Pollution Report Profile - EPA OSC Response

Powhatan Mining Company
Woodlawn, MD - EPA Region III
POLREP #32

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On-Scene Coordinator - Jack Kelly	9/3/2011
Time-Critical - Removal Action	Pollution Report (POLREP) #32
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 occured 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
8/22 and 8/23 - OSC Kelly not onsite due to family priority. EPA internal finance audit commenced at the site on 8/23 to last until 8/25. Each year in Region III a removal site is selected for a field audit,  Two EPA Field Accountants present and two individuals from the EPA Finance Program (auditors). Additional funding for START processed (see POLREP 29).

8/24 - ERRS crew working on bio-retention system, stockpiling contaminated soil for disposal, and grading the former facility footprint. The OSC and site Field Accountant answered questions posed by the auditors.

8/25 - Asphalt bidder arrived to discuss area to be covered (only one showed interest). ERRS RM discussed specifics with the owner.  ERRS adding rip-rap around the top of the bio retention system for stability (Weston PE agreed). ERRS continues soil stockpiling and grading. EPA contracting officer (CO) processed additional funds from the Action Memo approval to amend the ERRS task order. Funding ceiling is now $2,725,000.00. The OSC and site Field Accountant answered auditors' questions.

8/26 - Weston PE onsite to view the bio-retention system and discuss plans for the area behind the old facility and behind and adjacent to the owner's home.  He is pleased with the bio retention system.  The OSC, ERRS RM and Weston PE agreed on what will be an effective erosion control in the area mentioned; mainly top soil and sod will be placed after excavation of top approximately 6" of contaminated soil.  Stone will be placed behind the house kitchen. The trench drain is slightly cracked;   ERRS repairing. ERRS placing filter fence down in anticipation of Hurricane Irene.

The owner asked if we could reduce the slope of the vegetated bank below the driveway.  Weston PE said we cannot for stability reasons (and the OSC cannot as the work was completed weeks ago). The owner upset because the check he received from LVI Inc. for scrap steel did not clear. The ERRS RM called LVI.  LVI said the problem will be resolved by tomorrow. The OSC informed the owner.  The OSC and site Field Accountant attended a closure meeting with the auditors.

8/27 -  Due to the approach of Hurricane Irene, ERRS is taking measures to protect the bio retention system. The OSC emailed the Pastor of the adjoining church property to let him know where asphalt will be placed as there is a right of way between the cul de sac and the owner's property.  The OSC sought alternatives from co-workers for addressing lawn watering once residential yards are sodded.

8/29 -  The OSC in Philadelphia all day for meetings and administrative work.  Hurricane Irene arrived over the weekend. The only problem at the site was loss of electrical power.

8/30 - Generator in use for electricity.  The ERRS crew grading the old footprint and beginning to lay down clean soil and grass erosion blankets on specific areas of the former building footprint. Orange warning fence was placed on the ground before new soil and grass blankets were laid.

The OSC and ERRS RM discussed and agreed on asphalt thickness (3"). This thickness determined to be sufficient for a property zoned residential. Asphalt is only being placed on the portion of the site that will receive constant vehicle traffic as it will provide the most effective and permanent cover.  Other areas will receive stone or additional soil with grass or sod.

8/31 - ERRS continues grading, laying stone and clean fill, laying grass blankets and watering. START here to assist the OSC with administrative paper work. The selected asphalt bidder went over work details with the owner. Electric power restored in the evening.

9/1 -  The OSC and ERRS went down to the residential yards and collected measurements for costing. The OSC took photos of the tree-covered yard areas near the border with the old facility as a low-lying ground cover of some type will be needed here after grubbing.  The OSC discussed possibilities with BTAG coordinator BPluta and USFWS KPatnode given their knowledge of plant characteristics. Both provided the OSC with possible alternatives. The OSC obtained photos of each potential ground cover type for llater discussion with residents. The OSC spoke with one resident about the need to remove a dying, small conifer tree.

9/2 and 9/3 -  The ERRS crew continues grading, stone and clean fill placement, laying of grass blankets. The ERRS RM and OSC discussed future schedule of activities.  The crew will demobe 9/3 and return on 9/12.

....Nine additional truckloads of contaminated soil transported offsite for disposal this reporting period.

Planned Removal Actions
- Continue to transport and dispose of stockpiled contaminated soil.
- Complete placement of clean fill and grass blankets over former processing facility footprint.
- Begin to move to area behind and adjacent to owner's home just above residential yards for excavation and sodding.
- Asphalt the identified area.

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Disposition Of Wastes
Below values are all rough estimates for

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	20.32 tons total	057176, 057177, 057178	Old Dominion Landfill, Richmond, VA
Asbestos	1.92 tons	057183	Old Dominion Landfill, Richmond, VA
Asbestos from demolition	114.19 tons total	Tracking Numbers 1 through 19	Cumberland County LF, Shippensburg, PA
Asbestos (mainly from interior cleanup)	~ 30 cu yds	Tracking Number 20	Cumberland County LF, Shippensburg, PA
Asbestos contaminated soil	~ 23 tons EACH 996.38 tons total	Tracking numbers 001 through 043 transported from 7/22 to 8/30	Modern/Republic Landfill, York, PA