Polution Situation Report

U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Powell Lead - Removal Polrep
Final Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region III

Subject:

POLREP #4
Final POLREP - Removal Completion
Powell Lead
A3XF
Big Stone Gap, VA
Latitude: 36.8607475 Longitude: -82.7954852

To:

Fran Burns, EPA Region 3
Jack Tolbert, VDEM
Lora Werner, Agency for Toxic Substances and Disease Registry
Dwight Flammia, Virginia Department of Health
Pat Murphy, Town of Big Stone Gap
Devlin Harris, DEQ
Paul Kurzanski, CSX
Stacy Bowers, DEQ
Sue Cantrell, VDH

From:

Myles Bartos, On-Scene Coordinator

Date:

8/10/2017

Reporting Period:

Through August 10, 2017

1. Introduction

1.1 Background

Site Number:	A3XF	Contract Number:
D.O. Number:		Action Memo Date:
Response Authority:	CERCLA	Response Type:	Time-Critical
Response Lead:	EPA	Incident Category:	Removal Action
NPL Status:	Non NPL	Operable Unit:
Mobilization Date:	3/18/2014	Start Date:	3/18/2014
Demob Date:		Completion Date:
CERCLIS ID:		RCRIS ID:
ERNS No.:		State Notification:
FPN#:		Reimbursable Account #:

1.1.1 Incident Category

CERCLA Time-Critical Removal Assessment and Removal Action being conducted by the PRPs, under the supervision of the OSC.

1.1.2 Site Description

The site is comprised of two parcels located in Big Stone Gap, Wise County, Virginia. Parcel 1, owned by CSX, is located near the intersection of West 9th Street North and Main Avenue West. Parcel 1 lies between CSX rail lines and Main Avenue West, across the street from several residential properties. From the road, it appears that Parcel 1 has several battery casings, transformer parts, and oil-stained soils. Parcel 2, owned by Robinette Steel & Scrap Metal, consists of a mounded area near a playground at the intersection of Main Avenue West and Short Street North. Parcel 2 is well vegetated with significant evidence of buried construction debris. Parcel 2 is located across the street from several residences and adjacent to a playground. In September 2014, Robinette erected a fence around Parcel 2 to restrict access to the area from the playground; however, the fence has an opening along the eastern side of the mounded pile, adjacent to Robinette's parking lot/roll-off staging area.

1.1.2.1 Location

The site is located in Big Stone Gap, Wise County, Virginia.

1.1.2.2 Description of Threat

According to complaints received by the Virginia Department of Emergency Management (VDEM) and the Virginia Department of Environmental Quality (DEQ), Parcels 1 and 2 were dumping sites in the past. At this time, the contaminants of concern at the site are lead and polychlorinated biphenyls (PCBs). OSC Cruz will be determining if levels of lead and PCBs in the surface soils pose an imminent threat to public health and the environment.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

A visual inspection of the parcels shows evidence of dumped battery casings, transformer parts, and oil-stained soils. A surface soil sampling event was conducted on 3/19/14 to determine the extent of lead and PCB contamination on Parcel 2. Screening of Parcel 2 with an X-Ray Fluoresence Device (XRF) indicated lead levels ranging from Non-Detect to 1290 parts per million (ppm). The validated analytical data confirmed concentrations of lead in the mounded area of Parcel 2 up to 1,180 ppm.

An additional surface soil sampling event was conducted in the playground adjacent to Parcel 2 on 06/10/2014. In total, 102 locations were screened using an XRF. XRF lead data for the playground area ranged between 19 and 73 ppm, and the open field lead data ranged between 24 and 149 ppm. Validated data determined lead concentrations ranging from non-detect to 141 ppm. PCB results for those same locations ranged from non-detect to 370 ppm. The data results do not exceed EPA's Regional Screening Level (RSL) of 400 ppm for lead.

Robinette Steel and Scrap Metal installed fencing in September 2014 to restrict access to Parcel 2. Although Parcel 2 has dense vegetation and is not secured from trespassers, EPA will be consulting VDH and ATSDR to help determine if the site poses a threat to human health. Initial indications are that the site does not pose an imminent threat to human health, but further analysis of the data by the public health agencies is required.

In September 2014, CSX through their contractor collected 9 soil samples on Parcel 1. Data from the sampling event has not been finalized, yet. CSX's contractor will email DEQ, VDEM, and EPA copies of the sample results. Following an analysis of the validated data, CSX's contractor will propose a course of action for the property. Currently, site access is being restricted with a temporary fence.

