U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Liberty Fibers - Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV
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Subject:
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POLREP #18
ACM Debris Removal Continues
Liberty Fibers
B457
Morristown, TN
Latitude: 36.1493481 Longitude: -83.2048083
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To:
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James Webster, ERRB Reg 4
Brenda Apple, TDEC
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From:
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Karen Buerki, On-Scene Coordinator
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Date:
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8/8/2013
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Reporting Period:
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9/29/12 to 12/31/12
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1. Introduction
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1.1 Background
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Site Number: |
B457 |
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Contract Number: |
EP-S4-07-02 |
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D.O. Number: |
0115 (Mod. 008) |
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Action Memo Date: |
9/26/2012 |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
4/21/2010 |
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Start Date: |
4/21/2010 |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
TNN000410507 |
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RCRIS ID: |
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ERNS No.: |
NRC 937191 |
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State Notification: |
4/21/2010 |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Time-Critical Removal Action
The scope of work for this action is the removal of Asbestos-Containing Material (ACM) debris and deteriorated Thermal System Insulation (TSI), consolidation and disposal of containers of hazardous waste and hazardous materials, modification of the reservoir dam to prevent retention of more than 30 acre-feet of water, demolition of what remains of the Power House and disposal of the resulting ACM debris, and capping and closure of the Class III Landfill.
1.1.2 Site Description
The Liberty Fibers Site (Site) is approximately 230 acres of the American Enka/BASF Corporation textile plant located in the Lowland Community. It began manufacturing Rayon in 1947. It is bordered to the north by a Norfolk Southern railroad line and a small residential neighborhood; to the east by a landfill and a retention pond; to the south by the former Nylon Staple Plant; and to the west by Enka Highway and farmland. The topography of the Site is relatively flat. Drainage is to Flat Creek and the Nolichucky River.
1.1.2.1 Location
The Site is located at 4901 Enka Highway (State Route 160), Morristown, Hamblen County, Tennessee. The geographic coordinates for the Site are 36.15580 degrees north latitude and -83.20645 degrees west longitude.
1.1.2.2 Description of Threat
Exposure to friable asbestos is the primary threat. The Site is covered in piles of demolition debris interspersed with friable asbestos and has tens of thousands of linear feet of pipe wrapped in deteriorated asbestos-containing TSI throughout. The Site is not secure as evidenced by almost routine trespass. There are businesses operating in the buildings surrounding the Site and several residential properties adjacent to the Site.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
A Multimedia Inspection was conducted March 20-21, 2008. EPA inspected the Site again on December 3-4, 2009, and a Removal Site Evaluation was performed on January 18-22, 2010. On April 19, 2010, Hot Work (cutting torch) activities initiated a fire along the southern perimeter of the Site. EPA and The Morristown Fire Department responded. OSC Perry Gaughan requested that EPA Region 4 Technical Services Section evaluate asbestos sampling results from January 2010 to determine if a threat to human health and the environment exists on Site. OSC Perry Gaughan concluded that the threat exists, served the owner with a Notice of Federal Interest, and initiated an emergency response action.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
Removal of ACM debris and glove-bagging every 20 feet and plastic wrapping of the elevated pipe runs throughout the Site and within the partially demolished Rayon Filament Warehouse that are identified as asbestos-containing TSI continues. An asbestos abatement subcontractor was hired to supplement CMC's work on the elevated pipe runs.
2.1.2 Response Actions to Date
During this period:
CMC resumed moving ACM from basement sub-structures to the landfill.
START collected accumulated groundwater samples from on-site basement sub-structures on October 12, 2012.
START completed mapping of property boundaries for Lowland Industrial Complex, LLC, according to the survey description in the property deed. Some overhead pipe encased in deteriorated TSI on the south side of the Site was discovered to be outside the previously recognized property boundary.
CMC deconned drums and containers and staged them outside the asbestos exclusion zone for sampling and bulking activities.
CMC continued removing ACM from vegetated areas of the Site. START continued visual inspection and clearance of grids.
START sampled visually stained soil for PCBs in Grid H-7.
CMC began ACM and debris removal within the partially demolished Rayon Filament Warehouse on
November 7, 2012.
CMC's asbestos abatement subcontractor began glovebag work in the partially demolished Rayon Filament Warehouse on November 28, 2012.
CMC continued removal ACM from trenches and shallow channels around foundations. Removal of debris from basement sub-structures limited to material above the groundwater level on December 20, 2012.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
PRPs have been identified and enforcement is ongoing.
