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Velsicol Chemical Corporation (Hardeman County)


Velsicol Soil Vapor Extraction System Pilot Test

Additional Resources
Site Summary Profile
EPA ID: TND980559033
Location: Toone, Hardeman County, TN
Lat/Long: 35.381930, -088.926380
Congressional District: 07
NPL Status: Proposed: 12/30/82; Final: 09/08/83
Affected Media: Ground water, Soil, Solid waste, Air, Surface water
Cleanup Status: Construction Complete - Physical cleanup activities have been completed.
Human Exposure Under Control: Yes
Groundwater Migration Under Control: There is insufficient data to determine
Sitewide Ready for Anticipated Use: No
Site Reuse/Redevelopment: None
Site Manager: John Nolen (nolen.john@epa.gov)

Current Status

The Velsicol Chemical Corp. (Hardeman County) site includes an area where Velsicol Chemical Corporation operated a landfill from 1964 to 1973. EPA placed the site on the National Priorities List (NPL) in 1983 because of contaminated ground water, soil, solid waste, air and surface water resulting from landfill operations. EPA, the Tennessee Department of Environment and Conservation (TDEC), and Velsicol Chemical Corporation, the site’s potentially responsible party (PRP), have investigated site conditions and taken steps to clean up the site in order to protect people and the environment from contamination. A water line connects nearby residences and businesses to the public water supply. By evaluating cleanup options, monitoring the site, placing institutional controls on most affected properties, and undertaking Five-Year Reviews, EPA, TDEC and the site’s PRP continue to protect people and the environment from site contamination.

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Site Location and Background

The 27-acre site is located on the east side of Old Toone Road, approximately one mile north of Tennessee Highway 100 in Toone, Hardeman County, Tennessee. The site includes a landfill, which is located on a 242-acre parcel of land owned by the site’s Custodial Trust. Pugh Creek borders the site to the east. A forested area borders the site to the north and south. Old Toone Road borders the site to the west. Clover Creek and a wetland area are located approximately one mile north of the site. People use this area for fishing and hunting activities. The site’s broader surroundings include rural, agricultural and forested areas. Residences are located along Old Toone Road and include low-income residents.

From 1964 to 1973, Velsicol Chemical Corporation used the site as a landfill for the disposal of wastes generated at the Velsicol Chemical Corporation facility in Memphis, Tennessee. Operations disposed of approximately 130,000 drums of plant waste in the landfill. In 1983, EPA listed the site on the NPL.

The site is not in use.

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Threats and Contaminants

Site investigations identified contamination in ground water, soil, solid waste, air and surface water that could potentially harm people in the area. Contamination resulted from waste handling practices at the site. Contaminants of concern include base neutral acids, pesticides, polycyclic aromatic hydrocarbons (PAHs), volatile organic compounds (VOCs) and carbon tetrachloride.

Contamination affected ground water on site and off site. Ground water contamination extends 2.5 miles from the site. In 1979, EPA identified ground water contamination in private wells and the City of Toone connected residences and businesses to the public water supply. As of 2009, residents or businesses do not use ground water impacted by the site as a drinking water source. EPA has placed institutional controls on most properties to prohibit well drilling for drinking water purposes.

Contamination affected approximately 3.7 million cubic yards of soil.

The PRP considered children’s health issues as part of the site’s risk assessment.

In 2005 and 2007, EPA conducted air sampling and assessed whether residents or workers might be at risk from harmful ground water vapors in buildings. In 2007, EPA installed vapor mitigation systems in the crawl spaces of two homes to address vapor intrusion. In 2008, EPA initiated an air sampling program. Based upon this program, EPA determined that that vapor intrusion did not pose a threat to residents and workers and that no additional homes would require indoor air vapor mitigation systems. EPA continues to monitor indoor and outdoor air at the site.

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Investigation and Cleanup Responsibility / Oversight

Velsicol Chemical Corporation, the site’s PRP, led site investigation and cleanup activities, with oversight provided by EPA and TDEC. The company conducted site activities until 2002. The company entered into an Environmental Settlement Agreement in 2002 and created a Custodial Trust.

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Site Cleanup Plan

Site investigations and cleanup activities have focused on two areas, which EPA refers to as operable units, or OUs. These areas include OU-1: ground water contamination; and OU-2: contamination source control.

In 1991, EPA issued a cleanup plan (a Record of Decision, or ROD) for the site. The plan included the following activities:

In 1995, EPA issued a cleanup plan (a ROD) for OU-2. The plan included the following activities:

Summaries of site cleanup approaches are also available online in key site cleanup documents, including the RODs.

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Cleanup Progress

The site’s PRP installed extraction wells and began operation of the ground water treatment system for OU-1.
The PRP also completed upgrades to the cap for OU-2.

In 2008, EPA began a soil vapor extraction (SVE) pilot study for the southwest disposal area at the site. The results of the pilot study indicated that full-scale SVE is suitable as a cleanup option for OU-2.

Remedy performance evaluations found the ground water treatment system was not containing ground water and waste was leaching from the landfill and discharging to nearby surface water. EPA has suspended ground water treatment and begun to evaluate alternative cleanup options to address ground water contamination.
The site’s third Five-Year Review, completed in 2011, found the cleanup for OU-1 and OU-2 is not protective of human health and the environment because cleanup activities are not addressing ground water contamination and institutional controls need to be placed on the remaining affected properties.

In September 2012, EPA issued a ROD amendment for OU-2.  The Amended OU2 ROD included landfill cap extension with drainage improvements and Soil Vapor Extraction (SVE) remedies for the site’s waste disposal area landfills (north, middle, and south).  The Region is electing to implement the Amended ROD OU2 Source Control Remedies prior to initiating further work on evaluating and implementing an OU1 Groundwater remedy.
Currently Remedial Design efforts are underway for the OU-2 cap and SVE remedial actions.

Summaries of cleanup activities are also available in Five-Year Reviews online.

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Enforcement Activities

EPA negotiated legal agreements with the site’s PRP to investigate and clean up the site. The PRP maintained responsibility for the site until 2002. In 2002, EPA and the PRP entered into an Environmental Settlement Agreement, creating a Custodial Trust. When cleanup costs exceed available funding in the Custodial Trust, EPA and TDEC will fund site activities.

RODs and Five-Year Reviews online provide additional information on specific legal agreements for the site.

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Community Involvement

EPA is working with the community and its state partner to develop a long-term cleanup plan for the site, reflecting the Agency’s commitment to safe, healthy communities and environmental protection. Community engagement and public outreach are core components of EPA program activities.

EPA is conducting a range of community involvement activities to solicit community input and to make sure the public remains informed about site activities throughout the cleanup process. Outreach efforts include public notices, fact sheets, interviews and public meetings.

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Future Work

Long-term monitoring of ground water, surface water, fish tissue and air is ongoing.

EPA is currently evaluating alternative cleanup activities to address ground water contamination and the contamination source area. EPA expects to select a new ground water cleanup plan.

The Trust contractor is currently conducting the remedial design for the SVE system and cap construction and maintenance, and EPA is currently negotiating a State Superfund Contract with the State of Tennessee.

EPA completed the last Five-Year Review in 2011 and plans to complete the next Five-Year Review in 2016.

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Additional Information

EPA keeps additional site documents and information in a site information repository at the location below. EPA also posts site documents, when available, on EPA’s CERCLIS Site Profile page. For documents not available on the website, please contact the Region 4 Freedom of Information Office.

Site Repository

Hardeman County Library
213 North Washington Street
Bolivar, TN 38008

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