1.1.1 Incident Category
Time-Critical Removal Action

The scope of work for this action is to complete site restoration and remove concrete barriers, steel cables and high visibility fencing and warning signage along there restricted access borders of the former hot-zone work perimeter within the site property. 

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 Industrial Complex community. Liberty Fibers began manufacturing Rayon in 1947. The Site is located in a rural area approximately six miles southeast of downtown Morristown, Hamblen County, Tennessee. The Site is bordered immediately to the south and southeast by the former Nylon Staple and Polyester Staple plants. The Site is bordered to the north by a Norfolk Southern railroad line and approximately six residences and farmland. The Site is bordered to the east by a former BASF landfill, forest, and other rural land. The Site is bordered to the west by Enka Highway, beyond which is farmland and a wastewater treatment facility. Distances from the Site to nearby residences range from approximately 300 to 2,500 feet to the north, northeast, and northwest of the LF site. The nearest school, Union Heights Elementary School, is located less than three miles northwest of the Site. A daycare center, Tabernacle Day Care, is located about six miles west-northwest of the LF Site. The topography of the Site is relatively flat.  Drainage is to Nylon Creek  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 estimated thousands of linear feet of pipe wrapped in deteriorated asbestos-containing thermal system insulation (TSI) throughout the Site.  The Site is not secure by evidence of routine trespassing.  There are businesses operating in the buildings surrounding the Site and several residential properties neighboring 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 December 3-4, 2009, and a Removal Site Evaluation (RSE) was performed on January 18-22, 2010.  On April 19, 2010, alleged hot work (cutting torch) activities initiated a fire along the southern perimeter of the Site.  EPA and The Morristown Fire Department responded.  The responding OSC (Perry Gaughan) requested that EPA Region 4 Technical Services Section (TSS) evaluate asbestos sampling results from January 2010 RSE to determine if a threat to human health and the environment exists on Site.  The OSC determined  that the threat exists, served the owner with a Notice of Federal Interest, and initiated an emergency response action.

In April 2010 EPA and contractor support provided by the Emergency Rapid Response Service (ERRS) responded to a fire on the former Liberty Fibers property on the Lowland Industrial Complex located east of Morristown, Tennessee on Hwy 160 (Enka Highway).  Since 2006, equipment and metal salvage operations had been conducted on the property as well as abatement operations for asbestos insulation and asbestos based containing substances (ABS). After a removal site evaluation (RSE) identified friable asbestos throughout the property in demolition debris piles, the EPA OSC initiated measures to stabilize the site including restricting site access, establishing site security and application of a polymer-based agent on the debris piles to fix the asbestos piles in place and prevent off-site migration.

The removal action by EPA from August 2011 through May 2015 was conducted in multiple stages or phases to include (See 2.1.4 - Progress Metrics)  -  Obtaining written access to the property from the PRP; Construction of a Class III landfill on-site; Removal of  ACM contaminated building demolition debris piles over approximately 80 acres of building foundation, basements and soil; removal and disposal of approximately 7-miles of elevated pipe-runs over the property that was jacketed with TSI; Disposal of over 20,000 bags of abandoned asbestos waste, stored in the Electrical Building, left behind from previous abatement work; and disposal/recycling coordination of numerous orphan containers of hazardous waste, cylinders, and miscellaneous waste streams identified throughout the site. Approximately 1,800 gross tons of structural steel was also segregated/decontamoinated and recycled.

2.1.2 Response Actions to Date

During this reporting period:

February 10, 2015 – CMC remobilized to the Site to conduct replace and repair barrier fences that were cut down.

March 23-26, 2015 – CMC remobilized to the Site to evaluate site conditions, conduct site maintenance and mow areas within the operational grids prior to upcoming activity based sampling event scheduled for May 2015.

May 11–14, 2015 - EPA and the Superfund Technical Assessment and Response Team (START) conducted activity-based sampling (ABS) and bulk material sampling event. The primary objective was to evaluate the grid 92 grids encompassing the Liberty Fibers Site for potential human exposures to asbestos, by conducting activities at the site that cause disturbance of soil, surfaces, and debris potentially contaminated with asbestos.  Additionally, the data gathered will be used to qualify if the mitigation efforts by EPA were effective in removing the source contamination which would correspond to a reduction in exposure risk to asbestos at the site. 

