HAZARD RANKING SYSTEM (HRS) DO CUMENTATION 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., 11 th Floor Atlanta, Georgia 30303

Pathways, Components, or Threats Not Scored

The ground water migration, soil exposure, and air mi gration 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). Th ese 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 Sout heastern 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 wate r is mixed in distribution lines (Ref. 28). All six CMU wells are completed in the Sparta aquifer a nd 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 duri ng 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 thic k. The Cockfield and Sparta aquifers are separated by the Cook Mountain confining unit, which is encounte red 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 propert y during the 2008 expanded s ite 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, Ta ble 2, pp. B-3, B-4). Two of these properties are located within the original footprint of King Lumb er, which operated a saw mill, lumber yard, and wood treating facility from 1928 to 1961 (Refs. 5, Appendix A, Fi gure 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 Ma dison 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, Mississi ppi; 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 Covi ngton 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 Preservi ng 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 contamin ant locations presented in this HRS documentation record identify the general area where the site is locat ed. They represent one or more locations the U.S. Environmental Protection Agency (EPA) considers pa rt of the site based on the screening information
EPA used to evaluate the site for National Prioriti es 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 othe rwise 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

12 WORKSHEET FOR COMPUTING HRS SITE SCORE

S Pathway S 2 Pathway

Ground Water Migration Pathway Score (S gw ) NS NS

Surface Water Migration Pathway Score (S

sw ) 96.06 9227.5236

Soil Exposure Pathway Score (S

s ) NS NS

Air Migration Pathway Score (S

a ) NS NS

S 2

gw + S 2

sw + S 2

s + S 2

a 9227.5236

(S 2

gw + S 2

sw + S 2

s + S 2

a ) / 4 2306.8809 √

(S 2

gw + S 2

sw + S 2

s + S 2

a ) / 4 48.03

Note:

NS = Not scoredTable 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

3Table 4-1 –Surface Water Overland/Flood Mi gration 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 Score c (lines 13+21+28, subject to a maximum of 100) 100 96.06

Surface Water Overland/Flood Migration Component Score
30. Component Score (S

sw ) 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

4I01,000500Feet Path: C:\GIS_Workspace\TTEMI-05-003-0042_Southeastern_Wood_Preserving_ESI\Figures\GIS\MXDs\Site Location Maps\SE-ESI WOOD SITE LOC MAP 7-21-11.mxd Date Saved: 7/21/2011 12:30:36 PM User: dale.vonbuschFIGURE 1PROPERTY LOCATIONUnited States Environmental Protection AgencySOUTHEASTERN WOOD PRESERVINGCANTON,MADISON COUNTY,MISSISSIPPITDD No.TTEMI-05-003-0042MADISON COUNTY,MISSISSIPPIMap Source:USGS, Canton, MS 1989Topographic Quadrangle.Reference: 6, pp. 1, 2SOUTHEASTERN WOODPRESERVING1:12,000LEGENDApproximate Property Boundary

5D 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 T r i b u t a r y 1

T r i b u t a r y 3PENICKORGANICSLEGENDApproximate Extent ofBatchelor Creek RemovalBatchelor Creek Sediment PileApproximate Extent of Slurry WallDrainageRailroadApproximate Current Property BoundaryApproximate Historical King LumberProperty BoundaryD D

DD DStockpile0 700350FeetI1:8,400Notes:Aerial Photograph:Google Earth, 2010References: 6, pp. 1, 2; 7, pp. i, 3, 4, 5; 8, p. 3;67, pp. 2, 3 2010-7-19 \GIS_Workspace\TTEMI-05-003-0042_Southeastern_Wood_Preserving_ESI\Figures\GIS\MXDs\Property Layout Maps\SWP-ESI PRO PERTY LAYOUT 8x11 7-16-10.mxd TTEMI-KY dale.vonbuschFIGURE 2CURRENT PROPERTY LAYOUTUnited States Environmental Protection AgencySOUTHEASTERN WOOD PRESERVINGCANTON,MADISON COUNTY,MISSISSIPPITDD No.TTEMI-05-003-0042

6#*!(!(!(!(!(!(!(!(!(!(!(!(!(")")")

