HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD COVER SHEET

Name of Site: Kerr-McGee Chemical Corp-Columbus 

EPA ID No.: MSD990866329 

Contact Persons

U.S. Environmental Protection Agency, Region 4: 

 

 Ralph Howard, Remedial Project Manager

 61 Forsyth Street, S.W., 11th

 Atlanta, Georgia 30303 

 Floor 

 (404) 562-8829 

 Jennifer Wendel, National Priorities List Coordinator 

 61 Forsyth Street, S.W., 11th

 Atlanta, Georgia 30303 

 Floor 

 (404) 562-8799 

HRS Documentation Record:

 Shanna Davis, Site Manager

 Tetra Tech EM, Inc.

 1955 Evergreen Boulevard, Ste. 300 

 Duluth, Georgia 30096 

 (678) 775-3109 

Pathways, Components, or Threats Not Scored

The soil exposure and air migration pathways were not scored in this Hazard Ranking System (HRS) 

documentation record because they are not expected to significantly contribute to the overall site score. 
1 

HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD

Name of Site: Kerr-McGee Chemical Corp-Columbus 

EPA Region: 4 

Date Prepared: March 2011 

Street Address of Site*: East of the intersection of North 14th Avenue and North 20th Street

City, County, State, Zip: Columbus, Lowndes County, Mississippi, 39701 

General Location in the State: Northeastern portion of state 

Topographic Map: Columbus North, Mississippi 1987 

Latitude: 33o 30' 35.16" North

Longitude: 88o 24' 34.87" West

The coordinates above for the Kerr-McGee Chemical Corp-Columbus site were measured from the 

location of the former surface impoundments (Refs. 7, pp. 1, 5; 81; 82, p. 30). 

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

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

be part of the site based on the screening information EPA used to evaluate the site for NPL listing. EPA 

lists national priorities among the known “releases or threatened releases” of hazardous substances; thus, 

the focus is on the release, not precisely delineated boundaries. A site is defined where a hazardous 

substance has been “deposited, stored, placed or otherwise come to be located.” Generally, HRS scoring 

and the subsequent listing of a release merely represent the initial determination that a certain area may 

need to be addressed under the Comprehensive Environmental Response, Compensation, and 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 as to where the contamination has 

come to be located. 

Pathway Pathway Score

Ground Water Migration 95.88 

Surface Water Migration 42.66 

Soil Exposure NS

Air Migration NS

HRS SITE SCORE 52.47

Note:

NS Not scored
2 

WORKSHEET FOR COMPUTING HRS SITE SCORE

S Pathway S2

Ground Water Migration Pathway Score (S

Pathway

gw) 95.88 9,192.9744

Surface Water Migration Pathway Score (Ssw) 42.66 1,819.8756

Soil Exposure Pathway Score (Ss) NS NS

Air Migration Pathway Score (Sa) NS NS

S2

gw + S2sw + S2s + S2a 11,012.8500

(S2

gw + S2sw + S2s + S2a) / 4 2,753.2125

√ (S2

gw + S2sw + S2s + S2a) / 4 52.47

Note:

NS Not scored
3 

Table 3-1 --Ground Water Migration Pathway Scoresheet

Aquifer Evaluated: Tuscaloosa Aquifer Group 

(Interconnected Gordo, Coker, and Massive Sand Aquifers)

Factor Categories and Factors Maximum Value Value Assigned

Likelihood of Release to an Aquifer: 

1. Observed Release 550

2. Potential to Release:

2a. Containment 10 10

2b. Net Precipitation 10 10

2c. Depth to Aquifer 5 1

2d. Travel Time 35 5

2e. Potential to Release [lines 2a(2b + 2c + 2d)] 500 160

3. Likelihood of Release (higher of lines 1 and 2e) 550 160

Waste Characteristics:

4. Toxicity/Mobility 10,000.00 (a)

5. Hazardous Waste Quantity 100 (a)

6. Waste Characteristics 100 32

Targets:

7. Nearest Well 50 18

8. Population:

8a. Level I Concentrations 0.00 (b)

8b. Level II Concentrations 0.00 (b)

8c. Potential Contamination 1,522 (b)

8d. Population (lines 8a + 8b + 8c) 1,522 (b)

9. Resources 5 0

10. Wellhead Protection Area 20 5.00

11. Targets (lines 7 + 8d + 9 + 10) (b) 1,545

Ground Water Migration Score for an Aquifer: 

12. Aquifer Score [(lines 3 x 6 x 11)/82,500] 100 c 95.88

Ground Water Migration Pathway Score:

13. Pathway Score (Sgw), (highest value from line 12 for all 

aquifers valuated)

100 c95.88

Notes:

a

 = Maximum value applies to waste characteristics category b

 = Maximum value not applicable c

NS = Not scored

 = Do not round to nearest integer
4 

HRS Table 4-1 –Surface Water Migration Pathway Scoresheet

Factor Categories and Factors Maximum Value Value Assigned

Drinking Water Threat

Likelihood of Release:

1. Observed Release 550 550 

2. Potential to Release by Overland Flow: 

2a. Containment 10 NS

2b. Runoff 25 NS

2c. Distance to Surface Water 25 NS

2d. Potential to Release by Overland Flow [lines 

2a(2b + 2c)] 

500 NS

3.Potential to Release by Flood:

3a. Containment (Flood) 10 NS

3b. Flood Frequency 50 NS

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

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

maximum of 500)

500 NS

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

Waste Characteristics:

6. Toxicity/Persistence (a) NS

7. Hazardous Waste Quantity (a) NS

8. Waste Characteristics 100 NS

Targets:

9. Nearest Intake 50

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 20
5 

Table 4-1 –Surface Water Migration Pathway Scoresheet (Continued)

Factor Categories and Factors Maximum Value Value Assigned

19. Population

19a. Level I Concentrations (b) 0

19b. Level II Concentrations (b) 0

19c. Potential Human Food Chain 

Contamination

(b) 0.000003 

19d. Population (lines 19a + 19b + 19c) (b) 0.000003 

20. Targets (lines 18 + 19d) (b) 20.000003 

Human Food Chain Threat Score:

21. Human Food Chain Threat Score [(lines 

14x17x20)/82,500, subject to maximum of 100]

100 42.66 

Environmental Threat

Likelihood of Release:

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

Waste Characteristics:

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

24. Hazardous Waste Quantity (a) NS

25. Waste Characteristics 1,000 NS

Targets:

26. Sensitive Environments

26a. Level I Concentrations (b) NS

26b. Level II Concentrations (b) NS

26c. Potential Contamination (b) NS

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

26c)

(b) NS

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

Environmental Threat Score:

28. Environmental Threat Score [(lines

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

60 NS

Surface Water Overland/Flood Migration Component 

Score for a Watershed

29. Watershed Scorec (lines 13+21+28, subject to a 100 

maximum of 100) 

42.66 

Surface Water Overland/Flood Migration Component Score

30. Component Score (Sof)

c

 (highest score from line 100 

29 for all watersheds evaluated)

42.66 

Notes:

a

 = Maximum value applies to waste characteristics category b

 = Maximum value not applicable c

NS = Not scored

 = Do not round to nearest integer
0 1,000 2,000

Feet

2011-01-25 \GIS_Workspace\TTEMI-05-003-0096_Kerr-McGee_Chemical_Corp\Figures\GIS\MXDs\Site Location Maps\R IV START SITE LOC MAP 9-28-10.mxd TTEMI-ATL collin.horace

FIGURE 1

PROPERTY LOCATION

United States Environmental Protection Agency

KERR-MCGEE CHEMICAL CORP.

COLUMBUS,

LOWNDES COUNTY,

MISSISSIPPI

TDD No.TTEMI-05-003-0096

LOWNDES COUNTY,

MISSISSIPPI

USGS 7.5 Minute Series Topographic

Quadrangle Map

Columbus North, MS 1987

References 9, pp. 3, 6, 9, 12, 13; 17, p. 80;

82, p. 126.

PROPERTY

LOCATION

1:24,000

6
N 14TH AVE

N 27TH ST

N 21ST ST

N 13TH AVE

TUFFY LN

DR. MARTIN LUTHER KING JR

N 21ST ST

Waste

Pile 1

Waste

Pile 2

Pine Yard

Green Tie Storage

Black Tie Storage

Green Tie Storage

Production

Process Area

Black Tie Storage

Creosote Recovery/

Waste Water Treatment

0 200 400

Feet

2011-01-25 GIS_Workspace\TTEMI-05-003-0096_Kerr-McGee_Chemical_Corp\Figures\GIS\MXDs\Site Layout Maps\KERR MCGEE SITE LAYOUT_8x11_09-20-10.mxd TTEMI-ATL collin.horace

FIGURE 2

PROPERTY LAYOUT

United States Environmental Protection Agency

KERR-MCGEE CHEMICAL

CORP-COLUMBUS,

LOWNDES COUNTY,

MISSISSIPPI

TDD No.TTEMI-05-003-0096

Map Sources:

Aerial Imagery, NAIP\2009 1m Color.

References 7, p. 2; 9, pp. 3, 6, 9, 12, 13; 

14, pp. 3, 27; 17, p. 80; 54, p. 61a; 56,

p. 9; 82, pp. 30, 126; 84, p. 68

Street Names, StreetMap USA

1:4,800

Legend

Backfilled Surface Impoundments

Property Boundary

Railroad Tracks

7
AVE

N 27TH ST

DR. MARTIN LUTHER KING JR

N 23RD AVE

MOSS ST

N 16TH AVE

Waste

Pile 1

Waste

Pile 2

Pine Yard

e Storage

0 200 400

Feet

2011-01-25 GIS_Workspace\TTEMI-05-003-0096_Kerr-McGee_Chemical_Corp\Figures\GIS\MXDs\Site Layout Maps\KERR MCGEE SITE LAYOUT_b_8x11_09-20-10.mxd TTEMI-ATL collin.horace

FIGURE 2A

PROPERTY LAYOUT

NORTHERN PROPERTY

United States Environmental Protection Agency

KERR-MCGEE CHEMICAL

CORP-COLUMBUS,

LOWNDES COUNTY,

MISSISSIPPI

TDD No.TTEMI-05-003-0096

Map Sources:

Aerial Imagery, NAIP\2009 1m Color.

References 9, pp. 3, 13; 14, p. 3; 82, p. 126; 84, p. 68

Street Names, StreetMap USA.

1:4,800

Legend

Property Boundary

Railroad Tracks

N 14TH 

Green Ti

8
N 14TH AVE

N 27TH ST

N 21ST ST

N 13TH AVE

TUFFY LN

DR. MARTIN LUTHER KING JR

N 21ST ST

SB5

SB4

SB1

SB3

SB2

SD7 SD8 SD9

SSB-01

SB6

B53

B56

B55

B54

SSB-03

SSB-02

SSB-09

SSB-08

SSB-07

SSB-06

SSB-05

SSB-04

0 200 400

Feet

2011-01-25 GIS_Workspace\TTEMI-05-003-0096_Kerr-McGee_Chemical_Corp\Figures\GIS\MXDs\Source Location Maps\KERR MCGEE SOURCE_LOCATIONS_8x11_09-21-10.mxd TTEMI-ATL collin.horace

FIGURE 3

SOURCE LOCATION

KERR-MCGEE CHEMICAL

CORP-COLUMBUS,

LOWNDES COUNTY,

MISSISSIPPI

TDD No.TTEMI-05-003-0096

Map Sources:

Aerial Imagery, NAIP\2009 1m Color.

References 7, p. 2; 9, pp. 3, 6, 9, 12, 13; 14, pp. 3,

27; 54, p. 61a; 56, p. 9; 82, pp. 30, 126; 84, p. 68

Street Names, StreetMap USA

1:4,800

United States

Environmental Protection Agency

Legend

Source No. 2

Contaminated Soil Underneath

the Former Drip Pad

Source No. 3

Contaminated Soil Located

in Various Areas

Source No. 3 Samples

Property Boundary

Railroad Tracks

Source No. 1

Backfilled Surface Impoundments

1996 Surface Soil Sample

1996 Soil Boring

2008 Surface Soil Sample

2008 Surface Soil Sample Background

9
N 14TH AVE

N 27 TH ST

N 21 ST ST

N 13 TH AVE

TUFFY LN

DR. M ARTIN L UT HER KING JR

N 21 ST ST

CMW-8

CMW-33 CMW-36

CMW-66

CMW-24

CMW-27

CMW-16

CMW-11R

CMW-19R

CMW-1AR

0 200 400

Feet

2011-01-25GIS_Workspace\TTEMI-05-003-0096_Kerr-McGee_Chemical_Corp\Figures\GIS\MXDs\Observed Release Maps\KERR-MCGEE_GWTR RELEASE_8x11_09-16-10.mxd TTEMI-ATL collin.horace

FIGURE 4

GROUND WATER OBSERVED RELEASE

United States Environmental Protection Agency

KERR-MCGEE CHEMICAL

CORP-COLUMBUS,

LOWNDES COUNTY,

MISSISSIPPI

TDD No.TTEMI-05-003-0096

Map Sources:

Aerial Imagery, NAIP\2009 1m Color.

References 7, p. 2; 9, pp. 3, 6, 9, 12, 13;

14, pp. 3, 27; 17, p. 80; 25, p. 21; 82,

pp. 30, 126; 84, p. 68

Street Names, StreetMap USA

1:4,800

Legend

Ground Water Wells

Background Well

Observed Release Well

Structures

Backfilled Surface Impoundment

Former Drip Pad

Property Boundary

Railroad Tracks

10
")$+

$+

")

")

!(

!(

!(

!(

#*

!(

#*

#*

#*

N 14 TH AVE

N 27 TH ST

N 21 ST ST

N 13 TH AVE

TUFF Y LN

DR. M ARTIN L UT HER KING JR

N 21 ST ST

PPE 1

PPE 2

PPE 3

Main Drainage Ditch

TN21S

TN22S

TN16S

TN19S

TN15S

Outfall #002

Outfall #005

Outfall #003

Outfall #004

Outfall #001

Drainage Ditch 1

Drainage Ditch 3

Drainage Ditch 4

Drainage Ditch 2 Drainage Ditch 3

Drainage Ditch 5

Drainage Ditch 3

Main Drainage Ditch

PPE 4

/ 0 400200

Feet

2011-01-25GIS_Workspace\TTEMI-05-003-0096_Kerr-McGee_Chemical_Corp\Figures\GIS\MXDs\Observed Release Maps\KERR-MCGEE_SURFACE WATER RELEASE_8x11_09-16-10.mxd TTEMI-ATL collin.horace

FIGURE 5

SURFACE WATER OBSERVED RELEASE

KERR-MCGEE CHEMICAL

CORP-COLUMBUS,

LOWNDES COUNTY,

MISSISSIPPI

TDD No.TTEMI-05-003-0096

Map Sources:

Aerial Imagery, NAIP\2009 1m Color.

References 7, p. 2; 9, pp. 3, 6, 9, 12, 13; 14, p. 3; 17,

p. 84; 55, p. 21a; 57, pp. 5-5, 5-13; 70, 

pp. 4, 5, 6, 7; 71; 72; 82, pp. 30, 126; 84, p. 68

Street Names, StreetMap USA

1:9,600

United States

Environmental Protection Agency

Legend

Main Drainage Ditch

Railroad Tracks

Property Boundary

Backfilled Surface Impoundments

Former Drip Pad

NOTES:

NPDES - National Pollution Discharge

 Elimination System

NPDES Outfall Location

Intermittent Drainage Ditch

PPE Location

2010 Observed Release Sediment Sample

2010 Background Sediment Sample

!( #*")$+
12

REFERENCES

1. U.S. Environmental Protection Agency (EPA). Hazard Ranking System, Title 40 Code of Federal 

Regulations (CFR) Part 300, 55 Federal Register 51532. December 14, 1990. 138 Pages. 

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

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

3. Tetra Tech. 4-Mile Radius Map. Source of Map: U.S. Geological Survey, 7.5-minute series. 

Topographic Maps of Mississippi: Columbus North 1987, Columbus South 1987, Steens 1987, New 

Hope 1987. Scale, 1:24,000. 1 Map. 

4. Tetra Tech. 15-Mile Surface Water Migration Pathway. Source of Map: U.S. Geological Survey, 

7.5-minute series. Topographic Maps of Mississippi: Columbus North 1987, Steens 1987, 

Columbus South 1987, New Hope 1987. Scale, 1:36,000. Insert: Aerial Photograph, NAIP\2009 

1m Color. 1 Map. 

5. Kerr-McGee Chemical Corporation, Forest Products Division. Letter with Attachment Regarding 

Consent Agreement 1636 89. From: Nick Bock, Staff Environmental Specialist. To: Steve 

Spengler, RCRA TSD Coordinator, Mississippi Bureau of Pollution Control. Attachment: RCRA 

Part B Modification/Engineering Feasibility Plan Addendum, Post-Closure Permit Application, 

Volume II. October 30, 1990. 331 Pages. 

6. Kerr-McGee, Forest Products Division. Letter with Attachment Regarding HW 90-329-01. From: 

Nick Bock, Staff Environmental Specialist. To: Steve Spengler, RCRA TSD Coordinator, 

Mississippi Bureau of Pollution Control. Attachment: RCRA Part B Modification/Engineering 

Feasibility Plan Addendum, Post-Closure Permit Application, Volume III. March 28, 1991. 105 

Pages.

7. Kerr-McGee, Forest Products Division. Impoundment Closure Report. October 15, 1986. 470 

Pages.

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Updated January 12, 2011. Accessed on January 12, 2011. 4 Pages. Accessed On-line at 

http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0402489. 

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Property. Attachment: Parcel Detail Reports. September 22, 2010. 16 Pages. 

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Columbus Corp Property. Attachment: Parcel Maps. August 10, 2010. 3 Pages.

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LLC, Forest Products Division, Columbus, Lowndes County, Mississippi. Prepared on behalf of 

EPA. September 2002. 331 Pages. 

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22, 2008. 101 Pages. 

13. A.T. Kearney, Inc., Kearney/Centaur Division. Interim RCRA Facility Assessment. Kerr-McGee 

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13

14. Kerr-McGee. Letter with Attachments Regarding RFA Comments, Kerr-McGee Chemical 

Corporation, Columbus, Mississippi. From: Stephen A. Ladner, Staff Environmental Specialist, 

Kerr-McGee Chemical Corporation, Forest Products Division. To: Mr. Russ McLean, RCRA 

Permitting Section, USEPA, Region 4. July 29, 1994. 81 Pages. 

15. Mississippi Department of Natural Resources (MDNR). Letter dated March 29, 1984 with 

Attachment. From: John Herrmann, MDNR Division of Solid Waste Management. To: P.C. 

Gaskin, Environmental and Quality Control, Kerr-McGee Corporation. Attachment: Groundwater 

Quality Assessment Plan. Kerr-McGee Chemical Corporation, Columbus, Mississippi, March 19, 

1984. 26 Pages.

16. EPA. Hazardous Waste Permit Application, Consolidated Permits Program. EPA ID Number: 

MSD990866329. November 13, 1980. 5 Pages. 

17. Kerr-McGee, Forest Products Division. Letter dated March 13, 1987 with Attachment Regarding 

Post-Closure Permit Application. From: Jeffrey H. Bull, Manager, Environmental Control and 

Regulatory Affairs. To: Donald G. McGraw, P.E., Hazardous Waste Section, Bureau of Pollution 

Control. Attachment: Post-Closure Permit Application, Columbus Facility, Volume I, March 12, 

1987. 227 Pages. 

18. Kerr-McGee. Letter with Attachments Regarding RCRA Facility Investigation Workplan Response 

to Comments, Kerr-McGee, Forest Products Division, Columbus, Mississippi. From: Stephen A. 

Ladner, Staff Environmental Specialist. To: Mr. Bruce Ferguson, Mississippi Department of 

Environmental Quality (MDEQ). February 2, 1996. 25 Pages. 

19. A.T. Kearney, Inc. Letter Regarding Responses to Questions on the Interim RFA Report. From: 

Gayle Kline, Technical Director. To: Ms. Rowena Sheffield, EPA, Region 4. January 13, 1989. 7 

Pages.

20. EPA. Letter Regarding Review Comments – Confirmatory Sampling Report, Kerr-McGee, 

Columbus, Mississippi. From: G. Alan Farmer, Chief, RCRA Branch, Waste Management Division. 

To: Mr. Jerry Banks, MDEQ, Hazardous Waste Division. November 6, 1995. 10 Pages. 

21. Kerr-McGee, Environmental Technology and Engineering Division. 1992 Phase II Off-Site 

Groundwater Assessment, Kerr-McGee, Forest Products Division, Columbus, Mississippi Facility. 

April 22, 1992. 91 Pages. 

22. Kerr-McGee. Letter with Attachment Regarding Columbus, Mississippi Facility. From: Jeffrey H. 

Bull, Manager, Environmental Control and Regulatory Affairs. To: Mississippi Department of 

Natural Resources, Bureau of Pollution Control. Attachment: Phase I Drilling Results for the KerrMcGee, Forest Products Division’s Facility in Columbus, Mississippi. June 21, 1988. 81 Pages. 

23. Kerr-McGee, Engineering Services Division. Annual Groundwater Monitoring Report for 1988, 

Kerr-McGee Chemical Corporation, Forest Products Division, Columbus, Mississippi, EPA ID No. 

MSD990866329. Prepared by Jami M. Poor, Hydrologist. March 1, 1989. 186 Pages. 

24. Mississippi Department of Natural Resources (MDNR), Bureau of Pollution Control. Letter dated 

September 11, 1989 with Attachment. From: Charles H. Chisolm, Bureau Director. To: KerrMcGee Chemical Corporation. Attachment: Administrative Order No. 1636-89, signed September 

8, 1989. 4 Pages. 

25. Tronox LLC. Letter with Attachment Regarding Tronox LLC. From: Robert E. Pounds, Project 

Manager. To: Toby M. Cook, P.E., Environmental Permits Division, Office of Pollution Control, 

MDEQ. Attachment: 2008 Annual/Semi-Annual Corrective Action Performance Evaluation and 

Groundwater Monitoring Report. February 13, 2009. 123 Pages. 
14

26. Kerr-McGee. Letter with Attachment Regarding Columbus, Mississippi Facility. From: Stephen A. 

Ladner, Staff Environmental Specialist. To: Bruce Ferguson, Office of Pollution Control. 

Attachment: 1993 Annual/Semi-Annual Corrective Action Performance Evaluation and 

Groundwater Monitoring Report. Letter Dated February 28, 1994. Report Dated March 1, 1994. 

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27. MDNR, Bureau of Pollution Control, Hazardous Waste Division. Comprehensive Groundwater 

Monitoring Evaluation, Kerr-McGee, Columbus, Mississippi. November 1988. 50 Pages. 

28. Electronic Code of Federal Regulations. Title 40: Protection of Environment, Part 261. Data 

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&idno=40

29. Google Earth. Map of Lowndes County, Mississippi. Image: 2010 Digital Globe. Imagery Dates: 

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Eutaw-McShan Aquifer and in the Tuscaloosa Aquifer System in Northeastern Mississippi. By Eric 

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Stephenson and Watson Hiner Monroe. Bulletin 40. 1940. Excerpt, 20 Pages.

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Thad N. Shows. Bulletin 113. 1970. Excerpt, 13 Pages. 

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April 1, 1987. Last Revision May 31, 1996. 340 Pages. 

38. MDEQ. Letter regarding Permit Modification, RCRA Permit No. HW-90-329-01, Kerr-McGee, 

Columbus, Mississippi. From Charles H. Chisolm, Head, Office of Pollution Control, MDEQ. To 

Mr. Steve Ladner, Staff Environmental Specialist, Kerr-McGee. July 17, 1996. 3 Pages. 
15

39. Kerr-McGee Chemical Corporation. Letter dated February 26, 2003 with Attachment Regarding the 

Columbus, Mississippi Facility. From: Stephen A. Ladner, Staff Environmental Specialist. To: 

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40. Kerr-McGee, Technology Division. Groundwater Quality Assessment Report. February 28, 1990. 

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41. Kerr-McGee Forest Products Division, Columbus, Mississippi, Hydrology Department. 2001 SemiAnnual Corrective Action Performance Evaluation. October 1, 2001. 108 Pages. 

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46. MDEQ, Office of Land and Water. Public Water Supply Reports, City of Columbus, Lowndes 

County. Accessed August 27, 2010. 18 Pages. Accessed On-line at 

http://landandwater.deq.ms.gov/swap/reports/report.aspx?id=0440003. 

47. Tetra Tech. Record of Telephone Conversation Regarding Columbus Light and Water. Between 

Shanna Davis, Environmental Scientist and Mitchell Brown, Lead Operator, Columbus Light and 

Water. August 27, 2010. 1 Page. 

48. Tetra Tech. Record of Telephone Conversation Regarding East Lowndes Water Association. 

Between Shanna Davis, Environmental Scientist and Grant Mitchell, Lead General Manager, East 

Lowndes Water Association. May 25, 2010. 1 Page. 

49. MDEQ, Office of Land and Water. Public Water Supply Reports, East Lowndes Water Association

#2-Ridge Road. Accessed August 27, 2010. 6 Pages. Accessed On-line at 

http://landandwater.deq.ms.gov/swap/reports/report.aspx?id=0440080. 

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

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

51. Tetra Tech. Project Note to File with Attachments. Subject: Source Water Assessment Program. 

Attachments: Maps for Columbus Light and Water Public Water System. August 30, 2010. 3 

Pages.

52. MDEQ. Mississippi Source Water Assessment Program. Accessed August 30, 2010. 1 Page. 

Accessed On-line at 

http://www.deq.state.ms.us/MDEQ.nsf/page/GPB_SourceWaterAssessment?OpenDocument. 
16

53. USGS. Surface Water Data for Mississippi: Surface-Water Annual Statistics. Accessed September 

8, 2010. 2 Pages. Accessed On-line at http://waterdata.usgs.gov/ms/nwis/. 

 

54. Kerr-McGee, Forest Products Division. RCRA Facility Investigation Report, Columbus, 

Mississippi. March 31, 1997. 150 Pages. 

55. Kerr-McGee, Forest Products Division. RCRA Facility Investigation Phase II Report, Columbus, 

Mississippi Facility. October 1998. 172 Pages. 

56. Tronox. Letter dated March 4, 2009 with Attachment Regarding the RCRA Facility Investigation 

Report of Supplemental Soil Sampling, Columbus, Mississippi Facility. From: Robert Pounds, 

Project Manager. To: Karen Knight, Chief, Corrective Action Section, RUST Branch, RCRA 

Division, EPA. Attachment: RCRA Facility Investigation Report of Supplemental Soil Sampling, 

Columbus, Mississippi Facility. Prepared by AquAeTer on Behalf of Tronox LLC, March 2009. 

118 Pages.

57. Kerr-McGee, Forest Products Division. Workplan for RCRA Facility Investigation. November 28, 

1995. 163 Pages. 

58. Grant Environmental. RCRA Facility Investigation Workplan Revision. Submitted on Behalf of 

Kerr-McGee, Forest Products Division. May 23, 1996. 48 Pages. 

59. Tronox LLC. Response to Comments, Supplemental RCRA Facility Investigation Work Plan. 

October 20, 2008. 14 Pages. 

60. Tetra Tech. Project Note to File with Attachment. Subject: Soil Map of the Kerr-McGee Chemical 

Corp. Property and Surrounding Areas. Attachment: USDA Soil Map. September 1, 2010. 4 Pages. 

61. Lancaster Laboratories. Analysis Report Prepared for Tronox LLC, Sample Group 1120232. 

Samples Arrived at Laboratory November 14, 2008. 74 Pages. 

62. Tetra Tech. Electronic Mail Correspondence Regarding Kerr-McGee Columbus Property Fenceline 

and Run-on and Runoff Control Systems. Between Shanna Davis, Environmental Scientist and Russ 

McLean, Project Manager, RCRA Division, EPA. September 1, 2010. 1 Page. 

63. Kerr-McGee, Hydrologic Services Group. Sampling and Analysis Plan, Kerr-McGee Chemical 

LLC, Columbus, Mississippi. Report Dated April 1, 1987. Last Revision June 15, 2003. 486 Pages. 

