United States Environmental Protection Agency
Region IV
POLLUTION REPORT

Subject: 

On March 29, 2005, EPA On-Scene Coordinator (OSC)Art Smith was contacted by the Kentucky Department for Environmental Protection (KYDEP)Superfund program regarding an abandoned creosote wood-treating facility in Mayfield, Graves County, KY.  The site is located at 311 E. Hunt Road in Mayfield and was formerly operated as Easterday Tie and Timber from 1977 until 2002.  At that time, Kentucky Tie & Timber (KY TT) purchased the property and continued wood-treating operations. KY TT ceased operating and abandoned the property in 2004.  A recent inspection of the premises by KYDEP in January 2005 disclosed evidence of creosote spillage from piping adjacent to the above-ground product storage tanks.  The facility is readily accessible and recent evidence of trespassing collected by the KYDEP Paducah Regional Office has prompted concerns regarding potential exposure to contaminants.

Upon receipt of email correspondence from KYDEP formally referring the matter to EPA, OSC Smith mobilized to the Site on March 30, 2005 to conduct a Removal Site Evaluation (RSE) purusant to Section 400.310 of the National Oil & Hazardous Substances Pollution Contingency Plan (NCP).  The OSC concluded the RSE on March 30, 2005, and determined that the conditions onsite meet criteria for a time-critical removal action listed under Section 300.415 of the NCP. After contacting the current owner who cited a financial inability to address threats currently posed by the Site, the OSC initiated a fund-lead removal action under his delegated CERCLA emergency authority.

The Action Memorandum ceiling increase was approved on September 20, 2005. Since then the EPA returned to the Site to complete the removal action. On October 6, 2005, the removal work resumed and CMC, EPA’s cleanup contractor, began to dismantle product pipelines. CMC has also continued water treatment of creosote contaminated waste water collected in sumps, tanks, and process equipment around the site.  Approximately 32,000 gal of water has been treated. Also, approximately 168,000 pounds of creosote and creosote water mixture were shipped off site for reuse to Railworks Co. in Memphis, Tennessee. While on site EPA and CMC discovered jars containing Mercury. It was staged properly and there was no evidence of a release.

CMC should complete the breakdown of piping and the removal of stabilize sludge from tanks, pits, and piping. The tanks, pipes, scrap steel will be cleaned as required for final disposal. The treatment and discharge of water will be continued throughout the cleanup.

The final steps of the removal action will include the removal and disposal of creosote waste materials and any impacted soils. Also, the final disposal of contaminated piping, scrap steel, tanks, and vessels will be completed.  The removal action should be completed in January of 2006.