B a t c h e l o r C r e e k T r i b u t a r y 1

T r i b u t a r y 3SWP-WS-02SWP-WS-02DSWP09SWP-WS-03SWP-WS-01SWP14SWP13SWP12SWP11SWP10SWP05SWP04SWP03SWP02SWP08SWP07SWP06SWPB01LEGEND")Source No. 1 Sample Location!(Source No. 2 Sample Location#*Background Sample LocationPPE 1DrainageRailroadApproximate Current Property BoundarySource No. 1 (Stockpile of PartiallyTreated Waste Material)Estimated Extent of Source No. 2(Contaminated Soil)0 700350FeetI1:8,400Notes:Aerial Photograph:DigitalGlobe/GlobeXplorer, 2007.References: 5, Appendix A, Figure 4, p. A-4;6, pp. 1, 2; 19, Appendix A, Figure 2, p. A-2B -D -SWP -WS -BackgroundDuplicateSoutheastern Wood PreservingWaste sample 2010-7-17 \GIS_Workspace\TTEMI-05-003-0042_Southeastern_Wood_Preserving_ESI\Figures\GIS\MXDs\Source Location Maps\SWP-ESI SOU RCE LOC MAP 8x11 7-16-10.mxd TTEMI-KY dale.vonbuschFIGURE 3SOURCE LOCATIONSUnited States Environmental Protection AgencySOUTHEASTERN WOOD PRESERVINGCANTON,MADISON COUNTY,MISSISSIPPITDD No.TTEMI-05-003-0042

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### .

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.

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.

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27. Tetra Tech. 4-Mile Radius Map for the SWP S ite. USGS Series Topographic Map Quadrangles: Way, MS 1989; Sharon, MS 1988; Canton, MS 1989; Shoccoe, MS 1989. 1 Map.

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32. MDEQ, Groundwater Assessment and Remediati on Division. Southeastern Woods, Canton, Mississippi, Radial Well Search Results Report. January 14, 2009. 8 Pages.

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.

37. Tetra Tech. Record of Telephone Conversation with Attachment. Subject: Fishing on Batchelor Creek, Bear Creek, and the Big Black River. Betw een Quinn Kelley, Environmental Scientist, and Greg Walters, Master Sergeant, Mississippi Department of Wildlife, Fisheries, and Parks, Bureau of Fisheries, Central Region. Attachment: One G oogleTM Earth Map. March 10, 2010. 2 Pages.

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75. Tetra Tech. Final Comprehensive Environmen tal Response, Compensation and Liability Act Removal Action Report. March 14, 2011. 327 Pages.

1213 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.di sp_program_facility?p_reg istry_id=110000766270

. RCRAInfo Accessed On-line at http://iaspub.epa.gov/enviro/efsystemquery.rcrai nfo?fac_search=handler_id&fac_search_type=Begi nning+With&postal_code=&lo cation_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&p rocname=&program_search=2&report=1& page_no=1&output_sql_s witch=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: Se ptember 2008 EPA Expanded S ite Inspection Sediment Sample Distances. July 14, 2011. 1 Page.

78. Tetra Tech. Electronic Mail Correspondence. Betw een Sandra Harrigan, Environmental Scientist, and Carter Williamson, Federal On-Scene Coordi nator, Emergency Response and Removal Branch, EPA Region 4. Subject: Southeastern Wood Preservi ng 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 stoc kpile 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 la ndscaping 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 agricu ltural, 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 st ockpile throughout this HR S 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 sedimen t samples collected from Batchelor Creek, which receives runoff from Source Nos. 1 and 2, indicatin g that a release has occu rred 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 19 61 and later purchased the property in 1964 (Ref. 8, p. 5). In 1965, Dickson Treating Company (Dicks on) 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 Develo pment 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 ye llow pine timbers were stripped of bark and placed in retort cylinders for drying. Wood preservatives, hot creoso te 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 Descriptionresidual 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 pr operty 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 fi nes from the Mississippi Pollution Control Commission (currently the Mississippi Office of Pollution Contro l) 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 reporte dly discharged approximately 50,000 gallons of wastewater per day directly into Batchelor Creek, wh ich 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 th e creek near the city park, suffering from creosote burns (Ref. 14, p. 4). When operations ceased in 197 9, 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 preliminaryassessment (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, a nd 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) cont ained anthracene, naphthalene, phenanthrene, and pyrene (Ref. 13, p. 18).