64. Lancaster Laboratories. Analysis Report Prepared for Tronox LLC, Sample Group 1119589. 

Samples Arrived at Laboratory November 12, 2008. 53 Pages. 

65. MDEQ, Office of Pollution Control. Mississippi Source Water Assessment Program Plan. 

Accessed September 8, 2010. 208 Pages. Accessed On-line at 

http://www.deq.state.ms.us/mdeq.nsf/pdf/GPB_MSSourceWaterAssessmentProgram/$File/msswapp

.pdf?OpenElement. 

66. Environmental Resources Management (ERM). Letter with Attachment Regarding the Interim 

Measures Report. From: Barrett A. Cieutat, P.G., Senior Associate, Environmental Resources 

Management. To: Steve Ladner, Kerr-McGee Chemical LLC. Attachment: Interim Measures 

Report, Columbus, Mississippi. Prepared on Behalf of Kerr-McGee. Letter Dated May 2, 2005. 

Report Dated April 29, 2005. 489 Pages. 

67. ERM EnviroClean-Southwest, LLC. Interim Measures Work Plan, Kerr-McGee Columbus, 

Mississippi. Prepared on Behalf of Kerr-McGee. August 8, 2004. 34 Pages. 
17

68. EPA, Region 4 Science and Ecosystem Support Division (SESD). Final Analytical Report, Project: 

10-0409, Tronox Inc. June 11, 2010. 88 Pages. 

69. EPA, Region 4. Memorandum Regarding Data Evaluation, Tronox (Kerr-McGee Site), Columbus, 

Lowndes County, Mississippi. From: Tim Frederick, Life Scientist, Superfund Division. To: Russ 

McLean, Project Manager, RCRA Division. August 6, 2010. 10 Pages. 

70. EPA, Region 4. Memorandum Regarding Final Report (Tronox, Incorporated), Columbus, 

Mississippi, SESD Project No. 10-0409. From: Art Masters, Enforcement Section. To: Russ 

McLean Corrective Action Section, Resource Conservation and Recovery Act (RCRA), EPA. 

September 17, 2010. 142 Pages.

71. Tetra Tech. Electronic Mail Correspondence Regarding Kerr-McGee Columbus Drainage Ditches. 

Between Shanna Davis, Environmental Scientist and Russ McLean, Project Manager, RCRA 

Division, EPA. September 7, 2010. 1 Page. 

72. Tetra Tech. Electronic Mail Correspondence Regarding Kerr-McGee Columbus Storm Water 

Runoff. Between Shanna Davis, Environmental Scientist and Russ McLean, Project Manager, 

RCRA Division, EPA. September 7, 2010. 1 Page. 

73. EPA, Region 4 SESD. Field Branches Quality System and Technical Procedures for Sediment

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

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

74. USGS. Surface Water Annual Statistics for Mississippi. Luxapallila Creek Near Columbus, 

Mississippi. Updated August 26, 2010. Accessed September 8, 2010. 3 Pages. Annual Statistics 

Accessed On-line at http://waterdata.usgs.gov/ms/nwis/annual/. Map Accessed On-line at 

http://wdr.water.usgs.gov/nwisgmap/map_only.html?site_no=02443500&agency_cd=USGS. 

75. EPA, Region 4 SESD. Analytical Support Branch Laboratory Operations and Quality Assurance 

Manual. January 11, 2010. 206 Pages. 

76. Tetra Tech. Record of Telephone Conversation Regarding Definitions of Minimum Reporting 

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

Limit. Between Shanna Davis, Environmental Scientist, and Charlie Appleby, Quality Assurance 

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

77. Kerr-McGee, Forest Products Division. Letter with Attachments Regarding the Confirmatory 

Sampling Report. From: Jami Poor, Senior Hydrologist. To: Bruce Ferguson, Office of Pollution 

Control. Attachments: Map Depicting Locations of Soil Borings Taken from Solid Waste 

Management Unit and Analytical Results. October 4, 1995. 55 Pages. 

78. Kerr-McGee, Forest Products Division. Letter with Attachment Regarding the Preliminary 

Assessment Dated March 19, 1984. From P.C. Gaskin, Environmental & Quality Control, KerrMcGee. To Paul Bierstine, Bureau of Pollution Control, MDNR. Attachment: Answers to 

Questions. April 11, 1984. 4 Pages. 

79. Tetra Tech. Electronic Mail Correspondence Regarding Kerr-McGee Columbus Surface Water 

Runoff from Outfall No. 002. Between Shanna Davis, Environmental Scientist and Russ McLean, 

Project Manager, RCRA Division, EPA. September 9, 2010. 1 Page. 

80. EPA. Envirofacts Warehouse, Safe Drinking Water Information System. List of Surface Water 

Systems in Lowndes County, Mississippi. Data Extracted April 23, 2010. Accessed September 9, 

2010. 2 Pages. Accessed On-line at http://www.epa.gov/enviro/html/sdwis/sdwis_ov.html. 
18

81. Tetra Tech. Project Note to File with Attachment. Subject: Coordinates for the Kerr-McGee 

Property. Attachment: Google Earth Map. August 9, 2010. 2 Pages. 

82. Kerr-McGee, Forest Products Division. RCRA Part B Modification/Engineering Feasibility Plan, 

Post-Closure Permit Application. April 12, 1990. 625 Pages. 

83. Tetra Tech. Project Note to File with Attachments. Subject: Columbus Brick Company. 

Attachments: Parcel Information and Maps, Company Information. September 9, 2010. 17 Pages. 

84. Kerr-McGee, Forest Products Division. Post-Closure Permit Application, Part B, Columbus 

Facility. May 12, 2000. Revised September 21, 2000. 341 Pages. 

85. EPA. CLP Chain-of-Custody for Tronox Inc Samples Shipped to SESD Regional Laboratory. Date 

Shipped April 28, 2010. 3 Pages. 

86. Tetra Tech. Project Note to File. Subject: Area of Northern Kerr-McGee Property. September 13, 

2010. 1 Page. 

87. USGS in Cooperation with the Mississippi Board of Water Commissioners. Cretaceous Aquifers of 

Northeastern Mississippi. By Earnest H. Boswell. Bulletin 63-10. 1963. 106 Pages

88. Tetra Tech. Approximate Location of Hooker Chemical Co. Observation Well and Soil Boring. 

Source of Map: U.S. Geological Survey, 7.5-minute series. Topographic Maps of Mississippi: 

Columbus North 1987, Steens 1987, Columbus South 1987, New Hope 1987. Scale, 1:72,000. 1 

Map.

89. OxyChem. Letter Regarding Information Request - Perchlorates. To Kathi Moore, Superfund 

Branch, Superfund Cleanup Branch, EPA Region 9. January 29, 2002. 8 Pages.

90. B2B Yellow Pages. Occidental Chemical Corp. Accessed September 15, 2010. 2 Pages. Accessed 

On-line at http://www.b2byellowpages.com/company-information/77495792-occidental-chemicalcorp.html. 

91. Tetra Tech. Project Note to File with Attachments. Subject: Review of Environmental Testing and 

Certification (ETC) 1988 Report Numbers (Nos.) BD0647 through BD0658 for TDD No. TTEMI05-003-0096 (Kerr-McGee Chemical Corp). Attachments: ETC Report Nos. BD0647 through 

BD0658. September 16, 2010. 38 Pages. 

92. Tetra Tech. Project Note to File with Attachments. Subject: Review of Southwest Laboratory of 

Oklahoma, Inc. 1996 Data for TDD No. TTEMI-05-003-0096 (Kerr-McGee Chemical Corp). 

Attachment: Analytical Data for Project KMFP-COL RFI-1996. September 16, 2010. 9 Pages. 

93. Tetra Tech. Project Note to File with Attachments. Subject: Review of Southwest Laboratory of 

Oklahoma, Inc. 2002 Data for TDD No. TTEMI-05-003-0096 (Kerr-McGee Chemical Corp). 

Attachment: Analytical Data for Project GWM. September 16, 2010. 15 Pages. 

94. Tetra Tech. Project Note to File with Attachment. Subject: Review of Lancaster Laboratories Inc. 

2008 Report Number 1120232 for TDD No. TTEMI-05-003-0096 (Kerr-McGee Chemical Corp). 

Attachment: Report Number 1120232. September 16, 2010. 75 Pages. 

95. Tetra Tech. Project Note to File with Attachment. Subject: Review of Lancaster Laboratories Inc. 

2008 Report Number 1119589 for TDD No. TTEMI-05-003-0096 (Kerr-McGee Chemical Corp). 

Attachment: Report Number 1119589. September 16, 2010. 54 Pages.
19

96. Tetra Tech. Project Note to File with Attachments. Subject: Review of ETC 1986 Report Nos. 

M4433 and M6279 TDD No. TTEMI-05-003-0096 (Kerr-McGee Chemical Corp). Attachments: 

ETC Report Nos. M4433 and M6279. September 16, 2010. 81 Pages.

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

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

November 1996. 18 Pages. 

98. U.S. Census Bureau. Lowndes County QuickFacts. Accessed September 21, 2010. 2 Pages. 

Accessed On-line at http://quickfacts.census.gov/qfd/states/28/28087.html. 

99. Tetra Tech. Record of Telephone Conversation. Subject: Kerr-McGee - Columbus. Between 

Jessica Vickers, Quality Assurance Manager, and Douglas Weir, Quality Assurance Manager, Test 

America Laboratories, Inc. September 21, 2010. 1 Page. 

100. EPA. Memorandum regarding Quality Assurance Project Plan (Tronox, Incorporated), Columbus, 

Mississippi, SESD Project No. 10-0409. From Art Masters, Enforcement Section. To Russ McLean 

Corrective Action Section, RCRA Division, EPA. April 23, 2010. 8 Pages. 

101. Tetra Tech. Project Note to File with Attachments. Subject: Logbook Notes for the 2010 EPA 

Region 4 Sampling Event. Attachments: Logbook Notes. September 28, 2010. 27 Pages.

102. Tetra Tech. Project Note to File with Attachments. Subject: Calculation of Net Precipitation for 

Columbus, Mississippi for the Period of 2000 to 2009. Attachments: Weather Warehouse Monthly 

Weather Data, Excerpt from the HRS Rule, and Calculations. December 20, 2010. 61 Pages. 

103. Tetra Tech. Project Note to File with Attachments. Subject: Chain of Custody Entry for Sample 

SB3 for Source No. 3. Attachments: Chain of Custody and Analytical Data Sheets. January 25, 

2011. 5 Pages.

104. EPAOSC.org. Site Profile, Kerr-McGee Chemical (Columbus) aka Tronox. Prepared by Steve 

Spurlin, EPA On-Scene Coordinator. Accessed January 25, 2011. 1 Page. Accessed On-line at 

http://www.epaosc.org/site/site_profile.aspx?site_id=6416. 

105. Tetra Tech. Electronic Mail Correspondence Regarding Containment Structures and Removals at 

Kerr-McGee Columbus. Between Sandra Harrigan, Project Manager and Russ McLean, RCRA 

Division, EPA. January 24, 2011. 4 Pages. 
20 Site Description

SITE DESCRIPTION

Kerr-McGee Chemical Corp-Columbus (Kerr-McGee) is located east of the intersection of North 20th

Street and North 14th Avenue (Ref. 81) (see Figures 1, 2, and 2a of this Hazard Ranking System [HRS] 

documentation record). The Kerr-McGee property is also known as the Kerr-McGee Chemical 

Corporation, Forest Products Division, Columbus, Mississippi facility (Ref. 82, pp. i, 3). More 

specifically, the geographic coordinates as measured from the backfilled surface impoundments located 

on the northwestern portion of the southern Kerr-McGee property are latitude 33o 30' 35.16" north and 

longitude 88o 24' 34.87" west (Refs. 7, pp. 1, 2, 5; 81; 82, p. 30). The EPA identification number as 

recorded in the Comprehensive Environmental Response, Compensation and Liability Information 

System (CERCLIS) database is MSD990866329 (Ref. 8). 

The property consists of five parcels of land covering a total area of about 90 acres (Refs. 9, pp. i through 

15; 82, pp. 10, 11). Land uses surrounding the property are predominantly commercial, industrial, and 

residential (Refs. 10; 12, p. 4). The Kerr-McGee property is bounded by a church, residential, and 

commercial properties to the north; a cemetery to the south; railroad tracks to the east; and a high school 

and residential properties to the west (Refs. 10, pp. 2, 3; 11, p. 5; 12, pp. 4, 5) (see Figure 1 of this HRS 

documentation record). The Kerr-McGee property is divided into two sections by North 14th Avenue (see 

Figures 1, 2, and 2a of this HRS documentation record). In this HRS documentation record, the section 

located to the north of North 14th Avenue will be referred to as the northern Kerr-McGee property and the 

section located to the south of North 14th Avenue will be referred to as the southern Kerr-McGee 

property. When referring to both the northern and southern sections of the Kerr-McGee property, the 

term “Kerr-McGee property” will be used (see Figures 2 and 2a of this HRS documentation record). 

The facility is closed and all structures located on the Kerr-McGee property have been decommissioned 

and dismantled (Refs. 12, p. 5; 56, p. 1). Access to the property is restricted by a fence, which surrounds 

the entire property (Ref. 62). Structures formerly located on the Kerr-McGee property include an inground pit, sumps, underground drip collection tanks, aboveground tanks, boiler, oil-water separators, 

surface impoundments, unlined sand filter beds, waste piles, and a pine yard (Refs. 7, p. 5; 13, 

Attachment B, pp. B-1 through B-31; 14, p. 3; 15, pp. 2, 4; 16, pp. 1, 5; 84, p. 68). 

For HRS scoring purposes, three sources have been identified on the Kerr-McGee property. Source No. 1 

consists of two backfilled surface impoundments, Source No. 2 consists of contaminated soil underlying 

the former drip pad area, and Source No. 3 consists of contaminated soil located in various areas of the 

Kerr-McGee property (Refs. 7, pp. i, 4, 5, 7; 17, p. 20; 14, pp. 26, 29; 18, pp. 1, 22; 54, pp. 2, 19, 23 

through 27, 42, 50, 120, 121, 122; 56, pp. 9, 13). Hazardous substances including acenaphthylene, 

benzo(a)anthracene, benzo(a)pyrene, carbazole, fluoranthene, indeno(1,2,3-cd)pyrene, naphthalene, 

phenanthrene, pentachlorophenol (PCP), and 1,2,3,4,6,7,8-heptachlordibenzodioxin (HpCDD) have been 

detected in Source Nos. 1, 2, and/or 3 (see Section 2.2.1, Source Nos. 1, 2, and 3 and Figure 3 of this HRS 

documentation record). 

Ground water underlying and/or downgradient of Source Nos. 1, 2, and 3 contain the same constituents at 

concentrations greater than background levels, indicating that a release of hazardous substances has 

occurred to the ground water migration pathway as documented in Section 3.0 of this HRS documentation 

record. Ten drinking water wells serving 34,817 people are located within a 4-mile radius of sources on 

the Kerr-McGee property and are evaluated as potential target wells (see Section 3.3 and Table 23 of this 

HRS documentation record). 

Sediment samples collected from a perennial drainage ditch, which receives runoff from Source Nos. 1, 2, 

and 3, contain the same constituents at concentrations greater than background levels, indicating 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. The drainage ditch begins at the northwestern boundary 

of the southern Kerr-McGee property, flows about 1.38 miles, and enters Luxapallila Creek (Refs. 4; 55, 

p. 21a; 71). Fishing occurs on Luxapallila Creek; some of the fish are eaten (Refs. 12, p. 5; 71) (see 

Section 4.0 of this HRS documentation record). 
21 Site Description

OPERATIONAL AND REGULATORY HISTORY

From 1928 until 2003, a wood preserving facility operated on the Kerr-McGee property (Refs. 14, p. 9; 

56, p. 1). The facility manufactured pressure-treated railroad products including wooden cross ties, 

switch ties, and timbers using several preservatives including PCP, creosote, and creosote coal tar 

solutions (Refs. 14, p. 9; 19, pp. 1, 2; 82, pp. 10, 13). PCP was used from 1928 through 1976 (Refs. 19, 

pp. 1, 2; 82, p. 13). Xylene was also used as a drying agent for untreated wood from 1970 through 1974 

(Refs. 13, p. I-1; 19, p. 2). The facility manufactured products for Burlington Northern Railroad, Norfolk 

Southern Railroad, and several regional railroad contractors (Ref. 82, p. 10). 

Kerr-McGee acquired the facility from T.J. Moss in 1964 (Ref. 14, p. 9). Following its purchase, the 

facility became part of Moss American Corporation, a wholly-owned subsidiary of Kerr-McGee 

Corporation. In 1974, Moss American Corporation became the Forest Products Division of Kerr-McGee 

Chemical Corporation (Ref. 82, p. 10). Currently, the property is owned by Tronox (Ref. 25, pp. 1, 20). 

During former operations, green lumber was received at the plant and sorted by type and grade of wood. 

The wood was then seasoned by natural air drying, which required the wood to be stacked in a drying 

yard for up to 12 months, or by artificial seasoning using the Boulton process. The wood was then 

pressure-treated in a retort (Ref. 17, p. 13). The Boulton drying process involved subjecting the green 

lumber to heated creosote under a vacuum, which boils the sapwater out of the wood (Ref. 17, pp. 92, 93). 

The pressure treating process involved filling a cylinder with creosote and applying pressure to force the 

creosote into the wood (Ref. 17, p. 93). Prior to 1986, two surface impoundments received the 

wastewater generated from the production process. Sludge, which formed at the bottom of the 

impoundments from the carryover of creosote, was classified as EPA hazardous waste K001: “bottom 

sediment sludge from the treatment of wastewaters from wood preserving processes that use creosote 

and/or pentachlorophenol” (Ref. 17, p. 15). The primary constituent compounds of creosote include 2-

chlorophenol; 2,4-dimethylphenol; p-chloro-m-cresol; pentachlorophenol; phenol; 2,4,6-trichlorophenol; 

2,3,4,6-tetrachlorophenol; 2,4-dinitrophenol; acenaphthylene; benzo(a)anthracene; benzo(a)pyrene; 

benzo(b)fluoranthene; carbazole; dibenz(a,h)anthracene; fluoranthene; indeno(1,2,3-cd)pyrene; 

naphthalene; and phenanthrene (Ref. 54, p. 42). These constituents are listed as K001 hazardous waste 

and were used at the Columbus, Mississippi Kerr-McGee facility (Refs. 28, p. 175; 54, p. 42). 

As a part of facility operations, hazardous waste (regulated by the Resource Conservation and Recovery 

Act [RCRA]) was generated on the Kerr-McGee property (Ref. 11, p. 2). Former releases from the 

production process area impacted the quality of local ground water (Ref. 54, p. 1). In 1989, Kerr-McGee 

entered into a consent order with the Bureau of Pollution Control (MBPC) of the Mississippi Commission 

on Environmental Quality (MCEQ), now called the Mississippi Department of Environmental Quality 

(MDEQ) (Refs. 6, p. vi; 21, p. 7; 24, pp. 1 through 4). The consent order required submittal of a Part B 

Post-Closure Permit Application (April 1990, revised) to comply with the requirements of RCRA (Ref. 

11, p. 2). The permit application included a proposal for recovery of creosote product from the 

subsurface of the facility (Ref. 54, p. 1). Once the Part B Post-Closure Permit Application was approved, 

Hazardous Waste Permit No. HW-90-329-1 was issued on September 11, 1990 (Ref. 11, p. 2). On 

August 1, 1995, EPA issued the facility a Hazardous and Solid Waste Amendments (HSWA) permit, 

which governs the solid waste management units (SWMU). The HSWA permit required that KerrMcGee perform a RCRA facility investigation (RFI) at the property to address 15 SWMUs grouped into 

eight solid waste management areas (SWMA) (Refs. 11, p. 2; 54, pp. 1, 2). On June 11, 2001, a 

modification to Hazardous Waste Permit No. HW-90-329-1 was issued incorporating interim corrective 

action measures; this permit will be effective until May 31, 2011 (Ref. 25, p. 1). 

Ground water sampling is performed semi-annually by Tronox as required by Section V.G.1, 2 of 

Hazardous Waste Permit No. HW-90-329-1 (Ref. 25, pp. 1, 2). 

At an unspecified time, Kerr-McGee was authorized to discharge stormwater to drainage ditches at five 

outfall locations under National Pollutant Discharge Elimination System (NPDES) Permit MSR20010 

(Refs. 54, p. 10; 55, p. 13; 57, p. 5-5). The permit required the facility to sample all stormwater outfalls 
22 Site Description

annually for releases to surface water from the drainage ditches. The permit required testing for pH, oil 

and grease, total phenols, and total suspended solids, as well as visually inspecting the drainage 

ditches/stormwater outfalls on a monthly basis for oil sheens or other indicators of releases to the 

environment (Ref. 14, pp. 18, 19). 

PREVIOUS INVESTIGATIONS

In July 1981, Kerr-McGee installed a ground water monitoring system consisting of five monitoring wells 

to monitor the surface impoundments (CMW-1 through CMW-5) (Refs. 21, p. 5; 22, p. 1; 23, pp. 1, 2). 

The monitoring system represented a first level detection system for the hazardous waste unit as specified 

by RCRA (Ref. 82, p. 52). The monitoring wells were installed in alluvial material overlying the Eutaw 

Formation (Ref. 82, pp. 52, 58). 

The impoundments were closed in 1987 in accordance with the MBPC-approved closure plan (Refs. 7, p. 

1; 82, p. 20). Following closure of the impoundments, Kerr-McGee collected samples at the bottom of 

the surface impoundments. One sample was collected from Impoundment No. 1 (aeration impoundment) 

and five samples were collected from Impoundment No. 2 (sedimentation impoundment). The samples 

were collected from 0 to 6 inches below the bottom surface of the impoundments (Ref. 7, pp. 4, 5; 17, p. 

15). The soil samples contained acenaphthylene (1,760 μg/kg); benzo(a)anthracene (8,900 μg/kg); 

benzo(a)pyrene (3,220 μg/kg); fluoranthene (up to 88,900 μg/kg); indeno(1,2,3-cd)pyrene (792 μg/kg); 

naphthalene (up to 7,970 μg/kg); phenanthrene (up to 52,500 μg/kg); and carbazole (8,640 μg/kg) (Ref. 7, 

pp. 5, 7). Because clean closure was not accomplished, Kerr-McGee submitted a Part B post-closure 

permit application in March 1987 (Refs. 17, p. 9; 27, pp. 1, 3). 

In September 1987, Kerr-McGee notified MBPC of the presence of dissolved creosote constituents in 

monitoring wells downgradient of the closed surface impoundments (Refs. 13, pp. II-11, II-13; 21, p. 7). 

Subsequently, a RCRA Facility Assessment (RFA) was conducted by A.T. Kearney, Inc. on behalf of 

EPA (Ref. 13, p. iv). The RFA included a preliminary review of available and relevant documents and a 

visual site inspection (Ref. 13, p. I-1). The RFA identified 41 SWMUs and one area of concern (AOC). 

Of the units identified, 32 were determined to have a potential for release to one or more environmental 

pathway (Ref. 13, p. III-1). The RFA suggested conducting a RFI at the facility (Ref. 13, p. ii). 

In 1988, the facility installed a concrete drip pad (track) to collect excess preservative that dripped off the 

wood following removal from the cylinder (Refs. 13, Attachment B, p. B-24; 14, pp. 10, 27; 82, p. 17). 

Prior to 1988, preservative (creosote and PCP) dripped onto bare soil at the current location of the drip 

pad (Refs. 13, p. ii, Attachment B, p. B-24; 82, p. 13). The new drip pad was constructed after visually 

impacted soil from the area was excavated to a depth of 4 feet. Soil samples were collected from 6 inches 

below the surface of the excavation designated as visually clean (Ref. 14, p. 26). The samples contained 

2,4-dimethylphenol (up to 14,400 μg/kg); p-chloro-m-cresol (up to 10,000 μg/kg); PCP (up to 358,000 

μg/kg); phenol (up to 23,200 μg/kg); 2,4,6-trichlorophenol (1,870 μg/kg); 2,3,4,6-tetrachlorophenol 

(11,000 μg/kg); acenaphthylene (up to 113,000 μg/kg); benzo(a)anthracene (up to 476,000 μg/kg); 

benzo(a)pyrene (up to 193,000 μg/kg); fluoranthene (up to 2,180,000 μg/kg); indeno(1,2,3-cd)pyrene 

(4,990 μg/kg); naphthalene (up to 1,930,000 μg/kg); phenanthrene (up to 3,420,000 μg/kg); and carbazole 

(up to 340,000 μg/kg) (Refs. 13, Attachment E, p. E-14; 18, p. 22). These constituents are listed as K001 

hazardous waste and were used at the Columbus, Mississippi Kerr-McGee facility (Refs. 28, p. 175; 54, 

p. 42). Due to the residual contamination that was left in place, the ground water pathway remains a 

concern in this area of the Kerr-McGee property (Ref. 14, p. 29). 

In 1989, Kerr-McGee entered into a consent order with MBPC because of the discovery of creosote 

product in monitoring wells downgradient of the closed impoundments (Refs. 21, p. 7; 24, pp. 1 through 

4). Numerous investigations have been conducted on the Kerr-McGee property to delineate ground water 

and soil contamination as well as to define the lateral and vertical extent of impacted surface water and 

sediment associated with wood preserving operations (Refs. 11, p. 8; 14, p. 14). 
23 Site Description

In 1996, Kerr-McGee conducted a RFI at the facility. The primary objectives of the RFI were to 

characterize the nature and extent of releases of hazardous waste, including hazardous constituents and 

affected media, and to identify actual or potential receptors (Ref. 54, p. 2). During the RFI, four SWMAs 

(SWMA IV, SWMA V, SWMA VII, SWMA VIII) were investigated to assess the nature and extent of 

impacts to soil and sediment within these areas (Ref. 54, pp. 23 through 27). 

Three surface and three subsurface soil samples were collected from SWMA IV (primary and secondary 

oil-water separators, holding tanks, and underground wastewater piping); one subsurface soil and three 

surface soil samples were collected from SWMA V (former cooling tower impoundment); four surface 

soil samples were collected from SWMA VII (treated wood storage area in the eastern section of the 

facility); and 10 sediment samples were collected from SWMA VIII (unlined ditches that collect surface 

water runoff from the facility) (Ref. 54, pp. 23 through 27, 59 through 61a). The surface and subsurface 

soil samples contained creosote constituents including 2,4-dimethylphenol, acenaphthylene, 

benzo(a)anthracene, benzo(a)pyrene, carbazole, dibenz(a,h)anthracene, fluoranthene, indeno(1,2,3-

cd)pyrene, naphthalene, PCP, and phenanthrene (Ref. 54, pp. 23 through 27, 42, 120, 121, 122, 124, 125). 

The sediment samples collected during the RFI were collected from the five NPDES Outfalls. Two 

sediment samples were collected from each Outfall location. Specifically, one sediment sample was 

collected within the Kerr-McGee property boundary at the beginning of the ditch and a second sediment 

sample was collected at the location where the ditch left the property (Ref. 54, pp. 26, 27, 119). The 

sediment samples contained creosote constituents including acenaphthylene, benzo(a)anthracene, 

benzo(a)pyrene, carbazole, dibenz(a,h)anthracene, fluoranthene, indeno(1,2,3-cd)pyrene, naphthalene, 

PCP, and phenanthrene (Ref. 54, pp. 42, 116, 117, 119, 120). 

In 1998, Kerr-McGee conducted a Phase II RFI at the facility (Ref. 55, pp. 8, 12, 15, 16, 17). The Phase 

II RFI included advancement of seven soil borings and collection of three sediment samples (Ref. 55, pp. 

12 through 17, 21a, 48 through 54). The soil borings were advanced west of the production process area 

located on the southern Kerr-McGee property (Refs. 55, pp. 16, 23; 82, p. 30). Creosote stains and odors 

were noted in two of the borings located closest to the property (Ref. 55, pp. 16, 51, 54). Sediment 

samples were collected from the drainage ditch located to the east of the southern Kerr-McGee property, 

and the drainage ditch located south of the southwestern corner of the southern Kerr-McGee property

(Ref. 55, p. 21a). The sediment samples contained creosote constituents, including benzo(a)pyrene, 

benzo(b)fluoranthene, fluoranthene, indeno(1,2,3-cd)pyrene, and phenol (Ref. 55, pp. 26, 27, 30, 31, 32). 

