U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Copiah County Manufacturing - Removal Polrep
Initial Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV
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Subject:
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POLREP #4
Initial POLREP for Time Critical Removal Action
Copiah County Manufacturing
B4H9
Hazlehurst, MS
Latitude: 31.8719088 Longitude: -90.3836203
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To:
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Phillip Weathersby, MSDEQ
Jim Webster, USEPA R4 ERRB
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From:
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Matthew Huyser, On-Scene Coordinator
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Date:
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1/14/2014
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Reporting Period:
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9/12/2013 - 1/11/2014
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1. Introduction
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1.1 Background
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Site Number: |
B4H9 |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
9/12/2013 |
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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: |
1/6/2014 |
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Start Date: |
1/6/2014 |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
MSD000824961 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Time-critical removal action.
1.1.2 Site Description
The Copiah County Manufacturing Site (the “Site”) is a former wood treating facility that utilized both pentachlorophenol (PCP) and copper chromium arsenate (CCA) preservatives during its operation from 1968 to 1995.
The facility used by the Copiah County Manufacturing Company (CCM) was constructed by a preceding company and was operated as a saw mill. CCM purchased the facility and began wood treatment operations in 1968; operations primarily utilized just 6 acres of the 23 acre property. Treatment with pentachlorophenol was discontinued in 1980 and all wood treating operations ceased in 1995. CCM continued to operate a lumber retail outlet at the Site until it was closed in 2001 and it has remained closed since that time. Structures remaining at the Site include the former treatment building, drying kiln, three former wood storage buildings, an office, and a large storage shed. There is also a 0.8-acre surface impoundment on the property that was closed in 1983.
Wooded areas of the site have been commercially clear-cut for pulp material as recently as 2013. Aboveground storage tanks at the preservative storage building have been removed for steel recycling as recently as 2012.
In 1980, CCM notified EPA it was a RCRA hazardous waste generator and treatment, storage, and disposal (TSD) facility but subsequently requested to rescinded the application on the basis that hazardous wastes were no longer stored more than 90 days. The Mississippi Department of Environmental Quality (MDEQ) approved the request in 1982. Also in 1982, MDEQ sampled effluent at CCM that was entering the 0.8-acre surface impoundment and found elevated levels of arsenic, chromium, and copper; MDEQ required the facility to either install groundwater monitoring wells or close the impoundment. CCM elected to close the impoundment, removing the wastewater and excavating the impoundment. MDEQ approved the closure in 1984.
In 1983, the facility reported a release of 800 to 900 gallons of CCA solution. The liquid flowed into a central drainage ditch and subsequently into a tributary of Bahalia Creek. The pooled CCA solution was removed with a vacuum truck and contaminated soil was excavated. The day after, sampling was conducted along the spill route and results showed no significant CAA contamination.
In 1993 MDEQ informed CCM that the facility must either petition for clean closure equivalency or apply for a post-closure permit for the closed surface impoundment. CCM chose to petition and installed three groundwater monitoring wells. Based on data from four rounds of sampling and other information submitted by the facility, the MDEQ approved clean closure equivalency in 1996.
In 1996, EPA notified CCM of its intent to perform a RCRA Facility Assessment (RFA), recommending investigations of 4 Solid Waste Management Units (SWMUs): 1) the drip pad area; 2) a pile of soil that was excavated from the drip pad area; 3) a scrap pile; and, 4) the stormwater drainage ditches; and investigations of two Areas of Concern (AOCs): 1) the area of the CCA spill; and, 2) an area where an abandoned tank was found during the VSI. In order to determine the nature and extent of the contamination at the facility, EPA issued RCRA § 3013 Administrative Order requiring the facility to investigate the SWMUs and AOCs. CCM submitted a Sampling and Analysis Plan (SAP) in 1997 proposing a three-phased investigation: surface soil sampling followed by subsurface sampling and then groundwater monitoring. The EPA approved the SAP in 1998. In 1999, the Phase 1 Confirmatory Sampling Report found arsenic in quantities above Regional Screening Levels (RSLs) for industrial soils. In addition, significant concentrations of PCP were found at the Site. In 2001, the EPA and MDEQ attempted an inspection of the Site and found that the facility was closed.
1.1.2.1 Location
The Site is located at 600 Georgetown Street, Hazlehurst, Copiah County, Mississippi. The geographic coordinates of the Site are 31.8719088o North and 090.3836203o West.
The Site is bordered by Georgetown Street to the north and northwest. Single family residences line the opposing side of the street from the Site and more residences are located immediately adjacent to the Site on the west and southwest. Neighborhood children gather at a school bus stop which has been established at the front gate of the Site on Georgetown Street.
A high voltage power line easement dissects the property just east of the main structures of the facility. The east side of the property is vegetated with large trees as is the south border of the property. The main area where the facility operated remains mostly un-vegetated, with dirt roads and wide barren areas prone to dust generation.
