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 The Consolidation Area 
              Velsicol created a special soil "consolidation area" on
            the north side of its manufacturing plant site on Warford Avenue.
            The consolidation area was constructed to securely hold contaminated
            soils removed from properties identified by the Tennessee Department
            of Environment and Conservation (TDEC) as requiring cleanup, so that
            no pollutants are released to the environment. Soil collected from
            contaminated properties is brought to Velsicol's plant site by trucks
            and unloaded in the consolidation area. A polyethylene cover over
            the consolidation area, which covers an area of approximately 200
            feet by 150 feet, was designed to prevent dust blowing and to prevent
            rain water from coming into contact with the soils. Water that runs
            off the polyethylene covering is allowed to drain from the plant
          site with other uncontaminated storm water runoff. 
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