In 2001 and 2002, Kerr-McGee conducted Supplemental Phase II RFI sampling activities at the property 

(Ref. 11, pp. 1, 4). The supplemental sampling activities were conducted to characterize constituent 

distribution in the sediment and surface water contained in drainage ditches surrounding the Kerr-McGee 

property (Ref. 11, p. iii). Sampling activities included collection of six surface water and 24 sediment 

samples (Ref. 11, pp. 8, 9, 13). The surface water samples did not contain constituents at concentrations 

above their respective quantitation limits (Ref. 11, pp. 34, 35, 36, 53, 54). The sediment samples 

contained creosote constituents including benzo(a)anthracene, benzo(a)pyrene, chrysene, 

dibenz(a,h)anthracene, indeno(1,2,3-cd)pyrene, and PCP (Refs. 11, p. 30; 54, p. 42). Creosote 

compounds were detected at depths up to 13 feet below the ditch bed (Refs. 11, pp. 9, 30, 37 through 41; 

54, p. 42). The highest concentrations of creosote compounds were detected in sediment samples 

collected along the northern boundary of the southern Kerr-McGee property (SB10-B) and downstream of 

Outfall 001 (SB02-A) located at the southwestern corner of the southern Kerr-McGee property (Refs. 11, 

p. 30; 54, p. 42) (see Figure 5 of this HRS documentation record). 

In 2004, ERM EnviroClean-Southwest, LLC (ERM) conducted interim remedial measures at the property 

on behalf of Kerr-McGee (Ref. 66, pp. v, 1). The interim measures focused on excavation and off-site 

disposal of ditch sediments impacted by polynuclear aromatic hydrocarbons (PAH) that exceeded their 

respective EPA Region 9, Preliminary Remediation Goals (PRG) of 1 × 10-4 (Ref. 66, pp. 3, 15). 

Impacted ditch sediments were removed from four areas within drainage ditches on and bordering the 

Kerr-McGee property (Ref. 66, p. 6, 7, 16). A total of 1,780 linear feet of ditch sediments were removed 

up to 3 feet below the bed of the ditches (Ref. 66, pp. 7, 8, 17). 
24 Site Description

In 2008, EPA advised Tronox that additional soil sampling was required as a part of the RFI process to 

determine whether polychlorinated dibenzo-dioxins (PCDD) and polychlorinated dibenzofurans (PCDF) 

were present on soil and sediments at the property. AquAeTer, Inc. (AquAeTer), on behalf of Tronox, 

conducted supplemental soil sampling at the property (Ref. 56, pp. 1, 2, 4, 63). Surface soil samples were 

collected in five areas including the former wood treating area, former black tie storage area, Brickyard 

SWMU, surface water drainage channel in the former green tie storage yard, and a surface water channel 

located south of the former wood treating area (Ref. 56, pp. 2, 9). Ten surface soil samples collected from 

0 to 1 foot below ground surface (bgs) contained several PCDD and PCDF congeners (Ref. 56, pp. 6, 13). 

During the 2008 semi-annual ground water sampling event conducted by Tronox, monitoring wells 

contained hazardous constituents including naphthalene (up to 4,600 μg/L); phenanthrene (up to 1,300 

μg/L); benzo(a)pyrene (up to 150 μg/L); and dibenz(a,h)anthracene (66 μg/L), among others (Refs. 25, 

pp. ii, 42 through 83; 54, p. 42). 

In 2010, the EPA Region 4 Science and Ecosystem Support Division (SESD) collected sediment samples 

from drainage ditches surrounding the Kerr-McGee property (Ref. 68, p. 3; 70, pp. 5, 6). The sediment 

samples contained creosote constituents above background levels including benzo(a)anthracene (up to 

11,000 μg/kg); benzo(a)pyrene (up to 24,000 μg/kg); dibenz(a,h)anthracene (5,500 μg/kg); indeno(1,2,3-

cd)pyrene (up to 15,000 μg/kg); and naphthalene (up to 1,100 μg/kg), among others (Refs. 25, p. 32; 68, 

pp. 57 through 85; 69, p. 4). EPA is in the process of evaluating the sampling results and will determine 

if additional sampling or cleanup is necessary (Ref. 104). 

A variety of recovery methods are utilized on the Kerr-McGee property for collection of both creosote 

product and dissolved constituents in the ground water (Ref. 25, p. 12). In 1992, three containment 

trenches (Trench #1, Trench #1A, and Trench #2) along with three collection galleries (MH1, MH2, and 

MH3) were installed and serve as hydraulic barriers for capture of dissolved constituents as well as 

settings for recovery of free product (Refs. 25, pp. 12, 21, 34; 26, pp. 23, 40). Two of the three trenches 

are located to the south of the southern Kerr-McGee property and the third trench is located on the 

southeastern portion of the southern Kerr-McGee property. The collection galleries are located adjacent 

to the trenches (Ref. 25, p. 21). 

Twelve alluvial recovery wells have been installed at the property (from 1989 to 1997) and a total of 21 

alluvial piezometers (installed from 1990 to 1994) are in place to monitor the recovery wells and trench 

efficiency (Ref. 25, pp. 12, 30, 34). 

Beginning in 2003, ground water is routed through a new ground water treatment system. The system 

includes two 17,000-gallon tanks and one 31,800-gallon oil-water separator, which are used for oil-water 

separation and settlement of creosote product. The separated creosote is collected in storage tanks and 

sold as wood treating product (Ref. 25, p. 12). More than 160 million gallons of impacted ground water 

and free product have been recovered and treated since the installation of the recovery system in August 

1990 (Ref. 25, pp. 16, 17). Currently, 41 alluvial monitoring wells, 21 alluvial piezometers, and five 

Eutaw Formation monitoring wells are located on or near the southern Kerr-McGee property for ground 

water assessment purposes (Ref. 25, pp. 2, 21). Tronox, successor to Kerr-McGee and the sole potentially 

responsible party, has declared bankruptcy. Efforts to settle the bankruptcy are ongoing, and in the 

interim some funds have been provided to keep the ground water treatment system operating. The 

funding set aside is inadequate to completely address the site contamination (Ref. 104). 
Source No. 1

25 Source Description

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Number of source: 1

Name of source: Backfilled surface impoundments 

Source Type: Backfilled surface impoundment 

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

Source No. 1 consists of two backfilled surface impoundments located in the northwestern portion of the 

southern Kerr-McGee property (Refs. 13, Attachment B, pp. B-20, B-21; 15, p. 4; 25, p. 21) (see Figure 3 

of this HRS documentation record). Impoundment No. 1 (aeration impoundment) was about 50 feet wide 

by 50 feet long and Impoundment No. 2 (sedimentation impoundment) was about 60 feet wide by 225 

feet long (Ref. 7, p. 5). The impoundments were closed as a single unit (Refs. 82, p. 30; 84, p. 122). 

From 1928 until 2003, a wood preserving facility was operated on the property (Refs. 54, p. 3; 56, p. 1). 

The facility manufactured pressure-treated railroad products including wooden cross ties, switch ties, and 

timbers using several preservatives including PCP, creosote, and creosote coal tar solutions (Refs. 14, p. 

9; 19, pp. 1, 2; 82, pp. 10, 13). Constituents found in creosote include 2-chlorophenol; 2,4-

dimethylphenol; p-chloro-m-cresol; pentachlorophenol; phenol; 2,4,6-trichlorophenol; 2,3,4,6-

tetrachlorophenol; 2,4-dinitrophenol; acenaphthylene; benzo(a)anthracene; benzo(a)pyrene; 

benzo(b)fluoranthene; carbazole; dibenz(a,h)anthracene; fluoranthene; indeno(1,2,3-cd)pyrene; 

naphthalene; and phenanthrene (Ref. 54, p. 42). 

Prior to 1986, the two surface impoundments were used for the storage, treatment, and ultimate disposal 

of creosote and PCP, wastewater, and sludges from the wood treating operations (Refs. 13, p. I-1; 17, p. 

15). Sludge, which formed at the bottom of the impoundments from the carryover of creosote, was 

classified as EPA hazardous waste K001: “bottom sediment sludge from the treatment of wastewaters 

from wood preserving processes that use creosote and/or pentachlorophenol” (Ref. 17, p. 15). 

Closure of the impoundments began in 1986 and was completed in 1987. Closure activities were 

conducted by Kerr-McGee in accordance with the MBPC-approved closure plan (Refs. 7, p. 13; 17, p. 15; 

82, p. 20). Following removal of contaminated material from the impoundments, Kerr-McGee collected 

samples at the bottom of the surface impoundments. One sample was collected from Impoundment No. 1 

and five samples were collected from Impoundment No. 2. The samples were collected from 0 to 6 

inches below the bottom surface of the impoundments (about 2.5 to 9 feet bgs) (Refs. 7, pp. 3, 4, 5; 17, p. 

15). The samples contained creosote compounds including acenaphthylene, benzo(a)anthracene, 

benzo(a)pyrene, benzo(b)fluoranthene, fluoranthene, indeno(1,2,3-cd)pyrene, naphthalene, phenanthrene, 

and carbazole (Refs. 7, p. 7; 54, p. 42). Because clean closure was not accomplished, Kerr-McGee 

submitted a Part B post-closure permit application in March 1987 (Ref. 27, pp. 1, 3). MDEQ 

subsequently issued a hazardous waste permit to Kerr-McGee in September 1990 (Ref. 25, p. 1). 
Source No. 1

26 Source Description

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

May and June 1986 – Samples Collected from Soil at the Bottom of the Backfilled Surface 

Impoundments 

Source samples listed in Table 1 were collected by Kerr-McGee during closure of the backfilled surface 

impoundments (Ref. 7, pp. 4, 54, 270). Following removal of all visibly contaminated material from the 

surface impoundments, samples were collected from 0 to 6 inches below the bottom surface of the 

impoundments (Ref. 7, pp. 3, 4). 

Sludge, which formed at the bottom of the impoundments from the carryover of creosote, was classified 

as EPA hazardous waste K001: “bottom sediment sludge from the treatment of wastewaters from wood 

preserving processes that use creosote and/or pentachlorophenol” (Ref. 17, p. 15). Constituents found in 

creosote include acenaphthylene; benzo(a)anthracene; benzo(a)pyrene; benzo(b)fluoranthene; carbazole; 

fluoranthene; indeno(1,2,3-cd)pyrene; naphthalene; and phenanthrene, among others (Ref. 54, p. 42). 

Clean closure of the backfilled surface impoundments was not accomplished (Refs. 7, pp. 4 through 8; 27, 

pp. 1, 3). Reports describing closure of the impoundments do not mention the presence of a liner. 

Therefore, creosote contamination located at the bottom of and immediately beneath the surface 

impoundments would be representative of wood preserving wastes in the impoundments. 

The source samples listed in Table 1 were collected in accordance with applicable EPA, state, and 

corporate protocols (Ref. 7, pp. 54, 270). All samples were analyzed by Environmental Testing and 

Certification Laboratory (ETC) (Ref. 7, p. 4). The samples were analyzed for acid, base/neutral 

compounds in accordance with SW846 EPA Methods 3540/3530 followed by EPA Method 8270 (Refs. 

7, pp. 4, 18, 19, 26, 240, 241, 247). The method detection limits (MDL) are listed on the analytical data

sheets in Reference 7. 

Tetra Tech conducted a review of the quality control elements of the analytical data packages. The 

review was conducted in accordance with the EPA Contract Laboratory Program (CLP) National 

Functional Guidelines (NFG) for Organic Data Review and is contained in Reference 96. 

Analytical data sheets and chain-of-custody forms are contained in Reference 7. Field parameter forms 

are also contained in Reference 7. The locations of the source samples are provided in Reference 7, page 

5 (see Figure 3 of this HRS documentation record). 

TABLE 1: Analytical Results for Source No. 1 – May and June 1986 

Sample ID

Hazardous 

Substance

Hazardous

Substance 

Concentration MDL References

BCOLIMP1-01 Acenaphthylene 1,760 μg/kg 120 μg/kg 7, pp. 19, 53, 54; 96, p. 1 

BCOLIMP1-01 Benzo(a)anthracene 8,900 μg/kg 260 μg/kg 7, pp. 19, 53, 54; 96, p. 1 

BCOLIMP1-01 Benzo(a)pyrene 3,220 μg/kg 84 μg/kg 7, pp. 19, 53, 54; 96, p. 1 

BCOLIMP1-01 Benzo(b)fluoranthene 4,700 μg/kg 340 μg/kg 7, pp. 19, 53, 54; 96, p. 1 

BCOLIMP1-01 Fluoranthene 88,900 μg/kg 74 μg/kg 7, pp. 19, 53, 54; 96, p. 1 

BCOLIMP1-01 Indeno(1,2,3-

cd)pyrene 792 μg/kg 160 μg/kg 7, pp. 19, 53, 54; 96, p. 1 

BCOLIMP1-01 Naphthalene 7,970 μg/kg 54 μg/kg 7, pp. 19, 53, 54; 96, p. 1 

BCOLIMP1-01 Phenanthrene 52,500 μg/kg 180 μg/kg 7, pp. 19, 53, 54; 96, p. 1 

BCOLIMP1-01 Carbazole 8,640 μg/kg 340 μg/kg 7, pp. 19, 53, 54; 96, p. 1 
Source No. 1

27 Source Description

TABLE 1: Analytical Results for Source No. 1 – May and June 1986 

Sample ID

Hazardous 

Substance

Hazardous

Substance 

Concentration MDL References

BCOLIMP2-03 Fluoranthene 97.7 μg/kg 73 μg/kg 7, pp. 241, 267, 270; 96, p. 1 

BCOLIMP2-03 Naphthalene 89.2 μg/kg 53 μg/kg 7, pp. 241, 267, 270; 96, p. 1 

BCOLIMP2-03 Phenanthrene 285 μg/kg 180 μg/kg 7, pp. 241, 267, 270; 96, p. 1 

Notes:

ID Identification

μg/kg Micrograms per kilogram

MDL Method detection limit
Source No. 1

28 Source Description

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Soil samples used to characterize Source No. 1 contained creosote constituents including acenaphthylene, 

benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, fluoranthene, indeno(1,2,3-cd)pyrene, 

naphthalene, phenanthrene, and carbazole (see Table 1 of this HRS documentation record). Source No. 1 

consists of two backfilled surface impoundments located in the northwestern portion of the southern KerrMcGee property (Refs. 13, Attachment B, pp. B-20, B-21; 17, p. 15; 25, p. 32; 27, pp. 1, 3, 4) (see Figure 

3 of this HRS documentation record). Clean closure of the backfilled surface impoundments was not 

accomplished (Refs. 7, pp. 4 through 8; 13, Attachment B, pp. B-20, B-21; 27, pp. 1, 3). Reports 

describing closure of the impoundments do not mention the presence of a liner. Therefore, a containment 

factor value of 10, as noted in Table 2, was assigned for the ground water migration pathway (Ref. 1, 

Section 3.1.2.1, Table 3-2). Also, there is an engineered and maintained cover associated with the 

impoundments, but there are no run-on/runoff control systems in place (Refs. 62; 105, p. 2). Therefore, a 

containment factor value of 9, as noted in Table 2, was assigned for the surface water migration pathway 

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

TABLE 2: 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: No liner 10 1, Section 3.1.2.1, Table 3-2; 7, pp. 

4 through 8; 27, pp. 1, 3 

Release via overland migration and/or flood: 

maintained engineered cover, no run-on/runoff 

control system

9 1, Section 4.1.2.1.2.1.1, Table 4-2; 

62; 105, p. 2 

Notes:

NA Not applicable

NS Not scored
Source No. 1

29 Source Description

2.4.2.1 HAZARDOUS WASTE QUANTITY

2.4.2.1.1 Hazardous Constituent Quantity

The information available is not sufficient to evaluate Tier A, hazardous constituent quantity, as required 

by Reference 1, Section 2.4.2.1.1. 

Hazardous Constituent Quantity Assigned Value: NS

2.4.2.1.2 Hazardous Wastestream Quantity

The information available is not sufficient to evaluate Tier B, hazardous wastestream quantity, as required 

by Reference 1, Section 2.4.2.1.2. 

Hazardous Wastestream Quantity Assigned Value: NS

2.4.2.1.3 Volume

The information available is not sufficient to evaluate Tier C, hazardous volume quantity, as required by 

Reference 1, Section 2.4.2.1.3. 

Hazardous Wastestream Quantity Assigned Value: NS

2.4.2.1.4 Area

The area of the surface impoundments at closure was 16,000 ft2

 (Ref. 7, p. 5). As shown in Table 1 of 

this HRS documentation record, removal of hazardous substances from the source was not complete. 

 Sum (ft2

): 16,000 (Ref. 7, p. 5) 

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

 Area Value at Closure: 1,230.76 

Area Assigned Value: 1,230.76 

2.4.2.1.5 Source Hazardous Waste Quantity Value

A source hazardous waste quantity (HWQ) value of 1,230.76 is assigned for Source No. 1 (Ref. 1, Section 

2.4.2.1.5). 

Source HWQ Value: 1,230.76 
Source No: 2

30 Source Description

2.2.1 SOURCE IDENTIFICATION

Number of source: 2 

Name of source: Contaminated soil underlying the former drip pad 

Source Type: Contaminated soil 

Description and Location of Source

Source No. 2, an area of contaminated soil underlying the former drip pad, is located on the southwestern 

portion of the southern Kerr-McGee property (Ref. 14, p. 3) (see Figure 3 of this HRS documentation 

record). The former drip pad was located east of the process area (Ref. 14, p. 27). Prior to construction 

of the drip pad, preservative (creosote and PCP) dripped onto the bare soil (Ref. 13, p. ii, Attachment B, 

p. B-24). In 1988, a drip pad was constructed of 1 to 1.5 feet of clay overlain by a crushed rock buffer of 

1 to 1.5 feet, overlain by 12 inches of concrete with a 6-inch concrete berm (Ref. 13, Attachment B, p. B24). Prior to construction of the drip pad, visually impacted soil from the area was excavated to a depth 

of 4 feet. Kerr-McGee collected soil samples 6 inches below the surface designated visually clean (Ref. 

14, p. 26). The samples contained creosote compounds at high concentrations (Refs. 18, p. 22; 54, p.42). 

(with reference to a map of site):
Source No: 2

31 Source Description

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

January 1988 Soil Samples

Samples listed in Table 3 were collected from Source No. 2 by Kerr-McGee in January 1988, prior to 

installation of the concrete drip pad (Ref. 14, pp. 26, 47, 54, 59, 66, 72, 77). Prior to construction of the 

drip pad, visually impacted soil from the area was excavated to a depth of 4 feet. Kerr-McGee collected 

soil samples from 6 inches below the surface designated visually clean (Ref. 14, p. 26). The samples 

contain creosote constituents including PCP (Refs. 14, pp. 47, 48, 53, 54, 59, 60, 65, 66, 71, 72, 77, 78; 

54, p. 42) (see Table 3 below). 

All samples were analyzed by ETC (Ref. 14, pp. 47, 48, 53, 54, 59, 60, 65, 66, 71, 72, 77, 78). The 

samples were analyzed for certain acid and base/neutral compounds (Refs. 14, pp. 47, 48, 53, 54, 59, 60, 

65, 66, 71, 72, 77, 78). The MDLs are listed on the analytical data sheets in Reference 14. 

Tetra Tech conducted a review of the quality control elements of the analytical data packages. The 

review was conducted in accordance with the EPA CLP NFGs for Organic Data Review and is contained 

in Reference 91. 

Analytical data sheets are contained in Reference 14. 

TABLE 3: Analytical Results for Source No. 2 – January 1988 

Sample ID

Hazardous 

Substance

Hazardous

Substance 

Concentration MDL References

SSPJDPT1I 2,4-Dimethylphenol 1,950 μg/kg 520 μg/kg 14, p. 47; 18, p. 22 

SSPJDPT1I Pentachlorophenol 358,000 J μg/kg 690 μg/kg 14, p. 47; 18, p. 22; 91, pp. 2, 

4; 97, pp. 8, 15 

SSPJDPT1I 2,4,6-

Trichlorophenol 1,870 μg/kg 520 μg/kg 14, p. 47; 18, p. 22 

SSPJDPT1I Benzo(a)anthracene 95,000 μg/kg 60,000 μg/kg 14, p. 48; 18, p. 22 

SSPJDPT1I Benzo(a)pyrene 40,000 μg/kg 19,000 μg/kg 14, p. 48; 18, p. 22 

SSPJDPT1I Benzo(b)fluoranthene 171,000 μg/kg 77,000 μg/kg 14, p. 48; 18, p. 22 

SSPJDPT1I Fluoranthene 506,000 μg/kg 17,000 μg/kg 14, p. 48; 18, p. 22 

SSPJDPT1I Naphthalene 488,000 μg/kg 12,000 μg/kg 14, p. 48; 18, p. 22 

SSPJDPT1I Phenanthrene 814,000 μg/kg 42,000 μg/kg 14, p. 48; 18, p. 22 

SSPJDPT2I Benzo(a)anthracene 7,060 μg/kg 5,800 μg/kg 14, p. 54; 18, p. 22 

SSPJDPT2I Benzo(a)pyrene 3,430 μg/kg 1,900 μg/kg 14, p. 54; 18, p. 22 

SSPJDPT2I Benzo(b)fluoranthene 14,800 μg/kg 7,500 μg/kg 14, p. 54; 18, p. 22 

SSPJDPT2I Fluoranthene 37,400 μg/kg 1,600 μg/kg 14, p. 54; 18, p. 22 

SSPJDPT2I Naphthalene 40,200 μg/kg 1,200 μg/kg 14, p. 54; 18, p. 22 

SSPJDPT2I Phenanthrene 57,900 μg/kg 4,000 μg/kg 14, p. 54; 18, p. 22 

SSPJDPT3I 2,4-Dimethylphenol 14,400 μg/kg 510 μg/kg 14, p. 59; 18, p. 22 

SSPJDPT3I Phenol 23,200 μg/kg 280 μg/kg 14, p. 59; 18, p. 22 
Source No: 2

32 Source Description

TABLE 3: Analytical Results for Source No. 2 – January 1988 

Sample ID

Hazardous 

Substance

Hazardous

Substance 

Concentration MDL References

SSPJDPT3I Acenaphthylene 113,000 μg/kg 66,000 μg/kg 14, p. 60; 18, p. 22 

SSPJDPT3I Benzo(a)anthracene 476,000 μg/kg 150,000 μg/kg 14, p. 60; 18, p. 22 

SSPJDPT3I Benzo(a)pyrene 193,000 μg/kg 47,000 μg/kg 14, p. 60; 18, p. 22 

SSPJDPT3I Benzo(b)fluoranthene 810,000 μg/kg 190,000 μg/kg 14, p. 60; 18, p. 22 

SSPJDPT3I Fluoranthene 2,180,000 μg/kg 42,000 μg/kg 14, p. 60; 18, p. 22 

SSPJDPT3I Naphthalene 1,930,000 μg/kg 30,000 μg/kg 14, p. 60; 18, p. 22 

SSPJDPT3I Phenanthrene 3,420,000 μg/kg 100,000 μg/kg 14, p. 60; 18, p. 22 

SSPJDPT3I Carbazole 340,000 μg/kg 190,000 μg/kg 14, p. 60; 18, p. 22 

SSPJDPT4I 2,4-Dimethylphenol 1,030 μg/kg 100 μg/kg 14, p. 65; 18, p. 22 

SSPJDPT4I Phenol 596 μg/kg 57 μg/kg 14, p. 65; 18, p. 22 

SSPJDPT4I Benzo(a)anthracene 85,300 μg/kg 30,000 μg/kg 14, p. 66; 18, p. 22 

SSPJDPT4I Benzo(a)pyrene 33,100 μg/kg 9,600 μg/kg 14, p. 66; 18, p. 22 

SSPJDPT4I Benzo(b)fluoranthene 142,000 μg/kg 38,000 μg/kg 14, p. 66; 18, p. 22 

SSPJDPT4I Fluoranthene 407,000 μg/kg 8,400 μg/kg 14, p. 66; 18, p. 22 

SSPJDPT4I Naphthalene 316,000 μg/kg 6,100 μg/kg 14, p. 66; 18, p. 22 

SSPJDPT4I Phenanthrene 629,000 μg/kg 21,000 μg/kg 14, p. 66; 18, p. 22 

SSPJDPT4I Carbazole 43,900 μg/kg 38,000 μg/kg 14, p. 66; 18, p. 22 

SSPJDPT5I Benzo(a)anthracene 8,040 μg/kg 3,000 μg/kg 14, p. 72; 18, p. 22 

SSPJDPT5I Benzo(a)pyrene 3,690 μg/kg 960 μg/kg 14, p. 72; 18, p. 22 

SSPJDPT5I Benzo(b)fluoranthene 17,400 μg/kg 3,800 μg/kg 14, p. 72; 18, p. 22 

SSPJDPT5I Fluoranthene 43,000 μg/kg 840 μg/kg 14, p. 72; 18, p. 22 

SSPJDPT5I Naphthalene 6,800 μg/kg 610 μg/kg 14, p. 72; 18, p. 22 

SSPJDPT5I Phenanthrene 58,500 μg/kg 2,100 μg/kg 14, p. 72; 18, p. 22 

SSPJDPT5I Carbazole 5,490 μg/kg 3,800 μg/kg 14, p. 72; 18, p. 22 

SSPJDPT6I Phenol 105 μg/kg 58 μg/kg 14, p. 78; 18, p. 22 

SSPJDPT6I Acenaphthylene 1,690 μg/kg 1,400 μg/kg 14, p. 77; 18, p. 22 

SSPJDPT6I Benzo(a)anthracene 11,200 μg/kg 3,000 μg/kg 14, p. 77; 18, p. 22 

SSPJDPT6I Benzo(a)pyrene 8,030 μg/kg 970 μg/kg 14, p. 77; 18, p. 22 

SSPJDPT6I Benzo(b)fluoranthene 15,400 μg/kg 3,900 μg/kg 14, p. 77; 18, p. 22 

SSPJDPT6I Fluoranthene 65,300 μg/kg 850 μg/kg 14, p. 77; 18, p. 22 

SSPJDPT6I Indeno(1,2,3-

cd)pyrene 4,990 μg/kg 1,800 μg/kg 14, p. 77; 18, p. 22 
Source No: 2

33 Source Description

TABLE 3: Analytical Results for Source No. 2 – January 1988 

Sample ID

Hazardous 

Substance

Hazardous

Substance 

Concentration MDL References

SSPJDPT6I Naphthalene 31,300 μg/kg 620 μg/kg 14, p. 77; 18, p. 22 

SSPJDPT6I Phenanthrene 86,500 μg/kg 2,100 μg/kg 14, p. 77; 18, p. 22 

SSPJDPT6I Carbazole 14,700 μg/kg 3,900 μg/kg 14, p. 77; 18, p. 22 

Notes:

ID Identification

J Estimated value. Sample result should be considered estimated with an unknown bias because the QC 

replicate displayed poor precision (91, pp. 2, 4). 

μg/kg Micrograms per kilogram

MDL Method detection limit
Source No: 2

34 Source Description

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Source samples collected from Source No. 2 contained creosote constituents including 2,4-

dimethylphenol; PCP; 2,4,6-trichlorophenol; phenol; acenaphthylene; benzo(a)anthracene; 

benzo(a)pyrene; benzo(b)fluoranthene; fluoranthene; indeno(1,2,3-cd)pyrene; naphthalene; phenanthrene; 

and carbazole (Refs. 13, p. II-10, Attachment E, p. E-14; 18, p. 22; 28, p. 175; 54, p. 42) (see Table 3 of 

this HRS documentation record). Source No. 2 is an area of contaminated soil underlying the former drip 

pad (see Figure 3 of this HRS documentation record). Residual contamination caused by preservatives 

(creosote and PCP) dripping onto the bare soil was left in place (Refs. 13, pp. ii, Attachment B, p. B-24; 

14, p. 29). There is no evidence of the presence of a liner. Therefore, a containment factor value of 10, as 

noted in Table 4, was assigned for the ground water migration pathway (Ref. 1, Section 3.1.2.1, Table 

3-2). Source No. 2 was subsequently paved over which acts as an engineered cover preventing 

stormwater from coming into contact with the contaminated soil beneath; however, there are no runon/runoff control systems in place (Refs. 13, Attachment B, p. B-24; 62; 105, p. 2). Therefore, a 

containment factor value of 9, as noted in Table 4, was assigned for the surface water migration pathway.

