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., 11 th Atlanta, Georgia 30303 Floor

(404) 562-8829

Jennifer Wendel, National Priorities List Coordinator 61 Forsyth Street, S.W., 11 th 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 14 th Avenue and North 20 th Street

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

General Location in the Stat e: 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 (Ref s. 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 th e 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 sco ring 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

N ote:

NS Not scored2 WORKSHEET FOR COMPUTING HRS SITE SCORE

S Pathway S 2

Ground Water Migration Pathway Score (S Pathway

gw 95.88

) 9,192.9744

Surface Water Migration Pathway Score (S

sw 42.66 ) 1,819.8756

Soil Exposure Pathway Score (S

s NS ) NS

Air Migra tion Pathway Score (S

a NS ) NS

S 2

gw + S 2

sw + S 2

s + S 2

a 11,012.8500

( S 2

gw + S 2

sw + S 2

s + S 2

a ) / 4 2,753.2125 √ ( S 2

gw + S 2

sw + S 2

s + S 2

a ) / 4 52.47

Note:

NS Not scored3 Table 3 -1

-- Ground Water Migration Pathway Scoresheet Aquifer Evaluated: Tuscalo osa 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/Mobili ty 10,000.00 (a)
5. Hazardous Waste Quantity 10 0 (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 1,52 2 ( b)
8d. Population (lines 8a + 8b + 8c) 1,52 2 (b)

9. Resources 5 0

10. Wellhead Protection Area 20 5.00 11. Targets (lines 7 + 8d + 9 + 10) (b) 1,54 5 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 (S gw ), (highest value from line 12 for all aquifers valuated) 100

c 95.88

Notes:

a = Maximum value applies to waste characteristics category

b = Maximum value not applicabl e

c

NS = Not scored = Do not round to nearest integer4 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 Relea se 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. Leve l 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 [(lin es 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) 10 0

17. Waste Characteristics 1,000 320
Targets:

18. Food Chain Individual 50 205 Table 4

- 1

– Surface Water Migration Pathway Scoresheet (Continued)

Factor Categories and Factors Maximum Value Value Assi gned 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 Score c 100 (lines 13+21+28, subject to a maximum of 100) 42.66

Surface Water Overland/Flood Migration Componen t Score 30. Component Score (S of ) c 100 (highest score from line 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 integer0 2,000 1,000

Feet2011-01-25 \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 1:24,000N 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

0 400 200
Feet2011-01-25 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 TracksAVE 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 0 400 200

Feet2011-01-25 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 TiN 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

0 400 200

Feet2011-01-25 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 BackgroundN 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-36 CMW-33

CMW-66 CMW-24 CMW-27 CMW-16

CMW-11R CMW-19R CMW-1AR

0 400 200

Feet2011-01-25GIS_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" ) 

### $ +

$ +

" ) " )

! (

! ( ! (

! ( ! (
# *

# *

# *

# * 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 3 Drainage Ditch 2 Drainage Ditch 5

Drainage Ditch 3 Main Drainage Ditch

PPE 4 

# /

0 400200

Feet2011-01-25GIS_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 ! ( # *

" )



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21. K err

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- McGee , Forest Products Division. RCRA Facility Investigation Report, Columbus, Mississippi. March 31, 1997. 150 Pages.

55. K err

- 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. T o: 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.

1 18 Pages.

57. K err

- McGee , Forest Products Division. Work plan for RCRA Facility Investigation. November 28, 1995. 163 Pages.

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

K err

- 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 M ail Correspondence R egarding 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. K err

- McGee , Hyd rologic 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 R egarding the Interim Measures Report. From: Barrett A. Ci eutat, P.G., Senior Associate, Environmental Resources Management. To: Steve Ladner, Kerr

- McGee Chemical LLC. Attachment: Interim Measures Report, Columbus, Mississippi. Prepared on Behalf of K er r- 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 K err

- 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 R egarding 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, R esource Conservation and Recovery Act (R CRA ) , EPA. September 17, 2010. 142 Pages.

71. Tetra Tech. Electronic M ail Correspondence R egarding 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, Environ mental 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. Accesse d 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

Manu al. 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. K err

- 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. K err

- McGee , Fo rest Products Division. Letter with Attachment Regarding the Preliminary Assessment Dated March 19, 1984. From P.C. Gaskin, Environmental & Quality Control, Kerr

McGee. To Paul Bierstin e, Bureau of Pollution Control, MDNR. Attachment: Answers to Questi ons. 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 Co mpany. Attachments: Parcel Information and Maps, Company Information. September 9, 2010. 17 Pages.

