U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Liberty Fibers - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV
Subject: POLREP #15
Continue Removing ACM Demoltion Debris and Bagged ACM
Liberty Fibers
B457
Morristown, TN
Latitude: 36.1493481 Longitude: -83.2048083

To: James Webster, ERRB Reg 4
Brenda Apple, TDEC
From: David Andrews, On Scene Coordinator
Date: 4/20/2012
Reporting Period:

1. Introduction
  1.1 Background
   
Site Number: B457    Contract Number: EP-S4-07-02
D.O. Number: # 0115 (Mod 4)    Action Memo Date: 6/30/2011
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 4/21/2010    Start Date: 4/21/2010
Demob Date:      Completion Date:  
CERCLIS ID:    RCRIS ID:
ERNS No.: NRC 937191    State Notification: 4/15/2010
FPN#:    Reimbursable Account #:

1.1.1 Incident Category
Time-Critical Removal Action
Primary Tasks: Consolidate and dispose of demolition debris (and associated waste) containing asbestos. 

1.1.2 Site Description
The Liberty Fibers site (Site) is located at 4855 Enka Highway, Morristown, Hamblen County, Tennessee.  The geographic coordinates for the Site are 36.15580 degrees north latitude and -83.20645 degrees west longitude.  The Site is bordered to the north by a railroad, tree line, and a small residential neighborhood; to the east by a landfill and a retention pond; to the south by the Nylon Staple Plant; and to the west by farmland.  The Site is approximately 1,050 feet above sea level.  The topography of the site is relatively flat.

1.1.2.1 Location
The site is located at 4855 Enka Highway approximately one mile south of Interstate 81 (off Exit 12) in Morristown, Tenn in the Lowland Community.

1.1.2.2 Description of Threat
During recycling activities on April 19th, a debris pile along the southern perimeter caught fire and the Morristown Fire Dept responded. In order to minimize such future events, and to minimize the chance of asbestos exposure, the OSC elected to serve the owner with a Notice of Federal Interest in order to initiate site containment and mitigation measures. The site contains numerous construction debris piles interspersed with friable asbestos.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
Concurrent to the April 19th fire and recent activities on site, the OSC requested that Region 4 Technical Services Branch evaluate asbestos sampling conducted in Jan 2010 to determine if a threat to human health and the environment existed on site. The OSC concluded that the threat exist and preceeded forth with an emergency response action.

2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative
Removal ongoing with primary focus on removal and on-site disposal of ACM demolition debris and removal and on-site disposal of bagged ACM material located in Electrical Shop building.
 
2.1.2 Response Actions to Date

EPA initiated emergency response action in April 2010 to stabilize site and control access.  Subsequent ceiling increase action memorandums (June 2011 & March 2012) have maintained EPA pressence to complete removal of source contamination (ACM contaminated debris, bagged ACM (insulation from RP abatement), and existing pipe runs wrapped with insulation at is ACM and in deteriorating condition.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Responsible Party(ies) have been identified and enforcement in progress.

2.1.4 Progress Metrics (totals to-date)

Note: Actual volumes or weights are not used.  Approximately 10-15 X 0.5 cu yd buckets loads per truck in ACM demo debris haul.  Material is heavy therefore full-loads for the articulating dump trucks are forbidden to protect the road and prevent airflow over the material to prevent material drying.

Waste Stream Medium Quantity
(# Loads)		 Manifest # Treatment Disposal
ACM Demo Debris  Brick, Concrete, Metal  2090  N/A  N/A  On Site Repository
ACM Bagged  ACM from RP's abatement ops  36
(1701 bags)		  N/A  N/A  On Site Repository
Scrap Steel  Material may have attached concrete and is staged near BASF clarifier  362  N/A  N/A  Stagged for recycling


  2.2 Planning Section
    2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities

Maintian the landfill and access roads and dispose ACM and associated debris/materials in the landfill.

2.2.1.2 Next Steps

Complete removal of bagged ACM that is storred in the former Electrical Shop building and initiate pipe-run removal.

