Pollution/Situation Report Profile

Hemlock Street Battery Site
Tampa, FL - EPA Region IV
POLREP #3
TECO Begins Off-site Disposal

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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Hemlock Street Battery Site - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV

Subject:

POLREP #3
TECO Begins Off-site Disposal
Hemlock Street Battery Site
B4E8
Tampa, FL
Latitude: 27.9377824 Longitude: -82.4376082

To:

Jim Webster, USEPA R4 ERRB

From:

Chuck Berry, On Scene Coordinator

Date:

5/14/2013

Reporting Period:

May 4 - May 10, 2013

1. Introduction

1.1 Background

Site Number:	B4E8	Contract Number:
D.O. Number:		Action Memo Date:
Response Authority:	CERCLA	Response Type:	Time-Critical
Response Lead:	EPA	Incident Category:	Removal Assessment
NPL Status:	Non NPL	Operable Unit:
Mobilization Date:	11/17/2009	Start Date:	9/1/2009
Demob Date:	11/20/2009	Completion Date:
CERCLIS ID:	FLN000410641	RCRIS ID:
ERNS No.:		State Notification:
FPN#:		Reimbursable Account #:

1.1.1 Incident Category
Time-Critical Removal Action

1.1.2 Site Description
Hemlock Street Battery Site (the Site) abuts the former Musselman Steel Corporation, formerly Musselman Steel Fabricators, Inc. (Musselman Steel). The site is currently owned by TECO Energy, a local utility corporation, and is part of their overhead transmission lines.

The area around the site is a mix of heavy industrial/commercial industries of Tampa which has extensive rail yards, port terminals, and above ground storage tank (AST) farms. Homes are located approximately 300 feet northeast of the Site, but a group of homeless men live directly next to the site, in a dilapidated corrugated tin shack.

1.1.2.1 Location
The Site is located at 1710 South 20th Street in Tampa, Hillsborough County, Florida. The Site is located on Hookers Point, a peninsula bound by McKay Bay to the east, Sparkman Channel to the west, and Hillsborough Bay to the south.

1.1.2.2 Description of Threat
The site is covered with a layer of lead-contaminated soil and debris from an illicit battery-cracking operation. The majority of contaminated soil remains within a poorly maintained fenced area with at least one observed breach that could be accessed by trespassers who may become exposed to the soil. Anyone entering the Site may be exposed via inhalation of airborne dust, inadvertent ingestion of contaminated soil, and direct contact with the contaminated surface soils. Off-site migration of lead via erosion or airborne dust may lead to the exposure of nearby residents.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

In April 1992, the Environmental Protection Commission of Hillborough County (EPC) received an anonymous complaint regarding the Musselman Steel Site. During an investigation by EPC, large amounts of solid waste including empty drums and crushed battery casings were observed throughout Site. These battery casings extended onto the TECO-owned property.

During the week of November 17, 2009, the United States Environmental Protection Agency (EPA) Region 4 On-Scene Coordinator (OSC) and Superfund Technical Assessment and Response Team (START) began a Removal Site Evaluation (RSE) of Hemlock Street Battery Site. All activities were undertaken pursuant to Section 300.410 of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The purpose of the RSE was to delineate previously identified lead and arsenic contamination in the soil. A portable x-ray fluorescence (XRF) instrument was employed during field screening down to a maximum depth of 12 inches below ground surface (bgs).

Soil was screened for lead and arsenic at a total of 22 (11 surface and 11 subsurface) locations from 2 grids. Four samples were submitted to a laboratory for XRF confirmation purposes.

Confirmatory laboratory results for lead ranged from 2,250 mg/kg to 23,100 mg/kg. Analytical results for lead exceeded EPA’s industrial/commercial removal action level (RAL) for lead of 2,000 mg/kg.

Confirmatory laboratory analytical results for arsenic ranged from 3.5 mg/kg to 18.8 mg/kg. The analytical results for arsenic did not exceed EPA’s industrial/commercial removal action level (RAL) for arsenic of 177 mg/kg.

In 2010, EPA initiated a fund-lead CERCLA removal action on the Musselman Steel property. However, the TECO property was not included in the scope of the fund-lead removal.