84. K err

- 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 Coo peration 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- chemical

corp.html

.

91. Tetra Tech. Project Note to File with Attachments. Subject: Review of Environmental Testing and
Ce rtification (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 Attach ments. 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 F ile 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 198 6 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 O n- 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 Assu rance 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. F rom 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 Da ta, 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 Removal s at
Kerr

- McGee Columbus. Between Sandra Harrigan, Project Managerand Rus s McLean, RCRA Division, EPA. January 24, 2011. 4 Page s.20 Site Description 

### SITE DESCRIPTION

Kerr

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

Street and North 14 th 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 coord inates 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 identifi cation 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 (Ref s. 9, pp. i through
15 ; 82, pp. 10, 11 ). Land uses surrounding the property are predomina ntly 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 14 th 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 14 th Avenue will be referred to as the northern Kerr

- McGee property and the
section located to the south of North 14 th 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 be en decommissioned
and dismantled (Ref s. 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 in

ground 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, t hree source s ha ve been identified on the Kerr -McGee property. Source No. 1
consists of two backfilled surface impoun dments, 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 ; 5 4, 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, indica ting 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 d rinking 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 receive s runoff from Source Nos. 1, 2, and 3, contain the same c onstituents at concentrations greater than background levels, indicating that a release of hazardous substances has occurred to the surface water migration p athway 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 occu rs o n 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 w as used from 1928 through 1976 (Ref s. 19, pp. 1, 2; 82, p. 13). Xylene was also used as a drying agent for untreated wood from 1970 through 1974 (Ref s. 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 whol ly -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 o perations, green lumber was received at the plant and sor ted 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; ben zo(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 (Ref s. 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 Missis sippi Department of Environmental Quality ( MDEQ ) (Refs. 6, p. vi; 21, p. 7; 24, pp. 1 through 4). T he 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 applicat ion 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 Septemb er 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 Kerr

McGee perform a R CRA facility investig ation (R FI ) at the property to address 15 SWMUs grouped into eight solid waste management areas (SWMA ) (Ref s. 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

a ction 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 unspecif ied time, Kerr

- McGee was authorized to discharge stormwater to drainage ditches at five
outfall locations under National Pollutant Discharge Elimination System ( NPDES ) Permit MSR20010 (Ref s. 54, p. 10; 55, p. 13; 57, p. 5-5). The permit required the facil ity to sample all stormwater outfalls22 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 ) (Ref s. 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 M BPC -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 ); naph thalene (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 1 987 (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 a t the facility (Ref. 13, p. ii).

In 1988, the fac ility installed a concrete drip pad (track) to collect excess preservative that drip ped off the
wood following removal from the cylinder (Refs. 13, Attachment B, p. B-24 ; 14, p p. 10, 27; 82, p. 17). Prior to 1988, preservative (creosote and PCP) dripped o nto 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. S oil 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 μ g/kg ); p-chloro-m- cresol (up to 10 ,000 μ g/kg ); PCP (up to 358,000

μ g/kg ); phenol (up to 23,2 00 μ g/kg ); 2,4,6-trichlorophenol (1 ,870 μ g/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 ) (Ref s. 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 int o a consent order with MBPC because of the discovery of creosote product in monitoring wells downgradient of the closed impoundments (Ref s. 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 sedime nt within these areas (Ref. 54, pp. 23 through 27).

T hree surface and three subsurface soil samples were collected from SWM A 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 east ern 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 O utfalls. Two sediment samples were collected f rom 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 acenapht hylene, 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 faci lity (Ref. 55, pp. 8, 12, 15, 16, 17). The Phase
II RFI included advancemen t 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 ar ea located on the southern Kerr

- McGee property (Ref s. 55, pp. 16, 23; 82, p. 30). Creosote stains and odors

w ere noted in two of the borings located closest to the property (Ref. 55, pp. 16, 51, 54). Sediment samples were collected from the drainage ditc h 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

sa mples (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 i ncluding 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 t he 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 i nterim 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)

