U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Copiah County Manufacturing - Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV
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Subject:
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POLREP #5
Ongoing removal action
Copiah County Manufacturing
B4H9
Hazlehurst, MS
Latitude: 31.8719088 Longitude: -90.3836203
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To:
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From:
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Matthew Huyser, On-Scene Coordinator
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Date:
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1/28/2014
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Reporting Period:
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1/12/2014 - 1/25/2014
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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
See POLREP #4, dated 1/14/2014, for Site Description Information
1.1.2.1 Location
The Site is located at 600 Georgetown Street, Hazlehurst, Copiah County, Mississippi. The geographic coordinates of the Site are 31.8719088 degrees North and 090.3836203 degrees West.
See POLREP #4, dated 1/14/2014, for additional Site Location Information
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
See POLREP #4, dated 1/14/2014, for Preliminary Removal Assessment and Removal Site Inspection Results
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
Between 1/12/2014 and 1/25/2014, ERRS contractor WRS completed scraping of ditch 100 and laying rip rap (aka "gabion stone") along the ditch line. Stone was piled in areas where the creek bed experience significant drops (2-4 feet) in at least 3 locations to reduce the grade and prevent washout from falling water. Stone was also partially compacted into the soil bed to secure both the stone and the soil. At the lowest end of ditch 100, soils were hand-dug to avoid allowing equipment to track close to the exposed gas line. Stone was laid no closer than 20 feet to the gas line and scraping operations in ditch 100 were deemed complete by OSC Huyser.
At the confluence of ditch 100, 200, and 300, a wider area of surface soil was scraped from the surface. greater definition was provided to each ditch as they intersected one-another. Scraping of ditch 200 and ditch 300 were completed and stone was laid over the ditch lines as was done in 100. Stone laying in ditch 400 was also completed. Due to the depth, grade, and cover of the stone that was laid in all ditch lines, the order of larger stone (>12" dia.) that would have been used for check dams was cancelled; the existing rip rap should be sufficient to slow water velocity and reduce sediment transportation without risk of washout.
Analytical results of soils removed from the ditch determined that the soil can be classified as a nonhazardous waste. The Plantation Oaks Landfill in Sibley, Misissippi, was selected as an off-site disposal location and was approved according to 40CFR300.440 off-site rule requirements.
OSC Huyser and WRS visited the quarry from which the cover material would be obtained to both inspect the material and collect a sample for confirmatory analysis. A portion of the material was transported on-site the following week to cover zones 500 and 700. A layer of at least 6 inches was spread and compacted over the delineated hotspots.
In addition to zones 500, 600, and 700, zones with additional hotspots were labeled as zone "800" (east of the kiln building) and "900" (surrounding the kiln building). START contractor, OTIE, completed XRF screenings of zones 600, 700, 800, and 900. No hotspots were identified in zone 600. Hotspots in zone 700 and 800 were delineated and 10% of remaining points outside the areas to be covered were sampled for confirmation. The hotspot of zone 900 was delineated and samples will be collected from the remaining outside points.
On 1/15/2014, OTIE and OSC Huyser collected composite soil samples from the residential property at Erwin Lane. 17 locations were identified and sampled with 5-point composites along with one duplicate. The samples were mixed, bagged, and screened with XRF. A single sample exceeded the arsenic RML for residences of 34ppm, however a second screening of the same sample yielded arsenic concentrations below 20ppm. Three of the samples were sent for laboratory analysis which included additional mixing for proper homogenization; this included the sample that yielded the single elevated result. The laboratory analysis determined that each of the samples had arsenic concentrations below action levels.
Two sumps were identified at the process building as a safety and direct contact threat. The sumps are open concrete pits and each contain approximately 1,500 gallons of with bottom sludges. OSC Huyser and OTIE collected samples for wastewater analysis using glass coliwasa tubes to bias the sample for worst-case concentrations by collecting from the bottom sludge. Analytical results found low levels of arsenic, chromium, and pentachlorophenol in the samples which would allow the water to be disposed of as nonhazardous waste. However, the location of the water suggest that the pits were used to collect drippage from pressure vessels; as a result, the waste must be classified as a listed hazardous waste K001 "bottom sediment sludge from the treatment of wastewaters from wood preserving processes that use creosote and/or pentachlorophenol." The total 3,000 gallons will be agitated to lift the sludge, pumped, and transported off-site for disposal.