In 1986, EPA initiated an emergency response acti on 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 arom atic hydrocarbons (PAH) at a concentration of 3,815 milligrams per kilogram (mg/kg) and was, th erefore, 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 (US DA) Soil Conservation Service (SCS) (currently known as the Natural Resources Conservation Service) design ed 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 DescriptionEPA excavated contaminated soil from the creek ba nk 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 inst alled 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 stoc kpile 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 c onstructed on the SWP propert y (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 phenanthren e 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 c oncentrations 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 treat ed 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 pa rtially treated waste. The treated soil and debris were placed within the containment cell, with a visq ueen 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 a nd 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 Enviro nmental 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 prospec tive 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 cont amination was present in Batchelor Creek (Ref. 17, p. 2).

In 2006, MDEQ discovered new historical inform ation 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 DescriptionIn 2007, EPA Science and Ecosystem Support Division (SESD) personnel adva nced 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 (believe d 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 f our five-point composite waste samples, including one duplicate sample, from the stockpile to identify dispo sal 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 th e adjacent Batchelor Creek (Ref. 19, p. 2). The sediment and waste samples contained anthr acene, benzo(a)anthracene, benzo(a)pyrene, benzo(k)fluoranthene, chrysene, naphthalene, phena nthrene, 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 s ubsurface soil and waste samples were collected throughout the SWP property (Ref. 5, p. 7). In add ition, sediment samples were collected from Batchelor Creek and unnamed tributaries of Batchelor Creek (R ef. 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, dibenzofur an, indeno(1,2,3-cd)pyrene, pentach lorophenol, 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 c ontained 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, PI LE01 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 al ong 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 th e SWP property at depths ranging from 5 to 15 feet below the creek bed and stockpiled the creosote-cont aminated 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 sa mples 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 Batche lor 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)fluoran thene (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 samp les (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 Description18 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 cr eosote-contaminated sediment pile as Non-RCRA hazardous waste and removed the pile to an off-site Class B waste manageme nt facility in Lake, MS (Refs. 44, p. 42; 70; 75, p. 6, Appendix B, p. B-6). The removal of the en tire 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 la nd 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 ac tivities, 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. S od 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 doc umented (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 treat ment 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 stockpi led 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 genera lly 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 contai nment 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 wast e 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 contai nment 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 w eathered" (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, solidif ied 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 anthr acene, benzo(a)anthracene, benzo( a)pyrene, benzo(k)fluoranthene, naphthalene, phenanthrene, pyrene, a nd 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 CharacterizationSource 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 collect ed 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 demons trate the relative increase of source concentrations above background levels. A backgr ound 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 EP A September 2008 ESI. Samples collected during both investigations were collected using similar samp ling 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 CLPSOW 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 ch ain-of-custody records are provided in Reference 20. Logbook notes are available in Reference 5, Appe ndix 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)py rene 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)fluorant hene 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. 1Source 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)pyre ne 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)fluora nthene 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. 1Source No: 1

22 Source Characterization Notes:

( ) Concentrations shown in parentheses were adjust ed in accordance with Re ferences 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 accepta ble; 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 PreservingSource 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 wi th 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 Servi ces, Inc., for SVOCs in
accordance with SW-846 Method 8270C and for diox ins 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 Met hods 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 calib ration 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 Referen ce 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/k g 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/k g 19, Appendix C, p. 3; 45, pp. 8, 332

SWP-WS-02D Benzo(a)pyrene 639 μg/kg 423 μg/k g 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, 332Source 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)fluoranthe ne 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 adjust ed in accordance with Re ferences 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 accepta ble; 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 sampleSource No: 1

