creek from the 

SWP property. In response, EPA removed contaminated soil from the creek bank observed to be leaching 

contaminants into Batchelor Creek to facilitate the SCS stream widening project (Ref. 14, p. 3). EPA also 

installed a geofabric liner in the bed of the creek, and the banks were lined with rip-rap to prevent erosion 

(Ref. 9, p. 4). As a result of this stream widening project, Batchelor Creek adjacent to the SWP property 

moved from a 5-year flood plain to a 10-year flood. Also, each time the SWP property floods, 

contaminated soil washes into Batchelor Creek (Ref. 14, pp. 3, 4). 

During the EPA RSE conducted in February 2008, creosote was observed in Batchelor Creek downstream 

of Source No. 1, specifically at sediment sampling location SWP-SD-01 (Ref. 19, pp. 1, 2; 19, Appendix 

C, p. 5). During the September 2008 EPA ESI sampling event, creosote was observed in Batchelor Creek 

adjacent to and downstream from Source Nos. 1 and 2 (Ref. 5, p. 1; 5, Appendix A, Figure 4, p. A-4; 5, 

Appendix C, Logbook 2, pp. 3, 4; 5, Appendix D, pp. D-8, D-9, D-13). MDEQ personnel have observed 

creosote emanating from the SWP property into Batchelor Creek, as well as along the 15-mile surface 

water TDL as far as the Big Black River, approximately 12.5 miles downstream of the SWP property 

(Ref. 7, pp. i, 2). 

From August 2009 to November 2010, EPA conducted a time-critical removal action at the SWP property 

under CERCLA (Refs. 44, p. 1; 75, p. 1). Because of the extensive creosote contamination in Batchelor 

Creek, EPA excavated between 1,500 and 1,800 linear feet of Batchelor Creek adjacent to the SWP 

property at depths ranging from 5 to 15 feet below the creek bed (Refs. 44, p. 1; 62; 70; 78) (see Figure 2 

of this HRS documentation record). During excavation, free-phase creosote was observed in the creek 

bed and emanating from the creek bank adjacent to the SWP property (Refs. 7, p. 2; 44, p. 6). Coal tar 

creosote, or creosote, consists of aromatic hydrocarbons, anthracene, naphthalene, and phenanthrene 

derivatives. At least 75% of the creosote mixture is comprised of PAHs (Ref. 66, pp. 220, 223). 

 
51 SW-Observed Release 

4.1.2.1.1 OBSERVED RELEASE – Chemical Analysis 

EPA September 2008 Expanded Site Inspection 

Background Samples 

During the EPA September 2008 ESI, a background sediment sample (SWP-SD-01) was collected from 

Batchelor Creek upstream of SWP sources to attribute potential contaminants detected in samples 

downstream of runoff from the property. Background sediment samples were also collected from 

tributaries of Batchelor Creek to evaluate whether other possible off-site sources are affecting Batchelor 

Creek (Ref. 5, Appendix A, Figure 4, p. A-4). Results for background sediment samples SWP-SD-01 

(Batchelor Creek), SWP-SD-12 (Tributary 1), SWP-SD-14 (Tributary 3), SWP-SD-14-DUP (Tributary 

3), and SWP-SD-15 (Tributary 4) were compared with sediment samples collected from Batchelor Creek 

adjacent to and downstream from Source Nos. 1 and 2. Specifically, results for background sediment 

samples SWP-SD-01, SWP-SD-12, SWP-SD-14, and SWP-SD-14-DUP were compared with sediment 

samples collected from Batchelor Creek adjacent to and downstream from Source Nos. 1 and 2, but 

upstream of Tributary 4. Sediment samples collected from Batchelor Creek downstream of Tributary 4 

were also compared with the background Tributary 4 sample SWP-SD-15 (Ref. 54). 

The background sediment samples (except SWP-SD-15) were found to contain varying levels of SVOCs. 

In particular, the two sediment samples (SWP-SD-14 and SWP-SD-14-DUP) that were collected from 

unnamed Tributary 3, north of the SWP property, contained levels of SVOCs up to 1,500 μg/kg (Ref. 5, 

Appendix A, Figure 4, p. A-4; 5, Appendix B, Table 5, pp. B-7, B-8). Tributary 3 sediment samples were 

collected about 100 feet upstream of its confluence with Batchelor Creek and within the historical 

boundary of the original owner of the SWP property, King Lumber (Ref. 5, Appendix A, Figure 3, p. A-3, 

Figure 4, p. A-4). Therefore, the contaminant concentrations in these background samples may be 

attributable to the wood treating operations. However, as shown in the following tables, when 

conservatively using Tributary 3 samples to establish background levels, levels of SVOCs in sediment 

samples collected downstream of the PPE for Source Nos. 1 and 2 nonetheless contained SVOCs at levels 

meeting observed release criteria. 

A background sediment sample was not collected from Batchelor Creek during the EPA February 2008 

RSE; therefore, downstream sediment samples collected from Batchelor Creek during the EPA February 

2008 RSE were compared with background sediment samples collected during the EPA September 2008 

ESI. Samples collected during both investigations were collected using similar sampling procedures, at 

similar depths, and from similar areas within the creek (Refs. 5, pp. 7, 8; 5, Appendix C, Logbook 2, p. 1; 

19, p. 3; 19, Appendix C, p. C-2; 26, pp. 1, 3; 36; 63). 

Background sediment samples were collected in accordance with the EPA Region 4 SESD Field Branch 

Quality System and Technical Procedures for Sediment Sampling, SESDPROC-200-R1 (Ref. 36). 

Sediment samples were collected from depositional areas at depths ranging from 0 to 3 inches bgs along 

the banks of Batchelor Creek and the unnamed tributaries. The locations of the background sediment 

samples are depicted in Reference 5, Appendix A, Figure 4, page A-4 and are listed in Reference 5, 

Appendix B, Table 5, pages B-7 and B-8. Chain-of-custody records are provided in Reference 20. 

Logbook notes are provided in Reference 5, Appendix C. 

TABLE 8: Background Sediment Samples – September 2008 

Station ID Sample ID Sample Location

Depth 

(inches bgs)

Date 

Sampled References

Batchelor Creek 

SWPBC01 SWP-SD-01 

1,404 feet upstream of 

eastern-most point of 

PPE 1 

0 to 3 09/23/2008

5, Appendix A, Figure 4, p. 

A-4; 5, Appendix B, p. B7; 5, Appendix C, Logbook 
52 SW-Observed Release 

TABLE 8: Background Sediment Samples – September 2008 

Station ID Sample ID Sample Location

Depth 

(inches bgs)

Date 

Sampled References

2, p. 5; 20, p. 4; 54; 77 

Tributary 1 

SWPT01 SWP-SD-12 

274 feet upstream of 

confluence with 

Batchelor Creek 

0 to 3 09/24/2008

5, Appendix A, Figure 4, p. 

A-4; 5, Appendix B, p. B7; 5, Appendix C, Logbook 

2, p. 6; 20, p. 7; 54; 77 

Tributary 3 

SWP-SD-14 

SWPT03 SWP-SD-14-

DUP 

140 feet upstream of 

confluence with 

Batchelor Creek 

0 to 3 09/23/2008

5, Appendix A, Figure 4, p. 