While clearing brush from around zone 500, WRS identified stained soils that appeared "green" in color. A small sample was collected, bagged and screened with the XRF; resulting arsenic levels were measured at approximately 3% (~30,000ppm). OSC Huyser directed WRS to scrape the surface soil from the surrounding area of approximately 15ft wide by 30ft long. The resulting soil was a hard clay; a composite surface soil sample was collected from the area, bagged, and screened; resulting arsenic concentrations were measured at approximately 10ppm. Also in zone 500, WRS uncovered a small concrete sump measuring approximately 3ft by 3ft and over 5ft deep. The sump was filled with water black sludge was identified in the bottom. A concrete layer over an pipe leading to the bathroom of the process building and an overflow port near the top of the sump revealed that it was a small septic tank. The tank will be temporarily covered, but will later be filled with sand.
2.1.2 Response Actions to Date
- Flagged, screened, and sampled ditches 100, 200, 300, and 400
- Established soil staging area
- Cleared working path at ditches 100, 200, 300 and 400 as well as zones 500 and 600
- Completed 6" scrape of ditches 100, 200, 300, and 400
- Removed stockpile of soils from kiln building
- Installed rip-rap drainage control in ditches 100, 200, 300 and 400
- Flagged, screened, delineated and sampled zones 500, 600, 700, and 800
- Flagged and screened zone 900
- Installed cover material on zones 500 and 700
- Sampled and fenced suspected asbestos material
- Scraped hotspot on zone 500
- Sampled wastewater in pressure vessel sumps
- Excavated soil from former AST pad
- Screened concrete pads at former AST and storage building
- Completed sampling of residential property at Erwin Lane
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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| Haz Wastewater
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Liquid |
(anticipated: 3000 gal) |
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| Haz (?) Soil
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Solid |
(approx. 10 ton) |
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2.2 Planning Section
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2.2.1 Anticipated Activities
During the week of 1/27/2014, installation of cover material on zone 800 will likely be completed. Removal of wastewater from sumps and removal of asbestos will also be completed. Loading may begin for transport off-site and disposal of soil that was scraped from the ditch.
Sampling on zone 900 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; (COMPLETE)
- 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; (ONGOING)
- 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
Composite soil samples from the residential property on Erwin Lane yielded no locations above the residential action level. As a result, no excavation will be conducted at the residential property. The areas that were targeted for sampling include those areas that are exposed and easily accessed by the resident; they did not include wooded or forested areas. Previous sampling activities on the residential property, conducting during the removal assessment, identified elevated concentrations of arsenic in a wooded area at the north eastern edge of the parcel. Those soils will not be addressed during the course of this removal action.
OSC Buerki identified insulation material piled around the kiln building and found that the boiler had been stripped of its insulation, which was lying on the ground inside and outside the boiler house. OSC Buerki directed OTIE to collect a sample for asbestos analysis; WRS installed fencing around the material and will prepare to mobilize asbestos-trained staff to remove the material if analysis confirms the presence of RACM.
Elevated arsenic concentrations were discovered on the concrete pad to the west of the process building and within the covered storage building. High arsenic readings on the the concrete pad of the storage building suggest that the building may have been used as a drip pad. Cover material being used on hotspots would wash off of the concrete pad if it were applied. A two-part epoxy sealer will be used to seal the concrete pad to prevent direct contact threat and off-site migration of contaminants.
OSC Buerki discovered elevated concentrations of arsenic beyond 10% (100,000ppm) immediately adjacent to the concrete pad at the west site of the process building, buried below the initial surface layer of soil. The pads held the CCM ASTs and were adjacent to one of the pressure vessels. Approximately 10CY of impacted soil was excavated up to a depth of 12in; non-impacted hard clay material was found underneath. This impacted soil was staged separately from the primary stockpile and is being evaluated to determine if it must be disposed of as F035 hazardous waste.
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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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No information available at this time.
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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 (9)
START Tt (1)
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
Zone 900 - in and around the kiln building
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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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