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Kentucky Wood Preserving

All POLREP's for this site Kentucky Wood Preserving
Winchester, KY - EPA Region IV
POLREP #4 - Removal of Wood Debris Completed
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On-Scene Coordinator - Art Smith 8/6/2007
Time-Critical - Removal Action Pollution Report (POLREP) #4
Start Date: 7/18/2007
Pollution Report (POLREP) #4
Site Description
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 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 $250,000.



Current Activities
Various removal activities have taken place during the reporting period from 07/30/07 to 8/5/07 and are as follows:

• ERRS subcontractor Red River Ranch set-up wood grinding machine on site.
• Wood grinding activities began on 7/30/07 and were completed on 8/03/07.
• ERRS loaded semi-tractor trailers with wood chips for off-site disposal; a total of 55 tractor trailer loads were transported off site.
• ERRS crews implemented dust suppression measures in the work zone during grinding activities.
• ERRS loaded treated wood poles into dump trucks for off-site disposal; a total of 4 truckloads were transported off site.
• ERRS began personnel biomonitoring for arsenic.
• ERRS and START collected air samples for arsenic analysis; analytical results indicated that arsenic was not detected above the action limit of 0.01 milligrams(mg)per cubic meter.  
• ERRS and START performed continuous air monitoring for particulates; the maximum particulate reading observed in the work zone was 1.122 mg/cubic meter.
• ERRS crews cleared trees and brush along the railroad.
• ERRS received waste disposal results from samples collected from tanks for pH and TCLP. ERRS is still awaiting a decision from Arch Chemical as to whether they will accept the chemicals on site for reuse or not.


Planned Removal Actions
During the week of 8/6/2007, work activities are expected to include the following:

• ERRS will install a chain link fence around the site perimeter for additional security.
• ERRS will research disposal and treatment options for chemicals on site.
• ERRS will compile a list of small-containers and get an estimate for disposal.


Next Steps
- START will prepare a Sampling Work Plan, detailing the scope of a comprehensive investigation designed to characterize the nature and extent of contamination at the site.
- ERRS to complete analysis of removal and treatment options for CCA solutions.


Key Issues
Interim demobilization of EPA, ERRS and START resources is tentatively planned for the week of 08/13/07, until such time as plans for disposal/treatment of CCA solutions are finalized.