United States Environmental Protection Agency
Region IV
POLLUTION REPORT

Subject: 

In November 2006, EPA was notified of this site via an NRC report indicating a potential release of hazardous substances at the Kentucky Wood Preserving facility in Winchester, KY.  The facility was reported to have ceased operations in October 2006, and that wood treating chemicals abandoned onsite may pose a potential threat of a release.  The company used Copper Chromated Arsenate (CCA) wood preservatives, and the treatment works were reported to be full of CCA solution at the time that the business ceased to operate.  Based on this information, EPA OSC Smith initiated a Removal Site Evaluation (RSE) under Section 300.410 of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). See Polrep No. 1 for more complete information on the RSE.

On 06/12/07, KDEP visited the site and discovered that vandals had broken into the treatment building and pried open the door of the pressure cylinder.  KDEP referred the site to EPA on 06/15/07, for purposes of conducting a time-critical removal action, citing concerns over the unstable conditions at the site.  Due to the seriousness of the situation, the OSC initiated a time-critical removal action at the Site on 07/18/07.  The 1st phase of the removal action is short-term in nature and is designed to mitigate immediate threats.  Work activities include securing the site, clearing debris, and arranging for the offsite disposal/treatment or legitimate reuse of wood treating solutions.  This phase of work is expected to be completed by September 1, 2007, at an estimated cost of up to $250,000.

The OSC issued verbal task orders to the ERRS contractor (CMC, Inc.) and the START contractor (TN & Associates, Inc.) on 07/18/07.  CMC was issued a task order in the amount of $250,000 and includes the following tasks:
- Develop a Site Health and Safety Plan;
- Secure the site to deter trespassers from entering the premises.
- Obtain soil and stormwater samples and arrange for laboratory analytical services.
- Obtain samples from CCA process tanks and sumps; profile wastestreams for treatment/disposal or recycling/reuse by other legitimate business entities.
- Conduct on-site treatment and/or arrange for off-site transportation disposal/treatment and/or recycling of hazardous substances.
- Remove wood products and debris from the site.

TN&A Inc. was issued a Task Order in the amount of $50,000, which includes:
- documentation of removal activities.
- preparation of draft polreps.
- creating a SCRIBE database to compile environmental data.
- collecting environmental samples, and
- arranging for offsite analytical laboratory services

From 07/18/07 through 07/20/07, OSC Smith was onsite.  Work activities consisted primarily of site preparation activities.  ERRS subcontracted with a security service and there is a 24 hr. continuous presence at the site.  The OSC met with City of Winchester officials, and briefed them on EPA's actions. An EPA Community Involvement Coordinator (CIC) was onsite during this period and assisted by developing a Fact Sheet which was distributed to businesses and residents within 2 blocks of the site.  The CIC also assisted with development and distribution of a press release announcing a press conference which was held onsite on 07/20/07.

During the week of 07/23/07, work activities are expected to include:
- completion of site preparation tasks;
- sampling of CCA product and solutions to develop profiles for potential reuse

Complete arrangements for onsite processing and offsite transportation/disposal of unfinished wood products.

The OSC contacted the Agency for Toxic Substances and Disease Registry (ATSDR) to inquire about monitoring of workers for potential exposure to inorganic arsenic, which is classified as a proven human carcinogen.  ATSDR recommends biological monitoring for site workers, and air monitoring in the exclusion zone.  ERRS is arranging for a nearby medical provider to perform urinalysis for maximum exposed individuals, and an initial round of air samples will be collected during the week of 07/23/07.