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W.R. Grace - Wilder, KY

All POLREP's for this site W.R. Grace - Wilder, KY
Wilder, KY - EPA Region IV
POLREP #2
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On-Scene Coordinator - Brook Bass 11/6/2003
Time-Critical - Removal Action Pollution Report (POLREP) #2
Pollution Report (POLREP) #2
Site Description
  The W.R. Grace Site is located in Wilder, Campbell County, Kentucky.  W.R. Grace ("Grace") owned and operated a vermiculite ore processing facility at 112 North St. from 1960 until the mid-1990's.  Residues from the processing operation were disposed of on the Grace property and an adjoining tract as fill material.  The vermiculite ore and the residues contain actinolite and tremolite asbestos fibers.  EPA Region 8's experience with the Grace facilities in Libby, Montana demonstrates that exposure to this material represents a significant threat to human health.
  In January 2000, Grace notified Kentucky Department of Environmental Protection (KYDEP) of the environmental conditions at the site.  Grace submitted plans to KYDEP to construct a cap on areas where the presence of asbestos-containing material in soil (ACM) had been documented through a previous site investigation.  KYDEP approved Grace's conceptual plans to cap these areas.  However, Grace informed KYDEP in September 2001 that the Chapter 11 bankruptcy filing prohibited Grace from performing any further remedial activities at the site.  In January 2002, KYDEP referred the site to ERRB for consideration as a time-critical removal action.


Current Activities
  On September 4, 2003, the first W.R. Grace Site Public Meeting was held at the Wilder City Building.  Attendance consisted of EPA OSCs Bass and Smith, EPA CIC Wallace, 3 representatives from ATSDR, 3 reps from KYDEP, 2 reps from Campbell County Emergency Management, and approximately 7 residents.  No media was in attendance.  The purpose of this meeting was to discuss the site history, hazards of asbestos, and EPA's proposed activities for the site.

  On Sept. 8, ERRS mobilized to the site and began preparing for site set-up by clearing and grubbing, setting up office, as well as decon and shower trailers, hooking up utilities and creating a decon pad for the T&D trucks leaving the site.  ERRS began clearing and grubbing in the exclusion zone Sept 19.  From this point forward, perimeter and personnel air samples began to be collected on a daily basis, Monday-Friday, to monitor work and site conditions. Trees cleared were chipped and stockpiled for future use as backfill material.  Water was continually sprayed on clearing and chipping operations to control dust.

  On Sept 25, OSC Smith met with Wilder City Officials on-site to discuss potential emergency service response to the site.  On Sept 30, OSC Smith met with KYDEP in Frankfurt, KY to discuss applicable or relevant and appropriate requirements (ARARs).  It was determined that whether or not NESHAP which the KYDEP has adopted, is applicable would depend upon if the planned decontamination of the buildings on-site meets the definition of “renovation”.

  On Oct 2, OSC Smith, ERRS PM, and START saw visual evidence of ACM waste under the CSX spur line, from the SW corner of the site all the way to the manufacturing building.  Excavation activities began on Oct 7 with the areas for the sediment traps and along the spur line.  The sediment traps near the drainage pipe in the bottom of the excavation area are to contain any potential asbestos contaminated run-off from the excavation area.  Once excavated, the path along the spur line  is to be used as the access point into the exclusion zone for the T&D trucks for the duration of the excavation.  The spur line will be replaced at the completion of excavation activities.  START collected composite soil samples from the ditch between the RR tracks and the site retaining wall.  Four composite samples collected, one every 100 feet, from the ditch area.  Wastewater and woodchip pile samples also collected.  Spur line removal completed on Oct 14 and START collected composite grid samples from this area to determine if area is asbestos contaminated.

  During the week of Oct 20, excavation and stockpile activities continued.  Also, preparation of a haul road along the old rail spur continued.  OSC Smith made determination that confirmation sampling would be ineffective until enough waste is moved off-site, in order to avoid re-contamination of the excavated areas.


Planned Removal Actions
  Future removal activities to include continuing to excavate ACM in the exclusion zone and collecting perimeter and personnel air samples.  Also, Transportation and Disposal activities are scheduled to begin Oct 25, 2003.