EPA had collected samples on Parcel 2 and the nearby playground to determine if lead and PCBs pose a threat to human health and/or the environment. Initial indications, in consultation with VDH and ATSDR, show that the site does not pose an imminent threat, but that further analysis is required to fully analyze if the site poses a threat to the local population.

As of 2015, access to the sites is restricted, with Robinette fencing Parcel 2 and CSX erecting a temporary fence around Parcel 1. CSX has conducted soil sampling on Parcel 1, and is awaiting validated results from the sampling event. Robinette has proactively fenced Parcel 2 to restrict open access to the mound.

2. Current Activities

2.1 Operations Section

2.1.1 Narrative

Please see POLREPs 1-3 for information on previous activities.

2.1.2 Response Actions to Date

On January 21, 2015, the OSC and START returned to the site in order to define an extent of contamination for Parcel 2. Prior sampling events did not include sample collection along the eastern side of the mounded pile, which is located directly adjacent to Robinette's parking/roll-off staging area. START collected a total of seven soil samples, one being a duplicate sample, from just outside of the fence line on the eastern side of Parcel 2.

Validated analytical results for both the organics and inorganics were received on March 9, 2015. Lead concentrations in the soils ranged from 105 ppm to 1,550 ppm. The lead concentrations exceeded 400 ppm in two locations: PL-29 and PL-32. At PL-29, the lead concentration was 1,550 ppm; this location was along the opening of the fence line, closer to the mounded pile of soil/debris. At PL-32, the lead concentration was 502 ppm; this location was closest to the opening in the fence line. Two aroclor patterns were detected at low levels in most of the samples, specifically Aroclor-1242 and Aroclor-1254. These were in an industrial area where trucks were parked.

On June 18, 2015, the OSC and START conducted additional extent of contamination sampling for the Site.   Samples were collected and analyzed for lead and PCB Aroclors.   Additional samples were collected in "area 1" (parking lot area) as well as strategic points along the Robinnette Property. The goal was to determine if any contaminants have migrated offsite. This included outfalls near residential properties to the south, and drain lines to the north. Please refer to "Trip Report - #4 and Final", June 26, 2017 for complete data sets. Lead was detected at a high concentration of 1540 mg/kg in one sample. Aroclor-1254 was detected at a high concentration of 700 ug/kg in one sample.

Many of the PCB (Aroclor-1242 and 1254) are above the limit of 1 ppm for "high occupancy" areas.   A high occupancy area is defined as: "High occupancy area means any area where PCB remediation waste has been disposed of on-site and where occupancy for any individual not wearing dermal and respiratory protection for a calendar year is: 840 hours or more (an average of 16.8 hours or more per week) for non-porous surfaces and 335 hours or more (an average of 6.7 hours or more per week) for bulk PCB remediation waste. Examples could include a residence, school, day care center, sleeping quarters, a single or multiple occupancy 40 hours per week work station, a school class room, a cafeteria in an industrial facility, a control room, and a work station at an assembly line."   OSC Bartos has determined that the parking lot does not meet this definition. This determination was based on numerous site visits and observations. The parking lot seems to be utilized infrequently and there is no evidence of trespassing or children playing.

Additionally, there are several lead results that exceed screening values.   However, while the parking lot is used infrequently, it is not abandoned. The areas with higher levels of lead (mound) have been fenced in. Given the circumstances, OSC has determined that no removal response is necessary at this time. If the circumstances change for any reason, it will be re-evaluated.

The EPA continued dialogue with ATSDR and VDH in evaluating the data and circumstances.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

CSX has take responsibility for conducting an assessment of Parcel 1. In June of 2015, CSX erected a chain link fence around the entire parcel to restrict access. They provided a work plan to remove the contaminated soils within the parcel and the work was completed in February 2016. In all, approximately 560 tons of contaminated soils debris, and boulders were removed and properly disposed in Carter Valley Landfill (Tennessee).   The excavation was backfilled and covered with class A1 riprap to prevent erosion.   CSX provided EPA with a remediation report that documented the cleanup.

2.2 Planning Section

2.2.1 Anticipated Activities

All required removal actions are complete. No further action is anticipated at this time.

2.2.1.1 Planned Response Activities

The OSC has evaluated the analytical results, exactly where they came from (location with respect to public access), and the overall circumstances surrounding the Site. At this time, the OSC has determined that no additional removal action is necessary.

2.3 Logistics Section