Drainage from the Site flows to the south and along the property boundary to the power line easement and a total of 600ft to an intermittent tributary. Stormwater then flows 1200 feet to a 0.7 acre recreational pond in the yard of a private residence, then an additional 1.1 miles where it meets Bahalia Creek.
1.1.2.2 Description of Threat
Arsenic and PCP are listed hazardous substances under CERCLA, toxic pollutants under the Clean Water Act, hazardous air pollutants under Clean Air Act, toxic chemicals under EPCRA, and hazardous wastes under RCRA. The US DHHS, the IARC, and EPA have classified inorganic arsenic as a known human carcinogen; the IARC and EPA have classified PCP as a probable/possible human carcinogen.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
In March of 2011 MDEQ referred the Site to EPA Region 4 Emergency Response and Removal Branch (ERRB) to conduct a Removal Site Evaluation (RSE) at the property. The request was based on the presence of several leaking drums and other containers as well as the known contamination of CCA and PCP at the Site. During an RSE on 4/6/2011, EPA OSC Crowley discovered six drums of mostly oil and several smaller containers onsite. Several of the drums were leaking and impacted soil was observed nearby. In addition, the former PCP above ground storage tank (AST) was overturned and the contents were spilling onto the ground. OSC Crowley informed the property owner to remove and/or secure the drums. On 4/26/2011, EPA and START returned to conduct further sampling and found both that the drums were still leaking and that the impacted soils were still in place. EPA initiated and Emergency Response to stabilize the drums, remove the impacted soil and search the Site for any additional hazardous materials that may be present. EPA’s ERRS contractors overpacked and secured containers including drums, cans, a pentachlorophenol tank, an oil storage tank, cylinders, and buckets. Waste materials in the containers include liquid and tar, approximately half of which was found to be ignitable. ERRS also excavated soil and sludge from around the drums and the former pentachlorophenol storage tank. The pentachlorophenol tank was uprighted; approximately 600 gallons of material remains in the tank that has a tar-like consistency. A lined staging area was constructed for temporary storage of segregated and secured wastes. The initial phase of the emergency response was completed on 4/28/2011.
EPA conducted three additional assessment and sampling activities at the Site between 2011 and 2012. Results were compared to the EPA Removal Management Levels (RMLs) calculated for Total Risk (TR) of 1E-04 and Hazard Quotient (HQ) of 3. RMLs for inorganic arsenic in soils are 39mg/kg for residences and 160mg/kg on industrial properties. RMLs for pentachlorophenol in soils are 89mg/kg for residences and 270mg/kg on industrial properties.
From 4/26-4/28/2011, EPA and START sought to delineate extent of contamination by collecting 89 surface and subsurface soil samples from 78 locations. All samples were screened for arsenic and chromium with an X-Ray Flourescence meter (XRF) and 11 were submitted for laboratory analytical verification as well as analysis for semi-volatile organic compounds (SVOCs). 55 of 78 surface soil samples exceeded the residential RML for arsenic while 17 of those samples also exceeded the industrial RML. Surface soil concentrations of inorganic arsenic ranged up to 730 mg/kg (4.5 times industrial RML) with one reading at the preservative storage building exceeding 200,000 mg/kg (>20% inorganic arsenic). 10 of 30 subsurface soil samples exceeded the residential RML for arsenic while 4 of those samples also exceeded the industrial RML. Subsurface soil concentrations of inorganic arsenic ranged up to 1329 mg/kg (8.3 times industrial RML). 9 of 11 soil samples that were sent for laboratory analysis exceeded the residential RML for arsenic while 8 of those samples also exceeded the industrial RML with concentrations ranging up to 1880 mg/kg. Only one sample sent for laboratory analysis exceeded a RML for pentachlorophenol; this sample was collected from the on-site aboveground storage tank (AST) and yielded 92,000 mg/kg (9.2%) pentachlorophenol (340 times industrial RML).
From 8/17-8/18/2011, EPA and START sought to delineate the perimeter of the former surface impoundment (i.e. lagoon) and determine whether groundwater impacts were present by collecting samples through existing on-site wells. Aside from elevated levels of cobalt and manganese in one of the three monitoring wells, no significant readings were found in the groundwater. Three XRF readings in the drainage pathway from the Site exceeded the residential RML for inorganic arsenic while one reading exceeded the industrial RML at 414 mg/kg.
From 1/18-1/20/2012, EPA and START measured surface soils of residential yards adjacent to the Site to determine whether contaminants had migrated to these properties. Eight yards along the northwest and southwest of the Site were screened with XRF meter and four properties at the southwest showed elevated levels of inorganic arsenic. Laboratory analytical results showed that all four of these properties exceeded the industrial RML for inorganic arsenic with concentrations ranging from 240-585 mg/kg; these four properties are occupied by a single residence.