25 Source Characterization 2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Source samples collected from Source No. 1 cont ained 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 documente d 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 Batchelo r 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 controlsystems 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 Batchelo r 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 migratio n 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 scoredSource 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 evalua te 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 va lue 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 (ft 2 ): 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: 6,119.2Source 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) wa s 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 incl ude 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 containe d elevated concentrations of anthracene; benzo(a)anthracene; benzo(a)pyrene; benzo(k)fl uoranthene; 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 great er 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 lo cation about 1,000 feet north-northwest of the center of the SWP property (Ref. 5, Appendix A, Figu re 4, p. A-4). The background surface soil sample was collected at a depth of 0 to 1 foot bgs (Ref. 5, A ppendix A, Figure 4, p. A-4; 5, Appendix B, Table 1, pp. B-1, B-2). Background subsurface soil samples were collected at multip le 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 samp ling 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 C LP 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 Refere nce 5, Appendix C. The location of the background samples are depicted in Reference 5, Appendix A, Fi gure 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. 1Source 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)fluorant hene 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. 1Source 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)fluorant hene 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)fluorant hene 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)fluorant hene 4.0U μg/kg 4.0 μg/kg 5, Appendix C, Logbook 1, p. 7; 5, Appendix E, p. E-112; 20, p. 1Source 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 adjust ed in accordance with Re ferences 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 de pth of 12 to 16 feet bgs E Sample collected at a de pth of 16 to 20 feet bgs HpCDD Heptachlorodibenzodioxin HpCDF Heptachlorodibenzofuran
HxCDD Hexachlorodibenzodioxin
HxCDF Hexachlorodibenzofuran
ID Identification number J Identification of the analyte is accepta ble; 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 co llected 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 su rface 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 collect ed 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 adju sted 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 Referen ce 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. 8Source 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)pyre ne 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)fluorant hene 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)pyre ne 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)fluorant hene 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. 11Source 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)py rene 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)fluora nthene 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)pyre ne 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)fluorant hene 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. 5Source 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)pyre ne 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)fluorant hene 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)fluo ranthene 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)pyre ne 17,000 μg/kg 2,600 μg/kg 5, Appendix C, Logbook 1, p. 14; 5, Appendix E, p. E-64; 20, p. 8Source 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)fluorant hene 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)pyre ne 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)fluorant hene 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)pyre ne 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)fluorant hene 7,500 μg/kg 2,300 μg/kg 5, Appendix C, Logbook 1, p. 14; 5, Appendix E, p. E-79; 20, p. 8Source 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)fluo ranthene 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. 1Source 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)fluo ranthene 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)fluo ranthene 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. 5Source 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)pyre ne 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)fluora nthene 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. 4Source 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)py rene 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)fluo ranthene 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)fl uoranthene 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. 8Source 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)fl uoranthene 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)pyre ne 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)fluora nthene 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. 7Source 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)py rene 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)fluo ranthene 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. 8Source 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)fl uoranthene 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)fl uoranthene 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. 5Source 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)fl uoranthene 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)pyre ne 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. 8Source No: 2

45 Source Characterization Notes:

( ) Concentrations shown in parentheses were adjust ed in accordance with Re ferences 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 de pth of 12 to 16 feet bgs DUP Duplicate E Sample collected at a de pth of 16 to 20 feet bgs HpCDD Heptachlorodibenzodioxin HpCDF Heptachlorodibenzofuran
HxCDD Hexachlorodibenzodioxin
HxCDF Hexachlorodibenzofuran
ID Identification number J Identification of the analyte is accepta ble; 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 PreservingSource No: 2

46 Source Characterization 2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

The source samples collected from Source No. 2 (c ontaminated soil located on the SWP property)
contained elevated concentrations of SVOCs and diox ins 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, in dicate 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 contro l 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 activiti es, 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 th is 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 scoredSource 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 evalua te 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 evalua te 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, th e area of Source No. 2 is undetermined, but greater
than zero.

Sum (square feet [ft 2 ]): >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 undete rmined, but greater than zero (Ref. 1, Section 2.4.2.1.5).