A-4; 5, Appendix B, p. B8; 5, Appendix C, Logbook 

2, p. 4; 20, p. 4; 54; 77 

Tributary 4 

SWPT04 SWP-SD-15 

83 feet upstream of 

confluence with 

Batchelor Creek 

0 to 3 09/23/2008

5, Appendix A, Figure 4, p. 

A-4; 5, Appendix B, p. B8; 5, Appendix C, Logbook 

2, p. 3; 20, p. 2; 54; 77 

Notes: 

BC Batchelor Creek 

bgs Below ground surface 

DUP Duplicate 

ID Identification number 

SD Sediment sample 

SWP Southeastern Wood Preserving 

T Tributary 
53 SW-Observed Release 

Background Concentrations 

The sediment samples listed in Table 9 were collected during the EPA September 2008 ESI (Refs. 5, 

Appendix C, Logbook 2, pp. 3, 5, 6; 20, pp. 2, 4, 7). All sediment samples were analyzed under the EPA 

CLP for SVOCs in accordance with the EPA CLP SOW SOM01.2 (Refs. 5, p. 8; 5, Appendix E, pp. E-1, 

E-2; 21, Appendix B, Table 7, p. B-10; 21, Appendix C, p. C-12; 55). EPA Region 4 SESD reviewed all 

data according to the contract SOW and EPA guidelines (Ref. 5, Appendix E, p. E-2; 42). The MRLs are 

listed on the analytical data sheets in Reference 5, Appendix E. Each MRL is sample-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 MRLs are equivalent 

to SQLs (Ref. 23). The analytical data sheets are provided in Reference 5, Appendix E. 

TABLE 9: Analytical Results for Background Sediment Samples – September 2008 

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

Batchelor Creek 

SWP-SD-01 Anthracene 6.3 μg/kg 4.6 μg/kg 5, Appendix C, Logbook 2, p. 5; 5, 

Appendix E, p. E-121; 20, p. 4 

SWP-SD-01 Benzo(a)anthracene 40 μg/kg 23 μg/kg 5, Appendix C, Logbook 2, p. 5; 5, 

Appendix E, p. E-121; 20, p. 4 

SWP-SD-01 Chrysene 60 μg/kg 23 μg/kg 5, Appendix C, Logbook 2, p. 5; 5, 

Appendix E, p. E-121; 20, p. 4 

SWP-SD-01 Dibenzofuran 240U μg/kg 240 μg/kg 5, Appendix C, Logbook 2, p. 5; 5, 

Appendix E, p. E-121; 20, p. 4 

SWP-SD-01 Naphthalene 2.6J (26) μg/kg 4.6 μg/kg 

5, Appendix C, Logbook 2, p. 5; 5, 

Appendix E, p. E-122; 20, p. 4; 39, 

pp. 8, 15; 41, pp. i, 3 

SWP-SD-01 Phenanthrene 19 μg/kg 4.6 μg/kg 5, Appendix C, Logbook 2, p. 5; 5, 

Appendix E, p. E-122; 20, p. 4 

SWP-SD-01 Pyrene 150 μg/kg 23 μg/kg 5, Appendix C, Logbook 2, p. 5; 5, 

Appendix E, p. E-122; 20, p. 4 

Tributary 1 

SWP-SD-12 Anthracene 130U μg/kg 130 μg/kg 5, Appendix C, Logbook 2, p. 6; 5, 

Appendix E, p. E-229; 20, p. 7 

SWP-SD-12 Benzo(a)anthracene 130U μg/kg 130 μg/kg 5, Appendix C, Logbook 2, p. 6; 5, 

Appendix E, p. E-229; 20, p. 7 

SWP-SD-12 Chrysene 70J (700) μg/kg 130 μg/kg 

5, Appendix C, Logbook 2, p. 6; 5, 

Appendix E, p. E-229; 20, p. 7; 39, 

pp. 8, 14; 41, pp. i, 3 

SWP-SD-12 Dibenzofuran 3,300U μg/kg 3,300 μg/kg 5, Appendix C, Logbook 2, p. 6; 5, 

Appendix E, p. E-229; 20, p. 7 

SWP-SD-12 Naphthalene 150 μg/kg 130 μg/kg 5, Appendix C, Logbook 2, p. 6; 5, 

Appendix E, p. E-230; 20, p. 7 

SWP-SD-12 Phenanthrene 150 μg/kg 130 μg/kg 5, Appendix C, Logbook 2, p. 6; 5, 

Appendix E, p. E-230; 20, p. 7 
54 SW-Observed Release 

TABLE 9: Analytical Results for Background Sediment Samples – September 2008 

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL References

SWP-SD-12 Pyrene 110J (1,304.6) 

μg/kg 130 μg/kg 

5, Appendix C, Logbook 2, p. 6; 5, 

Appendix E, p. E-230; 20, p. 7; 39, 

pp. 8, 15; 41, pp. i, 3 

Tributary 3 

SWP-SD-14 Anthracene 99U μg/kg 99 μg/kg 5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-235; 20, p. 4 

SWP-SD-14 Benzo(a)anthracene 460 μg/kg 99 μg/kg 5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-235; 20, p. 4 

SWP-SD-14 Chrysene 430 μg/kg 99 μg/kg 5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-235; 20, p. 4 

SWP-SD-14 Dibenzofuran 2,500U μg/kg 2,500 μg/kg 5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-235; 20, p. 4 

SWP-SD-14 Naphthalene 57J (570) μg/kg 99 μg/kg 

5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-236; 20, p. 4; 39, 

pp. 8, 15; 41, pp. i, 3 

SWP-SD-14 Phenanthrene 99U μg/kg 99 μg/kg 5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-236; 20, p. 4 

SWP-SD-14 Pyrene 490 μg/kg 99 μg/kg 5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-236; 20, p. 4 

SWP-SD-14-

DUP Anthracene 190 μg/kg 130 μg/kg 5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-238; 20, p. 4 

SWP-SD-14-

DUP Benzo(a)anthracene 1,500 μg/kg 260 μg/kg 5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-238; 20, p. 4 

SWP-SD-14-

DUP Chrysene 1,500 μg/kg 260 μg/kg 5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-238; 20, p. 4 

SWP-SD-14-

DUP Dibenzofuran 3,300U μg/kg 3,300 μg/kg 5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-238; 20, p. 4 

SWP-SD-14-

DUP Naphthalene 88J (880) μg/kg 130 μg/kg 

5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-239; 20, p. 4; 39, 

pp. 8, 15; 41, pp. i, 3 

SWP-SD-14-

DUP Phenanthrene 120J (1,200) μg/kg 130 μg/kg 

5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-239; 20, p. 4; 39, 

pp. 8, 15; 41, pp. i, 4 

SWP-SD-14-

DUP Pyrene 690 μg/kg 130 μg/kg 5, Appendix C, Logbook 2, p. 4; 5, 

Appendix E, p. E-239; 20, p. 4 

Tributary 4 

SWP-SD-15 Anthracene 130U μg/kg 130 μg/kg 5, Appendix C, Logbook 2, p. 3; 5, 

Appendix E, p. E-244; 20, p. 2 

SWP-SD-15 Naphthalene 130U μg/kg 130 μg/kg 5, Appendix C, Logbook 2, p. 3; 5, 

Appendix E, p. E-245; 20, p. 2 
55 SW-Observed Release 

Notes: 

( ) Concentrations shown in parentheses were adjusted in accordance with References 39, 40, and 41. 

