1.1.1 Incident Category

Removal and disposal of abandoned drums that contain mostly degraded asphalt and oils; recovery and disposal of friable asbestos containing materials that are extensively damaged and weathered which has released asbestos fibers onto the ground requiring proper recovery and disposition; cleanout of a former API Oil Separator; and, removal and disposal of former tar storage tanks and miscellaneous debris scattered about the site.  

1.1.2 Site Description

The Site, is a former facility that was a comparatively small asphalt plant, located on slightly over twelve acres. The plant was divided into four areas: Area 1 consisting of an office building, locker room, laboratory, maintenance shop, and still area; Area 2 was a tank farm storage area; Area 3 was the container filling operations and tank car loading and unloading area; and Area 4 was the product storage, product bagging and filled asphalt operations area.

From the early 1900s until approximately 1985, the Pioneer Asphalt Corporation (Pioneer Asphalt) manufactured asphalt and other related products at the Site. In July 1985, the Ziegler Chemical and Mineral Corporation acquired the Pioneer Asphalt Corporation, incorporating and renaming it the Pioneer Asphalt Corporation. In November 1985, the Pioneer Asphalt Corporation acquired the Site and facility from the Witco Corporation, and commenced asphalt and other product manufacturing there. At the present time, the Pioneer Asphalt Corporation still owns the Site but has not manufactured anything at the Site since approximately 2004.

The Former Pioneer Asphalt Plant was an asphalt production facility located on-site in Lawrenceville, Illinois. In 1924, the Wishnich-Tumpeer Chemical Company purchased the facility and began manufacturing asphalt. Although owned and operated by several different entities over time, the Former Pioneer Asphalt Plant was consistently used to manufacture asphaltic products. In 1985, the facility was incorporated as Pioneer Asphalt Corporation. Pioneer Asphalt produced a number of industrial products at the Site including, but not limited to, coatings, sealers, adhesives, ink additives, and fillers. Production of unique asphalt blends, compounds, and oxidized products also took place at the Site by mixing raw asphalts with other raw materials. Pioneer Asphalt terminated operations at the Former Pioneer Asphalt Plant facility sometime in 2004.

Most recently, operations at the Site produced specialty asphalts, including but not limited to various roofing asphalts, culvert coating, vault sealer and waterproofing primer. The asphaltic materials were stored/processed in insulated above ground storage tanks (ASTs) and “pans”, and various petroleum products were stored in on-site drums. In 2009, a third-party demolition contractor was hired to demolish the on-site structures and ASTs. This demolition contractor performed Site demolition without securing the necessary permits and demolished only those items with scrap value and areas that were easy to access. As a result, releases of asphaltic materials and other petroleum products along with the release of friable asbestos containing materials (ACM), have occurred and unstable environmental conditions that remained thereafter at the Site that require the current removal actions.

The Site is surrounded on three sides by the Indian Refinery Superfund Site. Prior subsurface testing completed in the investigation of the Indian Refinery property has shown that the Pioneer Asphalt Site’s subsurface environment has been impacted as a result of this adjacent property. The majority of the materials of concern at the Site include asbestos-containing materials (ACMs) and petroleum-related asphaltic materials. The ACMs can be found on existing structures and on certain soils, and are likely impacting the air on and around the Site. The asphaltic materials are present within both intact and partially demolished ASTs, and are in various physical states ranging from solids to semi-solids that are insoluble in water but are likely impacting only the surface of the Site. The drums on-Site are located on concrete/asphalt surfaces, and contain asphaltic materials. As a result of the conditions outlined above, this RAWP does not generally include subsurface sampling and/or chemical analysis at this time1, but does include the remediation of surficial soils up to 3 inches that exhibit the presence of ACMs and/or visual evidence of impact associated with the materials of concern at the Site.

The dilapidated conditions at the Site, and the resultant environmental threats, prompted IEPA to sign an order to seal the facility on July 1, 2010. On August 26, 2010, the IEPA submitted a letter to USEPA requesting assistance from the USEPA Region 5 Superfund Division in conducting a potential time-critical removal action at the Site.

1.1.2.1 Location

The Site is located at 802 Ash Street, Lawrenceville, IL, 62439 and covers approximately 12-acres within the southeastern end of Lawrenceville.