Source HWQ Value: >048 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, lu mber 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 Batche lor Creek, which may be a result of King Lumber operations (Ref. 44, p. 43). Because King Lumber’s ope rations included wood trea ting, site operations and the types of hazardous substances (SVOCs) used are e xpected 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 contaminan ts, including anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(k)fluoranthene, chrysene, dibenzo(a,h)an thracene, 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, w aste 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 Mi gration Path for Overland/Flood Component

The hazardous substance migration pathway includes bot h the overland segment and the in-water segment that hazardous substances would take as they migrat e away from sources. The overland segment begins at the source and proceeds downgradient to the probabl e point of entry (PPE) to surface water. The inwater segment at the PPE continues in the dir ection 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, whic h slopes north toward Batchelor Creek (Ref. 62). The southern portion of the SWP property has an el evation of 240 feet above mean sea level and the
elevation of Batchelor Creek is 230 feet above me an 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, incl ude the construction of any run-on control or runoff management features (Refs. 62; 75, p. 3)

PPE 1 may be delineated by the downgradient intersec tion of the overland path with Batchelor Creek between sample stations SWP14 and SWP02. PPE 1 c overs 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). Batche lor Creek flows to the northwest approximately 8.5 miles before it merges with Bear Creek, which contin ues 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 Ya zoo County, Mississippi (Ref. 4). According to the U.S. Geological Survey (USGS), the average annual fl ow 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 Batche lor 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 Batchelo r Creek; and inadequate treatment of process wastewater before it was dischar ged 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 wast ewater per day directly into Batchelor Creek, which flows through a city park, a residential area, and dow ntown Canton before it enters Bear Creek (Refs. 11, p. 1; 15, p. 1). The State of Mississippi received complaints of childre n, 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 contaminat ed 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 wideni ng 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, creo sote 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 Ba tchelor Creek, as well as along the 15-mile surface water TDL as far as the Big Black River, approxi mately 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 excava tion, 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 hydr ocarbons, 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 sed iment 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. Backgr ound 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 w ith 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, a nd 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 collect ed 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, cont ained 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 confluen ce 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. Ho wever, as shown in the following tables, when conservatively using Tributary 3 samples to establis h background levels, levels of SVOCs in sediment samples collected downstream of th e PPE for Source Nos. 1 and 2 nonetheless contained SVOCs at levels meeting observed release criteria.

A background sediment sample was not collected fro m Batchelor Creek during the EPA February 2008 RSE; therefore, downstream sediment samples collect ed 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 we re collected using similar sampling procedures, at similar depths, and from similar areas within the creek (Ref s. 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 tribut aries. The locations of the background sediment samples are depicted in Reference 5, Appendix A, Fi gure 4, page A-4 and are listed in Reference 5, Appendix B, Table 5, pages B-7 and B-8. Chain-o f-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, Logbook52 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 Tributary53 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 SOM 01.2 (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 calib ration 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. 754 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. 255 SW-Observed Release Notes:

( ) Concentrations shown in parentheses were adjust ed in accordance with Re ferences 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 sedimen t 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 depos itional areas at depths ranging from 0 to 6 inches bgs (Refs. 5, Appendix C, Logbook 2, pp. 2, 3, 4; 19, Appendi x 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 Assuranc e Manual, November 2001 (Ref. 19, p. 2; 63). The September 2008 samples were collected in accordan ce 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 pr ovided 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 sedim ent 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; 7757 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 Preserving58 SW-Observed Release Contaminated Concentrations

The sediment samples listed in Table 11 were colle cted 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 accord ance with SW-846 Method 8270C (Refs. 19, Appendix D, p. D-15; 45, pp. 14, 15, 16, 19; 57). Tetra Tech reviewed a ll data according to the Na tional 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 ar e 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, Appendi x 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, Tribut ary 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. 259 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 Preserving60 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, re spectively. 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 sed iment 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). Sedi ment 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, Appe ndix 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), a nd 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, an d 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 Tributar y 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, Appe ndix 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 pr ior to the removal, during the September 2008 ESI.
Table 12 summarizes the hazardous subs tances 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 Loca tion 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 Preserving62 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 arom atic 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 th e 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 th e 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 wast ewater per day directly into Batchelor Creek, which flows through a city park, a residential area, and dow ntown Canton before it enters Bear Creek (Refs. 11, p. 1; 15, p. 1). The State of Mississippi received complaints of ch ildren suffering from creosote burns who had been playing in Batchelor Creek near the city park (R ef. 14, p. 4). When operations ceased in 1979, the property contained large areas of cont amination in the treatment and storage areas, piles of contaminated soil, creosote sludge storage tanks, and three unlin ed 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 a nd dioxins and furans (Ref. 65, pp. 12, 13). According to a risk assessment study conducted by the R esearch 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 documenta tion 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 treatme nt 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 know n 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 wast e leaching into the creek from the SWP property. In response, EPA removed contaminated soil from th e 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 we re lined with rip-rap to prevent erosion (Ref. 9, p. 4).