DUP Duplicate 

ID Identification number 

J The identification of the analyte is acceptable; the reported value is an estimate. 

μg/kg Microgram per kilogram 

MRL Minimum reporting limit 

SD Sediment sample 

SWP Southeastern Wood Preserving 

U The analyte was not detected at or above the minimum reporting limit.
56 SW-Observed Release 

Contaminated Samples 

Sediment samples listed in Table 10 were collected along Batchelor Creek during the EPA February 2008 

RSE and the EPA September 2008 ESI. Five sediment samples were collected along Batchelor Creek 

downstream of Source Nos. 1 and 2 (Refs. 5, Appendix A, Figure 4, p. A-4; 19, Appendix A, Figure 2, p. 

A-2). Sediment samples were collected from depositional areas at depths ranging from 0 to 6 inches bgs 

(Refs. 5, Appendix C, Logbook 2, pp. 2, 3, 4; 19, Appendix C, pp. 4, 5; 20, p. 2; 21, p. 8; 45, p. 332). The 

February 2008 samples were collected in accordance with the EPA SESD Environmental Investigations 

Standard Operating Procedures and Quality Assurance Manual, November 2001 (Ref. 19, p. 2; 63). The 

September 2008 samples were collected in accordance with the EPA Region 4 SESD Field Branch 

Quality System and Technical Procedures for Sediment Sampling, SESDPROC-200-R1 (Ref. 36). 

Logbook notes for the EPA February 2008 RSE are provided in Reference 19, Appendix C and logbook 

notes for the EPA September 2008 ESI are provided in Reference 5, Appendix C. The chain-of-custody 

record for samples collected during the EPA February 2008 RSE are provided in Reference 45 and the 

chain-of-custody records for samples collected during the EPA September 2008 ESI are provided in 

Reference 20. The locations of the downstream sediment samples are depicted in Reference 5, Appendix 

A, Figure 4, page A-4 and in Reference 19, Appendix A, Figure 2, page A-2. 

All of the observed release sediment samples presented below were collected downstream of the area 

addressed by the EPA removal action in Batchelor Creek (Refs. 5, Appendix A, Figure 4, p. A-4; 19, 

Appendix A, Figure 2, p. A-2; 67, pp. 1, 2, 3) (See also Figure 2 of this HRS documentation record). 

TABLE 10: Sediment Samples – February and September 2008 

Station 

ID Sample ID Sample Location

Distance from 

PPE 

Depth 

(in. bgs) 

Date 

Sampled References

February 2008 Sample 

NA SWP-SD-02 

Batchelor Creek, 

east of the 

intersection of 

Miller Street and 

Batchelor Creek 

741 feet 

downstream of 

western-most 

point of PPE 1 

0 to 6 02/28/2008 

19, Appendix A, 

Figure A-2; 19, 

Appendix B, 

Table 1, p. B-1; 

19, Appendix C, 

p. 5; 45, p. 332; 

54; 77 

September 2008 Samples 

SWPBC05 SWP-SD-05 

Batchelor Creek, 

at the confluence 

of the ditch 

located southwest 

of the historical 

SWP property 

boundary 

715 feet of 

western-most 

point of PPE 1 

0 to 6 09/23/2008 

5, Appendix A, 

Figure 4, p. A-4; 

5, Appendix B, 

Table 5, pp. B-7, 

B-8; 5, Appendix 

C, Logbook 2, p. 

3; 20, p. 2; 54; 77 

SWPBC06 SWP-SD-06 

Batchelor Creek, 

downstream of 

SWP property and 

east of U.S. 

Highway 51 

3,149 feet 

downstream of 

western-most 

point of PPE 1 

0 to 3 09/22/2008 

5, Appendix A, 

Figure 4, p. A-4; 

5, Appendix B, 

Table 5, pp. B-7, 

B-8; 5, Appendix 

C, Logbook 2, p. 

2; 20, p. 2; 54; 77 
57 SW-Observed Release 

TABLE 10: Sediment Samples – February and September 2008 

Station 

ID Sample ID Sample Location

Distance from 

PPE 

Depth 

(in. bgs) 

Date 

Sampled References

SWPBC11 SWP-SD-11 

Batchelor Creek, 

downstream of 

SWP property 

1.79 miles 

downstream of 

western-most 

point of PPE 1 

0 to 3 09/22/2008 

5, Appendix A, 

Figure 4, p. A-4; 

5, Appendix B, 

Table 5, pp. B-7, 

B-8; 5, Appendix 

C, Logbook 2, p. 

2; 20, p. 2; 54; 77 

Notes: 

BC Batchelor Creek 

bgs Below ground surface 

ID Identification 

in. Inches 

NA No Station ID assigned 

PPE Probable point of entry 

SD Sediment sample 

SWP Southeastern Wood Preserving 
58 SW-Observed Release 

Contaminated Concentrations

The sediment samples listed in Table 11 were collected during the EPA February 2008 RSE and the EPA 

September 2008 ESI sampling events (Refs. 5, Appendix C, Logbook 2, pp. 2, 3, 4; 19, Appendix C, pp. 

4, 5; 20, p. 2; 45, p. 332). 

Sediment samples collected during the EPA February 2008 RSE were analyzed by Pace Analytical 

Services, Inc., for SVOCs in accordance with SW-846 Method 8270C (Refs. 19, Appendix D, p. D-15; 

45, pp. 14, 15, 16, 19; 57). Tetra Tech reviewed all data according to the National Functional Guidelines 

for Superfund Organic Methods Data Review (Ref. 19, Appendix D, p. D-15). The data validation report 

is provided in Reference 19, Appendix D. The RLs are listed on the analytical data sheets in Reference 

45. Each RL is sample-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 (Ref. 49). The analytical data sheets are provided in 

Reference 45. 

Sediment samples collected during the EPA September 2008 ESI were analyzed under the EPA CLP for 

SVOCs in accordance with the CLP SOW SOM01.2 (Refs. 5, p. 8, Appendix E, pp. E-1, E-2; 21, 

Appendix B, Table 7, p. B-10; 21, Appendix C, p. C-12; 55). EPA Region 4 SESD reviewed all data 

according to the National Functional Guidelines for Superfund Organic Methods Data Review, as well as 

the contract SOW and EPA guidelines (Ref. 5, Appendix E, p. E-2; 42). The MRLs are listed on the 

analytical data sheets in Reference 5, Appendix E. Each MRL is sample-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 MRLs are equivalent to SQLs (Ref. 23). 

The analytical data sheets are provided in Reference 5, Appendix E. 