. Imp acted 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 dibe nzofurans (PCDF)
were present o n soil and sediments a t the property. AquAeTer, Inc. (AquAeTer), on behalf of Tronox,

co nducted 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, p p. 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); ph enanthrene (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 sa mples 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 ( 5,5 00 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 199 2, three c ontainment trenches (Trenc h #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 recover y of free pro duct (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 w ells 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 -w ater separation and settlement of creosote product. The separated creosote is collected in storage tanks and
sold as wood trea ting 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, p p. 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 : Backfille d 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 impoundment s located in the north western portion of the
southern Ke rr -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 faci lity 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). Constit uents fo und 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; carbazo le ; 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 pentac hlorophenol” (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 sam ples 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 ) (Ref s. 7, pp. 3, 4, 5; 17, p.
15 ). The samples contained creosote compounds including acenaph thylene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, fluoranthene, indeno(1,2,3-cd)pyrene, naphthalene, phenanthrene,
and carbazole (Ref s. 7, p. 7; 54, p. 42). Because clean closure was not accomplished, Kerr

- McGee submitted a Part B post- cl osure 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 Collec ted from Soil at the Bottom of the Backfilled Surface Impoundment s

Source samples listed in Table 1 were collected by Kerr

- McGee during closure of the backfilled surface impoundments (Ref. 7, p p . 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, p p. 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; ben zo(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 (Ref s. 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 Organi c 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. 1Source 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 Naphtha lene 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 Microgram s per kilogram

MDL Method detection limitSource No. 1

28 Source Description 2.2.3 HAZARDOUS SUBSTANCES AV AILABLE 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 impoundment s located in the northwestern portion of the southern Kerr

McGee 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 impound ments 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 as sociated 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 scoredSource 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 ft 2 (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 (ft 2 ): 16,000 (Ref. 7, p. 5) Equation for Assigning Value (Ref. 1, Table 2- 5): A rea (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).

S ource HWQ Value: 1,230.76Source No: 2

30 Source Description 2.2.1 SOURCE IDENTIFICATION

Number of source : 2

Name of source : Contaminated s oil underlying the former drip pad

Source Type : Contaminated soil

Description and Location of Source

Source No. 2 , an a rea of contaminated soil underlying the former drip pad , is loca ted on the south western 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 on to 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 of1 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 collec ted 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 Soi l Samples

S amples 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 . 2 6, 47, 54, 59, 66, 72, 77). Prior to construction of the drip pad, visually impacted soil fr om 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). T he samples
contain creosote constituents including PCP (Refs

. 14, pp. 47, 48, 53, 54, 59, 60, 6 5, 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 Revie w 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 Naphthale ne 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. 22Source 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 μ g/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

SSPJD PT5I 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

S SPJDPT6I 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. 22Source 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

SSPJD PT6I 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 t he QC replicate displayed poor precision (91 , pp. 2

, 4). μg/kg Microgram s per kilogram

MDL Method detection limitSource 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 (c reosote 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 . T herefore, a containment factor value of 10, as
noted in Table 4 , was assigned for the g round 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 run

on/ runoff control system s 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

Conta inment 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 scoredSource No: 2

35 Source Description 2.4.2.1 HAZARDOUS WASTE QUANTITY

2.4.2.1.1 Hazardous Constituent Quanti ty

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 informatio n 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 (ft 2

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 Val ue

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 proper ty

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 t his 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 h istorical production practices asso ciated 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 Kerr

McGee property. Specifically, surface and subsurface soil samples coll ected from the following areas
contain ed creosote and/or PCDD and PCDF constituents: black tie storage area

, creosote recovery system/wastewater treatment system, and cooling tower basin area (Ref s. 54, pp. 23 through 26, 59, 60, 61, 61a, 120, 121, 122 , 12 4; 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)pyr ene, 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 t he southern Kerr

- McGee property to determine whether PCDDs and PCDFs were present in the soil (Ref. 56, pp. 1, 2, 4, 14 ). The su rface soil samples
indicated the presence of dioxins and furans including 1,2,3,4,6,7,8-hepta chloro dibenzo-p-dioxin ( HpCDD ) (Re f. 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/waste water 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 contain ed creosote constituents including PCP (Re f. 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). A ll 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 MDL s are provided in Southwest’s Q uality 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 cus tody 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

SB 1 Acenaphthylene 38,000 μg/kg 37.8 μg/kg 37, p. 209; 5 4, p p. 121, 127 ; 92, pp. 1, 3

SB 1 Dibenz(a,h)anthracene 19,000 μg/kg 103.5 μg/kg 37, p. 209; 54, pp. 121, 127 ; 92, pp. 1, 3