1.1.2.2 Description of Threat

Extensive threats present at the Pioneer Asphalt Site are due primarily to the existence of containerized hazardous waste and substances in drums, barrels, tanks and other bulk storage containers along with friable ACM that has been damaged and is weathered with ongoing fiber releases.
The hazardous wastes found on the Pioneer Asphalt site have no secondary containment, and the contents of some of the 55-gallon drums are documented as containing ignitable and corrosive hazardous substances. U.S. EPA has documented more than 250 fiber and metal drums on-site. Some of the drums contained a black tar-like substance and several drums were overturned or ruptured. The main roadway of the facility is covered with a tar-like substance which has been released from cut-off above-ground tanks.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

During site visits, both the Illinois EPA and U.S. EPA have documented the presence of waste tars (flux, soft wax, unipet 9 wax, and roofers flux asphalt) and other contaminates that demonstrated the hazardous characteristics of ignitibility and corrosivity, friable asbestos within the demolition debris and soils on-site, and asbestos on above-ground storage tanks.
There are a number of drums as well as large tanks containing possible hazardous substances that is subject to removal as part of this response action.

Illinois EPA (IEPA) representatives conducted a site investigation in July 2010, which included the collection of samples from several different types of media. IEPA inspectors identified approximately 250 fiber or metal drums on-Site that were exposed to the outside elements, of which several drums were overturned or ruptured. IEPA observed a black tar-like substance in some drums, while other drums were unlabeled with unknown contents. IEPA’s samples collected from some of the drums on-Site revealed elevated levels of benzene, toluene, ethylbenzene, and total xylenes (BTEX). Contents of two waste drums indicated elevated concentrations of total petroleum hydrocarbons (TPH) and diesel range organics (DROs), at 29,800 milligrams per kilogram (mg/kg) and 41,800 mg/kg, respectively. One sample was collected from a drum labeled “phosphoric acid” and was found to have a pH of 1.19, which is characteristic of corrosivity. IEPA sample #301 had a flashpoint result of 80 degrees Fahrenheit (°F) and was considered a hazardous waste that exhibits the characteristic of ignitability. IEPA also collected six samples of suspected ACMs from surface debris on concrete slabs, thermal insulation, and tank bases located on-Site. Each of the sampled areas tested positive for friable asbestos (transite, crysotile, and amosite).

During the IEPA’s July 2010 inspection, it was observed that several of the ASTs had been cut down to a
level exposing the liquid contents of the tanks, and were releasing tar-like materials onto the ground. Depending on their location within the Site, these tanks contained fuel oil, asphalt flux, soft wax, hard asphalt, propane extracted asphalt (hard asphalt), unipet 9 wax, and roofers flux asphalt. Oily surface water was observed entering an American Petroleum Institute (API) oil/water separator located on the east side of the Site; however, IEPA samples did not reveal any significant levels of BTEX or TPH at that time.

The dilapidated conditions at the Site, and the resultant environmental threats, prompted IEPA to sign an order to seal the facility on July 1, 2010. On August 26, 2010, the IEPA submitted a letter to USEPA requesting assistance from the USEPA Region 5 Superfund Division in conducting a potential time-critical removal action at the Site.

On February 20, 2013, U.S. EPA observed continued deteriorating on-site conditions. U.S. EPA observed spills and prior releases of waste tars, in the same area where Illinois EPA had documented waste tars that were hazardous because of the characteristics of ignitibility that may migrate from the Site via storm water discharge to contaminate nearby properties or the municipal storm water collection system.

As a result to the existing site conditions, an AOC was entered into voluntarily with the USEPA and the Respondent, Ziegler Chemical & Mineral Corp., that was executed on September 22, 2014.

2.1.1 Narrative

Respondent Pioneer Asphalt Corporation c/o Ziegler Chemical & Mineral Corp., has agreed to perform the drum disposal, asbestos removal and site debris removal activities in accordance with the criteria and time-lines as specified in the December 24, 2014, Pioneer Asphalt Company Work Plan that EPA approved as part of the September 22, 2014 AOC.  

