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Arlington Blending & Packaging Site

Arlington Blending & Packaging Site
EPA ID: TND980468557
Location: Arlington, Shelby County, TN
Congressional District: 08
NPL Status: Proposed: 01/22/87; Final 07/22/87
Project Manager
Documents:About Adobe Portable Document Format

Site Background:
The 2-acre Arlington Blending & Packaging Site is located along U.S. Highway 70 in the town of Arlington, 23 miles northeast of Memphis. From 1971 to 1978 the Arlington Blending & Packaging Company (ABAP) operated as a pesticide formulation and packaging facility. ABAP blended technical grade pesticides with solvents and emulsifiers and packaged the products for client companies, which were primarily pesticide manufacturers. During the company's operation, spills and leakage of products occurred, resulting in soil, ditch sediment, and groundwater contamination.

Cleanup Progress: Construction Complete

In October 1983, EPA conducted a removal action which consisted of the excavation of 1,920 cubic yards of grossly contaminated surface soils (above 50 parts per million (ppm) of chlordane) and the removal and disposal of all equipment and waste chemicals present at the Site. These actions were taken, primarily, to address surficial contamination that posed significant risk to human health.  EPA formally requested that the identified Potentially Responsible Parties (PRPs) voluntarily conduct a Remedial Investigation / Feasibility Study in January 1988.  The PRPs declined to conduct the RI/FS at that time.  Therefore, in January 1991, EPA completed an in-house RI/FS at the Site. Contaminants of concern (COC) identified in site soils included the following: chlordane, heptachlor, endrin, pentachlorophenol (PCP), and arsenic. Additionally, the following COCs were identified in site surficial ground water: PCP and 1,1-dichloroethene.

The Record of Decision (ROD) was finalized in June 1991. The selected remedy consisted of both excavation and treatment of site soils and pump and treat of site ground water. In January 1992, EPA Region 4 issued a Unilateral Administrative Order (Section 106a of CERCLA) to site PRPs, requesting that they implement the 1991 ROD. The PRPs submitted the Remedial Design Report, which addressed only soils remediation, in January 1994. Remediation of site soils was conducted from January 1996 to July 1996. Approximately 41,431 tons of subsurface and surficial soils contaminated above 3.3 ppm chlordane, 0.6 ppm endrin, or 0.6 ppm PCP were excavated and treated using a thermal desorption process. These excavations removed more than 95 percent of contamination identified in Site soils and were undertaken, primarily, to protect ground water from leaching source soils.

The PRP initiated a groundwater modeling effort to evaluate the efficacy of monitored natural attenuation as an alternative to the ROD-selected remedy of pump and treat for contaminated groundwater.  The decision to evaluate natural attenuation was primarily based on observed decreasing contaminant trends and the recent removal of over 90% of the source contamination.

At that time based on the data available, the modeling report demonstrated that the site surficial aquifer contamination posed no threat to the public drinking water supply nearby the Site. EPA agreed to the PRP's request that long-term monitoring of the ground water be implemented, instead of pump and treat, and that surficial aquifer contaminants be allowed to naturally attenuate. The PRP demonstrated that the time required to cleanup site ground water via natural attenuation would be comparable to that of pump and treat. The ROD Amendment, which documented this change to the 1991 selected remedy was finalized in July 1997.  A Long Term Monitoring and Maintenance (LTMM) Plan was approved by the EPA June 1998.  Highlights of the LTMM Plan included annual sampling of the monitoring wells, semi-annual sampling of surface water sampling locations in the Loosahatchie River, and annual reports submitted to the EPA.  

Operation and Maintenance                                                
The site is currently in Operation and Maintenance and still being maintained by the PRP.  LTMM Annual Reports have been submitted to the EPA from 1999 – 2007.  The first Five Year Review was completed September 27, 2002.  Recommendations from the first Five Year Review included continuing with the monitoring program as outlined in the approved LTMM, the addition of a drainage ditch sampling location to the surface water monitoring program, and copying the Town of Arlington on all future reports.

Most recently, the Town of Arlington has purchased the land and developed it as a neighborhood park called Mary Alice Park.  Mary Alice Park is equipped with a walking trail, exercise stations, half basketball court, and playground equipment.  The park was constructed during the Spring and Summer of 2006 and put into use early Fall 2006.  The ground water monitoring wells remain in place and are monitored annually.  The second Five Year Review was completed September 2007.

The second Five Year Review concluded that the current remedy remains protective of human health and the environment although the site remains impacted by Site-specific contaminants.  The remedy is expected to be protective of human health and the environment upon attainment of the groundwater cleanup goals.

However, in order for the remedy to be protective in the long-term, several recommendations were made in order to ensure protectiveness.  Those recommendations included the installation of additional monitoring wells east of the sod farm to verify the horizontal boundaries of the plume, the installation of vertically deeper monitoring wells in the areas where the Memphis sand aquifer may be vulnerable, use of updated information from the new wells to recalibrate the fate and transport model coupled with current monitoring data to develop an updated conceptual site model, the evaluation of all available information including but no limited to results from new monitoring wells, updated fate and transport model, updated comparison of PCP concentrations to predicted results from the model to determine if natural attenuation remains a viable remedy to reach the remedial action objectives by the projected date, and consideration of other remedial action alternatives as necessary should it be determined that natural attenuation should not remain the selected remedy.  The PRP, TDEC, and EPA have met to discuss the PRP’s workplan submittal for implementation of the recommendations from the Second Five-Year Review Report.  It is expected that the PRP will begin field work under the oversight of the EPA after the workplan has been approved.  The next Five- Year Review is scheduled for September 2012.

For information about the contents of this page please contact Donna Bledsoe

For information about the contents of this page please contact Donna Bledsoe

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