SB 1 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

SB 1 (Diluted) Benzo(a)anthracene 190,000 μg/kg 146.7 μg/kg 37, p. 209; 54, pp. 121, 127 ; 92, pp. 1, 3

SB 1 (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

SB 1 (Diluted) Fluoranthene 1,000,000 μg/kg 85.1 μg/kg 37, p. 209; 54, pp. 121, 127 ; 92, pp. 1, 3Source No: 3

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

Sample ID Hazardous
Substance Hazardous
Substance
Concentration MDL References

SB 1 (Diluted) Naphthalene 260,000 μg/kg 74.2 μg/kg 37, p. 208; 54, pp. 121, 127 ; 92, pp. 1, 3

SB 1 (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)fluo ranthene 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, p p. 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, p p. 122, 127 ; 92, pp. 1, 4 ; 103 , pp. 1, 5

SB3 (D iluted) Benzo(a)anthracene 160,000 μg/kg 146.7 μg/kg 37, p. 209; 54, p p. 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, p p. 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, p p. 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, p p. 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, p p. 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, 127Source 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 In deno(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, p p. 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, 6Source 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, p p. 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, p p. 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' Acenaphthylen e 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, 2Source 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 44.1 μg/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, p p. 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' Flu oranthene 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, p p. 122, 127Source No: 3

42 Source Description Notes:

' Foot B Boring

D The sample was diluted

ID Identification μg/kg Micro gram s 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).

S urface soil samples were collected from five areas where previous RFI soil and sediment sampli ng 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 northeast ern 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 compl ex) at the
location (SSB -01) was similar to the soil type of samples collected from S ource No. 3 and (2) the background sampling location appear ed to have be en minimally impacted by past facility operation s (Refs. 14, p. 10; 56, p. 14; 60, pp. 1, 3).

Th e 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 di oxins and furans by EPA SW846 Method 8290 (Ref. 56, pp. 28, 31 through 52).

The reporting lim its are listed on the analytical data sheets in Reference 56. The repor ting 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 Analyti cal
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 5 6

. Boring logs are provided in Reference 56. L ocations 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* Refere nces 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

- Hp CDD 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, 43Source No: 3

44 Source Description TABLE 6 : Analytical Results for Source No. 3 – 2008

Sample ID Hazardous
Substance Hazardous
Substance
Concentration Reporting
Limit* Refere nces

SSB

- 08 1,2,3,4,6,7,8

- HpCD D 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 repor ting limits on the analytical data sheets are equivalent to SQLs (Ref. 99 )

ID Identification pg/g Picogram per gram HpCDD Heptachlor o dibenzo -p- dioxin
SSB Surface soil boringSource 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
Table s 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 (Re fs. 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 f or 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 scoredSource 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, h azardous 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 wastestre am 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, Sectio n 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, t he area o f Source No. 3 is undetermined, but greater than zero (Ref. 1, Section 2.4.2.1.4).

Sum (ft 2

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 So urce 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 use d to store settled creosote
until it could be reclaimed and cycled back to the process storage tanks. Once the new oil

- water separati on 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. U se of the surface impo undment to contain preservative and wastewater ceased in 1972 , and the surface impoundment was closed in 1983 (Ref. 7 8, p p. 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 impoun dment to ensure
clean closure. Description of Other Possible Sources

No o ther 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 southwest ern 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 norther n 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 pi ne yard at 18 inches bgs (Ref. 77, pp. 1, 2). The samples did not contain hazardous substances at concentrations above their respective quantitat ion limit s (Ref. 77, pp. 4, 6).
Because the northern Kerr

- McGee property encompasses about 47 acres, it is no t known whether
the areas between the four sampling points contain contamination. However, collection of four
sub surface 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 o rder, 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 t he 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 o f 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. Th is 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 conta ct 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 (R ef. 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 abo ut 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 A quifer 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 Gro up, 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 aqu ifer 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 aquif er 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 t apped 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 surfi cial 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 A quifer

– 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 aqu ifer (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 underli e 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 Mississi ppi 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
b elow msl to 383-474 feet b elow msl and shale is encountered from 462-558 feet b elow msl to 598 feet
b elow 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 b elow msl, which is the interval where municipal well No s. 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 a quifer s 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 perc olates 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 surfic ial aquif er is to the southeast except where affected by the ground water collection system (Ref. 25, pp. 24, 25).51 GW Pathway Description Eutaw-McShan A quifer – 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 Kerr