TABLE 11: Analytical Results for Sediment Samples – February and September 2008 

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL/RL* References

Samples Compared to Batchelor Creek, Tributary 1, and Tributary 3 Samples 

February 2008 Sediment Samples 

SWP-SD-02 Phenanthrene 14,100 μg/kg 2,520 μg/kg 19, Appendix C, p. 5; 45, pp. 19, 

332 

SWP-SD-02 Pyrene 6,350 μg/kg 2,520 μg/kg 19, Appendix C, p. 5; 45, pp. 19, 

332 

September 2008 Sediment Samples 

SWP-SD-05 Phenanthrene 10,000 μg/kg 3,100 μg/kg 5, Appendix C, Logbook 2, p. 3; 5, 

Appendix E, p. E-140; 20, p. 2 

SWP-SD-05 Pyrene 7,000 μg/kg 2,400 μg/kg 5, Appendix C, Logbook 2, p. 3; 5, 

Appendix E, p. E-140; 20, p. 2 

Samples Compared to Batchelor Creek, Tributary 1, Tributary 3, and Tributary 4 Samples

September 2008 Sediment Samples 

SWP-SD-06 Anthracene 1,100 μg/kg 220 μg/kg 5, Appendix C, Logbook 2, p. 2; 5, 

Appendix E, p. E-148; 20, p. 2 

SWP-SD-11 Anthracene 650 μg/kg 180 μg/kg 5, Appendix C, Logbook 2, p. 2; 5, 

Appendix E, p. E-169; 20, p. 2 
59 SW-Observed Release 

TABLE 11: Analytical Results for Sediment Samples – February and September 2008 

Sample ID

Hazardous 

Substance

Hazardous 

Substance 

Concentration MRL/RL* References

SWP-SD-11 Naphthalene 6,300 μg/kg 4,600 μg/kg 5, Appendix C, Logbook 2, p. 2; 5, 

Appendix E, p. E-170; 20, p. 2 

Notes: 

* The February 2008 RLs are equivalent to sample quantitation limits (Ref. 49). 

ID Identification number 

μg/kg Microgram per kilogram 

MRL Minimum reporting limit 

SD Sediment sample 

RL Reporting limit 

SWP Southeastern Wood Preserving
60 SW-Observed Release 

Additional Supporting Data

During the EPA February 2008 RSE, two sediment samples (SWP-SD-01 and SWP-SD-02) were 

collected from Batchelor Creek 0 feet and 700 feet downstream from PPE 1, respectively. These samples 

were analyzed for dioxins and furans in addition to SVOCs (Ref. 19, p. 2; 19, Appendix A, Figure 2, p. 

A-2; 19, Appendix B, Table 4, pp. B-4, B-5). Dioxins and furans detected in these samples could not be 

evaluated as observed releases because the background sediment sample was not analyzed for dioxins and 

furans. Sediment sample SWP-SD-01 contained 1,2,3,4,6,7,8-HpCDD (650 ng/kg); 1,2,3,4,6,7,8-HpCDF 

(380 ng/kg); and 1,2,3,6,7,8-HxCDD (25 ng/kg). Sediment sample SWP-SD-02 contained 1,2,3,4,6,7,8-

HpCDD (350 ng/kg); 1,2,3,4,6,7,8-HpCDF (200 ng/kg); and 1,2,3,6,7,8-HxCDD (11 ng/kg) (Ref. 46, pp. 

41, 42). 

During the EPA September 2008 ESI, one sediment sample (SWP-SD-08) was collected from Batchelor 

Creek, about 3,700 feet downstream from PPE 1, at a depth of 12 to 14 inches bgs (Refs. 5, Appendix A, 

Figure 4, p. A-4; 5, Appendix B, Table 5, pp. B-7, B-8; 5, Appendix C, Logbook 2, p. 2; 54). A 

background sample at a similar depth was not collected (Ref. 5, Appendix B, Table 5, pp. B-7, B-8). This 

sample was collected from a depositional area immediately west of the Union Street bridge over 

Batchelor Creek within Saab Park (Ref. 5, Appendix A, Figure 4, p. A-4). The following hazardous 

substances were detected in sediment sample SWP-SD-08: anthracene (1,100 μg/kg), benzo(a)pyrene 

(3,700 μg/kg), benzo(k)fluoranthene (3,800 μg/kg), and pyrene (3,300 μg/kg) (Ref. 5, Appendix B, Table 

23, pp. B-48, B-49, B-50). 

The current SWP property was originally part of a larger property owned by King Lumber, which 

operated the facility as a saw mill, lumber yard, and wood treating operation from 1928 to 1964 (Refs. 7; 

8, pp. 1, 5; 69). King Lumber also owned the railroad that runs along the northern bank of Batchelor 

Creek, north of the SWP property where Tributary 3 background sediment samples SWP-SD-14 and 

SWP-SD-14-DUP were collected (Refs. 5, Appendix A, Figure 4, p. A-4; 69). SVOCs were also detected 

in sediment samples SWP-SD-07, SWP-SD-09, and SWP-SD-10, downstream of Tributary 3 and the 

PPE. Sediment samples SWP-SD-07, SWP-SD-09, and SWP-SD-10 contained anthracene ranging from 

200 μg/kg to 440 μg/kg, benzo(a)anthracene ranging from 530 μg/kg to 1,500 μg/kg, benzo(a)pyrene 

ranging from 370 μg/kg to 810 μg/kg, benzo(k)fluoranthene ranging from 340 μg/kg to 820 μg/kg, 

chrysene ranging from 740 μg/kg to 2,000 μg/kg, indeno(1,2,3-cd)pyrene ranging from 290 μg/kg to 530 

μg/kg, phenanthrene ranging from 160 μg/kg to 540 μg/kg, and pyrene ranging from 610 μg/kg to 1,400 

μg/kg (Ref. 5, Appendix A, Figure 4, p. A-4; 5, Appendix B, Table 5, pp. B-7, B-8; 5, Appendix E, pp. E154, E-155, E-163, E-164, E-166, E-167). 

From August 2009 to November 2010, EPA conducted a time-critical removal action at the SWP property 

under CERCLA (Refs. 44, p. 1; 75, p. 1). Because of the extensive creosote contamination in Batchelor 

Creek, EPA excavated between 1,500 and 1,800 linear feet of Batchelor Creek adjacent to the SWP 

property (Refs. 44, p. 1; 62; 70; 78) (see Figure 2 of this HRS documentation record). One sediment 

sample was collected from this location prior to the removal during the February 2008 RSE, and one 

sediment sample was collected from this area, also prior to the removal, during the September 2008 ESI. 

Table 12 summarizes the hazardous substances detected in these samples. 
61 SW-Observed Release 

TABLE 12: Summary of Samples Collected from the Batchelor Creek Removal Area 

Station ID Sample ID Sample Location Hazardous Substances References 

February 2008 Sample 

NA SWP-SD-01 

Batchelor Creek, 150 

feet north west of the 

northwestern corner 

of Source No. 1 

Dibenzofuran, naphthalene, 

phenanthrene, pyrene 

19, Appendix C, p. 