The removal site evaluation has identified elevated concentrations of inorganic arsenic and pentachlorophenol at the Site above residential and industrial RMLs, as well as the presence of other hazardous wastes. Based on the criteria listed above, the Site was recommended for a time-critical removal action to remove and/or prevent migration of hazardous substances, pollutants, and contaminants.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
The ceiling increase Action Memorandum and 12-month exemption for Time Critical Removal Action at the Site was signed on 9/12/2013. Information was distributed to the custodians of the property and a meeting was held with the custodians on 10/24/2013 in Pearl, MS to discuss access procedures.
OSC Huyser and START contractor OTIE returned to the Site from 11/20-11/21 to collect additional surface soil samples from the drainage ditch to delineate the excavation area within the ditch path. Sampling consisted of 0-6" hand-augered samples collected from the center, right, and left at 33 locations in the ditch. Three distinct branches to the primary ditch were identified and sampled. These branches will be referred to as "100" (longer, lower south ditch approximatley 1100 feet long), "200" (near end of the 100 ditch and approximately 150 feet long), "300" (above the 200 ditch and approximately 50 feet long), and "400" (near the beginning of the 100 ditch and approximately 400 feet long). Arsenic concentrations identified in the ditches ranged from 10ppm to 1300ppm with an average concentration exceeding 300ppm.
OSC Huyser returned on 12/17/2013 to meet with representatives from MSDEQ, the City of Hazlehurst, and the Copiah County EMA. Information was presented to the local representatives regarding the purpose and scope of EPA's presence. A site walkthrough was conducted with the ERRS response manager to discuss mobilization strategies and operational tactics.
OSC Huyser, ERRS contractor WRS, and START contractor Tetra Tech mobilized to the Site on 1/6/2014. Initial site setup was conducted and operations began clearing work areas to obtain access to both the ditch and known hotspots. A staging area for excavated materials was established and bermed on a known hotspot at the south end of the site. From 1/7/2014 to 1/10/2014 the 100 ditch and 400 ditch were scraped at a depth of 6" and removed soils deposited in the staging area. The entire 400 ditch was completed and approximately 60% of the 100 ditch was completed. Silt fence and hay bales were installed and work ceased on 1/10/2014 in anticipation of heavy rain.
A stockpile of approximately 10CY of contaminated soils was removed mechanically from the kiln building. Large garage doors at either end of the building provide light and ventilation, but crews were instructed to don Level C PPE during the activity to mitigate threats posed by contaminated dust that would be generated during the operation.
Known hotspots were identified and labeled as zone "500" (adjacent to the chemical storage and treatment building), zone "600" (in the treated wood storage area at the northwest corner of the Site), and zone "700" (north of the material storage building, located between the kiln and the treatment building). 20-foot grids were flagged on the zones and in-situ XRF readings were collected at the grid points. Zone 500 was completed and a hotspot (concentrations above 70% of the industrial RML of 240ppm) was drawn on the ground. 3 samples and 1 duplicate were collected from zone 500 which represented approximately 10% of the remaining points which fell outside of the delineation zone and will not be covered. XRF screening of zone 600 was nearly completed by the end of the week and will be completed during week two.
2.1.2 Response Actions to Date
- Flagged, screened, and sampled ditch 100, 200, 300, and 400
- Established soil staging area
- Cleared working path at ditch 400, 60% of ditch 100, and zone 600
- Completed 6" scrape of ditch 400
- Completed 60% of 6" scrape of ditch 100
- Removed stockpile of soils from kiln building
- Installed silt fencing and hay bales as temporary drainage control
- Flagged, screened, delineated and sampled zone 500
- Flagged and partially screened zone 600
- Flagged zone 700
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Signed access was obtained from the custodian to the property on 12/20/2013
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| Non-haz Soil
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Solid |
(anticipated: 600 ton) |
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| Non-haz Wastewater
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Liquid |
(anticipated: 3000 gal) |
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2.2 Planning Section
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2.2.1 Anticipated Activities
During the week of 1/13/2014, scraping of ditch 200 and 300 will likely be completed while ditch 100 will be approximately 80-90% completed. Cover material will arrive and be spread to high end of ditch 100 (stone) and zone 500 (clay).
