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 emergency phase of the removal action is short-term in nature and is deigned 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 $500,000.

Efforts to find a recycling or reuse alternative for the CCA solutions have been unsuccessful.  The primary focus is to finalize disposal arrangements for 3 wastestreams:
- CCA concentrate
- CCA solutions & wastewater
- CCA sludges
Various removal activities have taken place during this reporting period from 08/13/2007 through 08/19/07 and are as follows:

•ERRS completed installation of a chain link fence around the site perimeter for additional security.
•ERRS constructed an outfall structure at the low point of the site to remove arsenic-contaminated sediment in surface water runoff.  The control structure is filled with limestone, and is designed to filter runoff before discharging into a culvert beneath the railroad tracks.
•ERRS and START collected a sediment sample from the storm water outfall pipe that empties into the outfall structure.  The sample will be analyzed for arsneic, copper and chromium, in order to determine if the stormwater system is contributing to the off-site release of arsenic.
•ERRS repaired segments of the wooden fence and boarded up the entrance gate from Holly Avenue for additional security.
•ERRS hung “Danger – Arsenic Hazard” signs around the perimeter of the site property.
•ERRS decontaminated and demobilized heavy equipment from the site.
•ERRS locked the treatment and storage buildings, and secured the site.
•Heritage Environmental (CCA disposal facility) collected CCA waste profile samples.

EPA, ERRS and START demobilized the site on 08/17, after securing the perimeter and completion of the sediment trap.

Obtain approval for waste profiles and schedule  return to the site in approximately 1-2 weeks to perform disposal activities.

- START will prepare a Work Plan, including a Quality Assurance Project Plan (QAPP), which details the scope of a comprehensive investigation designed to characterize the nature and extent of contamination at the site.
- EPA to prepare response to issues raised at 08/07 City Commission meeting.

An Amended Emergency Action Memo was approved, authorizing additional funding to complete site stabilization activities.  The new site ceiling is $500,000 for completing the emergency phase of the removal action.