TABLE 4: 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: No liner 10 1, Section 3.1.2.1, Table 3-2; 13, 

pp. ii, Attachment B, p. B-24; 14, 

pp. 26, 29 

Release via overland migration and/or flood: 

maintained engineered cover, no run-on/runoff 

control system

9 1, Section 4.1.2.1.2.1.1, Table 4-2; 

62; 105, p. 2 

Notes:

NA Not applicable

NS Not scored
Source No: 2

35 Source Description

2.4.2.1 HAZARDOUS WASTE QUANTITY

2.4.2.1.1 Hazardous Constituent Quantity

The information available is not sufficient to evaluate Tier A, hazardous constituent quantity, as required 

by Reference 1, Section 2.4.2.1.1. 

Hazardous Constituent Quantity Assigned Value: NS

2.4.2.1.2 Hazardous Wastestream Quantity

The information available is not sufficient to evaluate Tier B, hazardous wastestream quantity, as required 

by Reference 1, Section 2.4.2.1.2. 

Hazardous Wastestream Quantity Assigned Value: NS

2.4.2.1.3 Volume

The information available is not sufficient to evaluate Tier C, hazardous volume quantity, as required by 

Reference 1, Section 2.4.2.1.3. 

Volume Assigned Value: 0

2.4.2.1.4 Area

Source No. 2 is an unknown quantity of contaminated soil underlying the former drip pad. Therefore, the 

area of Source No. 2 is undetermined, but greater than zero (Ref. 1, Section 2.4.2.1.4). 

Sum (ft2

Source HWQ Value: >0

): Undetermined but greater than zero 

 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

A source HWQ value of >0 is assigned for Source No. 2 (Ref. 1, Section 2.4.2.1.5). 
Source No: 3

36 Source Description

2.2.1 SOURCE IDENTIFICATION

Number of source: 3 

Name of source: Contaminated soil located in various areas on the southern Kerr-McGee property 

Source Type: Contaminated soil 

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

Source No. 3 is contaminated soil located in various areas on the southern Kerr-McGee property (see 

Figure 3 of this HRS documentation record). As part of Kerr-McGee’s past operations, the facility 

generated hazardous waste now regulated under RCRA (Ref. 54, p. 1). As a result of historical 

production practices associated with the oil-water separators and tank farm storage, the soil underlying 

the southern Kerr-McGee property has been impacted by preservative (Ref. 14, p. 14). 

Surface and subsurface soil samples were collected from various areas throughout the southern KerrMcGee property. Specifically, surface and subsurface soil samples collected from the following areas 

contained creosote and/or PCDD and PCDF constituents: black tie storage area, creosote recovery 

system/wastewater treatment system, and cooling tower basin area (Refs. 54, pp. 23 through 26, 59, 60, 

61, 61a, 120, 121, 122, 124; 56, pp. 5, 6, 9, 13). 

Surface and subsurface soil samples collected from the southern Kerr-McGee property in these areas

during the 1996 RFI contained creosote constituents including 2,4-dimethylphenol, acenaphthylene, 

benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, carbazole, dibenz(a,h)anthracene, 

fluoranthene, indeno(1,2,3-cd)pyrene, naphthalene, PCP, and phenanthrene (Ref. 54, pp. 2, 23 through 26, 

42, 61a, 120, 121, 122, 124). 

In 2008, Tronox conducted supplemental soil sampling at the southern Kerr-McGee property to determine 

whether PCDDs and PCDFs were present in the soil (Ref. 56, pp. 1, 2, 4, 14). The surface soil samples 

indicated the presence of dioxins and furans including 1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin 

(HpCDD) (Ref. 56, p. 13). Soil removals have not occurred in the areas evaluated as Source No. 3 since 

the 1996 samples were collected (Ref. 105, p. 1). 
Source No: 3

37 Source Description

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

1996 Soil Samples

Soil samples listed in Table 5 were collected by Kerr-McGee during the 1996 RFI (Ref. 54, pp. 2, 23, 25, 

26). Surface and subsurface soil samples were collected from the creosote recovery system/wastewater 

treatment system, cooling tower basin, and the black tie storage area (Ref. 54, pp. 18, 19, 23 through 26). 

Surface soil samples were collected from 0 to 12 inches bgs after 6 to 12 inches of surface gravel had 

been removed (Ref. 54, pp. 23 through 26). The subsurface soil samples were collected at depths ranging 

from 2 to 11 feet bgs (Ref. 54, pp. 120, 121, 122). As documented in the boring logs, odors and visual 

impacts of product were noted during sampling activities (Ref. 54, pp. 24, 25, 105, 107, 109, 111). In 

addition, the samples contained creosote constituents including PCP (Ref. 54, pp. 24, 25, 42, 44 through 

46) (see Table 5 below). 

The soil samples were collected in accordance with the EPA-approved RFI Work Plan (Refs. 54, pp. 2, 

23, 24, 25, 26; 56, p. 1; 57). All samples were analyzed by Southwest Laboratory of Oklahoma 

(Southwest) (Ref. 54, pp. 120, 121, 122, 124). The samples were analyzed for selected semivolatile 

organic compounds (SVOC) by EPA SW846 Method 8270 (Refs. 54, pp. 120, 121, 122, 124; 57, 

Appendix A, pp. 8-7, 10-8). The MDLs are provided in Southwest’s Quality Assurance Manual 

contained in Reference 37 (Ref. 37, pp. 41, 208, 209, 211, 217, 218, 219). 

Tetra Tech conducted a review of the quality control elements of the analytical data packages. The only 

quality control item available for review was custody documentation (Ref. 92). The review is contained 

in Reference 92. 

Analytical data sheets and chain-of-custody records are contained in Reference 54. The locations of the 

surface and subsurface soil samples are depicted in Reference 54, page 61a (see Figure 3 of this HRS 

documentation record). 

TABLE 5: Analytical Results for Source No. 3 – 1996 

Sample ID

Hazardous 

Substance

Hazardous

Substance 

Concentration MDL References

Surface Soil

SB1 Acenaphthylene 38,000 μg/kg 37.8 μg/kg 37, p. 209; 54, pp. 121, 127; 

92, pp. 1, 3 

SB1 Dibenz(a,h)anthracene 19,000 μg/kg 103.5 μg/kg 37, p. 209; 54, pp. 121, 127; 

92, pp. 1, 3 

SB1 Indeno(1,2,3-

cd)pyrene 37,000 μg/kg 77.9 μg/kg 37, p. 209; 54, pp. 121, 127; 

92, pp. 1, 3 

SB1 (Diluted) Benzo(a)anthracene 190,000 μg/kg 146.7 μg/kg 37, p. 209; 54, pp. 121, 127; 

92, pp. 1, 3 

SB1 (Diluted) Benzo(a)pyrene 82,000 μg/kg 144.4 μg/kg 37, p. 209; 54, pp. 121, 127; 

92, pp. 1, 3 

SB1 (Diluted) Benzo(b)fluoranthene 99,000 μg/kg 131.8 μg/kg 37, p. 209; 54, pp. 121, 127; 

92, pp. 1, 3 

SB1 (Diluted) Fluoranthene 1,000,000 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 121, 127; 

92, pp. 1, 3 
Source No: 3

38 Source Description

TABLE 5: Analytical Results for Source No. 3 – 1996 

Sample ID

Hazardous 

Substance

Hazardous

Substance 

Concentration MDL References

SB1 (Diluted) Naphthalene 260,000 μg/kg 74.2 μg/kg 37, p. 208; 54, pp. 121, 127; 

92, pp. 1, 3 

SB1 (Diluted) Phenanthrene 750,000 μg/kg 44.1 μg/kg 37, p. 209; 54, pp. 121, 127; 

92, pp. 1, 3 

SB2 Benzo(a)anthracene 3,200 μg/kg 146.7 μg/kg 37, p. 209; 54, pp. 121, 127 

SB2 Benzo(a)pyrene 4,200 μg/kg 144.4 μg/kg 37, p. 209; 54, pp. 121, 127 

SB2 Benzo(b)fluoranthene 5,600 μg/kg 131.8 μg/kg 37, p. 209; 54, pp. 121, 127 

SB2 Fluoranthene 14,000 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 121, 127 

SB2 Indeno(1,2,3-

cd)pyrene 2,400 μg/kg 77.9 μg/kg 37, p. 209; 54, pp. 121, 127 

SB2 Phenanthrene 3,300 μg/kg 44.1 μg/kg 37, p. 209; 54, pp. 121, 127 

SB3 Acenaphthylene 16,000 μg/kg 37.8 μg/kg 37, p. 209; 54, pp. 122, 127; 

92, pp. 1, 4; 103, pp. 1, 5 

SB3 Benzo(a)pyrene 75,000 μg/kg 144.4 μg/kg 37, p. 209; 54, pp. 122, 127; 

92, pp. 1, 4; 103, pp. 1, 5 

SB3 Benzo(b)fluoranthene 98,000 μg/kg 131.8 μg/kg 37, p. 209; 54, pp. 122, 127; 

92, pp. 1, 4; 103, pp. 1, 5 

SB3 Carbazole 81,000 μg/kg 85.5 μg/kg 37, p. 211; 54, pp. 122, 127; 

92, pp. 1, 4; 103, pp. 1, 5 

SB3 Indeno(1,2,3-

cd)pyrene 17,000 μg/kg 77.9 μg/kg 37, p. 209; 54, pp. 122, 127; 

92, pp. 1, 4; 103, pp. 1, 5 

SB3 (Diluted) Benzo(a)anthracene 160,000 μg/kg 146.7 μg/kg 37, p. 209; 54, pp. 122, 127; 

92, pp. 1, 4; 103, pp. 1, 5 

SB3 (Diluted) Fluoranthene 840,000 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 122, 127; 

92, pp. 1, 4; 103, pp. 1, 5 

SB3 (Diluted) Naphthalene 670,000 μg/kg 74.2 μg/kg 37, p. 208; 54, pp. 122, 127; 

92, pp. 1, 4; 103, pp. 1, 5 

SB3 (Diluted) Pentachlorophenol 1,000,000 μg/kg 136.5 μg/kg 37, p. 209; 54, pp. 122, 127; 

92, pp. 1, 4; 103, pp. 1, 5 

SB3 (Diluted) Phenanthrene 1,000,000 μg/kg 44.1 μg/kg 37, p. 209; 54, pp. 122, 127; 

92, pp. 1, 4; 103, pp. 1, 5 

SB4 Acenaphthylene 1,900 μg/kg 37.8 μg/kg 37, p. 209; 54, pp. 122, 127 

SB4 Benzo(a)anthracene 9,500 μg/kg 146.7 μg/kg 37, p. 209; 54, pp. 122, 127 

SB4 Benzo(a)pyrene 9,300 μg/kg 144.4 μg/kg 37, p. 209; 54, pp. 122, 127 

SB4 Benzo(b)fluoranthene 15,000 μg/kg 131.8 μg/kg 37, p. 209; 54, pp. 122, 127 

SB4 Dibenz(a,h)anthracene 3,300 μg/kg 103.5 μg/kg 37, p. 209; 54, pp. 122, 127 
Source No: 3

39 Source Description

TABLE 5: Analytical Results for Source No. 3 – 1996 

Sample ID

Hazardous 

Substance

Hazardous

Substance 

Concentration MDL References

SB4 Fluoranthene 13,000 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 122, 127 

SB4 Indeno(1,2,3-

cd)pyrene 10,000 μg/kg 77.9 μg/kg 37, p. 209; 54, pp. 122, 127 

SB4 Phenanthrene 1,900 μg/kg 44.1 μg/kg 37, p. 209; 54, pp. 122, 127 

SB5 Acenaphthylene 4,700 μg/kg 37.8 μg/kg 37, p. 209; 54, pp. 122, 127 

SB5 Benzo(a)anthracene 25,000 μg/kg 146.7 μg/kg 37, p. 209; 54, pp. 122, 127 

SB5 Benzo(a)pyrene 21,000 μg/kg 144.4 μg/kg 37, p. 209; 54, pp. 122, 127 

SB5 Benzo(b)fluoranthene 33,000 μg/kg 131.8 μg/kg 37, p. 209; 54, pp. 122, 127 

SB5 Carbazole 8,100 μg/kg 85.5 μg/kg 37, p. 211; 54, pp. 122, 127 

SB5 Dibenz(a,h)anthracene 5,800 μg/kg 103.5 μg/kg 37, p. 209; 54, pp. 122, 127 

SB5 Fluoranthene 54,000 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 122, 127 

SB5 Indeno(1,2,3-

cd)pyrene 16,000 μg/kg 77.9 μg/kg 37, p. 209; 54, pp. 122, 127 

SB5 Phenanthrene 5,400 μg/kg 44.1 μg/kg 37, p. 209; 54, pp. 122, 127 

SB6 Fluoranthene 800 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 122, 127 

SD7 (Diluted) Benzo(a)anthracene 220,000 μg/kg 146.7 μg/kg 37, p. 209; 54, pp. 123, 125; 

92, pp. 1, 7 

SD7 (Diluted) Benzo(a)pyrene 110,000 μg/kg 144.4 μg/kg 37, p. 209; 54, pp. 123, 125; 

92, pp. 1, 7 

SD7 (Diluted) Benzo(b)fluoranthene 160,000 μg/kg 131.8 μg/kg 37, p. 209; 54, pp. 123, 125; 

92, pp. 1, 7 

SD7 (Diluted) Carbazole 160,000 μg/kg 85.5 μg/kg 37, p. 211; 54, pp. 123, 125; 

92, pp. 1, 7 

SD7 (Diluted) Fluoranthene 1,000,000 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 123, 125; 

92, pp. 1, 7 

SD7 (Diluted) Naphthalene 170,000 μg/kg 74.2 μg/kg 37, p. 208; 54, pp. 123, 125; 

92, pp. 1, 7 

SD7 (Diluted) Phenanthrene 1,100,000 μg/kg 44.1 μg/kg 37, p. 209; 54, pp. 123, 125; 

92, pp. 1, 7 

SD8 Acenaphthylene 2,300 μg/kg 37.8 μg/kg 37, p. 209; 54, pp. 123, 124; 

92, pp. 1, 6 

SD8 Carbazole 840 μg/kg 85.5 μg/kg 37, p. 211; 54, pp. 123, 124; 

92, pp. 1, 6 

SD8 Dibenz(a,h)anthracene 3,700 μg/kg 103.5 μg/kg 37, p. 209; 54, pp. 123, 124; 

92, pp. 1, 6 
Source No: 3

40 Source Description

TABLE 5: Analytical Results for Source No. 3 – 1996 

Sample ID

Hazardous 

Substance

Hazardous

Substance 

Concentration MDL References

SD8 Indeno(1,2,3-

cd)pyrene 7,900 μg/kg 77.9 μg/kg 37, p. 209; 54, pp. 123, 124; 

92, pp. 1, 6 

SD8 Phenanthrene 2,300 μg/kg 44.1 μg/kg 37, p. 209; 54, pp. 123, 124; 

92, pp. 1, 6 

SD8 (Diluted) Benzo(a)anthracene 17,000 μg/kg 146.7 μg/kg 37, p. 209; 54, pp. 123, 125; 

92, pp. 1, 7 

SD8 (Diluted) Benzo(a)pyrene 20,000 μg/kg 144.4 μg/kg 37, p. 209; 54, pp. 123, 125; 

92, pp. 1, 7 

SD8 (Diluted) Fluoranthene 95,000 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 123, 125; 

92, pp. 1, 7 

SD9 (Reanalyzed) Fluoranthene 550 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 123, 124; 

92, pp. 1, 6 

Subsurface Soil

B53 3-4' 2,4-Dimethylphenol 4,500 μg/kg 95.8 μg/kg 37, p. 208; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 3-4' Acenaphthylene 16,000 μg/kg 37.8 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 3-4' Benzo(a)pyrene 66,000 μg/kg 144.4 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 3-4' Dibenz(a,h)anthracene 16,000 μg/kg 103.5 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 3-4' Indeno(1,2,3-

cd)pyrene 33,000 μg/kg 77.9 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 3-4' (Diluted) Fluoranthene 770,000 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 3-4' (Diluted) Naphthalene 1,000,000 μg/kg 74.2 μg/kg 37, p. 208; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 3-4' (Diluted) Phenanthrene 1,500,000 μg/kg 44.1 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 10-11' 2,4-Dimethylphenol 7,800 μg/kg 95.8 μg/kg 37, p. 208; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 10-11' Acenaphthylene 12,000 μg/kg 37.8 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 10-11' Benzo(a)pyrene 39,000 μg/kg 144.4 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 10-11' Benzo(b)fluoranthene 58,000 μg/kg 131.8 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 
Source No: 3

41 Source Description

TABLE 5: Analytical Results for Source No. 3 – 1996 

Sample ID

Hazardous 

Substance

Hazardous

Substance 

Concentration MDL References

B53 10-11' Dibenz(a,h)anthracene 9,800 μg/kg 103.5 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 10-11' Indeno(1,2,3-

cd)pyrene 17,000 μg/kg 77.9 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 10-11' 

(Diluted) Benzo(a)anthracene 76,000 μg/kg 146.7 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 10-11' 

(Diluted) Carbazole 40,000 μg/kg 85.5 μg/kg 37, p. 211; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 10-11' 

(Diluted) Fluoranthene 360,000 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 10-11' 

(Diluted) Naphthalene 580,000 μg/kg 74.2 μg/kg 37, p. 208; 54, pp. 120, 127; 

92, pp. 1, 2 

B53 10-11' 

(Diluted) Phenanthrene 620,000 μg/kg 44.1μg/kg 37, p. 209; 54, pp. 120, 127; 

92, pp. 1, 2 

B54 2-3' Benzo(a)anthracene 36,000 μg/kg 146.7 μg/kg 37, p. 209; 54, pp. 121, 127 

B54 2-3' Benzo(a)pyrene 40,000 μg/kg 144.4 μg/kg 37, p. 209; 54, pp. 121, 127 

B54 2-3' Benzo(b)fluoranthene 48,000 μg/kg 131.8 μg/kg 37, p. 209; 54, pp. 121, 127 

B54 2-3' Carbazole 20,000 μg/kg 85.5 μg/kg 37, p. 211; 54, pp. 121, 127 

B54 2-3' Fluoranthene 210,000 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 121, 127 

B54 2-3' Indeno(1,2,3-

cd)pyrene 20,000 μg/kg 77.9 μg/kg 37, p. 209; 54, pp. 121, 127 

B54 2-3' Naphthalene 80,000 μg/kg 74.2 μg/kg 37, p. 208; 54, pp. 121, 127 

B54 2-3' Phenanthrene 70,000 μg/kg 44.1 μg/kg 37, p. 209; 54, pp. 121, 127 

B54 10-11' Benzo(a)anthracene 23,000 μg/kg 146.7 μg/kg 37, p. 209; 54, pp. 121, 127 

B54 10-11' Carbazole 18,000 μg/kg 85.5 μg/kg 37, p. 211; 54, pp. 121, 127 

B54 10-11' Fluoranthene 130,000 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 121, 127 

B54 10-11' Naphthalene 190,000 μg/kg 74.2 μg/kg 37, p. 208; 54, pp. 121, 127 

B54 10-11' Phenanthrene 210,000 μg/kg 44.1 μg/kg 37, p. 209; 54, pp. 121, 127 

B55 6-8' Benzo(a)anthracene 24,000 μg/kg 146.7 μg/kg 37, p. 209; 54, pp. 121, 127 

B55 6-8' Carbazole 24,000 μg/kg 85.5 μg/kg 37, p. 211; 54, pp. 121, 127 

B55 6-8' Fluoranthene 120,000 μg/kg 85.1 μg/kg 537, p. 209; 54, pp. 121, 127 

B55 6-8' Naphthalene 180,000 μg/kg 74.2 μg/kg 37, p. 208; 54, pp. 121, 127 

B55 6-8' Phenanthrene 210,000 μg/kg 44.1 μg/kg 37, p. 209; 54, pp. 121, 127 

B56 10-11' Phenanthrene 980 μg/kg 44.1 μg/kg 37, p. 209; 54, pp. 122, 127 
Source No: 3

42 Source Description

Notes:

' Foot

B Boring 

D The sample was diluted

ID Identification

μg/kg Micrograms per kilogram

MDL Method detection limit

SB Surface soil

SD Surface soil

Sample SD9 was analyzed twice. The first analysis involved higher detection limits than the second analysis. Quality control 

elements are not available for the analytical data package. The analytical results of the reanalysis are used in Table 5. 
Source No: 3

43 Source Description

2008 Soil Samples 

In 2008, EPA advised Tronox that additional sampling would be required as part of the RFI process to 

determine if PCDDs and PCDFs were present in the soil at the Kerr-McGee property (Ref. 56, p. 1). In 

December 2008, AquAeTer, on behalf of Tronox, conducted a supplemental soil sampling event (Ref. 56, 

pp. 4, 63). 

Surface soil samples were collected from five areas where previous RFI soil and sediment sampling 

results had shown elevated PCP concentrations (Ref. 56, p. 2). The surface soil samples were collected 

from 0 to 1 foot bgs (Ref. 56, p. 6). A background surface soil sample was not collected during the 

sampling event; however, surface soil sample SSB-01 collected at the northeastern corner of the southern 

Kerr-McGee property was selected to represent background conditions (Ref. 56, p. 14). This location was 

chosen to represent background conditions because (1) the soil type (Prentiss-urban land complex) at the 

location (SSB-01) was similar to the soil type of samples collected from Source No. 3 and (2) the 

background sampling location appeared to have been minimally impacted by past facility operations 

(Refs. 14, p. 10; 56, p. 14; 60, pp. 1, 3). 

The surface soil samples were collected in accordance with the EPA-approved Work Plan (Refs. 56, pp. 

4, 63; 59). All samples were analyzed by Test America for dioxins and furans by EPA SW846 Method 

8290 (Ref. 56, pp. 28, 31 through 52). 

The reporting limits are listed on the analytical data sheets in Reference 56. The reporting limits are 

adjusted for sample characteristics that may affect quantitation, such as dilutions and percent moisture. 

The reporting limits on the analytical data sheets are equivalent to sample quantitation limits (SQL) (Ref. 

99). 

Data validation was conducted by AquAeTer (Ref. 56, p. 63). The data validation report is contained in 

Reference 56, pages 62 through 114. Data validation was performed in accordance with EPA Analytical 

Services Branch NFGs for Chlorinated Dioxin and Furan Data Review, September 2005 (Ref. 56, p. 63). 

Analytical data sheets and chain-of-custody records are contained in Reference 56. Boring logs are 

provided in Reference 56. Locations of the soil samples listed in Table 6 are provided in Reference 56, 

page 9 (see Figure 3 of this HRS documentation record). 

TABLE 6: Analytical Results for Source No. 3 – 2008 

Sample ID

Hazardous 

Substance

Hazardous

Substance 

Concentration

Reporting 

Limit* References

Background Sample

SSB-01 1,2,3,4,6,7,8-HpCDD 220 pg/g 12 pg/g 56, p. 28, 31

Contaminated Samples

SSB-02 1,2,3,4,6,7,8-HpCDD 35,000 pg/g 560 pg/g 56, pp. 28, 33 

SSB-03 1,2,3,4,6,7,8-HpCDD 5,500 pg/g 520 pg/g 56, pp. 28, 35 

SSB-04 1,2,3,4,6,7,8-HpCDD 74,000 pg/g 530 pg/g 56, pp. 28, 37 

SSB-05 1,2,3,4,6,7,8-HpCDD 6,900 pg/g 540 pg/g 56,pp. 28, 39

SSB-06 1,2,3,4,6,7,8-HpCDD 25,000 pg/g 570 pg/g 56, pp. 28, 41 

SSB-07 1,2,3,4,6,7,8-HpCDD 71,000 pg/g 540 pg/g 56, pp. 28, 43 
Source No: 3

44 Source Description

TABLE 6: Analytical Results for Source No. 3 – 2008 

Sample ID

Hazardous 

Substance

Hazardous

Substance 

Concentration

Reporting 

Limit* References

SSB-08 1,2,3,4,6,7,8-HpCDD 15,000 pg/g 550 pg/g 56, pp. 28, 45 

SSB-09 1,2,3,4,6,7,8-HpCDD 58,000 pg/g 570 pg/g 56, pp. 28, 47 

Notes:

* The reporting limits are adjusted for sample characteristics that may affect quantitation, such as dilutions and

percent moisture. The reporting limits on the analytical data sheets are equivalent to SQLs (Ref. 99) 

ID Identification

pg/g Picogram per gram

HpCDD Heptachlorodibenzo-p-dioxin

SSB Surface soil boring
Source No: 3

45 Source Description

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Source samples collected from Source No. 3 contained 2,4-dimethylphenol, acenaphthylene, 

benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, carbazole, dibenz(a,h)anthracene, 

fluoranthene, indeno(1,2,3-cd)pyrene, naphthalene, PCP, phenanthrene, and 1,2,3,4,6,7,8-HpCDD (see 

Tables 5 and 6 of this HRS documentation record). Source No. 3 consists of contaminated soil located in 

various areas on the southern Kerr-McGee property (see Figure 3 of this HRS documentation record). 

There is no evidence of the presence of a liner (Refs. 54, pp. 105, 107, 109, 111; 56, pp. 18 through 27). 

No maintained engineered cover or run-on/runoff control system is associated with Source No. 3 (Refs. 

62; 105, p. 2). Therefore, a containment factor value of 10, as noted in Table 7, was assigned for the 

ground water and surface water migration pathways (Ref. 1, Sections 3.1.2.1, Table 3-2 and 4.1.2.1.2.1.1, 

Table 4-2). 

TABLE 7: Containment Factors for Source No. 3 

Containment Description

Containment 

Factor Value References

Gas release to air NS NA

Particulate release to air NS NA

Release to ground water: No liner 10 1, Section 3.1.2.1, Table 3-2; 54, 

pp. 105, 107, 109, 111; 56, pp. 18 

through 27 

Release via overland migration and/or flood: No 

run-on or runoff control system or maintained 

engineered cover

10 1, Section 4.1.2.1.2.1.1, Table 4-2; 

62; 105, p. 2 

Notes:

NA Not applicable

NS Not scored
Source No: 3

46 Source Description

2.4.2.1 HAZARDOUS WASTE QUANTITY

2.4.2.1.1 Hazardous Constituent Quantity

The information available is not sufficient to evaluate Tier A, hazardous constituent quantity, as required 

by Reference 1, Section 2.4.2.1.1. 

Hazardous Constituent Quantity Assigned Value: NS

2.4.2.1.2 Hazardous Wastestream Quantity

The information available is not sufficient to evaluate Tier B, hazardous wastestream quantity, as required 

by Reference 1, Section 2.4.2.1.2. 

Hazardous Wastestream Quantity Assigned Value: NS

2.4.2.1.3 Volume

The information available is not sufficient to evaluate Tier C, hazardous volume quantity, as required by 

Reference 1, Section 2.4.2.1.3. 

Volume Assigned Value: 0 

2.4.2.1.4 Area

Source No. 3 consists of contaminated soil located in various areas on the southern Kerr-McGee property. 

It is not known if all areas between sampling points are contaminated. Therefore, the area of Source No. 

3 is undetermined, but greater than zero (Ref. 1, Section 2.4.2.1.4). 

Sum (ft2

Source HWQ Value: >0

): Undetermined but greater than zero 

 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

A source HWQ value of >0 is assigned for Source No. 3 (Ref. 1, Section 2.4.2.1.5). 
47 Source Characterization

SUMMARY OF SOURCE DESCRIPTIONS

TABLE 8: Summary of Source Descriptions

Source 

No.

Source

Hazardous 

Waste 

Quantity

Value

Source 

Hazardous 

Constituent 

Quantity

Complete?