McGee 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 ove rlying surficial aquifer, where present (Ref s. 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 Mississipp i (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 aquifer s are interconnected and regionally maintain a hydraulic continuity (Refs. 46, p. 1 through 18; 30, p. 11). No m onitoring well s 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 -M cGee 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 ascontaining 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). T he 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 sugges ts that both the surficial aquifer (where present) and the Eutaw

- McShan aquifer receive recharge from Luxapa llila 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 th rough 18).
Further review reveals that municipal well Nos. 1 and 2 encounter clay from approximately 340 feet
b elow msl to 383-474 feet b elow msl and shale is encountered from 462-558 feet b elow msl to 598 feet
b elow 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 aquifer s 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 deposit s 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. 3 0

, 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 limit53 GW

- Likelihood of Release 3.1 LIKELIHOOD OF RELEASE

3.1.1 OBSERVED RELEASE

Aquifer Being Evaluated: Interconnected Surficial and Eutaw

- McShan aquifer s

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 b ackground monitoring well sample listed in Table 10 was collected by Kerr

- McGee during the May 2002 sampling event (Ref. 3 9, pp. 2, 3, 49). Monitoring well CMW

- 16 is located west of Source No. 1 (Ref. 3 9, p. 22). Th e location of CMW -16 is upgradient of ground water underlying and/or downgradient of Source Nos. 1, 2 , and 3 (Ref. 3 9, p. 25) (see Figure s 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. 3 9, p. 25 ; 40, pp. 150, 151, 152; 82, p. 51) (see Figure 3 of this HRS documen tation 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. 3 9, 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 wit h 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 Elevati on of Well
Bottom (feet a msl ) Screened

Interval (feet a msl ) Date Sampled Location References

CMW -16 159.80 169.80 to
160.80 5/15/2002 West of the backfilled surface impoundment s 39, pp. 25, 29, 49

Notes:

amsl Above mean sea level
CMW Shallow well

ID Identification number54 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
Metho d 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 sheet s 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. A nalytical data
sheets are contained in Reference 39.

TABLE 11 : Analytical Results for May 2002

Sample ID Hazardous
Substanc e 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:

C MW Shallow well

ID Identification number

MDL Method detection limit μg/L Microgram per liter

U Analyte was not detected to the level shown55 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 (Ref s. 5, pp. 122, 1 23; 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 Figure s 3 and 4 of t his 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, p p. 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 Reference s 5, pp. 122, 123; 40, pp. 119, 120, 121; 41, pp. 92, 93, 99, 100; 42, p p. 256, 25 7. Locations of the contaminated grou nd 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 a msl ) Screened

Interval (feet a msl ) 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 Kerr

McGee property 39, 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

o f the southern Kerr

McGee property 39, pp. 22, 29, 43

Notes:

amsl Above mean sea level
CMW Shallow well

ID Identification

R Replacement well56 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 R eference 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 Ma y 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)fluoranthe ne 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. 4357 GW

- Likelihood of Release TABLE 13 : Analytical Results for Ma y 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 well58 GW

- Likelihood of Release November 2008 Hazardous Waste Permit No. HW-90-329-01 Sampling Event– Surficial Aquifer

Background Samp les

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 to tal 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 w ere collected in accordance with the revised sampling and analysis plan (Ref s. 25, p. 3; 63 ). Locations of the background ground water sampl es 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 interv als, 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 a msl ) Screened
Interval (feet a msl ) Date Sampled Location References

CMW -16 159.8 169.80 to
160.80 11/11/2008 West of the backfilled surface impoundment s 25, pp. 21, 29 ; 64, p p . 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:

a msl Above mean sea level
CMW Shallow well

ID Identification number59 GW

- Likelihood of Release Background Concentrations

The background ground water samples listed in Table 15 were collected from the surficial aquifer (Ref s. 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 ( Ref s. 94; 95).
The reviews are contained in References 94 and 95. Analytical data sheets and chain -of- custody records
are contained in Reference s 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. 1860 GW

- Likelihood of Release Notes:

