Memphis Defense Depot
Site Summary ProfileEPA ID: TN4210020570
Location: Memphis, Shelby County, TN
Lat/Long: 35.093330, -090.003330
Congressional District: 23
NPL Status: Proposed: 02/07/92; Final: 10/14/92
Affected Media: Ground water, Sediment, Soil, Surface water
Cleanup Status: Physical cleanup activities are underway
Human Exposure Under Control: Yes
Ground water Migration Under Control: Yes
Sitewide Ready for Anticipated Use: Yes
Site Reuse/Redevelopment: Portions of site in reuse / planned or actual reuses include residential, industrial, public, and recreational uses
Site Manager: Turpin Ballard (firstname.lastname@example.org)
The Memphis Defense Depot (Depot) is a former warehousing and distribution center for the U.S. military where waste handling and disposal occurred. EPA, the Tennessee Department of Environmental Conservation (TDEC) and the Defense Logistics Agency (DLA) have undertaken a series of investigations and cleanup actions to protect human health and the environment. Three EPA-approved cleanup plans (Records of Decision, or RODs) have addressed all contaminants of concern, enabling the site to be returned to productive use. The Department of Defense (DoD), EPA, and TDEC continue to ensure the protectiveness of the site’s remedy through long-term monitoring of ground water, land use controls and required Five-Year Reviews. The summary sections below provide more details about the Depot’s history and current status.
The Depot is located at 2163 Airways Boulevard in Memphis, Tennessee. The Depot covers 642 acres in a mixed residential, commercial and industrial area of south-central Memphis. The surrounding area’s population is largely African-American and economically disadvantaged. The Depot consists of two adjacent areas:
- Main Installation: An intensively developed 578-acre area with open storage space, warehouses, former military family housing and outdoor recreational areas.
- Dunn Field: An approximately 60-acre open storage and waste burial area.
The Depot is surrounded by small commercial and manufacturing businesses to the north and east and by single-family residences to the south and west.
Operations at the Depot began in 1942; the installation provided supplies, including clothing, food, medical supplies, electronic equipment, petroleum products and industrial chemicals, to the U.S. military. Hazardous substances were used and stored on site as part of Depot operations, resulting in soil and ground water contamination from leakage, spillage, disposal of out-of-date materials and normal application of pesticides. In 1946, the U.S. Army disposed of leaking mustard bombs at Dunn Field. Other wastes disposed of at the Depot included oil, grease, paint thinners, methyl bromide, pesticides and cleaning fluids. Storage and distribution of material continued until the facility closed in September 1997. Environmental assessment activities at the Depot began in the 1980s. The Depot was placed on EPA’s National Priorities List of contaminated sites in 1992. EPA, TDEC and DLA worked collaboratively with DRC throughout the 2000s to enable the Depot’s cleanup, environmental restoration and reuse.
Threats and Contaminants
Contaminants of concern identified in ground water, sediment, soil and surface water include arsenic, dieldrin, polycyclic aromatic hydrocarbons, polychlorinated biphenyls, tetrachloroethene and trichloroethene.Land use controls currently prevent unacceptable human exposure to all remaining contamination, including exposure to contaminated ground water. Health Consultations prepared by the Agency for Toxic Substances and Disease Registry have not identified any site-related children’s health issues. The remedy’s land use controls prohibit the operation of any schools or child care facilities on site.
To address risks associated with contamination at the Depot, the cleanup plan below was developed.
Investigation and Cleanup Responsibility / Oversight
In 1995, EPA, TDEC and the Depot entered into a Federal Facilities Agreement (FFA) with DLA that outlined the process for site investigation and cleanup under EPA’s Superfund program. DLA, a DoD agency and the former operator of the Depot, is the lead agency for cleanup and restoration activities, with oversight provided by EPA and TDEC. DoD maintains overall responsibility for site cleanup and long-term stewardship.
Site Cleanup Plan
The cleanup of contamination and environmental restoration activities at the Depot have been undertaken under both the federal Resource Conservation and Recovery Act (RCRA) and the Superfund law. Since early 2005, all activities have taken place under the authority of the Superfund program.
To assist Superfund-related investigations and cleanup efforts, the Depot was divided into four areas, or operable units (OUs).
- OU-1: Dunn Field, located north of the Main Installation, is the only documented waste burial area at the Depot.
- OU-2: Former industrial area located in the southwestern quadrant of the Main Installation where maintenance and repair activities took place.
- OU-3: The southeastern watershed and golf course, located in the southeastern quadrant of the Main Installation.
- OU-4: Former material storage area, located in the north-central section of the Main Installation.
EPA, TDEC, and DLA selected the remedy for the Depot in a series of RODs that addressed remaining contamination across all OUs.
EPA, TDEC, and DLA issued the ROD for the Main Installation (OUs 2-4) in 2001. The cleanup approach included the excavation and off-site disposal of lead-contaminated soil in a permitted landfill. Enhanced bioremediation was selected for the most contaminated portion of the ground water area, to be followed by long-term monitoring. To ensure the long-term protection of human health and the environment, land use controls were selected to restrict inappropriate future uses like schools and residential areas on portions of the Main Installation.