(Yes/No)

Containment Factor Value by Pathway

Ground 

Water 

(Ref. 1, 

Table 3-2)

Surface 

Water 

Overland/ 

Flood 

(Ref. 1, 

Table 4-2)

Air

Gas

(Ref. 1, 

Table 6-3)

Particulate

(Ref. 1, 

Table 6-9)

1 1,230.76 No 10 9 NS NS

2 >0 No 10 9 NS NS

3 >0 No 10 10 NS NS

Notes:

 

NS Not scored

• Surface impoundment – Prior to 1972, a surface impoundment was used to store settled creosote 

until it could be reclaimed and cycled back to the process storage tanks. Once the new oil-water 

separation facility was completed in 1972, all creosote and visibly settled sludge was removed 

from the impoundment by pumping and dredging, and reclaimed and recycled to preservative 

storage tanks for reuse in the wood preserving process. Use of the surface impoundment to 

contain preservative and wastewater ceased in 1972, and the surface impoundment was closed in 

1983 (Ref. 78, pp. 2, 3). The location of this surface impoundment is not known. It is also not 

known whether samples were collected from the bottom of the surface impoundment to ensure 

clean closure. 

Description of Other Possible Sources

No other possible sources at Kerr-McGee were identified; however, hazardous substances associated with 

site activities may be present, but have not been documented, in the following areas: 

• Cooling tower surface impoundment – This impoundment was located at the southwestern corner 

of the southern Kerr-McGee property (Ref. 14, pp. 3, 35, 37). The surface impoundment received 

cooling water containing creosote and PCP. Use of the surface impoundment reportedly ceased 

in the 1980s (Ref. 13, Attachment B, p. B-28). It is not known if samples were collected from the 

cooling tower surface impoundment. 

• Northern Kerr-McGee property – The northern Kerr-McGee property was used as a pine yard for 

storage of untreated wood waste and scrap metal (Ref. 20, p. 6). Sampling of this area occurred 

in 1995 (Refs. 20, p. 4; 77, pp. 1, 2). Four soil samples were collected from the southern section 

of the pine yard at 18 inches bgs (Ref. 77, pp. 1, 2). The samples did not contain hazardous 

substances at concentrations above their respective quantitation limits (Ref. 77, pp. 4, 6). 

Because the northern Kerr-McGee property encompasses about 47 acres, it is not known whether 

the areas between the four sampling points contain contamination. However, collection of four 

subsurface soil samples from an area of about 47 acres is not sufficient to adequately characterize 

the contamination status of the northern Kerr-McGee property (Ref. 86). 
48 GW Pathway Description

3.0 GROUND WATER MIGRATION PATHWAY

3.0.1 GENERAL CONSIDERATIONS

The top of the Gordo Formation is encountered at about 100 feet below msl in the Columbus area (Refs 

29; 44, p. C17). The Gordo Formation consists of thick beds of sand containing gravel in the lower part 

and multicolored clay and shale interbedded with sand in the upper part (Ref. 45, p. B10). The Gordo 

Ground Water Migration Pathway Description

Regional Geology 

Kerr-McGee is located in the central portion of Lowndes County, Mississippi within the Gulf Coastal 

Plain physiographic province, mainly on the eastern flank of the Mississippi Embayment subprovince 

(Refs. 29; 30, pp. 2, 3). The topography of the area has been modified by erosion of the Tombigbee River 

and its tributaries (Ref. 13, p. II-1). The elevation of the Kerr-McGee property ranges from 170 to 190 

feet above mean sea level (msl) (Ref. 82, p. 121) (see Figure 1 of this HRS documentation record). The 

geology in the vicinity of the Kerr-McGee sources may include, in descending stratigraphic order, some 

or all of the following units: quaternary alluvium of Pleistocene to recent age; terrace deposits of 

Pleistocene age; Eutaw Formation of Upper Cretaceous age; McShan Formation of Upper Cretaceous 

age; Tuscaloosa Group containing the Gordo Formation, Coker Formation, and Massive Sand; and the 

undifferentiated strata of Lower Cretaceous age (Refs. 30, pp. 3, 7, 9, 16; 31, p. 70, Plate 1B; 33; 87, pp. 

32, 64, 65). 

The quaternary alluvium of Pleistocene to recent age consists of sand, silt and gravel on flood plains (Ref. 

31, Plate 1B). The alluvium ranges from 18 to 26 feet thick at the Kerr-McGee property (Refs. 35, p. 1; 

40, p. 11). Terrace deposits (where present) contain loams, sands, and gravels that were laid down on 

terrace plains cut in the Eutaw deposits by the meandering of streams during Pleistocene and recent times 

(Ref. 32, p. 35). The terrace deposits are about 16 to 25 feet thick in the Columbus area (Refs. 31, p. 70; 

32, p. 308). 

In the Columbus area, the Eutaw Formation crops out (Ref. 87, p. 53). The Eutaw Formation is covered 

in some places by the terrace deposits and is characterized by massive and cross-bedded, more or less 

glauconitic, fine- to medium-grained, more or less micaceous sand (Ref. 32, p. 31). Throughout much of 

the formation, the sand is interstratified with clay in the form of subordinate thin laminae, laminated 

layers, and some more massive layers. The clays are commonly dark gray to nearly black, though lighter 

colored clays occur in places. Most of the clays contain plant fragments, and small pieces of lignite are 

common or even abundant in some parts (Ref. 32, p. 31). The top of the formation is weathered and 

contains deep reddish to brownish sand (Refs. 31, p. 64; 32, p. 31). 

At the base of the Eutaw Formation is the McShan Formation. This formation consists of greenish-gray, 

micaceous, locally very glauconitic, very fine-grained sand and thin-bedded light-gray clay; small chert 

gravels may be present in basal beds (Ref. 33). In some places, the contact between the Eutaw and 

McShan Formations is not discernable (Ref. 44, p. C21). The formations are generally mapped together 

as the Eutaw Formation (Ref. 45, p. B11). The Eutaw Formation (including the McShan Formation) 

crops out in the Columbus area (Ref. 44, pp. C20, C21). According to a geologic section of observation 

well L22, located about 5 miles south of the Columbus city center, the top of the Eutaw-McShan 

Formation is encountered at about 200 feet above msl and has a thickness of about 385 feet (200 feet 

above msl to 185 feet below msl) (Refs. 30, pp. 3, 7; 87, pp. 32, 129; 88; 89, p. 1; 90). 

The Eutaw Formation is underlain by the Tuscaloosa Group. The transition from the Tuscaloosa Group 

to the Eutaw Formation type deposits is marked by a band of more or less lignitic and carbonaceous clay 

(Ref. 32, p. 30). The Tuscaloosa Group consists of (in descending stratigraphic order) the Gordo 

Formation, Coker Formation, and Massive Sand Formation (Ref. 30, pp. 3, 7, 9). 
49 GW Pathway Description

Formation consists of 61 to 80 percent sand and is about 300 feet thick in the Columbus area (Refs. 29; 

44, p. C-18). 

The Coker Formation consists of an unnamed member at the top and the Eoline Member at the bottom 

(Ref. 44, p. C13). The top of the formation contains multicolored clay and shale containing subordinate 

sand beds and the bottom of the formation contains thin-bedded clay, sandy clay, shale and sand, mostly 

of marine origin (Ref. 45, p. B10). The top of the Coker Formation is encountered at about 400 feet 

below msl (Ref. 87, p. 44). The top of the Massive Sand, which underlies the Coker Formation, is 

encountered at about 650 feet below msl, indicating that the Coker Formation is about 250 feet thick in 

the Columbus area (Refs. 87, pp. 40, 41). 

The Massive Sand Formation consists of a series of thick beds of coarse sand, chert, and quartz gravel 

with interbedded shale and clay (Refs. 45, p. B10; 87, p. 42). In well L22, the Massive Sand Formation 

has a thickness of about 200 feet (Refs. 30, pp. 3, 7; 87, p. 32; 88). 

 

The Massive Sand Formation is underlain by undifferentiated rocks of the Lower Cretaceous age of 

unknown thickness (Ref. 30, p. 9). 

Regional Aquifer Description:

Overview Narrative – Ground water in the Lowndes County, Mississippi area exists generally within 

three aquifers: (1) the terrace and alluvial deposits, (2) the Eutaw-McShan aquifer, and (3) the Tuscaloosa 

aquifer system containing the Gordo, Coker, and Massive Sand aquifers of the Tuscaloosa Group, and the 

Lower Cretaceous aquifer (Refs. 30, pp. 3, 6, 9, 11; 87, p. 64). The terrace and alluvial (alluvium) 

deposits are referred to as the “surficial aquifer” in regional geology references; therefore, from this point 

forward, the term surficial aquifer will be used. 

The Eutaw-McShan aquifer is most widely used and has the greatest potential for ground water 

development throughout northeastern Mississippi (Ref. 34, pp. 46, 47). The Gordo, Coker, and Massive 

Sand aquifers of the Tuscaloosa aquifer system are an important source of water throughout most of 

northeast Mississippi and are second to the Eutaw-McShan aquifer in potential ground water-development 

over the area (Refs. 30, pp. 6, 9; 34, p. 46). The lower Cretaceous aquifer has not been tapped for water 

in northeastern Mississippi because of the availability of shallower aquifers and the depth to aquifer, 

1,500 to 2,500 feet, and thus is not evaluated further in this HRS documentation record (Ref. 34, p. 45). 

Surficial Aquifer – The surficial aquifer is present in Lowndes County, Mississippi (Ref. 31, Plate 1B). 

The surficial aquifer may consist of loams, sands, and gravels, which are erosional remnants of alluvial 

plains of old river systems or alluvial fans at the base of cuestas (Refs. 32, p. 35; 87, p. 64). This aquifer 

may also consist of sand, silt and gravel on flood plains (Ref. 31, Plate 1B). The surficial aquifer is 

generally capable of yielding small quantities of water and may furnish enough water for domestic use 

(Ref. 87, pp. 64, 65). 

Eutaw-McShan Aquifer – The Eutaw-McShan aquifer crops out in northeastern Mississippi and includes 

sediments of the Eutaw and McShan Formations (Refs. 30, p. 6; 44 p. C20). In Mississippi, these 

formations are considered a single aquifer because the sands are hydraulically connected (Ref. 30, p. 6). 

The upper part of the aquifer (Tombigbee Sand Member) contains finer grain sizes and greater silt content 

than the rest of the aquifer and produces little water (Ref. 30, p. 6). The remainder of the Eutaw-McShan 

aquifer mainly consists of thin beds of fine to medium glauconitic sand (Ref. 30, p. 6). The aquifer 

receives recharge from precipitation in the outcrop area, which includes Columbus with smaller amounts 

of recharge from underlying or overlying aquifers (Refs. 30, pp. 6, 10; 36). The Eutaw-McShan aquifer 

crops out in the Columbus area and is about 300 to 400 feet thick (Refs. 29; 44, pp. C17, C20, C21; 82, p. 

51). The Eutaw-McShan aquifer discharges to topographic lows in the outcrop area and to the 

Tombigbee and Black Warrior rivers through upward leakage (Ref. 30, p. 6). 
50 GW Pathway Description

Tuscaloosa Aquifer System – The Tuscaloosa aquifer system consists of the Gordo, Coker, and Massive 

Sand aquifers of the Tuscaloosa Group, and the Lower Cretaceous aquifer (Ref. 30, p. 11). Available data 

suggests that the Tuscaloosa aquifer system is confined beneath the overlying Eutaw-McShan aquifer by 

clay and silt with the transition marked by a nearly continuous 15 to 20 foot thick carbonaceous and 

lignitic clay band in northeastern Mississippi (Refs. 30, pp. 11, 13; 32, p. 34). 

The top of the Tuscaloosa aquifer system (Gordo Formation) is encountered at about 100 feet below msl 

in the Columbus area (Ref. 87, p. 46). The top of the Paleozoic rocks, which underlie rocks of lower 

Cretaceous age, are encountered at about 900 feet below msl, indicating that the thickness of the 

Tuscaloosa aquifer system is about 800 feet (Ref. 87, pp. 46, 36, 37). 

Studies of the Tuscaloosa aquifer system within northeastern Mississippi indicate that confining units 

exist between the Gordo, Coker, and Massive Sand aquifers but that these aquifers “regionally maintain a 

hydraulic continuity” (Ref. 30, p. 11, 13). However, water-level data indicate that the Coker aquifer may 

discharge water in the downdip area to the Gordo aquifer and to the Massive Sand aquifer in the updip 

area (Ref. 30, p. 13). 

A review of well completion data for Columbus Light and Water municipal wells located between 0.25 

and 1.0 mile east of Kerr-McGee sources, indicate that the Massive Sand aquifer is confined above by 

layers of clay (49 to 182 feet thick) and shale (44 to 261 feet thick) (Refs. 3; 46, pp. 1 through 18). 

Further review reveals that municipal well Nos. 1 and 2 encounter clay from approximately 340 feet 

below msl to 383-474 feet below msl and shale is encountered from 462-558 feet below msl to 598 feet 

below msl. However, municipal well Nos. 4 and 5 (adjacent to municipal well Nos. 1 and 2) encounter 

shale from 330 feet below msl to 500-578 feet below msl, which is the interval where municipal well Nos. 

1 and 2 encounter clay. Because these confining units do not correlate with each other, this evidence 

suggests that the confining units may not be continuous, and that the Coker and Massive Sand aquifers 

may be in direct hydraulic connection (Refs. 3; 46, p. 1 through 10; 47).

Site Geology/Aquifer Description

The bottom elevation of the deepest well installed on the Kerr-McGee property is 125.68 feet above msl 

and is completed in the Eutaw Formation (Refs. 25, p. 29; 39, p. 29). Therefore, the verified geology of 

the Kerr-McGee property is limited to the Eutaw Formation and overlying deposits. Documents prepared 

by Kerr-McGee name the uppermost aquifer at the property “the alluvial aquifer” and the underlying 

aquifer the “Eutaw aquifer”. Based on regional geology references, the accepted names for these aquifers 

are the “surficial” and “Eutaw-McShan” aquifers; therefore, from this point forward, they will be referred 

to as such.

The Kerr-McGee property is underlain by Quaternary-age alluvial deposits consisting of gravel, sand, silt, 

and clay. The gravel is generally encountered at the base of the alluvium and grades upward into sand 

and silts (Ref. 82, p. 46). Boring logs indicate the thickness of the alluvium is about 15.5 to 23.5 feet at 

the Kerr-McGee property (Refs. 22, pp. 16 through 60; 40, p. 11). The Eutaw Formation underlies the 

terrace deposits and is encountered at about 25 feet bgs (155 feet above msl) (Ref. 21, pp. 5, 6). The 

approximate elevation at the Kerr-McGee property is about 180 feet above msl (Refs. 25, p. 29; 82, p. 

121). 

Surficial Aquifer – The surficial aquifer consists of interbedded layers of clay, silt, sand, and gravel 

(alluvium) deposited by Luxapallila Creek (Ref. 82, p. 51). The saturated zone is about 20 feet thick and 

is subject to seasonal fluctuations (Ref. 82, p. 51). The aquifer recharges from and discharges to 

Luxapallila Creek, depending on the season and flow stage of the creek. Rainwater also percolates down 

to the aquifer through overlying material (Ref. 82, p. 51). Wells installed within the surficial aquifer at 

the Kerr-McGee property range in depth from 163.56 to 149.13 feet above msl (Ref. 39, p. 29). Ground 

water flow in the surficial aquifer is to the southeast except where affected by the ground water collection 

system (Ref. 25, pp. 24, 25). 
51 GW Pathway Description

Eutaw-McShan Aquifer – The alluvium is unconformably underlain by the uppermost member of the 

Cretaceous-Age Eutaw Formation consisting of fine grained, silty, micaceous, and glauconitic fluvial and 

deltaic sands (Ref. 40, p. 11). A weathered zone containing an orange medium to coarse-grained 

glauconitic sand occurs at some surface locations of the zone (Ref. 40, p. 13). Local ground water 

discharge in the Eutaw-McShan aquifer is most likely to Luxapallila Creek, about 1 mile east of the KerrMcGee property (Ref. 40, p. 13). The Kerr-McGee property lies within the outcrop boundary of the 

Eutaw-McShan aquifer and is, therefore, unconfined from the overlying surficial aquifer, where present 

(Refs. 30, p. 10; 82, p. 51). Wells installed on the Kerr-McGee property within the Eutaw-McShan 

aquifer range in depths from 131.70 to 125.68 feet above msl (Ref. 39, p. 29). Ground water flow in the 

Eutaw-McShan aquifer is to the southeast (Ref. 25, pp. 26, 27). 

Tuscaloosa Aquifer System – Available data suggests that the Tuscaloosa aquifer system is confined 

beneath the overlying Eutaw-McShan aquifer by clay and silt with the transition marked by a nearly 

continuous 15 to 20 foot thick carbonaceous and lignitic clay band in northeastern Mississippi (Refs. 30, 

pp. 11, 13; 32, p. 34). Available data suggests the Eutaw Formation rests conformably upon the 

Tuscaloosa Formation throughout its occurrence in Mississippi (Ref. 32, p. 34). The Tuscaloosa aquifer

system consists of the Gordo, Coker, and Massive Sand aquifers of the Tuscaloosa Group and a Lower 

Cretaceous aquifer of undifferentiated sediments. Columbus Light and Water municipal wells indicate 

the presence of confining units; however, these units do not correlate with each other, indicating that the 

Gordo, Coker and Massive Sand aquifers are interconnected and regionally maintain a hydraulic 

continuity (Refs. 46, p. 1 through 18; 30, p. 11). No monitoring wells are completed in the Tuscaloosa 

aquifer system on the Kerr-McGee property (Refs. 5, pp. 122, 123, 128, 129; 40, pp. 97 to 99, 119 to 121, 

150 to 152; 41, pp. 90 to 93, 99, 100; 42, pp. 256, 257; 43, pp. 116, 117). 

Aquifer Interconnection

The Kerr-McGee property lies within the outcrop area of the Eutaw-McShan Formation (Ref. 30, p. 10). 

Boring logs of some wells installed on the Kerr-McGee property describe the surficial aquifer as 

containing sand and gravel (Ref. 40, pp. 21, 22, 126, 130, 142). Also, wells completed in the EutawMcShan aquifer on the Kerr-McGee property contain sand and sandy silt (Refs. 5, pp. 144 through 147; 

40, pp. 42, 43; 54, p. 39). The surficial and Eutaw-McShan aquifers are interconnected because no 

continuous layer of significantly lower hydraulic conductivity separates the two aquifers throughout the 

2-mile radius from the sources (Refs. 1, Section 3.0.1.2.1, Table 3-6; 5, pp. 144 through 147; 40, pp. 21, 

22, 41, 42, 126, 130, 142; 54, p. 39). Available data also suggests that both the surficial aquifer (where 

present) and the Eutaw-McShan aquifer receive recharge from Luxapallila Creek indicating that ground 

water is able to freely migrate between the two aquifers (Ref. 82, p. 51). 

A review of well completion data for Columbus Light and Water municipal wells located between 0.25 

and 1.0 mile east of Kerr-McGee sources, indicate that the Massive Sand aquifer is confined above by 

layers of clay (49 to 182 feet thick) and shale (44 to 261 feet thick) (Refs. 3; 46, pp. 1 through 18). 

Further review reveals that municipal well Nos. 1 and 2 encounter clay from approximately 340 feet 

below msl to 383-474 feet below msl and shale is encountered from 462-558 feet below msl to 598 feet 

below msl. However, municipal well Nos. 4 and 5 (adjacent to municipal well Nos. 1 and 2) encounter 

shale from 330 feet below msl to 500-578 feet below msl, which is the interval where municipal well Nos.

1 and 2 encounter clay. Because these confining units do not correlate with each other, this evidence 

suggests that the confining units may not be continuous and that the Coker and Massive Sand aquifers 

may be in direct hydraulic connection (Refs. 3; 46, p. 1 through 10; 47).
52 GW Pathway Description

Aquifer Discontinuities

The surficial aquifer within alluvial deposits is discontinuous because water-bearing alluvium is not 

present everywhere within a 4-mile radius of the Kerr-McGee property (Refs. 3; 31, p. 70, Plate 1B; 32, p. 

308). The Eutaw-McShan aquifer is continuous in the northeastern portion of Mississippi and crops out 

in certain counties bordering Alabama, including Lowndes County, Mississippi (Ref. 44, p. C20). The 

Tuscaloosa aquifer system is continuous throughout the 4-mile radius of sources at Kerr-McGee (Ref. 30, 

pp. 12, 14, 15).

SUMMARY OF AQUIFERS BEING EVALUATED

TABLE 9: Summary of Aquifers Being Evaluated 

Aquifer Name

Is Aquifer 

Interconnected with 

Upper Aquifer 

within 2 Miles? 

(Yes/No/NA)

Is Aquifer 

Continuous within 

4-mile TDL? 

(Yes/No)

Is Aquifer 

Karst? 

(Yes/No) References

Surficial NA No No

1, Section 3.0.1.2.1; 

31, p. 70, Plate 1B; 

32, p. 308; 40, pp. 

11, 21, 22, 126, 130, 

142

Eutaw-McShan Yes Yes No

1, Section 3.0.1.2.1; 

5, pp. 144 through 

147; 30, p. 10; 40, 

pp. 21, 22, 41, 42, 

126, 130, 142; 44, p. 

C20; 54, p. 39; 82, 

p. 51 

Tuscaloosa Group of 

the Tuscaloosa Aquifer 

System (comprised of 

the interconnected 

Gordo, Coker, and 

Massive Sand aquifers)

No Yes No

1, Section 3.0.1.2.1; 

30, pp. 12, 14, 15; 

44, p. C17; 87, pp. 

40, 41, 42 

Notes:

NA Not applicable

TDL Target distance limit
53 GW-Likelihood of Release

3.1 LIKELIHOOD OF RELEASE

3.1.1 OBSERVED RELEASE

Aquifer Being Evaluated: Interconnected Surficial and Eutaw-McShan aquifers 

TABLE 10: Background Ground Water Sample – Surficial Aquifer

Chemical Analysis

May 2002, Hazardous Waste Permit No. HW-90-329-01 Sampling Event– Surficial Aquifer

Background Sample

The background monitoring well sample listed in Table 10 was collected by Kerr-McGee during the May 

2002 sampling event (Ref. 39, pp. 2, 3, 49). Monitoring well CMW-16 is located west of Source No. 1

(Ref. 39, p. 22). The location of CMW-16 is upgradient of ground water underlying and/or downgradient 

of Source Nos. 1, 2, and 3 (Ref. 39, p. 25) (see Figures 3 and 4 of this HRS documentation record). The 

background monitoring well sample listed in Table 10 was collected from the surficial aquifer and is used 

to represent background conditions for observed releases to the surficial aquifer underlying and 

downgradient of Source Nos. 1, 2, and 3 at the southern Kerr-McGee property (Refs. 39, p. 25; 40, pp. 

150, 151, 152; 82, p. 51) (see Figure 3 of this HRS documentation record). 

Screened intervals of wells installed in the surficial aquifer listed in Tables 10 and 12 range from 169.8 to 

150.82 feet above msl (Ref. 39, p. 29). The boring log and monitoring well installation diagram for 

monitoring well CMW-16 is provided in Reference 40, pages 150 through 152. 

The background ground water sample was collected in accordance with the MDEQ-approved revised 

sampling and analysis plan (Refs. 37, pp. iii, 1 through 18; 38, pp. 1, 2, 3; 39, p. 3). The location of the 

background ground water sample is depicted in Reference 39, page 22 (see Figure 4 of this HRS 

documentation record). 

The background and contaminated ground water samples were collected from permanent monitoring 

wells installed in the surficial aquifer with similar screened intervals, during the same sampling event, in 

accordance with same sampling procedures, and were analyzed by the same laboratory using the same 

analytical methods (Refs. 5, pp. 122, 123; 37, pp. iii, 1 through 18, 28, 29; 38, pp. 1, 2, 3; 39, pp. 3, 4, 29, 

41 through 54; 40, pp. 119, 120, 121, 150, 151, 152; 41, pp. 92, 93, 99, 100; 42, pp. 256, 257) (see Tables 

10 and 12 of this HRS documentation record). 

Sample ID

Elevation 

of Well 

Bottom

(feet amsl)

Screened 

Interval 

(feet amsl) 

Date 

Sampled Location References

CMW-16 159.80 169.80 to 

160.80 5/15/2002 West of the backfilled surface impoundments 39, pp. 25, 29, 49 

Notes:

amsl Above mean sea level

CMW Shallow well

ID Identification number
54 GW-Likelihood of Release

Background Concentrations

The background ground water sample listed in Table 11 was collected from the surficial aquifer (Refs. 40, 

pp. 150, 151, 152; 82, p. 51). The sample was analyzed by Southwest for SVOCs by EPA SW-846 

Method 8270 (Refs. 37, pp. 28, 29; 39, pp. 3, 4, 49). 

The MDLs are provided in Reference 37, pages 208 and 209. The MDL is equivalent to the lowest 

concentration of analyte that a method can detect reliably in either a sample or a blank (Ref. 1, Section 

1.1). Southwest presented the practical quantitation limits (PQL) instead of the MDLs on the analytical 

data sheets for non-detect (U) results (Refs. 37, pp. 103, 208, 209; 39, p. 49). 

 

Tetra Tech conducted a review of the elements of the analytical data package. Tetra Tech evaluated the 

initial and diluted analyses reported (Ref. 93). The review is contained in Reference 93. Analytical data 

sheets are contained in Reference 39. 

TABLE 11: Analytical Results for May 2002 

Sample ID

Hazardous 

Substance Concentration MDL References

CMW-16 Naphthalene 10U μg/L 1.6 μg/L 37, p. 208; 39, p. 49 

CMW-16 Acenaphthylene 10U μg/L 1.1 μg/L 37, p. 209; 39, p. 49 

CMW-16 Pentachlorophenol 25U μg/L 4.8 μg/L 37, p. 209; 39, p. 49 

CMW-16 Phenanthrene 10U μg/L 1.8 μg/L 37, p. 209; 39, p. 49 

CMW-16 Fluoranthene 10U μg/L 2.7 μg/L 37, p. 209; 39, p. 49 

CMW-16 Benzo(a)anthracene 10U μg/L 1.6 μg/L 37, p. 209; 39, p. 49 

CMW-16 Benzo(a)pyrene 10U μg/L 1.2 μg/L 37, p. 209; 39, p. 49 

CMW-16 Benzo(b)fluoranthene 10U μg/L 2.7 μg/L 37, p. 209; 39, p. 49 

CMW-16 Indeno(1,2,3-

cd)pyrene 10U μg/L 2.1 μg/L 37, p. 209; 39, p. 49 

Notes:

CMW Shallow well

ID Identification number

MDL Method detection limit

μg/L Microgram per liter

U Analyte was not detected to the level shown
55 GW-Likelihood of Release

Contaminated Samples

Ground water samples listed in Table 12 were collected from the surficial aquifer underlying and/or

downgradient of Source Nos. 1, 2, and 3 during the May 2002 sampling event conducted by Kerr-McGee 

(Refs. 5, pp. 122, 123; 39, pp. 2, 25, 41, 43, 47, 49; 40, pp. 119, 120, 121; 41, pp. 92, 93, 99, 100; 42, pp. 

256, 257; 82, p. 51) (see Figures 3 and 4 of this HRS documentation record). The ground water samples 

were collected in accordance with the MDEQ-approved revised sampling and analysis plan (Refs. 37, pp. 

iii, 1 through 18; 38, pp. 1, 2, 3; 39, p. 3). 

The contaminated ground water samples and their corresponding depths and screened intervals are listed 

in Table 12. Contaminated ground water samples underlying and/or downgradient of Source Nos. 1, 2, 

and 3 were compared with a ground water sample collected from monitoring well CMW-16, which is 

completed in the same aquifer at a corresponding screened interval (Ref. 39, pp. 25, 29) (see Tables 10 

and 12 of this HRS documentation record). Boring logs and monitoring well installation diagrams for the 

wells listed in Table 12 are provided in References 5, pp. 122, 123; 40, pp. 119, 120, 121; 41, pp. 92, 93, 

99, 100; 42, pp. 256, 257. Locations of the contaminated ground water samples are depicted in Reference 

39, page 22 (see Figure 4 of this HRS documentation record). 