CMW Shallow well

ID Identification

MDL Method detection limit μg/L Microgram per liter

N.D. Non detect61 GW

- Likelihood of Release Contaminated Samples

Ground water samples listed in Table 16 were collected from the surficial aquifer underlyi ng 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 F igure s 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/o r 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 1 4 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, p p. 128, 129; 40, pp. 119, 120, 121; 41, p p. 90, 91, 92, 93; 42, pp. 256, 257; 43, pp. 116, 117. L ocation s 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 a m sl ) Screened
Interval (feet a msl ) 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 sou thern Kerr

McGee 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 Kerr

McGee 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 impound ment s 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:

a msl Above mean sea level
CMW Shallow well

ID Identification number

R Replacement well62 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 (Ref s. 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 con ducted 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 shee ts and chain -of- custody records
are contained in Reference s 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 Naphtha lene 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 Carb azole 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. 3563 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 well64 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. S oil samples were collected from Source No. 2 at 6 inches below the surface of the excavation designated as
visua lly clean (Ref. 14, p. 26). The samples contained creosote constituent s, 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 collec ted from Source No. 3 ( various areas on the southern Kerr

McGee 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
surfac e 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 (Ref s. 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) w as detected in the black tie storage area
located in the centr al 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 p ressure -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-c hloro -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 K0 01: “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
cond ucted 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 (Ref s. 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 app lication 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 ord er with MBPC because of the discovery of creosote product in monitoring wells downgradient of Source No. 1 ( two backfilled surface impoundment s) (Ref. 21, p. 7; 24, pp. 1 through 4). Numerous investigations have been conducted on the Kerr- McGee property65 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 ne ar 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).

C reosote constituents were detected in Source Nos. 1 , 2, and 3 at the southern Kerr

- McGee property.
Source No. 1 consists of two backfilled surface impoundment s, Source No. 2 consists of contaminated
soil located under the for mer 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 hazard ous 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, a nd 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 constituent s 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, p p. 5, 26 ). Potentiometric surface maps prepared based on ground water elevations obtained during monit oring 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 (Ref s. 25, p. 25; 39, p. 25). Columbus Brick Company, a brick manufacture r, 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 pas t 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: 550.0066 GW

- Likelihood of Release 3.1.2 POTENTIAL TO RELEASE

Aquifer Being Evaluat ed: 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 sur face of Source No. 1 (Ref. 7, pp. 4, 5; 17, p. 15). The Source No. 1 samples contained creosote constituent s (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

accom plished (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 drip ped 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, p p. 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 cons tituents: 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, 1 20, 121, 122 , 124; 56, pp. 2, 9, 13) (see Tables 5 and 6 of this HRS documentation record).

Table 1 8 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 Qu antity 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 2767 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 aquifer s of the Tuscaloosa aquifer system . Table 19 lists the depth to the aquifer.

Depth to Lowe st 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 moni toring well CMW

- 33 located at the northern edge of the southern Kerr

- McGee property (see Table 13 of this HRS documentation record) (Ref s. 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).

TABL E 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 l owest k nown p oint of h azardous s ubstances

a msl Above m ean 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 aqui fers)

.

TABLE 20 : Travel Time

Layer Type of Material Thickness (feet) Hydraulic Conductivity (cm/sec) 1 References

Surficial Aquifer I nterbedded layers of clay, silt, sand, an d gravel 5.82 10 1, Table 3-6; 82, p. 51 -4

Eutaw

- McShan
Formation More or les s 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 light

gray clay; small chert gravels may be present in ba sal 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 Facto r 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 factor69 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 1 a 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 1 a 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 document ed HpCDD Heptachlor o dibenzo -p- dioxin

Toxicity/Mobility Factor Value: 10,000.00 (Re f. 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 Impoun dments 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: 10 0 (Ref. 1, Sec tion 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 × 10 8

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: 10 0

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 w ithin 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 ). D epth s 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 municip al wells

, is located within a 4 -mile radius of sources on the

Kerr

- McGee property (Ref s. 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 independ ent 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 m unicipal wells loca ted 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 (Ref s. 3; 47; 48 ). These wells withdraw wate r from the Gordo and
Massive Sand aquifers of the Tuscaloosa aquifer system (Ref s. 30, p. 11; 46, pp. 1 through 18; 49, pp. 1 through 4). Table 2 3 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. Th e 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 req uired element of the SWAP is delineation of protecti on 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
Reference s 46 and 49 . Figures depicting the SWAP areas for Columbus Light and Water and East
Lowndes Water Association are contained in Reference s 51 and 49, respectively.72 GW

