Pollution Report Profile - EPA OSC Response

Powhatan Mining Company
Woodlawn, MD - EPA Region III
POLREP #24

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On-Scene Coordinator - Jack Kelly	5/21/2011
Time-Critical - Removal Action	Pollution Report (POLREP) #24
Start Date: 8/16/2010

Site Description
The Powhatan Mining Company site is the location of a former asbestos processing facility. The mill operated from approximately 1920 to 1980 primarily processing anthophyllite asbestos.  Asbestos ore for the mill was mined in Maryland until about the 1940s and later brought in from several States including California, Georgia and Alabama. The site is bordered on all sides by residential properties and the residential yards to the southwest lie within feet of the former processing facility and in the path of site runoff.  In 2006, the property to the east of the former mill was  subdivided into residential lots for new home construction. From 2006 to 2008, the residential lots were  cleared and graded and retention ponds were installed. Development ceased after only two homes were constructed.

The former processing facility is a multi-story building with a loading area on the northeast end (cement block portion) and a processing area at the southwest end (rusted metal portion).  The asbestos fiber extraction process took place inside the building complex.  Asbestos ore was reportedly received and first dried in the cement block portion of the complex.  Further processing of the rock ore is believed to have occurred in the metal portion of the facility, a multi-level, timber-framed structure with stone foundation and corrugated metal siding.  In the milling operation believed used at this facility, the asbestos ore was first crushed to a normal, even size and then dried.  Fiber extraction then occurred through a series of crushing operations, each followed by vacuum aspiration of the ore running on a vibrating screen.  On the screen, the fibers were released from the ore and collected into a vacuum system.  Fibers recovered from consecutive vibrating screens were brought to cyclone separators, and the air filtered to remove the finer, suspended fibers.

The property was brought to EPA's attention by the Maryland Dept of the Environment.  After an initial assessment, a non-emergency Removal Action primarily intended to secure building openings was initiated by the OSC in a Special Bulletin dated August 11, 2009.  More recent sampling data and conditions warranted a time-critical action. A time-critical Action Memorandum for the site, concurred on by HQ, was signed on June 8, 2010. In addition, a memorandum authorizing demolition and compensation to the property owner was approved by the Region and HQ on this date.

EPA will be conducting removal activities at the site in order to deconstruct the facility and remove/cover soil which may pose a threat to public health and/or the environment.  During activities which will cause significant disturbance of interior dust or outdoor soils, air samples periodically will be collected from personal sampling devices on cleanup personnel to determine if proper levels of protection are being used at the site.  Additional air samples will be collected along the perimeter of the site to confirm that engineering controls are protective of the surrounding community.

Current Activities
5/9 - OSC arrived onsite 1230.  Subcontractor LVI here and delivered equipment for demolition activities: excavator, backhoe, straps, and miscellaneous. LVI is using ARC Construction Services Inc (ARC) as a sub to perform the demolition work. LVI installed filter fence for runoff control. EPA CRC Taylor onsite and going door to door delivering updated fact sheets. CRC Taylor spoke with six residents.  Community concerns include runoff during demolition activities and possible cleanup if E&S controls fail.  OSC discussed personnel air sampling activities during demolition with the subcontractor.  The OSC had ERRS cover asbestos-containing exposed soil adjacent to the filter fence.

5/10 - Demolition activities began on the building roof.  All tech personnel in Level C PPE. Three hoppers were removed. Half of Bay 1 was demolished.  START conducted air sampling -- four perimeter samplers and personnel pumps on two individuals.  START also performing air monitoring (DATARAM for particulates). The OSC met with a representative from the mortgage holder for the PHD property to go over the geoprobe/sampling report.  She would like to set up a meeting among the County, State, and EPA to discuss what would be required before any building could proceed on that property.  The OSC checked in with the property owner regarding demolition activities.