Screening and sampling of the residential yard on Erwin Lane will be completed. Flagging of zone 800 will be completed and screening of zones 600 and 800 will be completed
2.2.1.1 Planned Response Activities
- Mechanical scraping, stockpiling, treatment and/or disposal of contaminated surface soils from the drainage ditch exiting the CCM property; (ONGOING)
- Excavation, stockpiling, treatment and/or disposal of contaminated surface soils (upper 12 inches) from accessible areas in adjacent residential properties that exceed a cleanup standard for residential uses;
- Removal, treatment and/or disposal of pentachlorophenol hazardous wastes as well as any other containerized hazardous wastes that may be encountered at the Site; (ONGOING)
- Disposal of hazardous and non/hazardous wastes at an off-site location;Install semi-permanent ground cover over surface soils within CCM property that exceed arsenic concentrations of 160mg/kg;
- Install stable ground cover in drainage ditch to slow surface water flow for the prevention of off-site migration; (ONGOING)
- Grade and establish vegetative cover on all contaminated surface soils to reduce runoff and dust for the prevention off-site migration; and, (ONGOING)
- Continue sampling and monitoring, as needed, for site safety purposes and to further delineate or identify contaminants. (ONGOING)
2.2.1.2 Next Steps
See sections 2.2.1 and 2.2.1.1 above.
2.2.2 Issues
On 1/7/2014, OSC Huyser met with representatives from Entergy and Boardwalk Pipeline to discuss access requirements in the right-of-way at the east side of the Site regarding the transmission line and the natural gas pipeline. There were no identified concerns regarding the transmission line. The natural gas pipeline was identified as a potential concern: the 6" line was installed in approximately 1928 and is loaded at a pressure of 1000 psi; a 12 foot section of the pipe is exposed in ditch approximately 1.5 feet above the normal water surface and 3-4 feet of unsupported bank covering it on both ends. Boardwalk will address the exposed line during an annual inspection later in 2014 but did not identify any issues that needed to be addressed immediately. In response to this information, OSC Huyser elected to forego removal activities at or under the pipeline and will end excavation and backfilling 10-20 feet upstream. ERRS crews did remove several logs that were propped at or on the pipeline to alleviate stress on the exposed line.
Initial site designs called for use of limestone "crush run" as a cover material for hotspots on-site. This material was selected for it's simplicity of installation and relative impermeability due to the fines content that will create a hard packed surface layer. Upon mobilization and inspection of available local materials, it was realized that all limestone products are transported from non-local sources and, as a result, are much more expensive. A locally mined clay material was chosen, and approved by OSC Huyser, as an alternative capping layer. The clay will be applied at a thicker depth than was anticipated for the crush run and will be packed with a roller prior to seeding.
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2.3 Logistics Section
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N/A
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2.4 Finance Section
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2.4.1 Narrative
START contractor OTIE could not be retained for removal work past 12/31/2013 due to administrative contracting problem unrelated to the Site. START contractor Tetra Tech was obtained for remaining removal work; duplication of several documents including a QAPP and HASP was necessary. Costs for OTIE are still being totaled.
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Budgeted |
Total To Date |
Remaining |
% Remaining |
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Extramural Costs
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| ERRS - WRS |
$557,000.00 |
$53,616.05 |
$503,383.95 |
90.37% |
| IAGs - USCG |
$15,000.00 |
$0.00 |
$15,000.00 |
100.00% |
| START - OTIE |
$55,000.00 |
$15,965.26 |
$39,034.74 |
70.97% |
| START - Tetra Tech |
$90,000.00 |
$0.00 |
$90,000.00 |
100.00% |
| CLP |
$3,500.00 |
$0.00 |
$3,500.00 |
100.00% |
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Intramural Costs
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| Total Site Costs |
$720,500.00 |
$69,581.31 |
$650,918.69 |
90.34% |
* 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
A remotely monitored air monitoring system is setup daily using two DataRAM 4000's. One DataRAM is deployed near the operating area at the ditch while the second is set atop the office trailer at the entrance of the site. A third dust monitor is attached to the excavator and data collected by the monitor will be regularly downloaded for evaluation.
An alarm level of 0.9 mg/m3 has been established for total particulate dust levels for on-site monitoring. Average total particulate dust concentrations have been below 10 ug/m3.
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
N/A
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3. Participating Entities
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3.1 Unified Command
N/A
3.2 Cooperating Agencies
MSDEQ
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4. Personnel On Site
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EPA (1)
ERRS WRS (7)
START Tt (2)
MSDEQ (1)
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5. Definition of Terms
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Ditch 100 - longer, lower south ditch approximately 1100 feet long
Ditch 200 - near end of the 100 ditch and approximately 150 feet long
Ditch 300 - just north of the 200 ditch and approximately 50 feet long
Ditch 400 - near the beginning of the 100 ditch and approximately 400 feet long
Zone 500 - adjacent to the chemical storage and treatment building
Zone 600 - in the treated wood storage area at the northwest corner of the Site
Zone 700 - north of the dried material storage building, located between the kiln and the treatment building
Zone 800 - on the eastern side of the site, between the kiln building and the reminants of the saw mill
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6. Additional sources of information
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6.1 Internet location of additional information/report
N/A
6.2 Reporting Schedule
POLREPs will be submitted weekly
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7. Situational Reference Materials
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N/A
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POLREP #4 Last Updated 2/10/2014
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