2.2.2 Issues

None at this time.
  2.3 Logistics Section
    N/A
  2.4 Finance Section
    2.4.1 Narrative

An emergency response action was initiated under the OSC's warrant authority to stabilize & secure the site.  TO No. 0115 was issued to Environmental Restoration, LLC, in the ammount of $200,000 and TDD No. TTEMI-05-001-0145 was issued to Tetra Tech in the ammount of $30,000.

A Verbal Ceiling Increase and Change of Scope for Response was signed on September 7, 2010.  The new site ceiling is $450,000.  The new ERRS ceiling is $400,000 and the START (Tetra Tech EMI) ceiling remains unchanged at $30,000.

A Ceiling Increase for Continuation Of A Removal Action was signed on December 16, 2010.  The new site ceiling is $582,000.  The new ERRS ceiling is $520,00 and the START ceiling remains unchanged at $30,000.

ERRS - Environmental Restoration, LLC: (initiated April 21, 2010)
Task Order No. EP-S4-07-04 #115                      $200,000
Task Order No. EP-S4-07-04 #115 Mod 1            $400,000
Task Order No. EP-S4-07-04 #115 Mod 2            $520,000

A Ceiling Increase and Exemption from the Twelve Month Statutory Limit and $2 Million Exemption for a Time-Critical Removal Action was signed on June 30, 2011 and the ERRS contractor was changed from Environmental Restoration, LLC to CMC, Inc.  ER would maintain security on site through August 15, 2011.

ERRS - CMC, Inc (6/30/2011)
Task Order No.EP-S4-07-04 #115 Mod 3       $1,974,195  [ceiling $2,274,195]
Task Order No.EP-S4-07-04 #115 Mod 4       $  900,000   [ceiling $3,174,195]

START - Tetra Tech (6/30/2011)
TDD No. TTEMI-05-001-0126                            $150,000 [ceiling $180,000]  
TDD No. TTEMI-05-001-0126                            $190,000 [ceiling $370,000]  

                                     ********* COST TO DATE AS OF March 20, 2012  ************      
 
   
Estimated Costs *
  Budgeted Total To Date Remaining % Remaining
Extramural Costs
ERRS - Cleanup Contractor $3,174,195.00 $2,583,435.00 $590,760.00 18.61%
Cooperative Agreements/Letter Contracts $40,000.00 $0.00 $40,000.00 100.00%
TAT/START $250,000.00 $180,954.37 $69,045.63 27.62%
Intramural Costs
USEPA - Direct $60,000.00 $45,400.00 $14,600.00 24.33%
 
Total Site Costs $3,524,195.00 $2,809,789.37 $714,405.63 20.27%

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.


  2.5 Other Command Staff
    2.5.1 Safety Officer

The OSC (D. Andrews)

2.6 Liaison Officer

N/A

2.7 Information Officer

N/A

2.7.1 Public Information Officer

N/A

2.7.2 Community Involvement Coordinator

The Community Involvement Coordinator assigned to the site is Ms. Sherryl Carbonaro.
3. Participating Entities
  3.1 Unified Command

N/A

3.2 Cooperating Agencies

TDEC Department of Solid Waste (Knoxville Office) consults on the design and preparation of the on-site landfill.
4. Personnel On Site
  As of March 15, 2012:

1 EPA OSC  (Andrews/Buerki rotation)
1 START      (P. Prys & B. Erickson : Tetra Tech EMI)
16/17 ERRS  (CMC, Inc)  - 1 Project Manager, 1 Field Clerk, I Foreman, 12 Equipment Operators, 2 Laborers
5. Definition of Terms
  Asbestos - A generic name given to a number of naturally occuring hydrated mineral silicates that possess a unique crystalline structure, are incombustible in air, and separate into fibers.  Asbestos includes asbestiform varieties of chrysotile (serpentine); crocidolite (riebeckite); amosite (cummingtonite-grunerite); anthophyllite; tremolite, and actinolite.

NESHAP - National Emission Standards for Hazardous Air Polutants

AHERA - Asbestos Hazard Emergency Response Act.
6. Additional sources of information
  6.1 Internet location of additional information/report

No Information available at this time.

6.2 Reporting Schedule
7. Situational Reference Materials
  No information available at this time.
POLREP #15 Last Updated 5/17/2016