2.1.4 Progress Metrics
Note: Volumes or weights are estimates due to the natue of the material. The number of articulated dump loads of ACM transported to the landfill is tracked on a daily basis.
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| Asbestos-Containing Material (ACM) |
Demolition Debris |
6,019 loads |
N/A |
N/A |
Class III Landfill On-Site
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| Bagged ACM (Electrial Equipment Building) |
Friable asbestos insulation from previous abatement activity |
20,520 bags |
N/A |
N/A |
Class III Landfill On-Site
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Glove-Bagged TSI
CMC |
Overhead Pipe Runs |
289 bags |
N/A |
N/A |
Class III Landfill On-Site
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Glove-Bagged TSI
NEO Corporation
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Overhead Pipe Runs |
718 bags |
N/A |
N/A |
Class III Landfill On-Site |
| Recycleable |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| Scrap Metal |
Rebar and structural steel from demolition activity |
636 loads |
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Recycle
Tennessee Metals Company
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2.2 Planning Section
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2.2.1 Anticipated Activities
2.2.1.1 Planned Response Activities
ERRS' asbestos abatement subcontractor will continue to wrap and glove bag TSI on the elevated pipe runs.
ACM debris will continue to be removed from below-grade basement structures and disposed of in the on-site landfill.
ACM debris on the surface and within the partially demolished Rayon Filament Warehouse will continue to be removed and disposed of in the on-site landfill.
TSI will be removed from the afterburner.
Containers of hazardous materials will be staged, haz-catted, sampled, and disposed of off-site.
The partially demolished Power House will be demolished and ACM disposed of in the on-site landfill.
The reservoir dam will be modified to allow for no more than 30 acre-feet of water retention.
The natural gas pipeline will be restored.
The on-site landfill will be capped and a vegetative cover established.
2.2.1.2 Next Steps
Explore AOC options with adjacent property owners, Jolley-Rock, LLC, and Paint Oak, LLC.
2.2.2 Issues
There is a nest of an unidentified bird of prey on top of a portion of the Power House. Prior to demolition, not only will the City of Morristown need to condemn the remaining structure, but, the bird needs to be identified and the Migratory Bird Treaty Act applicability determined.
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2.3 Logistics Section
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No information available at this time.
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2.4 Finance Section
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2.4.1 Narrative
CERCLA Section 104(b) investigatory costs are not counted against the Site ceiling in the Action Memoranda, however, they are cost recoverable.
TTEMI-05-003-0041 $20,000 3/18/2008
TTEMI-05-003-0041 Mod. 1 $107,781 1/20/2010
TTEMI-05-003-0041 Mod. 2 $92,781 8/25/2011
TTEMI-05-003-0041 Mod. 3 $91,573 1/15/2013
TTEMI-05-003-0041 Mod. 4 $91,572.29 3/13/2013
An Emergency Response was initiated under OSC Perry Gaughan's warrant authority to stabilize and secure the Site. The Site ceiling is $250,000. Task Order No. 0704-F4-0082 was issued to Environmental Restoration, LLC, in the amount of $200,000 and TDD No. TTEMI-05-001-0126 was issued to Tetra Tech EM, Inc., in the amount of $30,000.
A Verbal Ceiling Increase and Change of Scope for Response was signed on September 7, 2010. The new Site ceiling is $450,000. The new ERRS ceiling is $400,000 and the START ceiling remains unchanged at $30,000.
A Ceiling Increase for Continuation of a Removal Action was signed on December 16, 2010. The new Site ceiling is $582,000. The new ERRS ceiling is $520,000 and the START ceiling remains unchanged at $30,000.
ERRS - Environmental Restoration, LLC: (initiated April 21, 2010)
Task Order No. 0704-F4-0082 $200,000
Task Order No. 0704-F4-0082 Mod 1 $300,000
Task Order No. 0704-F4-0082 Mod 2 $400,000
Task Order No. 0704-F4-0082 Mod 3 $485,000
Task Order No. 0704-F4-0082 Mod 4 $520,000
Task Order No. 0704-F4-0082 Mod 5 $552,000
Task Order No. 0704-F4-0082 Mod 6 $564,000
START - Tetra Tech EM, Inc.
TDD No. TTEMI-05-001-0126 $30,000 4/26/2010
A Ceiling Increase and Exemption from the Twelve Month Statutory Limit and $2 Million Exemption for a Time-Critical Removal Action was prepared by OSC David Andrews and approved on June 30, 2011. The new Site ceiling is $3,057,000. The new ERRS ceiling is $2,520,000 and the new START ceiling is $180,000. The ERRS contractor was changed from Environmental Restoration, LLC, to CMC. Environmental Restoration, LLC, maintained security on site through August 15, 2011.