TABLE 12: Ground Water Samples – Surficial Aquifer

Sample ID

Elevation of 

Well Bottom

(feet amsl)

Screened 

Interval 

(feet amsl) 

Date 

Sampled Location References

CMW-8 156.24 167.74 to 

157.74 5/14/2002 

Downgradient of the 

backfilled surface 

impoundments 

39, pp. 22, 29, 41 

CMW-24 154.13 164.63 to 

154.93 5/14/2002 

Southeastern corner 

of the southern KerrMcGee property39, pp. 22, 29, 47 

CMW-19R 151.81 162.61 to 

152.81 5/14/2002 Center of the southern 

Kerr-McGee property 39, pp. 22, 29, 43 

CMW-66 150.97 163.48 to 

153.77 5/15/2002 South of the southern Kerr-McGee property 39, pp. 22, 29, 49 

CMW-33 160.80 160.82 to 

150.82 5/14/2002 

Northeastern portion 

of the southern KerrMcGee property39, pp. 22, 29, 43 

Notes:

amsl Above mean sea level

CMW Shallow well

ID Identification

R Replacement well
56 GW-Likelihood of Release

Contaminated Concentrations 

Ground water samples listed in Table 13 were collected from monitoring wells completed in the surficial 

aquifer (Refs. 5, pp. 122, 123; 40, pp. 119, 120, 121; 41, pp. 92, 93, 99, 100; 42, pp. 256, 257; 82, p. 51). 

The samples were analyzed by Southwest for SVOCs by EPA SW-846 Method 8270 (Refs. 37, pp. 28, 

29; 39, pp. 3, 4, 41, 43, 47, 49). 

The MDLs are provided in Reference 37, pages 208 and 209. The MDL is equivalent to the lowest 

concentration of analyte that a method can detect reliably in either a sample or a blank (Ref. 1, Section 

1.1). 

Tetra Tech conducted a review of the elements of the analytical data package. Tetra Tech evaluated the 

initial and diluted analyses reported (Ref. 93). The review is contained in Reference 93. Analytical data 

sheets are contained in Reference 39. 

TABLE 13: Analytical Results for May 2002 

Sample ID Hazardous Substance Concentration MDL References

CMW-8 Acenaphthylene 37 μg/L 1.1 μg/L 37, p. 209; 39, p. 41; 93, 

pp. i, 1 

CMW-8 Fluoranthene 30 μg/L 2.7 μg/L 37, p. 209; 39, p. 41; 93, 

pp. i, 1 

CMW-8 DL Naphthalene 4,700 μg/L 1.6 μg/L 37, p. 208; 39, p. 41; 93, 

pp. i, 1 

CMW-24 Fluoranthene 20 μg/L 2.7 μg/L 37, p. 209; 39, p. 47

CMW-19R Acenaphthylene 12 μg/L 1.1 μg/L 37, p. 209; 39, p. 43; 93, 

pp. i, 3 

CMW-19R Phenanthrene 57 μg/L 1.8 μg/L 37, p. 209; 39, p. 43; 93, 

pp. i, 3 

CMW-19R DL Naphthalene 1,200 μg/L 1.6 μg/L 37, p. 208; 39, p. 43; 93, 

pp. i, 3 

CMW-19R DL Pentachlorophenol 1,100 μg/L 4.8 μg/L 37, p. 209; 39, p. 43; 93, 

pp. i, 3 

CMW-66 Naphthalene 21 μg/L 1.6 μg/L 37, p. 208; 39, p. 49; 93, 

pp. i, 9 

CMW-66 Phenanthrene 10 μg/L 1.8 μg/L 37, p. 209; 39, p. 49; 93, 

pp. i, 9 

CMW-66 Benzo(a)anthracene 32 μg/L 1.6 μg/L 37, p. 209; 39, p. 49; 93, 

pp. i, 9 

CMW-66 Benzo(a)pyrene 13 μg/L 1.2 μg/L 37, p. 209; 39, p. 49; 93, 

pp. i, 9 

CMW-66 Benzo(b)fluoranthene 15 μg/L 2.7 μg/L 37, p. 209; 39, p. 49; 93, 

pp. i, 9 

CMW-66 DL Fluoranthene 140 μg/L 2.7 μg/L 37, p. 209; 39, p. 49; 93, 

pp. i, 9 

CMW-33 Naphthalene 77 μg/L 1.6 μg/L 37, p. 208; 39, p. 43
57 GW-Likelihood of Release

TABLE 13: Analytical Results for May 2002 

Sample ID Hazardous Substance Concentration MDL References

CMW-33 Phenanthrene 11 μg/L 1.8 μg/L 37, p. 209; 39, p. 43 

Notes:

CMW Shallow well

DL The sample was diluted

ID Identification

MDL Method detection limit

μg/L Microgram per liter

R Replacement well
58 GW-Likelihood of Release

November 2008 Hazardous Waste Permit No. HW-90-329-01 Sampling Event– Surficial Aquifer

Background Samples

The background monitoring well samples listed in Table 14 were collected by Kerr-McGee during the 

November 2008 sampling event (Refs. 25, pp. 3, 4; 61, p. 53; 64, p. 3). Monitoring wells CMW-1AR and 

CMW-16 are located northeast and west of Source No. 1 (Ref. 25, p. 21). These locations are upgradient 

of ground water underlying and/or downgradient of Source Nos. 1, 2, and 3 (Ref. 25, p. 25) (see Figures 3 

and 4 of this HRS documentation record). The background monitoring well samples listed in Table 14 

were collected from the surficial aquifer and are used to represent background conditions for observed 

releases to the surficial aquifer underlying and/or downgradient of Source Nos. 1, 2, and 3 at the southern 

Kerr-McGee property (Ref. 25, pp. 25, 29; 40, pp. 97, 98, 99, 150, 151, 152; 82, p. 51) (see Figure 3 of 

this HRS documentation record). 

Screened intervals of wells installed in the surficial aquifer listed in Tables 14 and 16 range from 175.06 

to 152.81 feet above msl (Ref. 25, p. 29). The total well depth in feet above msl was calculated by 

subtracting the depth of the well bgs from the surface elevation above msl provided in Reference 25, page 

29. The boring logs and monitoring well installation diagrams for monitoring wells CMW-1AR and 

CMW-16 are provided in Reference 40, pages 97 through 99 and 150 through 152. 

The background ground water samples were collected in accordance with the revised sampling and 

analysis plan (Refs. 25, p. 3; 63). Locations of the background ground water samples are depicted in 

Reference 25, page 21 (see Figure 4 of this HRS documentation record). 

The background and contaminated ground water samples were collected from permanent monitoring 

wells installed in the surficial aquifer with similar screened intervals, during the same sampling event, in 

accordance with the same sampling procedures, and analyzed by the same laboratory using the same 

analytical methods (Refs. 5, pp. 128, 129; 25, pp. 3, 4, 29, 31; 40, pp. 97, 98, 99, 119, 120, 121, 150, 151, 

152; 41, pp. 90, 91, 92, 93; 42, pp. 256, 257; 43, pp. 116, 117; 61, pp. 8, 19, 21, 25, 28, 35; 63; 64, pp. 4, 

14; 82, p. 51). 

TABLE 14: Background Ground Water Samples – Surficial Aquifer 

Sample ID

Total Depth 

of Well

(feet amsl)

Screened 

Interval 

(feet amsl)

Date 

Sampled Location References

CMW-16 159.8 169.80 to 

160.80 11/11/2008 West of the backfilled surface impoundments 

25, pp. 21, 29; 64, pp. 3, 

36 

CMW-1AR 163.83 175.06 to 

165.06 11/12/2008 

Northeast of the 

backfilled surface 

impoundments 

25, pp. 21, 29; 61, p. 53 

Notes:

amsl Above mean sea level

CMW Shallow well

ID Identification number
59 GW-Likelihood of Release

Background Concentrations

The background ground water samples listed in Table 15 were collected from the surficial aquifer (Refs. 

40, pp. 97, 98, 99, 150, 151, 152; 82, p. 51). The samples were analyzed by Lancaster Laboratories for 

target compound list (TCL) semivolatiles by EPA SW-846 Method 8270 (Refs. 61, p. 19; 64, p. 4). 

The MDLs are provided on the analytical data sheets contained in References 61 and 64. The MDL is 

equivalent to the lowest concentration of analyte that a method can detect reliably in either a sample or a 

blank (Ref. 1, Section 1.1). 

 

Tetra Tech conducted a review of the quality control elements of the analytical data packages. The 

review was conducted in accordance with the EPA CLP NFGs for Organic Data Review (Refs. 94; 95). 

The reviews are contained in References 94 and 95. Analytical data sheets and chain-of-custody records 

are contained in References 61 and 64. 

TABLE 15: Analytical Results for November 2008 

Sample ID Hazardous Substance Concentration MDL References

CMW-16 2,4-dimethylphenol N.D. 3 μg/L 64, p. 3 

CMW-16 Naphthalene N.D. 1 μg/L 64, p. 3 

CMW-16 Acenaphthylene N.D. 1 μg/L 64, p. 3 

CMW-16 Phenanthrene N.D. 1 μg/L 64, p. 3 

CMW-16 Fluoranthene N.D. 1 μg/L 64, p. 3 

CMW-16 Benzo(a)anthracene N.D. 1 μg/L 64, p. 3 

CMW-16 Benzo(a)pyrene N.D. 1 μg/L 64, p. 3 

CMW-16 Benzo(b)fluoranthene N.D. 1 μg/L 64, p. 3 

CMW-16 Indeno(1,2,3-cd)pyrene N.D. 1 μg/L 64, p. 3 

CMW-16 Carbazole N.D. 1 μg/L 64, p. 3 

CMW-1AR 2,4-dimethylphenol N.D. 30 μg/L 61, p. 18 

CMW-1AR Naphthalene N.D. 10 μg/L 61, p. 18 

CMW-1AR Acenaphthylene N.D. 10 μg/L 61, p. 18 

CMW-1AR Phenanthrene N.D. 10 μg/L 61, p. 18 

CMW-1AR Fluoranthene N.D. 10 μg/L 61, p. 18 

CMW-1AR Benzo(a)anthracene N.D. 10 μg/L 61, p. 18 

CMW-1AR Benzo(a)pyrene N.D. 10 μg/L 61, p. 18 

CMW-1AR Benzo(b)fluoranthene N.D. 10 μg/L 61, p. 18 

CMW-1AR Indeno(1,2,3-cd)pyrene N.D. 10 μg/L 61, p. 18 

CMW-1AR Carbazole N.D. 10 μg/L 61, p. 18 
60 GW-Likelihood of Release

Notes:

CMW Shallow well

ID Identification

MDL Method detection limit

μg/L Microgram per liter

N.D. Non detect
61 GW-Likelihood of Release

Contaminated Samples

Ground water samples listed in Table 16 were collected from the surficial aquifer underlying and/or 

downgradient of Source Nos. 1, 2, and 3 during the November 2008 sampling event conducted by KerrMcGee (Refs. 5, pp. 128, 129; 25, pp. 3, 4, 31; 40, pp. 119, 120, 121; 41, pp. 90, 91, 92, 93; 42, pp. 256, 

257; 43, pp. 116, 117; 82, p. 51) (see Figures 3 and 4 of this HRS documentation record). 

The ground water samples were collected in accordance with the revised sampling and analysis plan 

(Refs. 25, p. 3; 63). The contaminated ground water samples and their corresponding depths and screened 

intervals are listed in Table 16. The total well depth in feet above msl was calculated by subtracting the 

depth of the well bgs from the surface elevation above msl provided in Reference 25, page 29. 

Contaminated ground water samples underlying and/or downgradient of Source Nos. 1, 2, and 3 were 

compared with ground water samples collected from monitoring wells CMW-1AR and CMW-16, which 

are completed in the same aquifer at corresponding screened intervals (Refs. 25, pp. 25, 29; 40, pp. 97, 

98, 99, 150, 151, 152) (see Tables 14 and 16 of this HRS documentation record). Boring logs and 

monitoring well installation diagrams for the wells listed in Table 16 are provided in References 5, pp. 

128, 129; 40, pp. 119, 120, 121; 41, pp. 90, 91, 92, 93; 42, pp. 256, 257; 43, pp. 116, 117. Locations of 

the contaminated ground water samples are depicted in Reference 25, page 21 (see Figure 4 of this HRS 

documentation record). 

TABLE 16: Ground Water Samples – Surficial Aquifer

Sample ID

Total Well 

Depth

(feet amsl)

Screened 

Interval 

(feet amsl)

Date 

Sampled Location References

CMW-27 162.01 168.66 to 

163.96 11/12/2008 

Eastern portion of the 

southern Kerr-McGee 

property 

25, pp. 21, 29; 61, p. 53

CMW-36 157.3 168.3 to 

158.3 11/12/2008 

Northern boundary of 

the southern KerrMcGee property

25, pp. 21, 29; 61, p. 54 

CMW-11R 156.3 167.70 to 

157.70 11/12/2008 

Southern boundary of 

the southern KerrMcGee property

25, pp. 21, 29; 61, p. 53 

CMW-8 156.28 167.74 to 

157.74 11/11/2008 

South of the 

backfilled surface 

impoundments 

25, pp. 21, 29; 64, pp. 13, 

36 

CMW-19R 151.21 162.61 to 

152.81 11/12/2008 Center of the southern 

Kerr-McGee property 25, pp. 21, 29; 61, p. 54 

CMW-66 150.97 163.48 to 

153.77 11/12/2008 South of the southern 

Kerr-McGee property 25, pp. 21, 29; 61, p. 54

Notes:

amsl Above mean sea level

CMW Shallow well

ID Identification number

R Replacement well
62 GW-Likelihood of Release

Contaminated Concentrations 

Ground water samples listed in Table 17 were collected from monitoring wells completed in the surficial 

aquifer (Refs. 5, pp. 128, 129; 40, pp. 119, 120, 121; 41, pp. 90, 91, 92, 93; 42, pp. 256, 257; 43, pp. 116, 

117; 82, p. 51). The samples were analyzed by Lancaster Laboratories for TCL semivolatiles by EPA 

SW-846 Method 8270 (Refs. 61, pp. 8, 21, 25, 28, 35; 64, p. 14).

The MDLs are provided on the analytical data sheets contained in References 61 and 64. The MDL is 

equivalent to the lowest concentration of analyte that a method can detect reliably in either a sample or a 

blank (Ref. 1, Section 1.1). 

 

Tetra Tech conducted a review of the quality control elements of the analytical data packages. The 

review was conducted in accordance with the EPA CLP NFGs for Organic Data Review (Refs. 94; 95). 

The reviews are contained in References 94 and 95. Analytical data sheets and chain-of-custody records 

are contained in References 61 and 64. 

TABLE 17: Analytical Results for November 2008 

Sample ID Hazardous Substance Concentration MDL References

CMW-27 Indeno(1,2,3-cd)pyrene 6 μg/L 1 μg/L 61, p. 20 

CMW-36 Naphthalene 220 μg/L 10 μg/L 61, p. 24 

CMW-36 Phenanthrene 1,300 μg/L 100 μg/L 61, p. 24 

CMW-36 Fluoranthene 1,200 μg/L 100 μg/L 61, p. 24 

CMW-36 Benzo(a)anthracene 320 μg/L 10 μg/L 61, p. 24 

CMW-36 Benzo(a)pyrene 150 μg/L 10 μg/L 61, p. 24 

CMW-36 Benzo(b)fluoranthene 220 μg/L 10 μg/L 61, p. 24 

CMW-36 Indeno(1,2,3-cd)pyrene 89 μg/L 10 μg/L 61, p. 24 

CMW-36 Dibenz(a,h)anthracene 66 μg/L 10 μg/L 61, p. 24 

CMW-11R 2,4-dimethylphenol 50 J- (50) μg/L 3 μg/L 61, p. 7; 94, p. 7; 97, p. 8 

CMW-11R Carbazole 130 μg/L 10 μg/L 61, p. 7 

CMW-11R Naphthalene 2,200 μg/L 100 μg/L 61, p. 7 

CMW-8 Naphthalene 3,400 μg/L 510 μg/L 64, p. 13 

CMW-8 Acenaphthylene 70 μg/L 1 μg/L 64, p. 13 

CMW-8 Phenanthrene 300 μg/L 10 μg/L 64, p. 13 

CMW-8 Fluoranthene 52 μg/L 1 μg/L 64, p. 13 

CMW-8 Indeno(1,2,3-cd)pyrene 6 μg/L 1 μg/L 64, p. 13 

CMW-8 Carbazole 210 μg/L 10 μg/L 64, p. 13 

CMW-19R Naphthalene 190 μg/L 10 μg/L 61, p. 28 

CMW-66 Naphthalene 180 μg/L 5 μg/L 61, p. 35 
63 GW-Likelihood of Release

Notes:

CMW Shallow well

ID Identification

J- Estimated value. Recoveries for acid extractable surrogates were below their QC limits; therefore, the acid 

extractable compounds were qualified as estimated with a potential low bias (94, p. i). The value presented 

parenthetically is the concentration obtained by applying EPA fact sheet Using Qualified Data to Document 

an Observed Release and Observed Contamination (November 1996) (Ref. 97, p. 8).

MDL Method detection limit

μg/L Microgram per liter

R Replacement well
64 GW-Likelihood of Release

In 1988, the facility installed a concrete drip pad to collect excess preservative, which dripped off the 

wood following removal from the cylinder (Ref. 82, p. 17). Prior to 1988, preservative (creosote and 

PCP) dripped onto bare soil (Refs. 13, p. ii, Attachment B, p. B-24; 82, p. 13). The new drip pad was 

constructed after visually impacted soil from the area had been excavated to a depth of 4 feet. Soil 

samples were collected from Source No. 2 at 6 inches below the surface of the excavation designated as 

visually clean (Ref. 14, p. 26). The samples contained creosote constituents, including PCP; the 

contamination was left in place (Refs. 14, p. 29; 18, p. 22; 54, p. 42) (see Table 3 of this HRS 

documentation record). 

Surface and subsurface soil samples collected from Source No. 3 (various areas on the southern KerrMcGee property) in 1996 and 2008 contain creosote constituents, including PCP and 1,2,3,4,6,7,8-

HpCDD (see Tables 5 and 6 of this HRS documentation record). Creosote constituents detected in 

surface and subsurface soil samples include 2,4-dimethylphenol, acenaphthylene, benzo(a)anthracene, 

benzo(a)pyrene, benzo(b)fluoranthene, carbazole, dibenz(a,h)anthracene, fluoranthene, indeno(1,2,3-

cd)pyrene, naphthalene, PCP, and phenanthrene (Ref. 54, pp. 23 through 27, 42, 120, 121, 122, 124). The 

highest concentrations of these constituents were detected in surface soil samples. Specifically, the 

greatest concentrations of dibenz(a,h)anthracene (19,000 μg/kg) and PCP (1,000,000 μg/kg) were 

detected in the former creosote recovery area located in the western portion of the southern Kerr-McGee 

property (Refs. 14, p. 27; 54, pp. 23, 61a; 92, pp. 1, 4) (see Table 5 of this HRS documentation record). 

The highest concentration of benzo(a)pyrene (110,000 μg/kg) was detected in the black tie storage area

located in the central portion of the southern Kerr-McGee property (Refs. 54, p. 61a; 82, p. 126; 92, pp. 1, 

7) (see Tables 5 and 6 of this HRS documentation record). 

Attribution

From 1928 until 2003, a wood preserving facility operated on the Kerr-McGee property (Refs. 54, p. 3; 

56, p.1). The facility manufactured pressure-treated railroad products including wooden cross ties, switch 

ties, and timbers using several preservatives including PCP, creosote, and creosote coal tar solutions 

(Refs. 14, p. 9; 19, pp. 1, 2; 82, pp. 10, 13). The primary constituent compounds of the preservative 

creosote used at the Kerr-McGee facility include 2-chlorophenol; 2,4-dimethylphenol; p-chloro-m-cresol; 

PCP; phenol; 2,4,6-trichlorophenol; 2,3,4,6-tetrachlorophenol; 2,4-dinitrophenol; acenaphthylene; 

benzo(a)anthracene; benzo(a)pyrene; benzo(b)fluoranthene; carbazole; dibenz(a,h)anthracene; 

fluoranthene; indeno(1,2,3-cd)pyrene; naphthalene; and phenanthrene (Ref. 54, p. 42). 

Prior to 1986, two surface impoundments received wastewater generated from the production process. 

Sludge which formed at the bottom of the impoundments from the carryover of creosote was classified as 

EPA hazardous waste K001: “bottom sediment sludge from the treatment of wastewaters from wood 

preserving processes that use creosote and/or pentachlorophenol” (Ref. 17, p. 15). 

Closure of the impoundments began in 1986 and was completed in 1987. Closure activities were 

conducted in accordance with the MBPC-approved closure plan (Refs. 17, p. 15; 82, p. 20). Following 

removal of contaminated material from the impoundments, Kerr-McGee collected samples from 0 to 6 

inches below the bottom surface of the impoundments (Ref. 7, pp. 4, 5; 17, p. 15). The Source No. 1 

samples contained creosote constituents (Refs. 7, pp. 5, 7; 54, p. 42) (see Table 1 of this HRS 

documentation record). Because clean closure was not accomplished, Kerr-McGee submitted a Part B 

post-closure permit application in March 1987 (Refs. 17, p. 9; 27, pp. 1, 3). In September 1987, KerrMcGee notified MBPC of the presence of dissolved creosote constituents in monitoring wells 

downgradient of the backfilled surface impoundments (Ref. 21, p. 7). Based on the screened intervals of 

the monitoring wells (CMW-1 through CMW-5) located downgradient of the backfilled surface 

impoundments (Source No. 1), the dissolved creosote constituents were detected in the surficial aquifer 

(Ref. 21, pp. 5, 7, 8, 17, 21). 

In 1989, Kerr-McGee entered into a consent order with MBPC because of the discovery of creosote 

product in monitoring wells downgradient of Source No. 1 (two backfilled surface impoundments) (Ref. 

21, p. 7; 24, pp. 1 through 4). Numerous investigations have been conducted on the Kerr-McGee property 
65 GW-Likelihood of Release

to delineate ground water and soil contamination associated with wood preserving operations (Ref. 14, p. 

14). Currently, 41 surficial aquifer monitoring wells, 21 surficial aquifer piezometers, and five Eutaw 

Formation monitoring wells are located on or near the southern Kerr-McGee property for ground water 

assessment purposes (Ref. 25, pp. 2, 21). Ground water sampling is performed semi-annually by KerrMcGee as required by Section V.G.1, 2 of Hazardous Waste Permit No. HW-90-329-1 (issued September 

11, 1990) (Ref. 25, pp. 1, 2). 

Creosote constituents were detected in Source Nos. 1, 2, and 3 at the southern Kerr-McGee property. 

Source No. 1 consists of two backfilled surface impoundments, Source No. 2 consists of contaminated 

soil located under the former drip pad, and Source No. 3 consists of contaminated soil located in various 

areas on the southern Kerr-McGee property (see Section 2.2.1, Source Nos. 1, 2, and 3 of this HRS 

documentation record). Analytical results of ground water samples collected underlying and/or 

downgradient of Source Nos. 1, 2, and 3 indicate creosote constituents at concentrations above 

background levels (see Section 3.1.1, Observed Release of this HRS documentation record). The highest 

concentrations of acenaphthylene (70 μg/L), naphthalene (4,700 μg/L), and carbazole (210 μg/L) were 

detected in monitoring well CMW-8 located about 15 feet downgradient of Source No. 1 (Refs. 25, pp. 

21, 25; 39, p. 41; 64, p. 13) (see Section 3.1.1 of this HRS documentation record). 

The hazardous substances listed below have been documented in Source Nos. 1, 2, or 3 and in ground 

water underlying and/or downgradient of Source Nos. 1, 2, and 3 on the southern Kerr-McGee property 

(see Tables 1, 3, 5, and 6 in Section 2.2.2 for Source Nos. 1, 2, and 3 and Tables 11, 13, 15, and 17 in 

Section 3.1.1, Observed Release, of this HRS documentation record). Creosote, creosote coal tar 

solutions, and PCP were used on the property to produce pressure-treated railroad products (Ref. 82, p. 

13). The primary constituents of the preservative creosote used at the Kerr-McGee facility include 2-

chlorophenol; 2,4-dimethylphenol; p-chloro-m-cresol; PCP; phenol; 2,4,6-trichlorophenol; 2,3,4,6-

tetrachlorophenol; 2,4-dinitrophenol; acenaphthylene; benzo(a)anthracene; benzo(a)pyrene; 

benzo(b)fluoranthene; carbazole; dibenz(a,h)anthracene; indeno(1,2,3-cd)pyrene; naphthalene; and 

phenanthrene (Ref. 54, p. 42). 

The Kerr-McGee property is located in a commercial, industrial, and residential area (Refs. 10, pp. 1, 2, 3; 

12, p. 4). Several industrial and commercial facilities have operated and still operate in the immediate 

vicinity of the Kerr-McGee property (Ref. 11, pp. 5, 26). Potentiometric surface maps prepared based on 

ground water elevations obtained during monitoring well sampling activities indicate that the direction of 

ground water flow in the surficial aquifer is to the southeast except where altered by the ground water 

recovery system (Refs. 25, p. 25; 39, p. 25). Columbus Brick Company, a brick manufacturer, is located 

upgradient of the Kerr-McGee property; however, creosote constituents are not used by the Columbus 

Brick Company (Refs. 11, pp. 5, 26; 83, pp. 13, 14). Moreover, background ground water samples 

collected from areas directly upgradient of past facility operations on the southern Kerr-McGee property 

do not contain hazardous substances at concentrations exceeding their respective laboratory MDLs (see 

Tables 11 and 15 of this HRS documentation record). 

Hazardous Substances in the Release

2,4-Dimethylphenol 

Carbazole 

Acenaphthylene 

Benzo(a)anthracene 

Benzo(a)pyrene 

Fluoranthene 

Indeno(1,2,3-cd)pyrene 

Naphthalene 

Pentachlorophenol 

Phenanthrene 

Ground Water Observed Release Factor Value: 550.00 
66 GW-Likelihood of Release

3.1.2 POTENTIAL TO RELEASE

Aquifer Being Evaluated: Interconnected Gordo, Coker, and Massive Sand Aquifers of the Tuscaloosa 

Group 

3.1.2.1 Containment

Source No. 1 is comprised of two backfilled surface impoundments. Following closure, Kerr-McGee 

collected soil samples from 0 to 6 inches below the bottom surface of Source No. 1 (Ref. 7, pp. 4, 5; 17, 

p. 15). The Source No. 1 samples contained creosote constituents (Refs. 7, pp. 5, 7; 54, p. 42) (see Table 

1 of this HRS documentation record). Clean closure of the backfilled surface impoundments was not 

accomplished (Refs. 17, p. 9; 27, pp. 1, 3). Reports describing closure of the impoundments do not 

mention the presence of a liner (Ref. 17, p. 15).

In 1988, the facility installed a concrete drip pad to collect excess preservative, which dripped off the 

wood following removal from the cylinder (Ref. 82, p. 17). Prior to 1988, preservative (creosote and 

PCP) dripped onto the bare soil (Ref. 13, p. ii, Attachment B, p. B-24). Prior to construction of the drip 

pad, visually impacted soil from the area had been excavated to a depth of 4 feet. Samples were collected 

from the bottom of the excavation. The Source No. 2 samples contained creosote constituents and the 

contamination was left in place (Refs. 14, pp. 26, 29; 18, p. 22; 54, p. 42) (see Table 3 of this HRS 

documentation record). 

Source No. 3 consists of contaminated soil located in various parts of the southern Kerr-McGee property. 

Specifically, surface and subsurface soil samples collected from the following areas contained creosote 

and/or PCDD constituents: black tie storage area, green tie storage area, brickyard area, holding tank area, 

tank farm area, creosote recovery system/wastewater treatment system, and cooling tower basin area 

(Refs. 54, pp. 17, 18, 19, 23, 24, 25, 26, 42, 120, 121, 122, 124; 56, pp. 2, 9, 13) (see Tables 5 and 6 of 

this HRS documentation record). 