- Targets TABLE 2 3 : Municipal Drinking Water Wells w ithin a 4

- Mile Radius o f Kerr

- McGee
Gordo and Massive Sand Aquifers

Distance

Ring
Miles Water System Name Number
of Wells Well No. and
Screen Base

(feet b g s ) 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, p p. 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: 6,81 8 people ÷2 wells = 3,40 9 people per well (Refs. 47; 48; 98)

Cont. Contamination

ID Identification number

N No
NA Not applicable

WTP Water treatment plant

Y Yes73 GW

- Targets 3.3.1 NEAREST WELL

The nearest well (Columbus Light and Water w ell No. 5) is located about 0.33 mile from Source No. 3 ; therefo re , a nearest well factor value of 18 was assigned (Ref s. 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 contaminat ion ground water targets for the Gordo and
Massive Sand aquifer s of the Tuscaloosa aquifer system a re 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, 52274 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 Wate r 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 req uired
element of the SW AP 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 Reference s 46 an d 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: 5.0075 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 1 70 to 190 feet above msl (Ref. 82 , p. 121 ) (see Figure 1 of this HRS d ocumentation 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).

During operations, stormwater runoff from Kerr

- McGee sources discharged to Luxa pallila Creek via an

un lined 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 sampl e 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).

Outf all No. 00 1 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 Dra inage Ditch 1) originated south of the office building located on the southwestern portion o f 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, p p. 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 northeast ern 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, p p. 5-5, 5-13; 82, p. 126). The fourth drainage ditch (designated as Drainage Ditch 4) originated on the easter n 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 r eceived surface wate r 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 th e 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 w ater runoff from Source No. 1 enters Drainage Ditch 2, which directs runoff to the north east into a perennial drainage ditch (designated Main Drainage Ditch) . W ater flow in the Main Drainage Ditch during dry weather is from two drainage ditches that flow south just east of 23 rd Street and 27 th
Street (Ref. 79). The point at which runoff from Drainage Ditch 2 enters the Main Drainage Ditch at76 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 a n 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 (Ref s. 4; 57, p. 5-13). Surface water runoff from Source No. 3 follows topography and exits the southern Kerr

McGee 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 r unoff 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 (Ref s. 4; 57, pp. 5-5, 5-13) (see Figure 5 of this HRS documentation record).

Surface water runoff from PPE 1 (Outfal l 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 (O utfall No. 005) in the northeastern corner of the southern Kerr

- McGee property at PPE 2 (Out fall 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 Outf all 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 loca ted
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 e ve ntually 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 mile s and joins Luxapallila Creek (Ref. 4) . Luxapallila Creek flows south for about 4.8 mile s before joi ning 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

K err

- 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 flo od 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 2 5 were collected by EPA Region 4 SESD in April 2010 from drainage ditches surrounding the Kerr

- McGee property (Ref s. 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 15 th

TABLE 2 5 : Background Sediment Sample Descriptions – April 2010 Avenue, north of the southern Kerr

McGee property (Ref s . 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 west ern edge of the nort hern Kerr

McGee property (Ref s . 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 ; 7 1 ; 79; 82, p. 121 ). Spec ifically, 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 s outhwestern corner of the northern Kerr

- McGee property (TN16S) (Ref s. 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 S ampling, SESDPROC -200- R1 (Ref s. 70, p. 6; 73 ). The Quality Assurance Project Plan (QAPP) is provided in Reference 100. C hain -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 (Ref s. 68, pp. 1, 3; 70, p. 6 ).

Sample ID Sample Location Depth Date Sampled References

TN21S North of the southern

Kerr

- McGee pro perty

, along North 15 th 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 p ine yard and
west of the northern Kerr

McGee 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 LLC78 SW

- Observed Release Background Concentrations

The sediment samples listed in Table 2 6 were collected in April 2010 during the EPA sampling event (Refs. 68, p. 3; 69, p. 1; 70, pp. 4, 5, 6 ). T he 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 per formed, as well as for percent moisture. The MRLs are equivalent to SQLs (Ref. 76 ).

