Wrigley Charcoal Plant

• Site Profile
• Administrative Record Index: OU1 (PDF, 20 pp., 1.0M)
• Proposed Plan Fact Sheet, May 2003 (PDF, 20 pp., 1,5M)
• Additional Site Documents including Five Year Reviews, Records of Decisions (ROD) and Explanation of Significant Differences (ESD).
• For documents not available on the website, please contact the Region 4 Freedom of Information Office (http://www.epa.gov/region4/foiapgs/submit.htm).

Site Background:
The Wrigley Charcoal Site located in Hickman County, Tennessee, consists of four distinct areas: 1) the 35-acre Primary Site, 2) the three-acre Storage Basin located 1,400 feet west of the Primary Site, 3) the 40-acre Irrigation Field located 3,500 feet northeast of the Primary Site, and 4) the three and one-half acre Athletic Field located 800 feet southeast of the Primary Site in the eastern portion of the Wrigley community. The Primary Site was used for industrial operations such as producing iron, charcoal, and wood distillation products intermittently from 1881 to 1966. The Storage Basin and Irrigation Field were utilized for the disposal of contaminated Site wastewaters beginning in the 1940s and continuing until the mid-1960s. Slag and soils derived from the Primary Site were utilized to fill the Athletic Field from 1938 to 1950 when the field was opened. Much of the waste at the Wrigley Site was disposed into the North Fork of Mill Creek. The leachate and wastes at the Primary site and Storage Basin contained volatile organic compounds including toluene, benzene, and phenol, and polycyclic aromatic hydrocarbons. The North Fork of Mill Creek was contaminated with low levels of these contaminants. Health threats included accidental ingestion of or direct contact with these wastes on-site.

Cleanup Progress: Actual Construction

• In 1988, the EPA declared the Wrigley Charcoal site an imminent and substantial danger and conducted a response action, under removal authority, to stabilize the tar pits to prevent a major release to the North Fork of Mill Creek. In 1989, the State of TN authorized the relocation of the downstream Bon Aqua-Lyles Water District primary water intake.
• In 1991, EPA signed the Interim Action Record of Decision (IROD) to address immediate threats of direct contact at the Primary Site.
• From 1993-1995 Interim Remedial Action was conducted in two phases between September 1993 and July 1995. Phase I of the remedial action included: disposal of transformers, waste debris, waste sludges, tar-cubes, and visibly friable asbestos corrugated material; and excavation and recycling as fuel of contaminated soil, and wood tar. Phase II included: removal, aeration, and discharge of water in the Storage Basin and Overflow Basin to Hollow Creek; removal of a discrete layer of fluid-like tar material on the bottom of the Storage Basin, blending and use as a fuel blend; removal and disposal of 2,172 tons of visible contaminated soil at the tar/soil interface of the Storage Basin; removal and disposal of a small amount of material consisting of tar residues from the Overflow Basin; and, removal and disposal of 3,113 tons of contaminated material from the former on-site tar pits.
• From 1995 until present the site has been used as a recycling facility. There are approximately seven workers at the Site. Plastic waste, cardboard boxes, debris, piles of insulated material (plastic wire), and scrap metal are spread all over the Primary Site. The operator has received several Notices Of Violation (N.O.V.) from TDEC. Burned areas were sampled by EPA in June 1999.
• During 2000, the Five-Year Review was completed. Also, the current operator on the Primary Site, continued with some modifications to the Site including the placement of clean fill in several areas, and paving of a large area.
• During 2001-2003, a supplemental RI/FS was conducted which included sampling of groundwater, surface and subsurface soil, surface water and sediment. The samples were collected in an effort to fill potential data gaps from previous investigations. All useable data from previous investigations was combined with the data from the supplement investigation.
• In July 2003, EPA finalized the Record of Decision (ROD) for the Site. The major components of the selected remedy include excavation and off-site disposal of approximately 25,000 cubic yards of contaminated soil which is a potential source of groundwater contamination; groundwater treatment by in-situ bioremediation enhanced by oxygen release compounds; extension of public water to the nearest downgradient residential property; periodic groundwater monitoring; and deed notices on the Site to prevent consumption of groundwater until cleanup levels have been met and to limit future use of the Primary Site to industrial uses.
• In December 2003, EPA began the Remedial Design investigation to delineate the areas of soil excavation. EPA discovered a previously unknown extensive area of Non Aqueous Phase Liquid (NAPL) in the shallow groundwater on the Primary site in the area planned for soil excavation. Additional areas of soil contamination on adjacent properties also need to be evaluated. As a result of these discoveries, and since it is more practical and less expensive to handle all excavation at the same time, EPA has postponed any further implementation of the ROD until it can investigate and sample these newly identified areas. After this additional investigation, EPA will determine if the ROD needs to be revised or amended.
• In September 2005, a second Five Year Review (FYR) for the site was completed. The recommendations are summarized here: 1) Re-evaluate groundwater conceptual model to address NAPL on site, "impacted subsurface water", and artesian conditions; 2) Perform additional monitoring in deep aquifer; 3) Re-evaluate remedial alternative to address new site conditions since the 2003 ROD/ Proposed Plan; 4) Re-evaluate potential risks to receptors with updated site data, ARARs, and toxicity factors; 5) Document connection of downgradient residence to public water supply and removal of contaminated soil; 6) Evaluate status of the site with regard to the national institutional controls system.
• EPA is currently implementing the above recommendations while conducting the Remedial Design investigation for the site. EPA began re-evaluating the groundwater conceptual model. In October 2007 EPA investigated and sampled NAPL from 14 additional test pits on the primary site.  In November 2007, EPA began additional monitoring in the deep aquifer beneath the site by installing 4 new deep monitoring wells. In December 2007, EPA began updating site data by the collecting additional soil, waste, surface water, pore water and shallow groundwater samples at the site.  Existing wells and the new wells were sampled in April 2008.  Private wells were sampled in May 2008.  EPA should begin review of the Draft Remedial Design investigation in May 2009.
• EPA has reviewed the Draft Remedial Investigation and has determined additional investigative work needs to be performed at the Site prior to completion of the Final Remedial Investigation Report. These additional activities are anticipated to be complete by December 2009. Following the completion of these activities, a Focused Feasibility Study and ROD Amendment will be performed by September 2010.

