Between approximately August and November 2007, Southern Iowa Mechanical (SIM) dismantled several buildings on property owned by Dico, Inc. (Dico) located at 200 SW 16th Street, Des Moines, Iowa (Dico property). The Dico property is part of the Des Moines TCE [trichloroethene] site which is listed on the National Priority List (NPL). Some of the buildings dismantled by SIM on the Dico property contained PCB-contaminated insulation in the walls and the ceilings. In 1994, EPA issued Dico a Unilateral Administrative Order (UAO) pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) section 106 requiring Dico, among other things, to repair any damaged insulation and encapsulate and maintain the encapsulated PCB-contaminated insulation. Limited portions of the insulation were too damaged to be repaired and were replaced with new insulation. Most of the insulation was encapsulated in-place in the buildings.
Neither Dico nor SIM provided any notice to EPA that the buildings with PCB-contaminated insulation were going to be dismantled. EPA learned that the buildings were being dismantled on September 19, 2007, when EPA conducted a site inspection related to completion of the five-year review for the Des Moines TCE site. At the time of the site inspection, a building known as the Maintenance Building had already been completely dismantled; two other buildings known as Buildings 4 and 5, the two largest buildings, were partially dismantled. No SIM workers were observed working on the buildings during the site inspection. Dico's representatives indicated that the buildings had been "sold" and would be re-erected at another location.
Various parts of the buildings were taken to different locations for disposition. The steel structural members, which are the subject of this Action Memorandum, were taken to SIM's Ottumwa, Iowa, facility. On May 16, 2008, EPA conducted a site assessment at the SIM site. The site assessment included an inspection of the SIM property and sampling for the purpose of determining whether PCB contamination was present on the beams or in the soil. EPA collected surface wipe samples from the steel beams, soil samples from areas which may receive runoff from the beams, and one bulk insulation sample. Prior to the inspection, EPA prepared and approved a Quality Assurance Project Plan (QAPP) supporting the collection and analysis of surface wipe samples and soil samples. The QAPP was based on EPA's understanding that all the insulation had been removed from the buildings as part of the dismantling process so there would not be any insulation left on the beams to sample. Therefore, EPA did not anticipate collecting samples of bulk insulation. However, when the EPA inspector arrived at the SIM site, he observed that some insulation remained adhered to the beams. EPA decided to use one of the sampling containers (glass jar) prelabeled as a soil sample to collect a bulk insulation sample. The sampling container was appropriate for the collection of a bulk insulation sample, and the same field preservation and handling requirements applied for the bulk insulation sample as would apply for a soil sample.
The steel beams are stored in a large open area on the SIM property and are spread out over an area about one acre in size. In some areas, the beams are stacked on top of wooden supports, but in many areas the beams are in contact with the ground.
Insulation residue is stuck to some of the beams, and what appears to be an adhesive residue is visible on many of the beams. The majority of the surfaces of the beams are coated with a white paint. Beneath the layer of white paint, the beams appear to be coated with a layer of' red paint.
Surface wipe samples from the beams contained PCBs ranging in concentration from non-detect to 370 micrograms per 100 square centimeters (ug/100 cm2). Wipe sampling results were reported in units of ug/cm2 in accordance with EPA Region 7 Standard Operating Procedure 3210. ID, "Extraction of Wipe Samples for PCB Analysis." In order to compare with regulatory levels, the units needed to be converted to ug/100 cm. This conversion was performed by multiplying the lab results (ug/cm2) by a factor of 100. Soil samples from areas beneath the beams contained PCBs ranging from nondetect to 3,100 micrograms per kilogram (ug/kg). The insulation sample contained PCBs (Aroclor 1254) at a concentration of 6,300,000 ug/kg. This result is consistent with historical results of insulation samples collected from the buildings on the Dico property in Des Moines which contained PCBs (Aroclor 1254) up to 29,000,000 ug/kg.
The key problems to be addressed by this potentially responsible party (PRP) lead removal action are the PCB residues remaining on the surfaces of the beams. Results of the limited soil sampling conducted during the site assessment indicate that only one sample exceeded the any-use cleanup standard of 1 part per million (ppm) for soil. Additional soil sampling would be conducted as part of this removal action to determine whether soil removal is necessary.