4; 45, pp. 14, 15, 16, 

332; 54 

September 2008 Sample 

SWPBC04 SWP-SD-04 

Batchelor Creek, west 

of the stockpile, 

within boundary of 

PPE 1 

Anthracene, benzo(a) 

anthracene, chrysene, 

dibenzofuran, naphthalene, 

phenanthrene, pyrene 

5, Appendix A, p. A4; 5, Appendix B, 

pp. B-7, B-8; 5, 

Appendix E, p. E136; 20, p. 2; 54 

Notes: 

BC Batchelor Creek 

ID Identification 

NA Not applicable 

PPE Probable point of entry 

SD Sediment 

SWP Southeastern Wood Preserving 
62 SW-Observed Release 

Attribution

The current SWP property was originally part of a larger property owned by King Lumber, which 

operated the facility as a saw mill, lumber yard, and wood treating operation beginning in 1928 (Refs. 7, 

p. i; 8, p. 1). During former operations, southern yellow pine timbers were stripped of bark and placed in 

retort cylinders for drying. Wood preservatives, creosote or PCP, were pumped into the cylinders (Refs. 

10, p. 2; 11, p. 1; 12, p. 1). Coal tar creosote, or creosote, consists of aromatic hydrocarbons, anthracene, 

naphthalene, and phenanthrene derivatives. At least 75% of the creosote mixture is comprised of PAHs 

(Ref. 66, pp. 220, 223). The cylinders were pressurized to force the liquid into the wood until it was 

saturated. The wood was then removed to drip dry, and the residual liquid was drained (Refs. 10, p. 2; 11, 

p. 1). King Lumber also constructed a mill pond on the northern bank of Batchelor Creek to store lumber. 

This pond is now owned and operated by CMU as a wastewater treatment pond (Ref. 69). 

During the 1970s, the facility received several notices of violation and fines from the Mississippi Office 

of Pollution Control for gross contamination of the process area; releases of hazardous substances to 

Batchelor Creek; and inadequate treatment of process wastewater before being discharged into the city 

sewage treatment facility (Ref. 10, pp. 1, 2). Before 1977, the facility reportedly discharged 

approximately 50,000 gallons of wastewater per day directly into Batchelor Creek, which flows through a 

city park, a residential area, and downtown Canton before it enters Bear Creek (Refs. 11, p. 1; 15, p. 1). 

The State of Mississippi received complaints of children suffering from creosote burns who had been 

playing in Batchelor Creek near the city park (Ref. 14, p. 4). When operations ceased in 1979, the 

property contained large areas of contamination in the treatment and storage areas, piles of contaminated 

soil, creosote sludge storage tanks, and three unlined wastewater surface impoundments that reportedly 

had been filled by a previous owner at an unspecified time (Ref. 9, p. 1). 

In 1986, EPA initiated an emergency response action at the SWP property to stabilize the three unlined 

surface impoundments that contained creosote sludge and water. The impoundments were excavated, and 

the contaminated sludge was stabilized with lime kiln dust (Ref. 14, p. 2). Lime kiln dust, or cement kiln 

dust, can contain various metals and dioxins and furans (Ref. 65, pp. 12, 13). According to a risk 

assessment study conducted by the Research Triangle Institute on behalf of EPA, the concentrations of 

dioxins and furans detected in the sampled cement kiln dust are generally well below the concentrations 

of dioxins and furans scored in this HRS documentation record, some being orders of magnitude below 

(Refs. 5, Appendix B, Table 14, pp. B-29, B-30, B-31; 19, Table 4, pp. B-4, B-5; 65, pp. 1, 11, 12, 13; see 

also Tables 2 and 5 of this HRS documentation record). Bottom sediment sludge from the impoundments 

contained total PAHs at a concentration of 3,815 mg/kg and was, therefore, classified as a RCRA K001-

listed hazardous waste (Ref. 51, pp. i, 2). Approximately 8,000 cubic yards, or 12,000 tons, of stabilized 

sludge were then stockpiled on the property to await treatment or disposal at a later date (Ref. 14, pp. 2, 3, 

5). Also in 1986, an EPA Emergency Response and Cleanup Services contractor dismantled the creosote 

sludge storage tanks (Ref. 9, p. 4). It is not known where these tanks were located on the property or how 

they were disposed. However, they are no longer present on the property (Ref. 68). In 1988, SCS 

designed a soil erosion prevention plan that included excavating and widening Batchelor Creek. While 

surveying the creek, SCS personnel observed oily waste leaching into the creek from the SWP property. 

In response, EPA removed contaminated soil from the creek bank observed to be leaching contaminants 

into Batchelor Creek to facilitate the SCS stream widening project (Ref. 14, p. 3). EPA also installed a 

geofabric liner in the bed of the creek, and the banks were lined with rip-rap to prevent erosion (Ref. 9, p. 

4).

From 1991 to 1994, EPA treated the stockpiled material from the surface impoundments using 

biotreatment (Ref. 16, pp. 1, 2). A treatability variance was approved after several failed attempts to 

reach land disposal restriction standards for wood preserving waste (K001), specifically with respect to 

phenanthrene and pyrene, which both have a K001 cleanup standard of 1.5 mg/kg (Refs. 16, pp. 1, 2; 43, 

pp. 3, 4, 7). The cleanup standards were modified to be based on total PAH concentrations instead of 

individual PAH analyte K001 treatment standards (Ref. 51, p. 7). Samples collected from Source Nos. 1 

and 2 during the EPA September 2008 ESI contained elevated concentrations of SVOCs, including 

anthracene, benzo(a)anthracene, chrysene, dibenzofuran, naphthalene, phenanthrene and pyrene. 
63 SW-Observed Release 

Analytical results of samples collected from Batchelor Creek, which receives runoff from Source Nos. 1 

and 2, also contained elevated concentrations of SVOCs, including anthracene, naphthalene, 

phenanthrene and pyrene (Refs. 5, Appendix E; 69) (see Sections 2.0 and 3.0 of this HRS documentation 

record). Anthracene was detected at concentrations as high as 4,830 μg/kg (SWP-WS-03) in Source No. 

1 and 970,000 μg/kg (SWP-SB-09C) in Source No. 2. Benzo(a)anthracene was detected at concentrations 

as high as 459 μg/kg (SWP-WS-02) in Source No. 1 and 66,000 μg/kg (SWP- SB-10B) in Source No. 2. 

Chrysene was detected at concentrations as high as 3,760 μg/kg (SWP-WS-03) in Source No. 1 and 

100,000 μg/kg (SWP-SB-10B) in Source No. 2. Dibenzofuran was detected at concentrations as high as 

1,600,000J μg/kg (SWP-SB-09C) in Source No. 2. Naphthalene was detected as high as 883 μg/kg 

(SWP-WS-02) in Source No. 1. Phenanthrene was detected at concentrations as high as 1,110 μg/kg 

(SWP-WS-02D) in Source No. 1 and at concentrations as high as 5,600,000 μg/kg (SWP-SB-09C) in 

Source No. 2. Pyrene was detected at concentrations as high as 3,090 μg/kg (SWP-WS-03) in Source No. 

1 and at concentrations as high as 1,800,000 μg/kg (SWP-SB-09C) in Source No. 2 (Refs. 5, Appendix E, 

p. E-62; 45, p. 13) (see Tables 2 and 5 of this HRS documentation record). The highest concentrations of 

phenanthrene and pyrene were detected in sample SWP-SB-09C, located at the northwestern corner of the 

stockpile (Source No. 1) at a depth of 8 to 12 feet bgs (Refs. 5, Appendix A, Figure 4, p. A-4; 5, 

Appendix E, p. E-62; 18, p. 4; 47, Enclosure 2, pp. E-27, E-28) (see Figure 3 of this HRS documentation 

record). Phenanthrene and pyrene were also detected at elevated concentrations (1,500,000 μg/kg 

phenanthrene and 400,000 μg/kg pyrene) in the deepest sample (SWP-SB-11E) collected from Source 

No. 2 (16 to 20 feet bgs) (Ref. 5, Appendix E, p. E-77) (see Table 5 of this HRS documentation record). 