From 1991 to 1994, EPA treated the stockpile d material from the surface impoundments using biotreatment (Ref. 16, pp. 1, 2). A treatability va riance 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, dibenz ofuran, naphthalene, phena nthrene and pyrene.63 SW-Observed Release Analytical results of samples collected from Batc helor 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 (S WP-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 det ected at elevated concentrations (1,500,000 μg/kg phenanthrene and 400,000 μg/kg pyrene) in the d eepest 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 Batche lor 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 indicat ed 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 th e 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, creo sote 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 S ource 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 thro ugh 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 con centrations 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 cr eosote-contaminated sediment stockpile was completed on September 24, 2010 (Ref. 75, p. 6). EPA also c onstructed a slurry wall measuring 1,500 feet long, three feet wide, and 30 feet below land surface be tween the SWP property a nd 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 di rected 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 fro m Source Nos. 1 and 2 in February and September 2008
contained site-related hazardous subs tances, including anthracene, benz o(a)anthracene, benzo(a)pyrene, benzo(k)fluoranthene, chrysene, dibenzo(a,h)anth racene, 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 pyre ne have been documented as observed releases in sediment samples collected from Batchelor Creek (see Table 11 in S ection 4.1.2.1.1, Observe d Release, of this HRS documentation record). All of the observed release se diment 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 Pl ating & Bumper Works, Inc. (CPBW) (EPA ID No. MSD008473282), Greif Industrial Packaging and Serv ices, LLC (GIPS) (EPA ID No. MSD082008921), and Van Leer Containers (VLC) (EPA ID No. MSD082008921). All three facil ities 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 Batc helor 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 classi fied as a RCRA large quantity generator of volatile organic compound (VOC) hazardous waste, including be nzene, 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 Ja nuary 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. VOC s 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 classi fied 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 receiv ed SNFA (State No Further Action) status in February65 SW-Observed Release 1999. The major contaminant detected at the VLC proper ty 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 trea tment 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 th is effluent contained 2-Methylnaphthalene and benzo(a)pyrene at concentrations above the surface wa ter 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 Batchelo r 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 (R efs. 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 pondis 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 downstrea m 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: 55066 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/Persi stence/Bioaccumulation

The toxicity, persistence, and bioaccumulation factor values for the hazardous substances detected in the sources with containment factor values of greater th an 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

Value 1 Bioaccumulation

Value 2 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 (stoc kpile 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, th e 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, roun ded 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 obtaine d by multiplying the toxicity/persistence and HWQ factor values, subject to a maximum product of 1 x 10 8 . Then, this product was multiplied by the bioaccumulation potential factor value, subject to a maximum product of 1 x 10 12 . 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 10 6

Toxicity/Persistence Factor Value × Hazardous Waste Quantity Factor Value × Bioaccumulation Factor Value (50,000): 5 x 10 10

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 re lease 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 c onsumed (Refs. 4; 7, p. i; 37, pp. 1, 2). No fish advisories are currently in effect for Batchelor Cr eek, 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 th e Batchelor Creek fishery at sample location SWPSD-11 (see Table 11 of Section 4.1.2.1.1 of this HR S 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 z one 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, n ear 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 becau se Batchelor Creek is a fishery (Refs. 7, p. i; 37, pp. 1, 2).

USGS flow rate data are not available for Batche lor Creek. Water level observations made during the EPA time-critical removal action since September 2009 i ndicate 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 (P i )

(Ref. 1,

Table 4- 18) Dilution Weight (D i ) (Ref. 1, Table

4-13) P i × D i 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, S ection 4.1.3.3). For the potential human food chain
contamination factor value the sum of P i × D i 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.