Puckett Smelter is a 3.01 acre site located at 3329 Mountainboro Road, Mountainboro, Etowah County, Alabama. The site is relatively level and slopes toward the unnamed tributary to Short Creek, which lies along the northern boundary of the site. The site is bordered to the east by Mountainboro Road and to the west and south by undeveloped land.
There is little historical information for Puckett Smelter. According to the original owner, the smelting operation was from the early 1990s to the mid 1990s. The property has 4 main ash piles. The rest of the ash is spread out in between the piles.
In 1999, a RCRA inspection of the site was conducted in response to a complaint by a department within Alabama Department of Environmental Management (ADEM). During the investigation ADEM sampled the ash piles. The analytical results revealed high levels of lead. Based on the results, ADEM issued a Notice of Violation (NOV) to the property owner for storing hazardous waste on site without a permit.
In 2000, ADEM’s Hazardous Waste Branch issued an Administrative Order (AO) due to the land owner not responding to the NOV. After the AO was issued the owner responded to ADEM and indicated he did not have the ability to pay for the cleanup or penalty. ADEM’s Hazardous Waste Branch referred the Site to the state’s Hazardous Substance Branch.
In 2003, a Preliminary Assessment (PA) was completed. Based on the findings of the PA, ADEM recommended the site for further assessment activities by the Environmental Protection Agency (EPA) Emergency Response and Removal Branch (ERRB). On April 9, 2007 ADEM requested that the site be reviewed for eligibility for expenditure of Federal funds to help mitigate the potential environmental impacts from the release of unsecured materials on site.
On May 14, 2007, EPA and Superfund Technical Assessment Response Team (START) arrived on Site to conduct a Removal Site Evaluation (RSE). One composite sample of each ash pile was collected for metals, volatile organic compounds (VOCs), semi volatile organic compounds (SVOCs), and Poly Chlorinated Biphenyls (PCBs). One composite sample consisting of all the ash piles was collected and sampled for dioxins. A total of 7 soil, 3 sediment, and 3 surface water samples were also collected.
For this evaluation, the data was reviewed by the Technical Services Section (TSS) and the maximum detected concentrations were compared to the Removal Action Levels (RALS). The Removal Action Levels were determined by converting the Region 9 PRGs to risk-based concentrations appropriate for time-critical removal actions. The derived RALs are based upon a residential human health risk of 1x10-4 for carcinogens and a Hazard Index of 3 for non-carcinogens. The values referenced in OSWER Directive 9200.4-26 (EPA, 1998) were used for screening dioxin concentrations. Surface water concentrations were evaluated based upon drinking water PRGs, and sediment was evaluated based upon surface soil PRGs.
It was determined that four metals exceeded the calculated RALs for surface soil: aluminum, antimony, copper, and lead. Copper and lead were found at concentrations above the RALs in all four composite samples, while antimony was detected in three of the four samples. Aluminum slightly exceeded its RAL in only one sample. PCBs were also detected above the RALs in two out of four composite samples.
Antimony: The RAL for antimony is 93 mg/kg. Antimony exceeded the RAL in samples PUC-SS-02 through PUC-SS-04 at concentrations ranging from 230 to 1200 mg/kg.
Copper: The RAL for copper is 9300 mg/kg. Copper exceeded the RAL in samples PUC-SS-01 through PUC-SS-04 at concentrations ranging from 9500 to 31,000 mg/kg.
Lead: The Region 4 RAL for lead is 400 mg/kg. Lead exceeded the RAL in samples PUC-SS-01 through PUC-SS-04 at concentrations ranging from 1300 to 43,000 mg/kg.
PCBs: The Region 4 recommended RAL for PCBs is 3300 ug/kg. PCBs exceeded the RAL in samples PUC-SS-02 and PUC-SS-03 with concentrations of 5000 and 16,800 ug/kg, respectively.
The RALs do not appear to have been exceeded in any of the other media sampled at the site. The dioxin toxicity equivalence quotient (TEQ) for the composite sample collected was reported to be 460 ng/kg (ppt). This concentration is below the OSWER recommended clean-up criteria for residential soil, 1 ppb.
Lead, copper, aluminum, antimony, and PCBs are hazardous substances as defined by section 101(14) of the CERCLA and RCRA characteristic definitions. CERCLA contaminants, if released from the Site, have the capability of presenting a potential hazard to the general public. The threats come primarily from human exposure to these hazardous substances in the ash piles (i.e. trespassers) as well as a potential for surface or air migration. Direct contact, ingestion, and inhalation of lead, antimony and PCBs are the primary pathways of exposure. Continued exposure of lead, antimony and PCBs in the soils may cause potential chronic health effects to persons living nearby and trespassers.
Site conditions meet the requirements for initiating a time-critical removal action according to criteria listed in Section 300.415 (b)(2) of the NCP:
• Section 300.415 (b)(2)(i): “Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances or pollutants or contaminants.” Upon arrival, EPA discovered that there were people on Site scavenging the ash pile for metal to smelt down. The site is bounded to the east by Mountainboro Road. There is no fence or security to keep out children, trespasser, and animals from the Site. There are multiple residences in close proximity to the site and evidence of trespassing. Direct contact, ingestion, and inhalation of these hazardous substances are primary pathways of exposure.
• Section 300.415 (b)(2)(iv): “High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface, that may migrate.” Sample analysis shows that all four ash piles exceed the RALs and pose a threat for both, surface and air migration, through runoff or dust respectively.
• Section 300.415(b)(2)(v): “Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released.” The source of contamination appears to be mainly in the ash piles. One soil sample down gradient from the piles is above the lead RAL. If the ash piles are not removed then significant contamination may migrated past the property boundary.
• Section 300.415(b)(2)(vii) "Availability of other appropriate federal or state response mechanisms to respond to a release." State funds are insufficient. No other governmental entity has funds available to conduct the necessary removal activity.
Due to the threat and/or future threat to human health from the hazardous substance, the Site achieves removal eligibility base on the removal criteria listed above.
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