In addition, sediment samples collected from Batchelor Creek contained concentrations of anthracene (up 

to 1,100 μg/kg), benzo(a)anthracene (8,000 μg/kg), chrysene (7,400 μg/kg), dibenzofuran (16,000 μg/kg), 

naphthalene (6,300 μg/kg), phenanthrene (up to 79,000 μg/kg) and pyrene (up to 36,000 μg/kg) (Ref. 5, 

Appendix E, p. E-137) (see Table 11 of this HRS documentation record). 

In 2007, EPA SESD personnel advanced soil borings along the northern border of the property, between 

the stockpile, former lagoons, and Batchelor Creek, to evaluate whether pathways for free-phase creosote 

to enter Batchelor Creek exist and, if so, where they enter the creek (Ref. 18, pp. 4, 5). Visible and 

odorous impacts (believed to be organic contamination) to the soil were observed in several of the borings 

adjacent to and west of the stockpile. In addition, free-phase creosote was observed in at least one boring 

located adjacent to the stockpile (Ref. 18, pp. 6, 12). SESD concluded that the presence of free-phase 

creosote in the subsurface soil at the SWP facility indicated a potential for creosote to flow into Batchelor 

Creek (Ref. 18, p. 7). 

EPA advanced boreholes in September 2008 throughout the SWP property and within the stockpile at 

depths ranging from 0 and 36 feet bgs. Borings advanced between the stockpile and Batchelor Creek, as 

well as west of the stockpile along Batchelor Creek, contained free product weeps. Free product was 

noted in 14 of the 29 boreholes (Ref. 47, p. 1, Enclosure 1, p. E1-1, Enclosure 2, pp. E2-1 through E2-29). 

Boring P3 contained free product weeps as deep as 33 to 36 feet bgs (Ref. 47, Enclosure 2, p. E2-20). 

During the EPA RSE conducted in February 2008, creosote was observed in Batchelor Creek downstream 

from Source Nos. 1 and 2 (Ref. 19, p. 2; 19, Appendix C, p. 5). In September 2008, an ESI was 

conducted at the SWP property (Ref. 5, pp. 1, 7). During the ESI sampling event, creosote was observed 

in Batchelor Creek adjacent to and downstream from Source Nos. 1 and 2 (Ref. 5, Appendix D, pp. D-8, 

D-9). MDEQ personnel have observed creosote emanating from the SWP property into Batchelor Creek, 

as well as along the 15-mile surface water migration pathway TDL as far as the Big Black River, 

approximately 12.5 miles downstream of the SWP property (Ref. 7, pp. i, 2). 

From August 2009 to November 2010, EPA conducted a time-critical removal action at the SWP property 

under CERCLA (Refs. 44, p. 1; 75, p. 1). Because of the creosote contamination in Batchelor Creek, 

EPA excavated between 1,500 and 1,800 linear feet of Batchelor Creek adjacent to the SWP property at 

depths ranging from 5 to 15 feet below the creek bed and stockpiled the creosote-contaminated sediment 

(approximately 45,000 to 50,000 tons) on the western portion of the property (Refs. 44, p. 1; 62; 70; 78) 

(see Figure 2 of this HRS documentation record). During excavation, free-phase creosote was observed 

in the creek bed and emanating from the creek bank adjacent to the SWP property (Refs. 7, p. 2; 44, p. 6; 
64 SW-Observed Release 

62). On March 11, 2010, EPA collected six sediment samples (including 1 duplicate) from the creosotecontaminated sediment stockpile. SVOCs detected in these samples included anthracene (up to 5,600 

μg/kg), benzo(a)anthracene (up to 3,200J μg/kg), benzo(a)pyrene (up to 1,200 μg/kg), 

benzo(k)fluoranthene (up to 1,200 μg/kg), chrysene (up to 2,800J μg/kg), dibenzo(a,h)anthracene (up to 

170J μg/kg), dibenzofuran (up to 14,000J μg/kg), fluoranthene (up to 22,000 μg/kg), indeno(1,2,3-

cd)pyrene (up to 440 μg/kg), naphthalene (up to 45,000 μg/kg), phenanthrene (up to 47,000 μg/kg), and 

pyrene (up to 12,000 μg/kg) (Refs. 74, pp. 15 through 31; 75, Appendix B, p. B-4). In addition to 

SVOCs, EPA analyzed the creosote-contaminated sediment stockpile samples for TCLP SVOCs and 

metals. No contaminants were detected at concentrations exceeding TCLP criteria; therefore, EPA 

classified the creosote-contaminated sediment stockpile as Non-RCRA hazardous waste and removed the 

pile to an off-site Class B waste management facility in Lake, MS (Refs. 44, pp. 34, 35; 70; 75, p. 6, 

Appendix B, p. B-6). The removal of the entire creosote-contaminated sediment stockpile was completed 

on September 24, 2010 (Ref. 75, p. 6). EPA also constructed a slurry wall measuring 1,500 feet long, 

three feet wide, and 30 feet below land surface between the SWP property and the southern bank of 

Batchelor Creek to prevent further migration of hazardous substances from the SWP property to 

Batchelor Creek (Refs. 70; 73, p. 6; 75, pp. 4, 5) (see Figure 2 of this HRS documentation record). 

Emplacement of the slurry wall did not, however, include the construction of any run-on control or runoff 

management features (Refs. 62; 75, p. 3) 

Surface water flow at the SWP property is generally directed toward Batchelor Creek (Ref. 62). Prior to 

emplacement of the slurry wall, there were no containment measures in place to prevent hazardous 

substance migration from Source Nos. 1 and 2 from reaching Batchelor Creek, and free-phase creosote 

was observed in Batchelor Creek during the September 2008 EPA ESI (Refs. 25; 5, Appendix D, p. D-8). 

Analytical results for source samples collected from Source Nos. 1 and 2 in February and September 2008 

contained site-related hazardous substances, including anthracene, benzo(a)anthracene, benzo(a)pyrene, 

benzo(k)fluoranthene, chrysene, dibenzo(a,h)anthracene, dibenzofuran, indeno(1,2,3-cd)pyrene, 

naphthalene, pentachlorophenol, phenanthrene, pyrene, and dioxins and furans (see Tables 2 and 5 in 

Section 2.2.2 for Source Nos. 1 and 2 of this HRS documentation record). In addition, anthracene, 

naphthalene, phenanthrene, and pyrene have been documented as observed releases in sediment samples 

collected from Batchelor Creek (see Table 11 in Section 4.1.2.1.1, Observed Release, of this HRS 

documentation record). All of the observed release sediment samples were collected downstream of the 

area addressed by the EPA removal action in Batchelor Creek (Refs. 5, Appendix A, Figure 4, p. A-4; 19, 

Appendix A, Figure 2, p. A-2; 67, pp. 1, 2, 3) (See also Figure 2 of this HRS documentation record). 