Table 18 summarizes ground water containment for Source Nos. 1, 2, and 3 at the Kerr-McGee property. 

TABLE 18: Ground Water Containment

Source No.

Source Hazardous 

Waste Quantity Value

Containment Factor 

Value, Description 

(Ref. 1, Table 3-2) References

1 1,230.76 10, no liner 

1, Section 3.1.2.1, Table 

3-2; 7, pp. 4 through 8; 

17, p. 15; 27, pp. 1, 3 

2 >0 10, no liner 

1, Section 3.1.2.1, Table 

3-2; 13, p. B-24; 14, pp. 

26, 29; 18, pp. 1, 22

3 >0 10, no liner 

1, Section 3.1.2.1, Table 

3-2; 54, pp. 105, 107, 

109, 111; 56, pp. 18 

through 27 
67 GW-Likelihood of Release

3.1.2.2 Net Precipitation

The net precipitation for Columbus, Mississippi was calculated using the formula provided in Reference 

1, Section 3.1.2.2. The 10-year mean annual net precipitation for years 2000 to 2009 is 31.745 (Ref. 102, 

p. 1). Using Table 3-4 in Reference 1, the net precipitation factor value for Source Nos. 1, 2, and 3 at the 

Kerr-McGee property located in Columbus, Mississippi is 10. 

 

Net Precipitation Factor Value: 10 

(Ref. 1, Table 3-4) 

3.1.2.3 Depth to Aquifer

Aquifer Being Evaluated: Interconnected Gordo, Coker, and Massive Sand aquifers of the Tuscaloosa 

aquifer system. Table 19 lists the depth to the aquifer. 

Depth to Lowest Known Point of Hazardous Substances (CMW-33): 160.82 feet above msl (deepest top 

of screen depth of observed release wells) (see Table 12 of this HRS documentation record). Observed 

releases of phenanthrene and naphthalene have been documented in monitoring well CMW-33 located at 

the northern edge of the southern Kerr-McGee property (see Table 13 of this HRS documentation record) 

(Refs. 25, p. 24; 39, p. 43). 

The depth to the top of the Eutaw-McShan Formation (25 feet bgs) was obtained from Reference 21, 

pages 5 and 6. The approximate elevation at the Kerr-McGee property is 180 feet above msl (Refs. 25, p. 

29; 82, p. 121). Therefore, the elevation at the top of the Eutaw-McShan Formation is 155 feet above msl 

(180 feet above msl – 25 feet bgs).

TABLE 19: Depth to Aquifer

Aquifer/Layer (In 

descending order, 

beginning at lowest 

known point of hazardous 

substances) Karst?

Elevation 

at Top of 

Formation 

(feet amsl)

Thickness

(ft)

Cumulative

Thickness (ft) References

Surficial Aquifer No 160.82 5.82 1 5.82 

25, p. 24; 

39, p. 43 

Eutaw-McShan Formation No 155 250 255.82 

21, pp. 5, 6; 25, 

p. 29; 82, p. 121, 

126; 87, p. 46 

Confining Layer No -100 20 275.82 

3; 30, p. 11; 32, 

p. 34; 87, p. 46 

Notes:

1 Elevation at the lowest known point of hazardous substances 

amsl Above mean sea level

Depth to Aquifer Factor Value: 1 

(Ref. 1, Section 3.1.2.3, Table 3-5) 
68 GW-Likelihood of Release

3.1.2.4 Travel Time 

Table 20 lists travel times within the layers overlying the Tuscaloosa Group aquifers (i.e., the Gordo, 

Coker, and Massive Sand aquifers). 

TABLE 20: Travel Time

Layer Type of Material Thickness (feet)

Hydraulic 

Conductivity 

(cm/sec) 1 References

Surficial Aquifer

Interbedded layers of clay, 

silt, sand, and gravel 5.82 10

1, Table 3-6; 82, 

p. 51 -4

Eutaw-McShan 

Formation 

More or less cross-bedded, 

more or less glauconitic, fineto medium-grained, more or 

less micaceous sand 

underlain by greenish-gray, 

micaceous, locally very 

glauconitic, very fine-grained 

sand and thin-bedded lightgray clay; small chert gravels 

may be present in basal beds 250 10

1, Table 3-6; 31, 

p. 70; 33; 82, p. 

126; 87, p. 46 -4

Confining Layer

Carbonaceous and lignitic 

clay 20 10

1, Table 3-6; 30, 

pp. 11, 13; 32, 

p. 34 -8

Notes:

1

 This value was taken from the thickness for each layer listed in Table 19 

cm/sec Centimeters per second

Lowest Hydraulic Conductivity: 10

Potential to Release Factor Value: 160 

3.2 WASTE CHARACTERISTICS

-8

Thickness of Layer(s) with Lowest Hydraulic Conductivity (ft): 20 (clay confining unit) 

Travel Time Factor Value: 5 

(Ref. 1, Table 3-7) 

3.1.2.5 Calculation of Potential to Release Factor Value

Net Precipitation Factor Value: 10 

Depth to Aquifer Factor Value: 1 

Travel Time Factor Value: 5 

 Sum of Values: 16 

 Sum of Values × Containment Factor Value = 16 × 10 = 160 

3.2.1 TOXICITY/MOBILITY

Table 21 summarizes toxicity and mobility factor values for hazardous substances detected in source 

samples with containment factor values of greater than 0. The combined toxicity and mobility factor 
69 GW-Waste Characteristics

values are assigned in accordance with Reference 1, Section 3.2.1. Hazardous substances detected in the 

observed release to ground water are assigned a mobility factor value of 1 (Ref. 1, Section 3.2.1.2). All 

other mobility factor values are based on liquid, non-karst values.

TABLE 21: Ground Water Toxicity/Mobility 

Hazardous 

Substance

Source 

No.

Does Hazardous 

Substance Meet 

Observed 

Release? 

(Yes/No)

Toxicity 

Factor 

Value

Mobility

Factor 

Value

Toxicity/

Mobility

(Table 3-9) Reference

Acenaphthylene 1, 2, 3 Yes 0 1 0 a 2, p. BI-1 

Benzo(a)anthracene 1, 2, 3 Yes 1,000 1a 1,000 2, p. BI-2 

Benzo(a)pyrene 1, 2, 3 Yes 10,000 1 10,000 a 2, p. BI-2 

Carbazole 1, 2, 3 Yes 10 1 10 a 2, p. BI-2 

Dibenz(a,h)anthracene 3 Yes 10,000 1 10,000 a 2, p. BI-4 

2,4-Dimethylphenol 2, 3 Yes 100 1 100 a 2, p. BI-5 

Fluoranthene 1, 2, 3 Yes 100 1a 100 2, p. BI-2 

1,2,3,4,6,7,8-HpCDD 3 No 10,000 1E-4 1 2, p. BI-6 

Indeno(1,2,3-cd)pyrene 1, 2, 3 Yes 1,000 1 1,000 a 2, p. BI-8 

Naphthalene 1, 2, 3 Yes 1,000 1 1,000 a 2, p. BI-9 

Pentachlorophenol 2, 3 Yes 100 1 100 a 2, p. BI-9 

Phenanthrene 1, 2, 3 Yes 0 1 0 a 2, p. BI-9 

Phenol 2 No 10 1 10 2, p. BI-9 

2,4,6-Trichlorophenol 2 No 10 1 10 2, p. BI-11 

Notes:

a A ground water mobility of 1 is assigned because an observed release to ground water has been documented

HpCDD Heptachlorodibenzo-p-dioxin

 Toxicity/Mobility Factor Value: 10,000.00 

(Ref. 1, Table 3-9) 
70 GW-Waste Characteristics

3.2.2 HAZARDOUS WASTE QUANTITY

TABLE 22: Hazardous Waste Quantity

Source No. Source Type Source Hazardous Waste Quantity

1 Backfilled Surface Impoundments 1,230.76 

2 Contaminated Soil Undetermined, but greater than zero 

3 Contaminated Soil Undetermined, but greater than zero 

Sum of source hazardous waste quantity values: 1,230.76 + >0 + >0 = 1,230.76 

As specified in Reference 1, Section 2.4.2.2, Table 2-6, a HWQ factor value of 100 was assigned. 

Hazardous Waste Quantity Factor Value: 100 

(Ref. 1, Section 2.4.2.2) 

3.2.3 WASTE CHARACTERISTICS FACTOR CATEGORY VALUE

The waste characteristics factor category value was obtained by multiplying the toxicity/mobility and 

HWQ factor values, subject to a maximum product of 1 × 108

Toxicity/Mobility Factor Value: 10,000.00 

. Based on this product, a value was 

assigned in accordance with Reference 1, Table 2-7. 

Hazardous Waste Quantity Factor Value: 100 

Toxicity/Mobility Factor Value ×

Hazardous Waste Quantity Factor Value: 1,000,000.00 

Waste Characteristics Factor Category Value: 32

(Ref. 1, Table 2-7) 
71 GW-Targets

3.3 TARGETS

Residents in the site vicinity are provided drinking water from Columbus Light and Water (City of 

Columbus) and East Lowndes Water Association (Refs. 46, pp. 1 through 18; 47; 48; 49, pp. 1 through 6; 

50, pp. 84, 85, 86). 

Columbus Light and Water operates two water treatment plants (WTP) served by eight municipal wells. 

WTP No. 1 receives water from Well Nos. 1, 2, 4, and 5 and WTP No. 2 receives water from Well Nos. 6, 

7, 8, and 9 (Refs. 46, pp. 1 through 18; 47). Well Nos. 1, 2, and 5 are located within a 0.25- to 0.5-mile 

radius of Source No. 3 and Well No. 4 is located within a 0.5- to 1.0-mile radius of Source No. 3 (Refs. 3; 

46, pp. 1 through 18). Well No. 9 is located within a 2- to 3-mile radius of Source No. 3 and Well Nos. 6, 

7, and 8 are located within a 3- to 4-mile radius of Source No. 3 (Refs. 3; 46, pp. 1 through 18). 

Depth to top of well screens range from 611 to 759 feet below msl (779 to 940 feet bgs). Depths to the 

bottoms of the well screens range from 712 to 864 feet below msl (880 to 1,045 feet bgs) (Ref. 46, pp. 1 

through 18). All eight wells are screened in the Massive Sand aquifer (Ref. 46, pp. 1 through 18). None 

of the Columbus Light and Water wells produce more than 40 percent of the total water supply. Water 

from both WTPs is sent to storage tanks where the water is mixed prior to distribution (Ref. 47). 

Columbus Light and Water serves about 28,000 people or 3,500 people per well (28,000 ÷ 8 wells) (Ref. 

47). 

East Lowndes Water Association operates five WTPs served by nine municipal wells; however, only one 

WTP (Ridge Road), served by two municipal wells, is located within a 4-mile radius of sources on the 

Kerr-McGee property (Refs. 3; 48; 49). The Ridge Road wells are located about 2.2 miles north of 

Source Nos. 1, 2, and 3 (Ref. 3). Depth to top of well screens are 247 and 251 feet below msl (557 and 

537 feet bgs) and bottoms of well screens are 307 and 311 feet below msl (617 and 597 feet bgs) (Ref. 49, 

pp. 1 through 4). Both wells are screened in the Gordo aquifer (Ref. 49, pp. 1, 4). Water is not mixed 

between WTPs; each WTP is an independent water system (Ref. 48). The Ridge Road WTP serves about 

2,612 connections or 6,818 people (2,612 connections × 2.61 persons per household = 6,818 people) 

(Refs. 48; 98). 

Columbus Light and Water and East Lowndes Water Association municipal wells located within a 4-mile 

radius of sources on the Kerr-McGee property provide drinking water to 34,818 people. The population 

served by these wells per distance ring is distributed as follows: > 0 to 0.25 mile, 0 people; > 0.25 to 0.50 

mile, 10,500 people; > 0.50 to 1 mile, 3,500 people; > 1 to 2 miles, 0 people; > 2 to 3 miles, 10,318 

people; > 3 to 4 miles, 10,500 people (Refs. 3; 47; 48). These wells withdraw water from the Gordo and 

Massive Sand aquifers of the Tuscaloosa aquifer system (Refs. 30, p. 11; 46, pp. 1 through 18; 49, pp. 1 

through 4). Table 23 lists the distance of each well from sources on the Kerr-McGee property.

The Mississippi Source Water Assessment Program (SWAP) is a result of the Federal Safe Drinking 

Water Act Amendments of 1996. The amendments mandated all states to identify public water systems 

that may be susceptible to contamination and to adopt appropriate management measures that will 

enhance their protection (Ref. 52). A required element of the SWAP is delineation of protection areas 

around all water wells (wellhead protection areas) used for public water supply (Ref. 65, pp. 3-1, 3-2, 3-

3). The SWAPs for Columbus Light and Water and East Lowndes Water Association are contained in 

References 46 and 49. Figures depicting the SWAP areas for Columbus Light and Water and East 

Lowndes Water Association are contained in References 51 and 49, respectively. 

 
72 GW-Targets

TABLE 23: Municipal Drinking Water Wells within a 4-Mile Radius of Kerr-McGee

Gordo and Massive Sand Aquifers

Distance

Ring

Miles Water System Name

Number 

of Wells

Well No. and 

Screen Base

(feet bgs)

Level I 

Cont. 

(Y/N)

Level II 

Cont. 

(Y/N)

Potential 

Cont. 

(Y/N)

Population 

Served References 1

0 to 0.25 NA 0 NA NA NA NA NA 3 

> 0.25 to 0.5 Columbus Light and 

Water 3 

Well No. 1 – 895

Well No. 2 – 895 

Well No. 5 – 910 

N N Y 10,500 

3; 46, pp. 1 

through 4, 9, 

10; 47 

> 0.5 to 1 Columbus Light and 

Water 1 Well No. 4 – 880 N N Y 3,500 3; 46, pp. 7, 8; 47 

> 1 to 2 NA 0 NA NA NA NA NA 3 

> 2 to 3 Columbus Light and 

Water 1 Well No. 9 – 1,020 N N Y 3,500 3; 46, pp. 17, 18; 47

> 2 to 3 

East Lowndes Water 

Association – Ridge 

Road WTP

2 Well No. 1 – 617 

Well No. 2 – 597 N N Y 6,818 

3; 48; 49, pp. 

1 through 4; 

98

> 3 to 4 Columbus Light and 

Water 3 

Well No. 6 – 1,045

Well No. 7 – 1,013 

Well No. 8 – 1,030 

N N Y 10,500 3; 46, pp. 11, 

13, 16; 47 

 Notes:

1 

 bgs Below ground surface

Columbus Light and Water: 28,000 people ÷ 8 wells = 3,500 people per well. East Lowndes Water Association: 6,818 people ÷2 wells = 3,409 people per well (Refs. 47; 48; 98)

Cont. Contamination

 ID Identification number

 N No

NA Not applicable

WTP Water treatment plant

 Y Yes
73 GW-Targets

3.3.1 NEAREST WELL

The nearest well (Columbus Light and Water well No. 5) is located about 0.33 mile from Source No. 3; 

therefore, a nearest well factor value of 18 was assigned (Refs. 3; 46 p. 9). 

Nearest Well Factor Value: 18.0 

(Ref. 1, Section 3.3.1) 

3.3.2 POPULATION

3.3.2.1 Level of Contamination

3.3.2.2 Level I Concentrations

No Level I wells have been identified.

Level I Concentrations Factor Value: 0.00 

3.3.2.3 Level II Concentrations

No Level II wells have been identified.

Level II Concentrations Factor Value: 0.00 

3.3.2.4 Potential Contamination

Distance-weighted population values for potential contamination ground water targets for the Gordo and 

Massive Sand aquifers of the Tuscaloosa aquifer system are presented in Table 24. 

TABLE 24: Distance-Weighted Population Values 

Distance Category 

(Miles) Population

Distance-Weighted 

Population Value

(Ref. 1, Table 3-12) References

Greater than 0 to 1/4 0 0 3 

Greater than 1/4 to 1/2 10,500 10,122 3; 46, pp. 1 through 4, 9, 10; 47 

Greater than 1/2 to 1 3,500 1,669 3; 46, pp. 7, 8; 47 

Greater than 1 to 2 0 0 3 

Greater than 2 to 3 10,318 2,122 3; 46, pp. 17, 18; 47; 48; 49; 98 

Greater than 3 to 4 10,500 1,306 3; 46, pp. 11, 13, 16; 47 

Calculations:

Sum of Distance - Weighted Population Values: 15,219 

Sum of Distance - Weighted Population Values ÷ 10: 1,521.9 

Potential Contamination Factor Value: 1,522 
74 GW-Targets

3.3.3 RESOURCES

Resources were not evaluated because they do not significantly contribute to the overall site score. 

Resources Factor Value: NS

3.3.4 WELLHEAD PROTECTION AREA

The Mississippi SWAP is a result of the Federal Safe Drinking Water Act Amendments of 1996. The 

amendments mandated all states to identify public water systems that may be susceptible to contamination 

and to adopt appropriate management measures that will enhance their protection (Ref. 52). A required 

element of the SWAP is delineation of protection areas around all water wells (wellhead protection areas) 

used for public water supply (Ref. 65, pp. 3-1, 3-2, 3-3). The SWAPs for Columbus Light and Water and 

East Lowndes Water Association are contained in References 46 and 49. Figures depicting the SWAP 

areas for Columbus Light and Water and East Lowndes Water Association are contained in References 51 

and 49, respectively.

Wellhead Protection Area Factor Value: 5.00 
75 SW Pathway Definition

4.0 SURFACE WATER MIGRATION PATHWAY

4.1 OVERLAND/FLOOD MIGRATION COMPONENT – Luxapallila Creek

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

The elevation of the Kerr-McGee property ranges from 170 to 190 feet above msl (Ref. 82, p. 121) (see 

Figure 1 of this HRS documentation record). The facility is closed and all structures located on the KerrMcGee property have been decommissioned and dismantled (Refs. 12, p. 5; 56, p. 1). 

During operations, stormwater runoff from Kerr-McGee sources discharged to Luxapallila Creek via an 

unlined drainage ditch system, which directed stormwater toward designated NPDES outfalls (Refs. 11, p. 

7; 54, pp. 26, 61a, 127; 55, pp. 13, 21a; 57, p. 5-13). At an unspecified time, Kerr-McGee was issued 

NPDES Permit MSR20010 (Ref. 54, p. 10). The permit authorized Kerr-McGee to discharge stormwater 

to drainage ditches at five outfall locations, four of which collect runoff from the southern Kerr-McGee 

property (Refs. 54, p. 10; 57, pp. 5-5, 5-13). The permit required the facility to sample all stormwater 

outfalls annually for releases to surface water from the drainage ditches. The permit required testing for 

pH, oil and grease, total phenols, and total suspended solids as well as visually inspecting the drainage 

ditches/stormwater outfalls on a monthly basis for oil sheens or other indicators of releases to the 

environment (Ref. 14, pp. 18, 19). Prior to 1972, wastewater containing trace amounts of creosote was 

discharged off property into an unnamed drainage ditch (Ref. 78, p. 3). 

Outfall No. 001 was located south of the southwestern corner of the southern Kerr-McGee property, 

Outfall No. 002 was located on the northwest boundary of the southern Kerr-McGee property, Outfall No. 

003 was located in the northeastern corner of the southern Kerr-McGee property, Outfall No. 004 was 

located along the eastern edge of the southern Kerr-McGee property, and Outfall No. 005 was located 

along the southern boundary of the northern Kerr-McGee property (Ref. 57, pp. 5-5, 5-13) (see Figure 5 

of this HRS documentation record). 

Five drainage ditches received runoff from former operational areas on the Kerr-McGee property. The 

first drainage ditch (designated as Drainage Ditch 1) originated south of the office building located on the 

southwestern portion of the southern Kerr-McGee property; it received runoff from the cooling water 

surface impoundment and two cooling tower basins, and exited the property through Outfall No. 001 

(Refs. 14, pp. 3, 6; 57, pp. 5-5, 5-13). The second drainage ditch (designated as Drainage Ditch 2) 

originated to the north of the mill; it received surface water runoff from the production process area, 

wastewater treatment and creosote recovery area, the mill, and the surface impoundments, and exited the 

property through Outfall No. 002 (Refs. 14, pp. 3, 27; 15, p. 4; 57, pp. 5-5, 5-13; 82, p. 126). The third 

drainage ditch (designated as Drainage Ditch 3) originated on the northeastern portion of the southern 

Kerr-McGee property; it received surface water runoff from the green and black tie storage areas, and 

exited the property through Outfall No. 003 (Refs. 57, pp. 5-5, 5-13; 82, p. 126). The fourth drainage 

ditch (designated as Drainage Ditch 4) originated on the eastern portion of the southern Kerr-McGee 

property; it received runoff from the black tie storage area, and exited the property through Outfall No. 

004 (Refs. 57, pp. 5-5, 5-13; 82, p. 126). The fifth Drainage Ditch (designated Drainage Ditch 5) was 

located on the northern Kerr-McGee property; it received surface water runoff from the pine yard and 

waste piles, and exited the property through Outfall No. 005 (Refs. 57, pp. 5-5, 5-13; 84, p. 68). During a 

1988 visual site inspection of the Kerr-McGee property, the drainage ditches contained an emulsified 

material on the water, staining, and sparse and dead vegetation (Ref. 13, p. i, ii, Attachment A, pp. A-1, 

A-22, Attachment B, p. B-27). Figure 5 of this HRS documentation record depicts the Main Drainage 

Ditch, other drainage ditches, and outfall locations. 

Surface water runoff from Source No. 1 enters Drainage Ditch 2, which directs runoff to the northeast

into a perennial drainage ditch (designated Main Drainage Ditch). Water flow in the Main Drainage 

Ditch during dry weather is from two drainage ditches that flow south just east of 23rd Street and 27th

Street (Ref. 79). The point at which runoff from Drainage Ditch 2 enters the Main Drainage Ditch at 
76 SW Pathway Definition

Outfall 002 is probable point of entry (PPE) 1 (Refs. 4; 57, p. 5-13). Surface water runoff from Source 

No. 2 enters Drainage Ditch 1, which directs runoff west then south into an intermittent drainage ditch 

located at the southwest corner of the southern Kerr-McGee property (Refs. 4; 57, p. 5-13; 82, p. 126). 

The intermittent drainage ditch located at the southwest corner of the southern Kerr-McGee property 

flows south, east, then northeast for about 0.71 mile then enters the Main Drainage Ditch at PPE 4 (Refs. 

4; 57, p. 5-13). Surface water runoff from Source No. 3 follows topography and exits the southern KerrMcGee property through one of the four Outfalls (001, 002, 003, or 004) that collect runoff from the 

southern Kerr-McGee property. The points at which runoff from Source No. 3 enters the Main Drainage 

Ditch through the outfalls are PPEs 1 through 4 (Refs. 4; 57, pp. 5-5, 5-13; 82, p. 126). Runoff from all 

outfalls and drainage ditches eventually combine and comingle in the Main Drainage Ditch. Figure 5 of 

this HRS documentation record depicts the drainage ditches, outfalls, and PPEs. 

The points at which runoff from Outfall Nos. 002, 003, 004, and 001 enter the Main Drainage Ditch are 

evaluated as PPE 1, PPE 2, PPE 3, and PPE 4, respectively (Refs. 4; 57, pp. 5-5, 5-13) (see Figure 5 of 

this HRS documentation record). 

Surface water runoff from PPE 1 (Outfall 002) on the southern Kerr-McGee property flows 0.3 mile east 

in the Main Drainage Ditch until combining with the drainage from the northern Kerr-McGee property 

(Outfall No. 005) in the northeastern corner of the southern Kerr-McGee property at PPE 2 (Outfall 003) 

(Refs. 55, p. 13; 67, pp. 1, 3; 71) (see Figure 5 of this HRS documentation record). The Main Drainage 

Ditch continues south along the eastern boundary of the southern Kerr-McGee property for about 0.18 

mile before meeting the drainage from Outfall No. 004 at PPE 3 (Ref. 71) (see Figure 5 of this HRS 

documentation record). From PPE 3, the Main Drainage Ditch, carrying runoff from Outfalls 002, 003, 

004, and 005, continues south for about 0.2 mile where runoff from Outfall 001 joins at PPE 4 located 

southeast of the Kerr-McGee property (Ref. 55, pp. 13, 21a; 57, pp. 5-5, 5-13). Runoff from all outfalls 

and PPEs from the Kerr-McGee property eventually forms one drainage system in the Main Drainage 

Ditch, which ultimately flows to Luxapallila Creek (Ref. 55, pp. 13, 21a) (see Figure 5 of this HRS 

documentation record). 

From PPE 4, the most downstream PPE, the Main Drainage Ditch flows about 0.7 miles and joins 

Luxapallila Creek (Ref. 4). Luxapallila Creek flows south for about 4.8 miles before joining the 

Tennessee Tombigbee Waterway. The waterway flows south for about 9.5 miles completing the 15-mile 

surface water migration pathway (Ref. 4).

The average flow rate for Luxapallila Creek near Columbus, Mississippi (about 0.5 mile northeast of the 

Kerr-McGee property) for water years 1996 to 2009 is 1,043.17 cubic feet per second (Refs. 4; 74, pp. 2, 

3). The flow rate of the Main Drainage Ditch is not known (Ref. 53). Most of the Kerr-McGee property 

is located within either the 100-year or 500-year flood plain of Luxapallila Creek (Ref. 82, p. 124). 
77 SW-Observed Release

4.1.2.1 LIKELIHOOD OF RELEASE 

4.1.2.1.1 OBSERVED RELEASE – Chemical Analysis

Background Samples 

April 2010 Sampling

The sediment samples listed in Table 25 were collected by EPA Region 4 SESD in April 2010 from 

drainage ditches surrounding the Kerr-McGee property (Refs. 68, p. 3; 70, pp. 4, 5, 6). The background 

samples were collected from perennial surface water (Refs. 70, p. 5; 82, p. 121). Background sample 

TN21S was collected from a drainage ditch located along North 15th

TABLE 25: Background Sediment Sample Descriptions – April 2010 

 Avenue, north of the southern KerrMcGee property (Refs. 70, p. 5; 81) (see Figure 5 of this HRS documentation record). Background 

sample TN22S was collected to the north of the pine yard, on the western edge of the northern KerrMcGee property (Refs. 70, p. 5; 84, p. 68) (see Figure 5 of this HRS documentation record). 

The background samples are compared to downgradient sediment samples collected from perennial 

surface water (Refs. 70, p. 5; 71; 79; 82, p. 121). Specifically, background samples TN21S and TN22S 

are compared to downgradient samples collected from the Main Drainage Ditch to the east of the southern 

Kerr-McGee property (TN 19S, TN15S) and a sample collected from a perennial drainage ditch located at 

the southwestern corner of the northern Kerr-McGee property (TN16S) (Refs. 71; 79) (see Figure 5 of 

this HRS documentation record). 

The sediment samples were collected in accordance with the EPA Region 4 Field Branches Quality 

System and Technical Procedures for Sediment Sampling, SESDPROC-200-R1 (Refs. 70, p. 6; 73). The 

Quality Assurance Project Plan (QAPP) is provided in Reference 100. Chain-of-custody records are 

provided in Reference 85. Logbook notes are provided in Reference 101. Locations of the background 

sediment samples are provided in Reference 70 (see Figure 5 of this HRS documentation record). 

The background sediment samples and downstream sediment samples were collected during the same 

sampling event, in accordance with the same sampling procedures, and analyzed using the same analytical 

methods (Refs. 68, pp. 1, 3; 70, p. 6).

Sample ID Sample Location Depth

Date 

Sampled References

TN21S 

North of the southern 

Kerr-McGee property, 

along North 15th

0 to 12 

inches Avenue 

4/27/10 

12, p. 46; 68, p. 75; 70, 

p. 5; 85, p. 3; 100, p. 2; 

101, p. 6 

TN22S 

North of the pine yard and 

west of the northern KerrMcGee property

0 to 12 

inches 4/27/10 

68, p. 77; 70, p. 5; 84, p. 