2. Current Activities

2.1 Operations Section

2.1.1 Narrative

2.1.2 Response Actions to Date
On April 15, TECO mobilized Envirotek (construction crew) and ECT (technical consultant) to the site to remove soil with lead levels greater than 1,400 milligrams per kilogram (mg/kg). Envirotek's first task was to remove the debris scattered throughout the site. Envirotek used an excavator and skid-steer to remove and carry debris to several piles. Envirtex also built a containment area for mixing amendment with contaminated soil. After viewing the site set up, OSC Berry requested ECT place dust monitors at the east and north fence-lines, where the property abuts neighboring active parcels.

During the week of April 22, Envirotek excavated 2 cells, B3 and C3 and treated with stabilizing agent. The excavation depth ranged from 1 to 1.5 feet below the approximate ground surface. Lead levels in the exposed soil were 111 and 506 mg/kg based on XRF readings of 5-point confirmation samples. During debris segregation, Envirotex spoke with the disposal facility and realized that segregation of attached soil particles was needed. A rotating screen was brought on site to further separated the soil from the debris. The segregated debris will be disposed of separately from the soil. During debris removal and segregation, it was noted that the large amount of debris actually constituted a considerable volume and removal altered the the original ground surface. It was agreed that any removal to a certain depth would be based on the soil level after debris removal

During the week of April 29, crews completed debris segregation. Approximately 500 cubic yards of debris were generated, and the parts heavily laden with battery chips were set aside for intensive treatment prior to sampling for off-site disposal. Currently, the piles have been sampled, and Envirotek is awaiting sample results.

During the week of May 6, Envirotek received TCLP results for some of the soil and debris piles. All of the soil passed the test for non-hazardous compliance, but about half of the debris required further treatment or segregation. TECO began shipping off material this week, and transferred approximately 390 tons of soil to the landfill during the week.

During the week of May 13, TECO continued to excavate, treat, and transport material to the landfill, shipping off another 547 tons. Excavation progress by the end of the week was at approximately 75% of the areal extent based on pre-excavation planning maps. Some of the debris which passed TCLP testing was shipped off site, and those amounts are included in the totals below.

For the reporting period ending May 17, 2013, TECO has excavated 1325 cubic years of soil and debris and treated 1200 cubic yards. An estimated 125 cubic yards remains to be treated with diammonium phosphate prior to sampling. TECO's contractor has shipped 937 tons of material to the landfill. Several debris piles remain on site, and TECO plans to re-screen the material to remove the contaminated soil still left behind from the first attempt, resample for disposal compliance, and treat, if necessary.

Air monitoring and sampling continued to indicate no fugitive off-site emissions, and no workers were required to apply respiratory protection at any time during the removal action.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
TECO has been identified as a PRP based on their ownership of the property. It is not believed TECO caused the contamination to be released. TECO signed an AOC in 2012 and has agreed to perform the removal action. Under the terms of the AOC, TECO will remove lead-contaminated soil from the property until the levels are below 1,400 mg/kg or a total excavated depth of 2 feet bgs has been achieved. Any areas with lead levels above 1,400 mg/kg at the 2-foot bgs level will be covered with 2 feet of clean backfill.

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal

Non-Haz Soil and Debris
Soil/Debris 937 tons

Tires
Tires 124

2.2 Planning Section

2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities
TECO's contractors will continue to excavate contaminated soil using XRF to guide the excavation. TECO has also agreed to dig past the 2-foot depth where battery chips or casings are present, on a case-by-case basis, as these areas are identified. TECO will re-screen the impacted debris and retest it for disposal compliance.

2.2.1.2 Next Steps
-- Remove contaminated soil to below 1,400 mg/kg or until 2 feet bgs is achieved
- Treat excavated soil
- Sample stockpiles and re-treat, if necessary
- Dispose of treated soil at Subtitle D landfill
- Backfill areas with >1,400 mg/kg lead with at least 2 feet of clean fill.

2.2.2 Issues
TECO's surveyors identified two swaths of property on the north and south sides of the lot that were identified as City of Tampa property for a planned street (at one time the area was planned for a residential subdivision). There was some confusion as to the actual ownership of the property, with the City claiming TECO still owns the land and TECO unsure of it's legal obligation and authority to perform the removal action. EPA's lawyers worked with TECO and City officials to resolve the issue. TECO has assumed control of the 25-foot section to the south and has agreed to excavate the entire 10-foot area to the north under its access agreement with the current property owner.

TECO's contractor is having difficulty treating and clearing the debris for nonhazardous disposal. The debris will be screened again to remove the remaining soil, and a new samples for TCLP testing will be obtained.

2.3 Logistics Section