Other regulated facilities in the area include Canton Plating & Bumper Works, Inc. (CPBW) (EPA ID No. 

MSD008473282), Greif Industrial Packaging and Services, LLC (GIPS) (EPA ID No. MSD082008921), 

and Van Leer Containers (VLC) (EPA ID No. MSD082008921). All three facilities are located within 

0.25 mile of the SWP property (Ref. 30, p. 9). A removal action was completed at the CPBW property in 

December 1984 (Ref. 71, p. 2). CPBW received a NFRAP (No Further Remedial Action Planned) 

designation in November 1990 and was archived in CERCLIS in July 2004 (Refs. 30, pp. 9, 14, 15; 71, p. 

2). CPBW is located south-southwest of the SWP property and based on its location and intervening 

features, is not expected to contribute runoff to Batchelor Creek (Ref. 30, p. 9). GIPS is classified as a 

metal barrels, drums, kegs, and pails shipping facility in the EPA Facility Registry System (Ref. 76, p. 2). 

GIPS is also listed in RCRA as inactive and is classified as a RCRA large quantity generator of volatile 

organic compound (VOC) hazardous waste, including benzene, methyl ethyl ketone, tetrachloroethylene, 

trichloroethylene, toluene, and xylenes (Refs. 30, pp. 19, 21; 76, p. 1). GIPS received several notices of 

violation from the State in 1993 and 2001. In January 1996, a preliminary assessment was completed for 

the GIPS site at which point GIPS received a NFRAP designation. GIPS was archived in CERCLIS in 

December 1996 (Ref. 30, pp. 23 through 31). GIPS is located northwest of the SWP property and may 

potentially contribute runoff to Batchelor Creek. VOCs are not scored in this HRS documentation record 

as hazardous substances associated with Source Nos. 1 and 2 (see Section 2.2.2. for Source Nos. 1 and 2) 

or the observed release to Batchelor Creek (see Section 4.1.2.1.1 for Observed Release by Chemical 

Analysis) (Refs. 30, p. 18; 76, p. 1). VLC is classified as a metal barrels, drums, kegs, and pails shipping 

facility in the EPA Facility Registry System and is owned by Greif, Inc., the parent company of GIPS 

(Refs. 30, p. 20; 72, p. 1; 76, pp. 1, 6). VLC received SNFA (State No Further Action) status in February 
65 SW-Observed Release 

1999. The major contaminant detected at the VLC property was arsenic (Ref. 30, p. 15). VLC is located 

northwest of the SWP property and may potentially contribute runoff to Batchelor Creek. Arsenic is not 

scored in this HRS documentation record as a hazardous substance associated with Source Nos. 1 and 2 

(see Section 2.2.2 for Source Nos. 1 and 2) or the observed release to Batchelor Creek (see Section 

4.1.2.1.1 for Observed Release by Chemical Analysis) (Ref. 30, p. 9). No other wood preserving facilities 

have been identified within a 4-mile radius of the SWP property (Ref. 30, pp. 5 through 9). 

Canton Municipal Utilities operates a waste water treatment plant (WWTP) just south of SWP on North 

Hargon Street. Effluent from the WWTP flows through a pipe leading from the WWTP, underneath 

Covington Drive and the SWP property, and discharges into Batchelor Creek, just upstream from Source 

No. 1. A surface water sample collected from this effluent contained 2-Methylnaphthalene and 

benzo(a)pyrene at concentrations above the surface water background (Refs. 5, p. 17; 5, Appendix A, p. 

A-4, Appendix B, p. B-36). Neither of these substances was included in the observed release to Batchelor 

Creek documented by sediment samples. 

Another possible source of contamination to Batchelor Creek is King Lumber. The current SWP property 

was originally part of a larger property owned by King Lumber, which operated the facility as a saw mill, 

lumber yard, and wood treating operation from 1928 to 1964 (Refs. 7; 8, pp. 1, 5; 69). King Lumber also 

owned the railroad that runs along the northern bank of Batchelor Creek, north of the SWP property. In 

addition, King Lumber constructed a mill pond north of the SWP property to store its lumber. This pond 

is currently being operated by CMU as a wastewater treatment pond (Ref. 69). Sediment samples SWPSD-14 and SWP-SD-14-DUP collected from Tributary 3 downstream of the mill pond contained some 

SVOCs and were conservatively used as additional background sediment samples. However, sediment 

samples collected from Batchelor Creek downstream of Tributary 3 contained SWP source-related 

SVOCs at elevated concentrations (i.e., significantly above the background levels) (see Tables 9 and 11 of 

this HRS documentation record), indicating that these contaminants are at least partially attributable to 

SWP. Specific operations, waste management, and disposal procedures employed by King Lumber are 

not known. 

The hazardous substances listed below have been documented in Source Nos. 1 and 2 as well as in 

Batchelor Creek, indicating migration of hazardous substances from the SWP sources (see Tables 2 and 5 

in Section 2.2.2 for Source Nos. 1 and 2, and Table 11 in Section 4.1.2.1.1, Observed Release, of this 

HRS documentation record). 

 

Hazardous Substances in the Release

Anthracene 

Naphthalene 

Phenanthrene 

Pyrene 

Surface Water Observed Release Factor Value: 550
66 SW-Drinking Water Threat 

4.1.2 DRINKING WATER THREAT 

The drinking water threat was not scored because it is not expected to contribute significantly to the 

overall score. 
67 SW-Human Food Chain Threat 

4.1.3.2 HUMAN FOOD CHAIN THREAT WASTE CHARACTERISTICS 

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation 

The toxicity, persistence, and bioaccumulation factor values for the hazardous substances detected in the 

sources with containment factor values of greater than 0 are summarized in Table 13. The combined 

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

Section 4.1.3.2.1. 

TABLE 13: Toxicity/Persistence/Bioaccumulation

Hazardous 

Substance 

Source 

No. 

Observed 

Release? 

(Yes/No) 

Toxicity 

Factor 

Value 

Persistence 

Factor 

Value1

Bioaccumulation 

Value2

Toxicity/ 

Persistence/ 

Bioaccumulation 

Factor Value 

(Table 4-16) Reference 

Anthracene 1, 2 Yes 10 0.4000 50,000 2 E+5 2, p. BI-1 

Benzo(a)anthracene 1, 2 No 1,000 1 50,000 5 E+7 2, p. BI-2 

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

Benzo(k) 

fluoranthene 1, 2 No 100 1 50,000 5 E+6 2, p. BI-2 

Chrysene 1, 2 No 10 1 5.0 50 2, p. BI-3 

Dibenzo(a,h) 

anthracene 2 No 10,000 1 50,000 5 E+8 2, p. BI-4 

Dibenzofuran 2 No 1,000 1 500 5 E+5 2, p. BI-4 

Indeno(1,2,3-cd) 

pyrene 

2 No 1,000 1 50,000 5 E+7 2, p. BI-8 

Naphthalene 1, 2 Yes 1,000 0.4000 50,000 2 E+7 2, p. BI-9 

Pentachlorophenol 2 No 100 1 50,000 5 E+6 2, p. BI-9 

Phenanthrene 1, 2 Yes 0 0.4000 5,000 0 2, p. BI-9 

Pyrene 1, 2 Yes 100 1 50,000 5 E+6 2, p. BI-10 

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

HpCDD 1, 2 No 10,000 1 50,000 5 E+8 2, p. BI-6 

1,2,3,4,6,7,8-HpCDF 1, 2 No 10,000 1 50,000 5 E+8 2, p. BI-7 

1,2,3,4,7,8-HxCDF 1, 2 No 10,000 1 50,000 5 E+8 2, p. BI-7 

1,2,3,6,7,8-HxCDD 1, 2 No 10,000 1 5,000 5 E+7 2, p. BI-7 

Notes: 