TABLE 2 6 : 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 Identifica tion number μg/kg Micrograms per kilogram

MRL Minimum reporting limit
S Sediment

TN Tronox, LLC

U The analyte was not detected at or ab ove the minimum reporting limit79 SW

- Observed Release Contaminated Samples

Sediment samples listed in Table 2 7 were collected in April 2010 f rom the Main Drainage Ditch and a perennial drainage ditch located about 100 feet north of the Main Drainage Ditch across North 14 th

TABLE 2 7 : 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 Figure s 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 Syste m and Technical Procedures for Sediment Sampling , SESDPROC -200- R1 ( Refs. 70, p. 6; 73 ). The QAPP is provided in Reference 100. L ocations of the sediment samples are provided in Reference 70.
Chain-of- custody records are provided in Reference 85. Logboo k 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 Kerr

McGee prop erty , 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 t he 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 ; 1 00, 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 LLC80 SW

- Observed Release Contaminated Concentrations

The sediment samples listed in Table 2 8 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 u sing

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 2 8 : 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 Ind eno(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 Phenanth rene 390 μg/kg 48 μg/kg 68, p. 5881 SW

- Observed Release Notes:

ID Identification number μg/kg Micrograms per kilogram

MRL Minimum reporting limit
S Sediment

TN Tronox, LLC82 SW

- Observed Release Additional Supporting Data

During the 1996 RFI, Kerr- McGee collected two sediment samples from each of the five NPDES O utfalls (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 le aves 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 t o 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”) con tained 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 (u p to 35,000 μg/kg); fluoranthene (up to 590,000 D [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 a nalytical data
sheets and chain -of- custody forms are contained in Reference 54. L ocations 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 limit s (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 close d 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 incl ude 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 s tormwater runoff from the Kerr

- McGee property discharged to Luxapallila Creek via
an unlined drainage ditch system directed towards designated NPDES o utfall s (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 p ermit authorized Kerr

- McGee to discharge stormwater to drainage
dit ches at five outfall locations , four of which collect runoff from the southern Kerr

- McGee property (Ref s. 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 (Ref s. 57, pp. 5-5, 5-13 ; 71; 79; 82, p p. 121, 126 ) (see Figure 5 of this HRS documentation record).

From PPE 4, the most downstream PPE, the Main Drainage D itch flows south for about 0.7 mile s 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 f rom 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 (se e 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 p artially 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 s ubstances 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, t he 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 s ediment samples collected
from perennial surface water downstream of PPE 1 document the pr esence of creosote constituents including PCP at concentrations above background levels ( see Tables 2 6 and 2 8 of this HRS documentation record) . In addition, historical sediment samples collected from the drainage ditches that
collect runoff from the sout hern 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 p roduce pressure -t reated railroad products (Ref. 82, p. 13). S ediment 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 2 6 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 No s. 1, 2, and 3 surface soil samples as indicated below in Table 2 9 (Ref. 54, p. 42 ) (see Section 2.2.1, Source No. 3 of this HRS documentation record).85 SW

- Observed Release TABLE 2 9 : Hazardous Substances Associated with Cr eosote, 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 th e 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)pyre ne 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

Pentachlo rophenol

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: 550.0086 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

T oxicity, persistence, and bioaccumulation factor values for the hazardous substances detected in the

sources wi th 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 Bioaccumul ation

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-1187 SW

- Environmental Threat N otes:

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 N ot 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: 1 00 (Ref. 1, Sec tion 2.4.2.2)

4.1.3.2.3 Calculation Of Human Food Chain Threat Waste Characteristics Factor Categor y 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 10 8 . 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: 1 00

Toxicity/Persistence Factor Value × Hazardous Waste Quantity Factor Value: 1 x 10 6

Toxicity/Persistence Factor Value × Hazardous Waste Quantity Factor Va lue ( 1 x 10 6 ) × Bioaccumulation Factor Value (50,000): 5 x 10 10

Waste Characteristics Factor Category Value: 320 (Re f. 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

A n observed release of hazardous substance s havi ng a bioaccumulation factor value of 500 or greater is documented in perennial surface water with a fishery downstream –s pecifically, an observed release to the Main Drainage Ditch (Refs. 70, pp. 5; 71; 82, p. 121 ) (see Figure 5 of t his HRS documentation re cord). 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). F ishing 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: Poten tial Human Food Chain Contamination

Identity of

Fishery Annual
Production

(pounds) Type of
Surface Water Body (Table 4

- 13) Average
Annual

Flow (cfs) Population Value (P i Dilution Weight (D ) (Ref. 1,
Table 4 -18) i

P ) (Ref. 1,
Table 4 -13) i × D Refs. i

Luxapa llila
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 P i x D i : 0.00003 (Sum of P i x D i )/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

.