Hazardous materials present in on-site surface and subsurface soils pose the following threats to public health or welfare as listed in Section 300.415 (b)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP):
Section 300.415 (b)(2)(i) Actual or potential exposure to nearby human populations, or the food chain from hazardous substances pollutants or contaminants;
EPA sampling revealed that there are hazardous substances (ethylene glycol, phenols, benzenes, naphthalenes) present on site. Current site conditions would easily allow a person to access the property and come into contact with these hazardous substances.
Section 300.415(b)(2)(ii) Actual or potential contamination of drinking water supplies or sensitive ecosystems;
Analysis of the containment surrounding drums and other storage containers has deemed it inappropriate to contain a release. Drainage leads off the Site and into South Fork Crooked Creek. Should there be a release of materials from the Site, it is possible for the materials to enter the creek ecosystem.
Section 300.415(b)(2)(iii) Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other bulk storage containers, that may pose a threat of release;
During the initial RSE conducted by EPA, 500 55-gallon drums, 27 ASTs, three 300-gallon totes, and several tanker trailers were inventoried at the Site. Many of these containers based on Site conditions observed on March 19, 2010, are in poor condition and inadequate for storing hazardous substances. The condition of the containers (mainly the ASTs) are a concern for a release.
Section 300.415 (b)(2)(v) Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released;
Areas of the site are already flooded with accumulated rainwater and there is also a large amount of surface staining from oils and other dry chemicals. Weather conditions such as rain could cause these materials to migrate off-site. Other weather conditions such as high wind or hail will continue to damage the bulk storage containers on site and could cause a release.
Section 300.415 (b)(2)(vii) The availability of other appropriate federal or state response mechanisms to respond to the release;
DENR has asked for EPA assistance with this Site.
Due to the threat and/or future threat to human health from the hazardous substance, the Site achieves removal eligibility based on the removal criteria listed above.
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