ERRS - CMC, Inc.
Task Order No.0702-F4-0115 $925,000 7/25/2011
Task Order No.0702-F4-0115 Mod 1 $1,900,000 8/11/2011
Task Order No.0702-F4-0115 Mod 2 $1,974,195 9/20/2011
Task Order No.0702-F4-0115 Mod 3 $2,274,195 2/08/2012
START - Tetra Tech
TDD No. TTEMI-05-001-0126 Mod. 1 $100,000 9/26/2011
TDD No. TTEMI-05-001-0126 Mod. 2 $115,000 2/07/2012
TDD No. TTEMI-05-001-0126 Mod. 3 $131,000 2/14/2012
TDD No. TTEMI-05-001-0126 Mod. 4 $180,000 3/05/2012
A Ceiling Increase and Change in Scope Action Memorandum was prepared by OSC David Andrews and approved on March 19, 2012. The new ERRS ceiling is $4,733,195 and the new START ceiling is $370,000.
ERRS - CMC, Inc.
Task Order No.0702-F4-0115 Mod. 4 $3,174,195 3/20/2012
Task Order No.0702-F4-0115 Mod. 5 $4,124,195 5/29/2012
Task Order No.0702-F4-0115 Mod. 6 $4,124,195 9/14/2012 POP
Task Order No.0702-F4-0115 Mod. 7 $4,538,695 9/21/2012
START - Tetra Tech
TDD No. TTEMI-05-001-0126 Mod. 5 $250,000 4/26/2012
TDD No. TTEMI-05-001-0126 Mod. 6 $306,852 6/18/2012
TDD No. TTEMI-05-001-0126 Mod. 7 $370,000 7/18/2012
TDD No. TTEMI-05-001-0126 Mod. 8 $420,000 9/07/2012
TDD No. TTEMI-05-001-0126 Mod. 9 $450,000 11/16/2012
A Ceiling Increase and Change in Scope Action Memorandum over $6,000,000 was prepared by OSC Karen Buerki and approved by EPA Headquarters on September 26, 2012. The new ERRS ceiling is $9,802,695 and the new START ceiling is $770,000.
ERRS - CMC, Inc.
Task Order No.0702-F4-0115 Mod. 8 $5,996,943 9/28/2012
START - Tetra Tech
TDD No. TTEMI-05-001-0126 Mod. 10 $469,900 12/21/2012
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Budgeted |
Total To Date |
Remaining |
% Remaining |
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Extramural Costs
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| ERRS - ER,LLC |
$564,000.00 |
$564,000.00 |
$0.00 |
0.00% |
| ERRS - CMC, Inc. |
$5,996,943.00 |
$5,693,451.04 |
$303,491.96 |
5.06% |
| IAGs - Bureau of Reclamation |
$40,000.00 |
$0.00 |
$40,000.00 |
100.00% |
| START- Tetra Tech |
$469,900.00 |
$457,409.94 |
$12,490.06 |
2.66% |
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Intramural Costs
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| USEPA - Direct |
$120,000.00 |
$60,400.00 |
$59,600.00 |
49.67% |
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| Total Site Costs |
$7,190,843.00 |
$6,775,260.98 |
$415,582.02 |
5.78% |
* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.
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2.5 Other Command Staff
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2.5.1 Safety Officer
OSC Karen Buerki (Lead) and OSC Terrence Byrd (Alternate)
2.6 Liaison Officer
N/A
2.7 Information Officer
N/A
2.7.1 Public Information Officer
N/A
2.7.2 Community Involvement Coordinator
Kyle Bryant
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3. Participating Entities
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3.1 Unified Command
N/A
3.2 Cooperating Agencies
TDEC Department of Solid Waste, Knoxville Office, has been consulted on the design of the Class III on-site landfill.
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4. Personnel On Site
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As of December 31, 2012:
1 EPA OSC Karen Buerki
1 EPA ERT Greg Powell
1 START Paul Prys or Bryan Erickson with Tetra Tech EM, Inc.
ERRS - CMC, Inc.
1 Project Manager
1 Field Clerk
9 Equipment Operators
1 Laborer
NEO Corporation
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5. Definition of Terms
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No information available at this time.
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6. Additional sources of information
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No information available at this time.
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7. Situational Reference Materials
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No information available at this time.
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POLREP #18 Last Updated 5/17/2016
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