2.1.2 Response Actions to Date

The OSC has tasked the Respondent to conducted or perform the following actions:

• Develop and implement a Removal Action Work Plan (RAWP);

• Develop and implement a Site Health & Safety Plan (HASP) consistent with the work to be performed, but not limited to an air monitoring plan that address asbestos removal and friable asbestos containing materials (ACM) during the removal of scrap steel and other metal products on the site;

• Retain the services of a third-party asbestos air monitoring contractor (Farmer Environmental Services, LLC.);

• On September 14, 2015, and consistent with the agency approved Removal Action Work Plan, Pioneer Asphalt Corporation and its contractor representatives, Pioneer Environmental Services LLC and CENPRO Services Inc., initiated project mobilization including the necessary equipment and manpower to remove drummed materials, abate friable ACM scattered about the site, removed up to 3-inches of soil where asphaltic tars are presently observed and remove miscellaneous debris scattered across the site;

• During the week of September 14, 2015, all debris was removed from the former drumming building concrete pad, with the exception of the melted asphalt drums, and the pad was power washed to abate any remaining asbestos;

• On September 16, 2015, Micro-vac samples (MV-01 through MV-03) were collected from the former drumming building concrete pad, and samples MV-04 and MV-05 were collected from the entrance roadway. These samples were collected in accordance with the RAWP and Quality Assurance Project Plan. Additionally, the truck wash decontamination station was constructed and logistical coordination with Republic Services occurred regarding load-out activities;

• On September 21, 2015, efforts to initiate the load-out of drummed non-hazardous waste materials to the Republic Services landfill in Sumner, Illinois, TSDF. All asphalt drums and materials were scraped from the former drumming building concrete pad, loaded into double-lined roll-offs, and transported to the Sumner landfill for disposal. Removing friable asbestos containing materials (ACMs) was initiated on September 22, 2015. Additionally, debris piles and non-friable ACMs were abated from the northern portions of the Site, and existing soil drums were loaded into roll-offs for removal;

• On September 23, 24, and 30, 2015; field crews from Safety Kleen vacuum removed oily solids from the API oil water separator (OWS). However, due to high quantities of sludge in the OWS, Safety-Kleen returned on October 6 and 7, 2015 to finish cleaning out the OWS, and complete removal of free liquids (rainwater) from drums located at the Site;

• During routine debris removal activities on September 30, 2015, a second OWS was discovered at the site. Also, a pit located near the northeast corner of the tank area containing an oil/asphalt mixture was also discovered;

• On October 6 and 7, 2015, Safety-Kleen completed cleanout of the previously known OWS; power washed the discovered man-way and evacuated associated free liquids; removed free liquids from drums;

• On October 21, 2015, OSC Turner participated in an on-site meeting with representatives of the Responsible Party (RP), Farmer Environmental, CENPRO, Environmental Management Alternatives (EMA), and Pioneer. The meeting was held to discuss logistics concerning potential beneficial reuse of the asphalt pan materials. During USEPA’s visit, the OSC requested several items be investigated (e.g., subsurface waste piping and pits, a “cistern”, potential underground storage tank (UST) and buried piping from tar processing and storage tanks);

• On November 5, 2015, 3 to 5 pounds of partially spilled liquid mercury was discovered under debris in one of the on-site buildings. This spilled mercury was properly cleaned-containerized and disposed off-site. This newly discovered mercury was added to the 3 mercury switches and one mercury thermometer also found on-site;

• On October 29 and November 18, 2015, OSC Turner and START participated in conference calls related to additional scope-of-work removal work related to asphaltic/tar materials, a newly discovered oil/water separator, the potential recycling of asphaltic materials, removal/closure of existing groundwater monitoring wells and work elements that maybe delayed due to inclement weather thus requiring to be delayed until 2016;

• On November 9 and 10, 2015, all the remaining over-packed drums on-site containing liquids were transported/disposed by Safety-Kleen. A total of 58 over-packed drums (2 used oil, 1 paraffin wax, and 55 asphaltic materials) were removed from the Site;

• On November 12, 2015, a fencing sub-contractor completed the installation of new fence sections on the norther end of the former facility near the offices;

• On November 24, 2015, the investigation of bermed materials along the fence line in the southwest corner of the Site was completed;

• On December 2, 2015, Pioneer completed an investigation of a potential “cistern” near the OWS in the East Field. It was determined that this was not a cistern but yet a manway to a combined storm-water sewer that appears to be connected with the nearby API Oil/Water Separator;

• On December 7, 2015, actions to clean out the trench drain with the oil pit at the northeast corner of the aboveground storage tank farm was completed. Clean rock was placed inside the trench and oil pit;

• On December 8, 2015, railroad ties scattered in the East Field (initiated in November 2015); were consolidated into two piles;

• During the week of December 14, 2015, an additional six inches of soil was excavated in the three soil areas in the north central portion of the Site to remove asbestos and asphaltic oil impacted soils;

• On December 18, 2015, all site work was suspended due to inclement weather and year end 2015 holidays.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

The work is being conducted in accordance with an Administrative Order on Consent. No additional enforcement actions are anticipated at this time. 