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
PRPs have been identified and enforcement is ongoing.  Notice Letters were mailed to Jolley Rock Investments, LLC, and Paint Oak, LLC, on September 25, 2013.

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. 

2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities

Based on the pending data from the ABS, determine if further action at the Site is indicated.
.
2.2.1.2 Next Steps

OSC to coordinate with the property manager (acting on behalf of the PRP) on final site restoration to be conducted at the Site.

2.2.2 Issues

None at this time.

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
Task Order No. 0702-F4-0115                       Mod. 9         $6,696,943     1/16/2013
Task Order No. 0702-F4-0115                       Mod. 10       $7,199,443     5/03/2013
Task Order No. 0702-F4-0115                       Mod. 11       $7,699,443     6/21/2013
Task Order No. 0702-F4-0115                       Mod. 12       POP Extension8/02/2013
Task Order No. 0702-F4-0115                       Mod. 13       Revised Rate on Water Trucks for O&M 8/09/2013
Task Order No. 0702-F4-0115                       Mod. 14       $8,196,943     8/09/2013
Task Order No. 0702-F4-0115                       Mod. 15       $8,601,943     9/25/3013

START - Tetra Tech
TDD No. TTEMI-05-001-0126                       Mod. 10          $469,900    12/21/2012
TDD No. TTEMI-05-001-0126                       Mod. 11          $511,047      1/15/2013
TDD No. TTEMI-05-001-0126                       Mod. 12          $561,047      3/01/2013
TDD No. TTEMI-05-001-0126                       Mod. 13          $601,047      5/02/2013
TDD No. TTEMI-05-001-0126                       Mod. 14          $636,047      6/18/2013
TDD No. TTEMI-05-001-0126                       Mod. 15          $671,047      7/30/2013
TDD No. TTEMI-05-001-0126                       Mod. 16          $711,047      8/21/2013

* 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.

2.5.1 Safety Officer

The OSC assumed this role.

2.6 Liaison Officer

The OSC assumed this role

2.7 Information Officer

The OSC assumed this role

2.7.1 Public Information Officer

The OSC assumed this role

2.7.2 Community Involvement Coordinator

Kyle Bryant

3.1 Unified Command

N/A

3.2 Cooperating Agencies

Over the period of this removal action:

USEPA Region 4

EPA Environmental Response Team

US Bureau of Reclamation 

Tennessee Department of Environment and Conservation

Morristown Fire Department

April 26-29, 2016

1 EPA OSC David Andrews

START - Tetra Tech, Inc..

Paul Prys, Environmental Scientist (December 21-21,2015 site visit) 

ERRS - CMC, Inc.
1 Response Manager 

1 Equipment Operator

2 Laborers

ACM – Asbestos Containing Material or Substances

Asbestos - Refers to a set of six naturally occurring fibrous minerals. Asbestos has six primary sub-classifications: chrysotile, crocidolite, amosite, anthophyllite, tremolite, and actinolite. Among these, chrysotile and amosite asbestos are the most common.

BOR – US Bureau of Reclamation

EPA – Environmental Protection Agency Region 4

ERRPB – Emergency Response, Removal and Prevention Branch (formerly ERRB)

ER – Emergency Response

ERRS – Emergency Rapid Response Service (Environmental Restoration, Inc. & CMC, Incorporated)

ERT – USEPA Environmental Response Team

f/cc – Fibers per cubic centimeter

OSC – Federal On-Scene Coordinator

PRP – Potential Responsible Party

RML – Regional Removal Management Level

RSE – Removal Site Evaluation

SOSC – State On-Scene Coordinator

START – Superfund Technical Assessment and Response Team (Tetra Tech, Inc)

TDEC – Tennessee Department of Environment and Conservation

TSI - Thermal System Insulation

TSS – Region 4 Technical Services Section (Resource & Scientific Integrity Branch/ REG 4 Superfund Division)

6.1 Internet location of additional information/report

https://www.epaosc.org/libertyfib

6.2 Reporting Schedule