United States Environmental Protection Agency
Region III
POLLUTION REPORT

Subject: 

The Browning Lumber Company operated a pressure treatment facility at the site location until 1996 and a sawmill at the site location until 1998.  Chromated Copper Arsenate was utilized during the pressure treatment processing of lumber and the company obtained an EPA ID number for hazardous waste activity in 1987; the company also received a WV/NPDES Permit for operation of the treatment facility.

Since the facility's abandonment in 1998, a fire destroyed portions of the facility.  However, during an inspection conducted by WVDEP in July, 2002, to evaluate compliance with the West Virginia Hazardous Waste Management Act, residual products from the operations conducted at the facility were observed on the site.  WVDEP observed that human trespassing was occurring at the site by evidence of dumped materials and trash.  WVDEP conducted TCLP sampling and determined that elevated TCLP values for arsenic were present in one of the pressure treatment vessels and in the soil below the vessel.  
WVDEP contacted EPA Region III and requested that they take the lead in conducting a full assessment at the site and take any necessary actions in mitigating the threats at the site.

On June 19, 2006, the OSC activated a removal action at the site under his delegation of authority for $250,000.  Initial actions included the installation of an entrance fence and coordination with the Army Corp of Engineers (ACOE) for assistance in design/construction of an access bridge across Pond Fork stream.

OSC received Stream Crossing Plan from ACOE on 06/20/2006.

EPA has notified current and former owners and/or operators of the Site that they may be potentially liable for the costs incurred by EPA for the Site clean-up.

On September 13, 2006, a Removal Action Memorandum for the amount of $2,516,339 was signed to address the environmental issues at the Site.

Analytical results collected from the wood treatment pressure vessel at the Site after it was pressure washed revealed that there were still elevated levels of arsenic that may leach from the vessel.  The OSC considered re-washing of vessel, sand-blasting the vessel, or cutting up the vessel for disposal.  Each of these options will present difficulties due to the need to enter the vessel with increased PPE for cleaning or non-standard cutting tools required to cut the vessel for disposal.

For another option, the OSC consulted with the WVDEP for the potential that the vessel may be reused within the State.  The OSC found that WVDEP agreed that it would be appropriate to transfer the vessel to another RCRA compliant facility for re-use and WVDEP provided EPA with the name of the company that would put the vessel back in service.  The OSC contacted the Acme Wood Preservative company and made arrangements for the company to accept the vessel.  The OSC finds that re-use of the vessel at an operating facility is more appropriate than leaving the vessel on the Site and significantly less costly than cutting or trying alternative cleaning methods in order to reduce the risks it may pose while at the Site.

In order for the vessel to be taken by another facility, the OSC coordinated with ORC for guidance. The parties involved with the ownership of the Site do not completely agree on ownership of equipment items at the Site.  The OSC contacted the former operator of Browning Lumber on January 4, 2007 and received oral permission to remove the vessel.  ORC contacted the present property owner and received oral permission on January 10, 2007 to transfer the vessel.

During the week of January 8, 2007, site activities included the cleaning and removal of the Baker storage tanks, the removal of 80 cubic yards of contaminated solid waste, 20 cubic yards of contaminated steel waste, 43 drums of waste liquid/sludge, and 2365 gallons of waste water used to pressure wash the equipment and contaminated items on the Site. In addition, Additionally, the pressure vessel was removed from its pad and placed in a location so a crane can place it onto a trailer for transportation to the Acme Wood Preservative company.

The OSC has coordinated with the Acme Wood Preservative company and the crane company to be on site on Wednesday, January 17, 2007 to load out the vessel and transport to the Acme Wood Preservative location.

Once the vessel is removed, all EPA response activities are anticipated to be complete and further response actions will be assumed by the potentially responsible parties.