68; 85, p. 3; 100, p. 2; 

101, p. 8 

Notes:

ID Identification number

S Sediment

TN Tronox LLC
78 SW-Observed Release

Background Concentrations

The sediment samples listed in Table 26 were collected in April 2010 during the EPA sampling event 

(Refs. 68, p. 3; 69, p. 1; 70, pp. 4, 5, 6). The samples were analyzed by EPA Region 4 SESD Analytical 

Support Branch (ASB) for SVOCs using EPA SW-846 Method 8270D (Ref. 68, p. 1). The analysis was 

performed in accordance with the ASB Laboratory Operations and Quality Assurance Manual (LOQAM)

(Refs. 68, p. 1; 75). The minimum reporting limits (MRL) are contained in Reference 68. 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. 76).

TABLE 26: Analytical Results for Background Samples – April 2010

Sample ID

Hazardous 

Substance Concentration MRL References

TN21S Acenaphthylene 41U μg/kg 41 μg/kg 68, p. 74 

TN21S Benzo(a)anthracene 41U μg/kg 41 μg/kg 68, p. 75 

TN21S Benzo(a)pyrene 41U μg/kg 41 μg/kg 68, p. 75 

TN21S Benzo(b)fluoranthene 41U μg/kg 41 μg/kg 68, p. 75 

TN21S Carbazole 41U μg/kg 41 μg/kg 68, p. 75 

TN21S Dibenz(a,h)anthracene 41U μg/kg 41 μg/kg 68, p. 75 

TN21S Fluoranthene 41U μg/kg 41 μg/kg 68, p. 75 

TN21S Indeno(1,2,3-

cd)pyrene 41U μg/kg 41 μg/kg 68, p. 75 

TN21S Naphthalene 41U μg/kg 41 μg/kg 68, p. 76 

TN21S Phenanthrene 41U μg/kg 41 μg/kg 68, p. 76 

TN22S Acenaphthylene 40U μg/kg 40 μg/kg 68, p. 77 

TN22S Benzo(a)anthracene 40U μg/kg 40 μg/kg 68, p. 78 

TN22S Benzo(a)pyrene 40U μg/kg 40 μg/kg 68, p. 78 

TN22S Benzo(b)fluoranthene 40U μg/kg 40 μg/kg 68, p. 78 

TN22S Carbazole 40U μg/kg 40 μg/kg 68, p. 78 

TN22S Dibenz(a,h)anthracene 40U μg/kg 40 μg/kg 68, p. 78 

TN22S Fluoranthene 40U μg/kg 40 μg/kg 68, p. 78 

TN22S Indeno(1,2,3-

cd)pyrene 40U μg/kg 40 μg/kg 68, p. 78 

TN22S Naphthalene 40U μg/kg 40 μg/kg 68, p. 79 

TN22S Phenanthrene 40U μg/kg 40 μg/kg 68, p. 79 

Notes:

ID Identification number

μg/kg Micrograms per kilogram

MRL Minimum reporting limit

S Sediment

TN Tronox, LLC

U The analyte was not detected at or above the minimum reporting limit
79 SW-Observed Release

Contaminated Samples

Sediment samples listed in Table 27 were collected in April 2010 from the Main Drainage Ditch and a 

perennial drainage ditch located about 100 feet north of the Main Drainage Ditch across North 14th

TABLE 27: Sediment Samples – April 2010

Avenue, from an area that may have been impacted by historical flooding of the Main Drainage Ditch 

(Refs. 12, pp. 15, 16; 68, p. 3; 70, p. 5; 79) (see Figure 5 of this HRS documentation record). The Main 

Drainage Ditch in this area receives runoff from Source Nos. 1, 2, and 3 (see Figures 3 and 5 of this HRS 

documentation record). Residents in the area have reported that the ditches occasionally overflow, 

causing contamination to move outward from the ditches onto surrounding residential yards and 

properties (Ref. 12, p. 16). 

The sediment samples were collected in accordance with the EPA Region 4 Field Branches Quality 

System and Technical Procedures for Sediment Sampling, SESDPROC-200-R1 (Refs. 70, p. 6; 73). The 

QAPP is provided in Reference 100. Locations of the sediment samples are provided in Reference 70. 

Chain-of-custody records are provided in Reference 85. Logbook notes are provided in Reference 101. 

Sample 

ID Sample Location

Estimated Distance 

from PPE Depth

Date 

Sampled References

TN16S 

Drainage ditch 

located in the 

southwestern corner 

of the northern KerrMcGee property, in 

an area that may have 

been impacted by 

flooding from the 

Main Ditch 

1,250 feet from PPE 1 0 to 12 

inches 4/27/2010 

12, pp. 15, 16; 68, p. 

59; 70, p. 5; 79; 85, p. 

2; 100, p. 2; 101, p. 8; 

see Figure 5 of this 

HRS documentation 

record

TN19S 

Main Drainage Ditch, 

east of the southern 

Kerr-McGee property

2,050 feet from PPE 1 

300 feet from PPE 2 

0 to 12 

inches 4/27/2010 

68, p. 68; 70, p. 5; 85, 

p. 2; 100, p. 2; 101, p. 

13; see Figure 5 of 

this HRS 

documentation record

TN15S 

Main Drainage Ditch, 

at the point where the 

intermittent ditch 

south of the southern 

Kerr-McGee property 

joins the Main 

Drainage Ditch

3,700 feet from PPE 1 

2,000 feet from PPE 2 

1,050 feet from PPE 3 

20 feet from PPE 4 

0 to 12 

inches 4/28/2010 

68, p. 56; 70, p. 5; 72; 

85, p. 2; 100, p. 2; 

101, p. 22; see Figure 

5 of this HRS 

documentation record

Notes:

ID Identification number

PPE Probable point of entry

S Sediment

TN Tronox LLC
80 SW-Observed Release

Contaminated Concentrations

The sediment samples listed in Table 28 were collected in April 2010 during the EPA sampling event 

(Refs. 68, p. 3; 70, pp. 5, 6). The samples were analyzed by EPA Region 4 SESD ASB for SVOCs using 

EPA Method 8270D (Ref. 68, p. 1). The analysis was performed in accordance with the ASB LOQAM

(Refs. 68, p. 1; 75). The MRLs are contained in Reference 68. 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. 76).

TABLE 28: Analytical Results for Contaminated Samples – April 2010 

Sample ID Hazardous Substance Concentration MRL References

TN16S Acenaphthylene 780 μg/kg 320 μg/kg 68, p. 60 

TN16S Benzo(a)anthracene 6,300 μg/kg 320 μg/kg 68, p. 60 

TN16S Benzo(a)pyrene 15,000 μg/kg 320 μg/kg 68, p. 60 

TN16S Benzo(b)fluoranthene 24,000 μg/kg 320 μg/kg 68, p. 60 

TN16S Dibenz(a,h)anthracene 3,100 μg/kg 320 μg/kg 68, p. 60 

TN16S Fluoranthene 5,000 μg/kg 320 μg/kg 68, p. 60 

TN16S Indeno(1,2,3-cd)pyrene 7,000 μg/kg 320 μg/kg 68, p. 60 

TN16S Phenanthrene 330 μg/kg 320 μg/kg 68, p. 61 

TN19S Benzo(a)anthracene 630 μg/kg 60 μg/kg 68, p. 69 

TN19S Benzo(a)pyrene 790 μg/kg 60 μg/kg 68, p. 69 

TN19S Benzo(b)fluoranthene 1,500 μg/kg 60 μg/kg 68, p. 69 

TN19S Dibenz(a,h)anthracene 200 μg/kg 60 μg/kg 68, p. 69 

TN19S Fluoranthene 910 μg/kg 60 μg/kg 68, p. 69 

TN19S Indeno(1,2,3-cd)pyrene 600 μg/kg 60 μg/kg 68, p. 69 

TN19S Naphthalene 71 μg/kg 60 μg/kg 68, p. 70 

TN19S Phenanthrene 150 μg/kg 60 μg/kg 68, p. 70 

TN15S Acenaphthylene 70 μg/kg 48 μg/kg 68, p. 56 

TN15S Benzo(a)anthracene 1,600 μg/kg 48 μg/kg 68, p. 57 

TN15S Benzo(a)pyrene 1,400 μg/kg 48 μg/kg 68, p. 57 

TN15S Benzo(b)fluoranthene 2,900 μg/kg 48 μg/kg 68, p. 57 

TN15S Carbazole 55 μg/kg 48 μg/kg 68, p. 57 

TN15S Dibenz(a,h)anthracene 280 μg/kg 48 μg/kg 68, p. 57 

TN15S Fluoranthene 3,200 μg/kg 48 μg/kg 68, p. 57 

TN15S Indeno(1,2,3-cd)pyrene 660 μg/kg 48 μg/kg 68, p. 57 

TN15S Naphthalene 160 μg/kg 48 μg/kg 68, p. 58 

TN15S Phenanthrene 390 μg/kg 48 μg/kg 68, p. 58 
81 SW-Observed Release

Notes:

ID Identification number

μg/kg Micrograms per kilogram

MRL Minimum reporting limit

S Sediment

TN Tronox, LLC
82 SW-Observed Release

Additional Supporting Data

During the 1996 RFI, Kerr-McGee collected two sediment samples from each of the five NPDES Outfalls 

(Ref. 54, pp. 2, 26). Samples designated with an “A” were collected within the Kerr-McGee property at 

the beginning of the ditch and samples designated with a “B” were collected at the point at which the 

ditch leaves the property (Ref. 54, p. 27). Samples designated with a “B” were collected from Outfalls 

002, 003, and 004 that discharge to the Main Drainage Ditch at PPEs 1, 2, and 3, which receive runoff 

from Source Nos. 1, 2, and 3 (Refs. 54, p. 61a) (also see Figure 5 of this HRS documentation record). 

The sediment samples collected from the unlined ditches on the property (designated with an “A”) 

contained creosote constituents including acenaphthylene (up to 4,800J [estimated] μg/kg); 

benzo(a)anthracene (up to 31,000 μg/kg); benzo(a)pyrene (up to 32,000 μg/kg); benzo(b)fluoranthene (up 

to 59,000 μg/kg); carbazole (up to 20,000 μg/kg); dibenz(a,h)anthracene (up to 11,000 μg/kg); 

fluoranthene (up to 120,000 μg/kg); indeno(1,2,3-cd)pyrene (up to 24,000 μg/kg); naphthalene (up to 

3,900J μg/kg); PCP (up to 1,400J μg/kg ); and phenanthrene (up to 47,000 μg/kg) (Ref. 54, pp. 26, 42, 

116, 117). Sediment samples collected from the unlined ditches at the point where the ditches leave the 

Kerr-McGee property (designated with a “B”) contained creosote constituents including acenaphthylene 

(up to 17,000 μg/kg); benzo(a)anthracene (up to 150,000 μg/kg); benzo(a)pyrene (up to 110,000 μg/kg); 

benzo(b)fluoranthene (up to 200,000 μg/kg); carbazole (up to 17,000 μg/kg); dibenz(a,h)anthracene (up 

to 35,000 μg/kg); fluoranthene (up to 590,000D [diluted] μg/kg); indeno(a,h)anthracene (up to 100,000 

μg/kg); naphthalene (up to 7,200JD μg/kg); PCP (up to 20,000 μg/kg); and phenanthrene (up to 260,000D 

μg/kg) (Ref. 54, pp. 26, 42, 116, 117, 120). Sediment samples corresponding with Outfall Nos. 003 and 

004 contained the highest concentrations of constituents (Ref. 54, pp. 116, 117, 120). The analytical data 

sheets and chain-of-custody forms are contained in Reference 54. Locations of the sediment samples 

collected during the 1996 RFI are depicted on page 61a of Reference 54. 

According to documents prepared by Kerr-McGee, only untreated wood waste and metal banding were 

stored in the pine yard (Ref. 20, p. 4). In 1995, Kerr-McGee collected four soil samples (18 inches bgs) 

from the pine yard (Refs. 20, p. 4; 77, pp. 1, 2). The samples did not contain hazardous substances at 

concentrations above their respective quantitation limits (Ref. 77, pp. 4, 6). 
83 SW-Observed Release

Surface soil samples collected from Source No. 3 (contaminated soil in various areas throughout the 

southern Kerr-McGee property), in 1996 (RFI conducted by Kerr-McGee) and 2008 (supplemental soil 

sampling event conducted by AquAeTer on behalf of Tronox) contained creosote constituents including 

PCP and 1,2,3,4,6,7,8-HpCDD (see Tables 5 and 6 of this HRS documentation record). The highest 

Attribution

From 1928 until 2003, a wood preserving facility operated on the Kerr-McGee property (Refs. 54, p. 3; 

56, p.1). The facility manufactured pressure-treated railroad products including wooden cross ties, switch 

ties, and timbers using several preservatives including PCP, creosote, and creosote coal tar solutions 

(Refs. 14, p. 9; 19, pp. 1, 2; 82, pp. 10, 13). The facility manufactured products for Burlington Northern 

Railroad, Norfolk Southern Railroad, and several regional railroad contractors (Ref. 82, p. 10). The 

facility is closed and all structures located on the Kerr-McGee property have been dismantled (Ref. 12, p. 

5). The property is currently owned by Tronox (Ref. 25, p. 1). 

The primary constituent compounds of the preservative creosote used at the Kerr-McGee facility include 

2-chlorophenol; 2,4-dimethylphenol; p-chloro-m-cresol; PCP; phenol; 2,4,6-trichlorophenol; 2,3,4,6-

tetrachlorophenol; 2,4-dinitrophenol; acenaphthylene; benzo(a)anthracene; benzo(a)pyrene; 

benzo(b)fluoranthene; carbazole; dibenz(a,h)anthracene; indeno(1,2,3-cd)pyrene; naphthalene; and 

phenanthrene (Ref. 54, p. 42). 

During operations stormwater runoff from the Kerr-McGee property discharged to Luxapallila Creek via 

an unlined drainage ditch system directed towards designated NPDES outfalls (Refs. 11, p. 7; 54, pp. 26, 

61a, 127; 55, pp. 13, 21a; 57, p. 5-13). At an unspecified time, Kerr-McGee was issued NPDES Permit 

MSR20010 (Ref. 54, p. 10). The permit authorized Kerr-McGee to discharge stormwater to drainage 

ditches at five outfall locations, four of which collect runoff from the southern Kerr-McGee property

(Refs. 54, p. 10; 57, pp. 5-5, 5-13). The permit required the facility to sample all stormwater outfalls 

annually for releases to surface water from the drainage ditches. The permit required testing for pH, oil 

and grease, total phenols, and total suspended solids as well as visually inspecting the drainage 

ditches/stormwater outfalls monthly for oil sheens or other indicators of releases to the environment (Ref. 

14, pp. 18, 19). Prior to 1972, wastewater containing trace amounts of creosote was discharged off site 

into an unnamed drainage ditch (Ref. 78, p. 3). 

Surface water runoff from Source Nos. 1, 2, and 3 either follows topography or enters drainage ditches 

that direct runoff to outfalls that collect runoff from the southern Kerr-McGee property and empties into 

the Main Drainage Ditch at PPEs 1 through 4 (Refs. 57, pp. 5-5, 5-13; 71; 79; 82, pp. 121, 126) (see 

Figure 5 of this HRS documentation record).

From PPE 4, the most downstream PPE, the Main Drainage Ditch flows south for about 0.7 miles and 

enters Luxapallila Creek (Ref. 4) (see Figure 5 of this HRS documentation record). The Main Drainage 

Ditch is perennial (Refs. 55, p. 21a; 71) (see Figure 5 of this HRS documentation record). 

Following removal of contaminated material from the impoundments, Kerr-McGee collected samples 

from 0 to 6 inches below the bottom surface of Source No. 1 (Ref. 7, pp. 4, 5; 17, p. 15). The Source No. 

1 samples contained creosote constituents (Refs. 7, pp. 5, 7; 54, p. 42) (see Table 1 of this HRS 

documentation record). Prior to 1988, preservative (creosote and PCP) dripped onto bare soil (Refs. 13, 

p. ii, Attachment B, p. B-24; 82, p. 13). A new drip pad was constructed after visually impacted soil from 

the area had been excavated to a depth of 4 feet. Soil samples were collected from Source No. 2 at 6 

inches below the surface of the excavation designated as visually clean (Ref. 14, p. 26). The samples 

collected from Source No. 2 contained creosote constituents, including PCP; the contamination was left in 

place (Refs. 14, p. 29; 18, p. 22; 54, p. 42) (see Table 3 of this HRS documentation record). Hazardous 

substances detected in Source Nos. 1 and 2 were also detected in the Main Drainage Ditch (see Tables 1, 

3, and 28 of this HRS documentation record). Source Nos. 1 and 2 have maintained engineered covers; 

however, these sources lack functioning and maintained run-on control and runoff management systems. 

Therefore, Source Nos. 1 and 2 are only partially contained (Refs. 1, Table 4-2; 62; 105, p. 2). 
84 SW-Observed Release

concentrations of these constituents were detected in the former creosote recovery area and black tie 

storage area. Specifically, the highest concentrations of dibenz(a,h)anthracene (19,000 μg/kg) and PCP 

(1,000,000D μg/kg) were detected in the former creosote recovery area (Refs. 14, p. 27; 54, p. 61a) (see 

Table 5 of this HRS documentation record). The highest concentration of benzo(a)pyrene (110,000D 

μg/kg) was detected in the black tie storage area (Refs. 54, p. 61a; 82, p. 126) (see Table 5 of this HRS 

documentation record). The presence of these hazardous substances in Source No. 3 (surface soil 

samples) and in the Main Drainage Ditch, and the lack of a functioning and maintained run-on control and 

runoff management system indicate that Source No. 3 is not contained (Refs. 1, Table 4-2; 62). 

 

The Kerr-McGee property is located in a commercial, industrial, and residential area (Refs. 10; 12, p. 4). 

Several industrial and commercial facilities have operated and still operate in the immediate vicinity of 

the Kerr-McGee property (Ref. 11, pp. 5, 26). Columbus Brick Company, a brick manufacturer, is 

located upgradient of the Kerr-McGee property; however, creosote constituents are not used by the 

Columbus Brick Company (Refs. 11, pp. 5, 26; 83, pp. 13, 14). Also, the Main Drainage Ditch is formed 

by stormwater runoff exiting the southern Kerr-McGee property through Outfall No. 002 (Refs. 57, pp. 5-

5, 5-13; 79) (see Figure 5 of this HRS documentation record). Analysis of sediment samples collected 

from perennial surface water downstream of PPE 1 document the presence of creosote constituents 

including PCP at concentrations above background levels (see Tables 26 and 28 of this HRS 

documentation record). In addition, historical sediment samples collected from the drainage ditches that 

collect runoff from the southern Kerr-McGee property contain many of the same constituents detected in 

sediment samples collected from the Main Drainage Ditch in 2010 (Refs. 54, pp. 2, 26, 27, 42, 61a, 116, 

117, 120; 70, pp. 5, 6, 8 through 11). 

Creosote, creosote coal tar solutions, and PCP were used on the property to produce pressure-treated 

railroad products (Ref. 82, p. 13). Sediment samples collected from the Main Drainage Ditch (which 

abuts the southern Kerr-McGee property) and a perennial drainage ditch about 100 feet north of the Main 

Drainage Ditch contained creosote constituents at concentrations above background levels (see Tables 26 

and 28 of this HRS documentation record) (see Figure 5 of this HRS documentation record). The primary 

constituents of creosote used at the Kerr-McGee property have been detected in Source Nos. 1, 2, and 3 

surface soil samples as indicated below in Table 29 (Ref. 54, p. 42) (see Section 2.2.1, Source No. 3 of 

this HRS documentation record). 
85 SW-Observed Release

TABLE 29: Hazardous Substances Associated with Creosote, Documented at Kerr-McGee And

Documented as Observed Release to the Surface Water Pathway

Major Constituents of Creosote 

Used at the Kerr-McGee 

Property (Ref. 54, p. 42)

Substances Documented in 

Source Nos. 1, 2, or 3

Substances Documented in the 

Observed Release to the 

Surface Water Migration 

Pathway

2-Chlorophenol 2,4-Dimethylphenol Acenaphthylene

2,4-Dimethylphenol 2,4,6-Trichlorophenol Benzo(a)anthracene

2,4,6-Trichlorophenol Acenaphthylene Benzo(a)pyrene

2,3,4,6-Tetrachlorophenol Benzo(a)anthracene Benzo(b)fluoranthene

2,4-Dinitrophenol Benzo(a)pyrene Carbazole

p-Chloro-m-cresol Benzo(b)fluoranthene Dibenz(a,h)anthracene

Acenaphthylene Carbazole Fluoranthene

Benzo(a)anthracene Dibenz(a,h)anthracene Indeno(1,2,3-cd)pyrene

Benzo(a)pyrene Fluoranthene Naphthalene

Benzo(b)fluoranthene Indeno(1,2,3-cd)pyrene Phenanthrene

Carbazole Naphthalene

Dibenz(a,h)anthracene Pentachlorophenol

Fluoranthene Phenanthrene

Indeno(1,2,3-cd)pyrene Phenol

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

Pentachlorophenol

Phenanthrene

Phenol

Hazardous Substances in the Release

Acenaphthylene 

Benzo(a)anthracene 

Benzo(a)pyrene 

Benzo(b)fluoranthene 

Carbazole 

Dibenz(a,h)anthracene 

Fluoranthene 

Indeno(1,2,3-cd)pyrene 

Naphthalene 

Phenanthrene 

Surface Water Observed Release Factor Value: 550.00
86 SW-Environmental Threat

4.1.2.2 Drinking Water Threat Waste Characteristics 

The drinking water threat was not scored because no surface water intakes are located within the 15-mile 

surface water pathway. Drinking water in Lowndes County, Mississippi is obtained from ground water 

(Refs. 12, p. 5; 80). 

4.1.3.2 Human Food Chain Threat Waste Characteristics

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation 

Toxicity, persistence, and bioaccumulation factor values for the hazardous substances detected in the 

sources with containment factor values greater than 0 are summarized in Table 30. The combined 

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

Section 4.1.3.2.1. Also see Section 2.2.2 for Source No. 3 and Section 4.1.2.1.1, Observed Release by 

Chemical Analysis, of this HRS documentation record.

TABLE 30: Toxicity/Persistence/Bioaccumulation

Hazardous 

Substance

Source 

No.

Toxicity 

Factor 

Value

Persistence 

Factor 

Value

Bioaccumulation 

Value 1

Toxicity/

Persistence/

Bioaccumulation 

Factor Value 

(Ref. 1, Table 4-16) 2 Reference

Acenaphthylene 1, 2, 3 0 0.4 500 0 2, p. BI-1 

Benzo(a)anthracene 1, 2, 3 1,000 1 50,000 50,000,000 2, p. BI-2 

Benzo(a)pyrene 1, 2, 3 10,000 1 50,000 500,000,000 2, p. BI-2 

Benzo(b)fluoranthene 1, 2, 3 3 NE NE NE NE NA

Carbazole 1, 2, 3 10 0.4 500 2,000 2, p. BI-2 

Dibenz(a,h)anthracene 3 10,000 1 50,000 500,000,000 2, p. BI-4 

2,4-Dimethylphenol 2, 3 100 1 500 50,000 2, p. BI-5 

Fluoranthene 1, 2, 3 100 1 500 50,000 2, p. BI-2 

1,2,3,4,6,7,8-HpCDD 3 10,000 1 50,000 500,000,000 2, p. BI-6 

Indeno(1,2,3-cd)

pyrene 1, 2, 3 1,000 1 50,000 50,000,000 2, p. BI-8 

Naphthalene 1, 2, 3 1,000 0.4 50,000 20,000,000 2, p. BI-9 

Pentachlorophenol 2, 3 100 1 50,000 5,000,000 2, p. BI-9 

Phenanthrene 1, 2, 3 0 0.4 5,000 0 2, p. BI-9 

Phenol 2 10 0.0007 50 0.35 2, p. BI-9 

2,4,6-Trichlorophenol 2 10 1 5,000 50,000 2, p. BI-11 
87 SW-Environmental Threat

Notes:

1 Persistence factor value for rivers 2 Bioaccumulation factor value for freshwater 3

TABLE 31: Hazardous Waste Quantity 

Benzo(b)fluoranthene is a Comprehensive Environmental Response, Compensation, and Liability Act hazardous 

substance; however, its toxicity, persistence, and bioaccumulation factor values have not been established. 

HPCDD Heptachlorodibenzo-p-dioxin

NA Not applicable

NE Not established

Toxicity/Persistence/Bioaccumulation Factor Value: 500,000,000.00 

(Ref. 1, Section 4.1.3.2.1.4, Table 4-16) 

4.1.3.2.2 Hazardous Waste Quantity

Source No. Source Type Source Hazardous Waste Quantity

1 Backfilled Surface Impoundments 1,230.76 

2 Contaminated Soil Undetermined, but greater than zero 

3 Contaminated Soil Undetermined, but greater than zero 

Sum of source hazardous waste quantity values: 1,230.76 + >0 + >0 = 1,230.76 

As specified in Reference 1, Section 2.4.2.2, Table 2-6, a HWQ factor value of 100 was assigned. 

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 value was obtained by multiplying the toxicity/persistence and 

HWQ factor values, subject to a maximum product of 1 x 108

. Based on this product, a value was 

assigned in accordance with Reference 1, Table 2-7. 

Toxicity/Persistence Factor Value: 10,000.00 

Hazardous Waste Quantity Factor Value: 100 

Toxicity/Persistence Factor Value × 

Hazardous Waste Quantity Factor Value: 1 x 106 

Toxicity/Persistence Factor Value × 

Hazardous Waste Quantity Factor Value (1 x 106

) × Bioaccumulation Factor Value (50,000): 5 x 1010

 

Waste Characteristics Factor Category Value: 320

 (Ref. 1, Table 2-7) 
88 SW-Environmental Threat

4.1.3.3 Human Food Chain Threat Targets

4.1.3.3.1 Food Chain Individual

An observed release of hazardous substances having a bioaccumulation factor value of 500 or greater is 

documented in perennial surface water with a fishery downstream–specifically, an observed release to the 

Main Drainage Ditch (Refs. 70, pp. 5; 71; 82, p. 121) (see Figure 5 of this HRS documentation record). 

The Main Drainage Ditch flows south and southeast for about 1.3 miles and joins Luxapallila Creek (Ref. 

4). Fishing occurs on Luxapallila Creek; some of the fish are eaten (Refs. 12, p. 5; 71). 

Food Chain Individual Factor Value: 20 

(Ref. 1, Section 4.1.3.3.1) 

4.1.3.3.2 Population

4.1.3.3.2.1 Level I Concentrations 

No Level I samples were collected.

Level Concentrations Value: Not Scored

(Ref. 1, Section 4.1.3.3.2.1) 

4.1.3.3.2.2 Level II Concentrations 

No Level II samples were collected.

Level II Concentrations Value: Not Scored 

(Ref. 1, Section 4.1.3.3.2.2) 

4.1.3.3.2.3 Potential Human Food Chain Contamination 

The Main Drainage Ditch flows east, south, then southeast for about 1.3 miles and joins Luxapallila 

Creek (Ref. 4). Fishing occurs on Luxapallila Creek; some of the fish are eaten (Refs. 12, p. 5; 71). 

Information is not available on the annual production of fish caught in Luxapallila Creek; therefore, the 

annual production is undetermined but greater than 0. 

TABLE 32: Potential Human Food Chain Contamination

Identity of 

Fishery

Annual 

Production 

(pounds)

Type of 

Surface 

Water Body 

(Table 4-13)

Average 

Annual 

Flow 

(cfs)

Population

Value (Pi

Dilution

) Weight (D

(Ref. 1, 

Table 4-18) 

i

P

) 

(Ref. 1, 

Table 4-13) i × D Refs. i

Luxapallila 

Creek >0 Large stream to river 1,043.17 0.03 0.001 0.00003 

1, Section 

4.1.3.3.2.3; 

74, pp. 1, 2, 

3 

Notes:

> Greater than 

cfs Cubic feet per second 

Sum of Pi x Di: 0.00003 

(Sum of Pi x Di)/10: 0.000003 

Potential Human Food Chain Factor Value: 0.000003 

(Ref. 1, Section 4.1.3.3.2.3) 
89 SW-Environmental Threat

4.1.4.2 Environmental Threat Waste Characteristics 

The environmental threat was not scored because sensitive environments are not expected to significantly 

contribute to the overall site score.