Current Funding Status

• EPA spent approximately $1.2 million on its 1988-89 removal action.
• EPA has spent approximately $4 million on its 1993-1995 Interim Remedial Action.
• EPA has spent approximately $2 million developing Supplemental RI/FS and Final ROD.

Key Accomplishments

• 1989: Site listed on NPL; Bon Aqua-Lyles Water Intake relocated.
• From 1989 to 1991, the EPA conducted an RI for all areas of the Wrigley site and an FS for the Primary Site and Storage Basin. Significant contamination was identified at the Primary Site in numerous waste piles, soils, buildings, tar pits, and above ground storage tanks. All residential wells were sampled during the RI/FS, and no contaminants were detected in wells surrounding the site.
• From 1993-1995 The TN Department of Environment and Conservation (TDEC) conducted remedial activities under a Cooperative Agreement with EPA. included the removal and disposal of 5,285 tons of contaminated soils and materials and sampling of private wells around the site and no site related contaminants were detected in wells surrounding the site.
• In November 2002, EPA collected two surface soil, four sediment, six surface water (spring), and eight potable well samples at request of local citizens and no site related contaminants were detected in potable wells surrounding the site.
• In December 2003, EPA the Remedial Design investigation discovered a previously unknown extensive area of groundwater contamination and additional areas of soil contamination on adjacent properties also need to be evaluated.
• September 2004, the Agency for Toxic Substances and Disease Registry (ATSDR) completed a Health Consultation of the Athletic Field concluding no health hazards.
• October 2004, Remedial Design investigation expanded to evaluate new discoveries.
• September 2005, Second Five Year Review completed and Remedial Design investigation is continuing.
• October 2007 to July 2008, Remedial Design investigation field work has been completed on site. 
• The Remedial Design and Supplemental Remedial Investigation Report is currently being compiled and a draft is anticipated in January 2009.   

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