EPA, TDEC, and DLA issued the final ROD for Dunn Field (OU-1) in 2004. The cleanup approach included the off-site disposal of pit and burial trench contents, the reduction of VOC concentrations in subsurface soils, the use of chemical injections to treat ground water, and the installation of a below-ground barrier wall to trap or modify contaminants. Monitored natural attenuation was selected as the remedy for contaminated ground water located down gradient of both active treatments zones. Long-term monitoring was also selected as part of the remedy for all ground water. To ensure the long-term protection of human health and the environment, land use controls were selected to restrict inappropriate future uses on portions of Dunn Field.
EPA, TDEC, and DLA issued a ROD amendment for Dunn Field in 2009; the amended ROD documented several significant changes in the site’s remedy to better achieve the 2004 ROD’s cleanup objectives. The revised cleanup approach included the use of new technologies to address off-site ground water contamination and a targeted approach to addressing subsurface soils as well as the extent of chemical injections for ground water treatment. Excavation and off-site disposal were selected to address source materials in two areas with shallow impacts.
Since 1998, a number of cleanup actions have been initiated at the site. Several areas of contaminated soil were also excavated between 1998 and 2001 at the Main Installation and Dunn Field to address lead, dieldrin and PCBs. One area was subsequently transferred to DRC for use as transitional housing for homeless veterans. As a result of all cleanup actions, approximately 16,000 pounds of VOCs have been removed from soil and ground water. Other cleanup actions specific to each OU are discussed in more detail below.
Main Installation (OUs 2-4)
Cleanup efforts at the Main Installation included installation of bioremediation injection wells to enhance the breakdown of chlorinated VOCs in ground water. Injections were performed on a regular basis for two years Monitoring wells were also installed to observe progress of the bioremediation process. In addition, land use controls required by the cleanup plan were put in place in 2005.
Dunn Field and Off-Site Ground Water (OU-1)
At Dunn Field, construction of a barrier well system was completed as an interim cleanup action in 1998. In 2001, the well system was extended. The system has been in continuous operation since November 1998. The success of the final remedy in reducing the contamination source allowed the interim cleanup action to be discontinued in February 2009.
Excavation of the waste burial pits at Dunn Field was completed in 2006. Treatment of VOC-contaminated subsurface soils using SVE began in 2007. Treatment of shallow subsurface soils began in 2008 using thermal desorption, a process which uses heat to change chemicals into gases. The thermal treatment system removed approximately 12,500 pounds of VOCs, reached cleanup levels and was discontinued in November 2008. SVE, which has removed approximately 3,500 pounds of VOCs, is still ongoing , but appears to be nearing the soil remediation goals.
The final component of the Dunn Field ROD was implemented in 2009: the construction and operation of a ground water treatment system to address off-site chlorinated VOCs that remained dissolved in ground water after the source material was treated on site. Operation of the off-site ground water treatment system is ongoing.
The 2008 Five-Year Review found that the remedy for the Depot is expected to be protective of human health and the environment following completion of cleanup actions for subsurface soils at Dunn Field and for ground water at both the Main Installation and Dunn Field. In the interim, human exposure pathways to site contaminants are being controlled and land use controls are preventing exposure to contaminated ground water.
In 2010, the Depot achieved Construction Completion status and met EPA’s Sitewide Ready for Anticipated Use criteria. All remedies are either complete or under operation and maintenance and long-term monitoring. Land use controls on both the Main Installation and Dunn Field ensure that only appropriate, protective land uses are located at the Depot.
In 1995, the Depot was placed on the list of DoD facilities to be closed under the Base Realignment and Closure (BRAC) process. The City of Memphis and Shelby County created the Depot Redevelopment Corporation (DRC) to plan and coordinate the reuse of the Depot. Since 1997, more than four million square feet of covered and uncovered facilities (94 percent of the Main Installation) have been returned to use, providing approximately 980 jobs. As of 2010, there are more jobs at the Depot than when the facility closed in 1997. All property at the Depot has been or will be transferred for reuse. Actual or planned reuses include transitional veterans’ housing, a golf course, a police precinct, and the Memphis Depot Business Park.
In 1995, EPA, TDEC and the Depot entered into an FFA with DLA that outlined the process for investigation and cleanup activities at the Depot under the Superfund program.
EPA has worked with the community and its state and federal partners to develop a long-term remedy for the Depot, reflecting the Agency’s commitment to safe, healthy communities and environmental protection. EPA cannot fulfill its mission without community engagement and public outreach as core components of the program’s activities.
At the Depot, EPA has conducted a range of community involvement activities to solicit community input and ensure that the public remains informed about activities throughout the cleanup process. Outreach activities have included public notices and information meetings. A Restoration Advisory Board (RAB) composed of a cross-section of community members also met from 1995 to 2010. Through the RAB as well as the information meetings, the community has been able to follow the progress of cleanup activities at the Depot, express concerns about how the contamination might affect public health, and receive answers addressing their concerns.
DoD is the lead agency for community involvement. Over the course of site activities, DoD has provided regular updates through quarterly newsletters, public meetings, and the RAB as part of its community involvement plan. Future community involvement activities will be primarily related to significant remaining milestones, such as Five-Year Reviews.
Soil and ground water treatment and related monitoring activities are ongoing at the Depot. EPA’s next Five-Year Review for the Depot is required by January 2013.
For more information or to view any site-related documents, please visit the site information repository at the following location or access site information online. As new documents are generated, they will be placed in the information repository.
Memphis Depot Business Park
DLA Community Outreach Room
2245 Truitt Street
Memphis, Tennessee 38114
For documents that are not available online, please contact the Region 4 Freedom of Information Office.