1

 Persistence factor value for rivers 

2

 Bioaccumulation factor value for fresh water

HpCDD Heptachlorodibenzodioxin 

HpCDF Heptachlorodibenzofuran 

HxCDD Hexachlorodibenzodioxin 

HxCDF Hexachlorodibenzofuran

Toxicity/Persistence/Bioaccumulation Factor Value: 5 E+8 

(Ref. 1, Section 4.1.3.2.1.4)
68 SW-Human Food Chain Threat 

4.1.3.2.2 HAZARDOUS WASTE QUANTITY

TABLE 14: Hazardous Waste Quantity 

Source No. Source Type Source Hazardous Waste Quantity

1 Pile 6,119.2 

2 Contaminated Soil Undetermined, but greater than zero 

The hazardous constituent quantity for Source No. 1 (stockpile of partially treated waste material) is not 

adequately determined. 

It is not known whether contamination in Source No. 2 is continuous between sampling points (Ref. 5, 

Appendix B, Table 1, pp. B-1, B-2). Therefore, the area of Source No. 2 is undetermined, but greater 

than zero. 

The sum of the Source HWQ values for Source Nos. 1 and 2 is 6,119.2, rounded to 6,119. Based on 

Reference 1, Table 2-6, the HWQ factor value is 100. Also, because Level II actual contamination is 

present in a fishery (Batchelor Creek), and 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: 6,119.2 + >0 = 6,119 

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) 
69 SW-Human Food Chain Threat 

4.1.3.3 HUMAN FOOD CHAIN THREAT TARGETS 

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 Batchelor Creek (see Tables 10 and 11 of this HRS 

documentation record). Fishing for consumption occurs on Batchelor Creek north of its intersection with 

Frey’s Lane in Canton, Mississippi, in the vicinity of where sediment sample SWP-SD-11 was collected. 

Fish that are typically caught for consumption include brim, bass, and catfish. Bear Creek and the Big 

Black River are both fished regularly, and the fish are consumed (Refs. 4; 7, p. i; 37, pp. 1, 2). No fish 

advisories are currently in effect for Batchelor Creek, Bear Creek, and the Big Black River along the 15-

mile surface water migration pathway TDL (Ref. 38). 

Level I Concentrations

No Level I concentrations have been documented. 

Level II Concentrations

Level II concentrations have been documented in the Batchelor Creek fishery at sample location SWPSD-11 (see Table 11 of Section 4.1.2.1.1 of this HRS documentation record), collected downstream of the 

removal action (Refs. 5, Appendix A, Figure 4, p. A-4; 19, Appendix A, Figure 2, p. A-2; 67, pp. 1, 2, 3). 

As fishing is documented north of Frey's Lane, the zone of actual contamination in a fishery extends from 

Frey's Lane to SWP-SD-11. 

Most Distant Level II Sample

Sample ID: SWP-SD-11 

Distance from probable point of entry: 1.79 miles 

References: 4; 5, Appendix A, Figure 4, p. A-4; 54; 77 

TABLE 15: Level II Fishery

Identity of Fishery 

Extent of Level II Fishery 

(Relative to PPE) References 

Batchelor Creek From Frey's Lane to SWP-SD-11, 1.79 miles 

downstream of the western-most point of PPE 1 

4; 5, Appendix A, 

Figure 4, p. A-4; 54; 77 

4.1.3.3.1 Food Chain Individual 

Level II Contamination Sample

Sample ID: SWP-SD-11 

Level I/Level II/Potential: Level II 

Hazardous Substances: Anthracene, naphthalene 

Bioaccumulation Potential: 50,000 

References: 2, pp. BI-1, BI-9; 5, Appendix A, Figure 4, p. A-4; 5, Appendix E, pp. E-169, E-170; 7, p. i; 

37, pp. 1, 2 

Level II concentrations have been found in Batchelor Creek within the TDL where a fishery has been 

documented to be present (Refs. 1, Section 4.1.3.3.1; 7, p. i; 37, pp. 1, 2; 54). 

Food Chain Individual Factor Value: 45 

(Ref. 1, Section 4.1.3.3.1) 
70 SW-Human Food Chain Threat 

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 

Fishing occurs on Batchelor Creek north of its intersection with Frey’s Lane in Canton, Mississippi, 

approximately 1.79 miles downstream of PPE 1, near the location where sediment sample SWP-SD-11 

was collected; and the fish are consumed (Refs. 7, p. i; 37, pp. 1, 2; 54; 77). The amount of fish caught 

on an annual basis is unknown but greater than zero because Batchelor Creek is a fishery (Refs. 7, p. i; 37, 

pp. 1, 2). 

USGS flow rate data are not available for Batchelor Creek. Water level observations made during the 

EPA time-critical removal action since September 2009 indicate that the flow rate for Batchelor Creek is 

estimated to be from 0.13 to 22 cfs (Refs. 59; 60). 

TABLE 16: Level II Population Threat 

Identity of Fishery 

Annual 

Production 

(pounds) 

Human Food Chain 

Population Value 

(Ref. 1, Table 4-18) References 

Batchelor Creek >0 0.03 5, Appendix A, Figure 4, p. A-4; 

59; 60 

Level II Concentrations Factor Value: 0.03 

(Ref. 1, Section 4.1.3.3.2.2)

4.1.3.3.2.3 Potential Human Food Chain Contamination

TABLE 17: Potential Population Targets

Identity 

of Fishery 

Annual 

Production 

(pounds) 

Type of 

Surface 

Water 

Body 

Average 

Annual 

Flow (cfs) 

Population 

Value (Pi) 

(Ref. 1, 

Table 4-

18) 

Dilution 

Weight 

(Di) (Ref. 

1, Table 

4-13) Pi × Di References 

Batchelor 

Creek >0 

Small to 

Moderate 

Stream 

10 to 100 0.03 0.1 0.003 

5, Appendix 

A, Figure 4, 

p. A-4; 59; 60

Notes: 

cfs Cubic feet per second 

The portion of Batchelor Creek that is downstream of the documented actual contamination is being 

scored as a potentially contaminated fishery (Ref. 1, Section 4.1.3.3). For the potential human food chain 

contamination factor value the sum of Pi × Di is divided by 10. 

Potential Human Food Chain Factor Value: 0.0003 

(Ref. 1, Section 4.1.3.3.2.3) 
71 SW-Environmental Threat 

4.1.4 ENVIRONMENTAL THREAT 

The environmental threat was not scored because it is not expected to contribute significantly to the 

overall score.