5/11 - Demolition activities continued.  A minor release from a pipe occurred during demolition.  The pipe was placed on the ground, sprayed thoroughly with water and contained for disposal.  START conducted air sampling and monitoring throughout the day.  The OSC adjusted sampling locations for greater bias towards adjacent residential properties.  EPA and ERRS slowed down demolition activities in order to mitigate the chance for releases.

5/12 - Demolition activities continued.  Former garage portion (cinder block)of the facility completely demolished.  START conducted perimeter and personnel air sampling, adding an additional perimeter sampler near the support zone.  Personnel samples received from 5/10/11 recorded levels above the OSHA PEL.  In order to reduce localized emission concentrations, an excavator or crane with a longer reach, increased wetting of material, and additional preparation of areas to be demolished will be conducted.   A meeting was held among all involved parties in the trailer to discuss work progress, forecast, and need for modifications.

5/13 - The OSC discussed demolition activities and approach with OSC Wenning who will be onsite for a few days (OSC Kelly has earlier scheduled work in Philadelphia).  Demolition activities continued.  START conducted air sampling and monitoring  activities.  ARC/LVI began tearing off metal skin from former processing side of the facility.

5/16 - OSC Wenning onsite.  Demolition activities continued.  START conducted air sampling and monitoring activities. .

5/17 - OSC Kelly onsite 1330.  Demolition activities continued, focusing on waste clearance.  START conducted air sampling/monitoring activities.  Resident called the OSC with concerns regarding demolition activities, a meeting was scheduled for 5/19.

5/18 - Demolition activities continued, focusing on waste clearance.  Rolloff container of waste transported offsite.  START conducted air sampling/monitoring activities. Electrician onsite with Rasche Bros to discuss upcoming activities.  OSC directed START to prepare a table of air sampling results to send to ATSDR for review.

5/19 - Demolition activities continued, focusing on waste clearance. START conducted air sampling/monitoring activities.  OSC met with the property owner regarding erosion control on the back of his property.  OSC sent sampling results to ATSDR for review, who reported no concerns.  OSC and START met with a resident to discuss demolition activities and future yard cleanup work. The OSC and ERRS RM met with ARC about personal protective equipment recommendations for employees.

5/20 - OSC adjusted air sampling locations.  Demolition activities continue, focused on peeling off the metal sheeting on the building and then removing structural components. Water spraying constantly. START conducted air sampling/monitoring activities.  EPA and ARC compared personnel air results.  Significant differences found. Based on EPA results, all workers stay in Level C.  The OSC informed Weston PE to submit the revised E&S/Storwater control application to MDE.  Rasche Bros here in force and completes all truss work.  START submits revised MDE stormwater application.  The OSC met with the property owner regarding ongoing work.

5/21 - ERRS conducted general cleanup operations onsite.  Demolition contractors not onsite. The OSC submitted a draft revised Action Memorandum, cover letter and enforcement memo to EPA management and ORC for concurrence. Additional funding needed for sampling activities.

Planned Removal Actions
- Continue demolition.
- Continue garage construction.

Disposition Of Wastes
Friable and Non-Friable asbestos-containing waste (ACM) has been disposed of. This includes porous, contaminated personal items and demolition waste. Beginning in late July, asbestos-contaminated soil will be disposed of.

Approximately twenty 30 cu yd containers of concrete were sent off for recycling to Machado Construction primarily from May 13 to June 6 after demolition.

The demolition subcontractor arranged for the recycling of approximately ten containers of scrap steel.

Personal "white good" items that were cleaned of asbestos but identified as not needed by the owner were sent off to the local county landfill for disposal.

Waste Stream	Quantity	Manifest #	Disposal Facility
Asbestos from interior cleaning	40 cu yds	057176	Old Dominion Landfill, Richmond, VA 10/16/10
Asbestos from interior cleaning	40 cu yds	057177	Old Dominion Landfill, Richmond, VA 11/11/10
Asbestos from interior cleaning	40 cu yds	057178	Old Dominion Landfill, Richmond, VA 12/17/10
Asbestos " "	1.92 tons	057183	Old Dominion Landfill, Richmond, VA 02/24/11