2.1.4 Progress Metrics

As part of the start-up of clean-up activities on this site, the Respondent contractors mobilized to the site and initiated site preparations to clean out a metal shed and prepare it for use as a command post which includes field office, breakroom and decontamination station. In addition the following activities were completed:

- The contractors arranged for electrical and water service be provided to support project needs inside the temporary field office and decontamination station.

- The contractors completed the improvements to the build-out of the temporary field office and decontamination station.

- The third-party asbestos air monitoring contractor representative (Farmer Environmental Services) initiated asbestos clearance sampling and asbestos air monitoring.

- The contractors initiated the removal of asphaltic tars on top of the large concrete pad and power-washed the surface to the best extent practical.

- The contractors placed clean rock next to the concrete pad to facilitate ingress/egress of trucks containing drummed materials, ACM and miscellaneous debris. Also, the contractors constructed a truck washing station to facilitate decontamination of all trucks leaving the site.

- The contractors initiated the loading, transportation and disposal of drummed asphalt materials. That same day, ACM abatement work was initiated and will continue as the site debris is removed during the course of this removal effort.

- The contractors initiated removal of liquids and solids from the on-site API Separator. The cleaning of this site feature is expected to extend into the future.

- The contractors arranged for the removal of drummed characteristically hazardous waste liquids stored in drums at the site.

- The contractors arranged for the demolition of all but one building.

- The contractors arranged for the excavation and disposition of asphalt oil impacted soils where the former AST tank farm was located.

- On December 18, 2015, a decision was made to shut-down all remaining removal work due to inclement weather along with end-of-the-year holiday period. Remaining removal work will resume sometime in 2016. Additionally, straw wattles were placed in areas where storm-water flow could potentially carry site soils off-site, and the Site was shut-down for the winter.

- Heavy equipment was picked up from the Site during the week of December 23, 2015.

2.2.1 Anticipated Activities

Ongoing site operations will abate ACM, remove and dispose of all non-hazardous drummed materials along with remove debris scattered across the site.

Sixteen ASTs are currently present at the Site. With the exception of one tank that was used for the storage of propane, the remaining tanks were utilized for the storage of asphaltic materials. Of the ASTs identified, seven tanks are intact with the exception of the tank piping which has been removed. Since the tank piping has been removed, some leakage of asphalt from the tanks has occurred when outdoor temperatures were high enough to lower the viscosity and allow the asphaltic materials to flow. The remaining ten ASTs have been partially demolished and contain residual asphalt products. Prior to removing the ASTs from the Site, any remaining ACMs on the exteriors of the tanks will be properly abated.

Following removal of the ASTs, impacted surface soils will be removed using excavation equipment. Once soil removal activities are initiated, the removal area may be expanded if visual observations of soil impacts (e.g., staining and/or sheen) are noted outside the initial inspection area.

Additionally, an API separator on the east side of the Site was previously observed to contain oily influent water. The contents of API separator will be pumped out and will be transported by a licensed waste hauler under standard waste manifesting procedures to an appropriate disposal facility. The API separator will be cleaned by the removal contractor and any wastewater generated will also be transported to an appropriate disposal facility.

Three to four buildings will be demolished from the site. Most of these buildings are near the front entrance and were the former office, laboratory and shower facilities. Currently the buildings are being cleared of asbestos, waste tars and other debris. Once clearance is achieved demolition will begin.

Various debris are present throughout the Site, particularly in the area of the former buildings and ASTs. The debris generally consists of cinder blocks, bricks, scrap-metal and hardened asphaltic materials. Some retail-sized containers of various chemicals were also observed in various areas of the Site. Most of the debris at the Site was found to contain ACMs. As a result, the majority of the debris at the Site will be disposed during asbestos abatement activities.

2.2.1.1 Planned Response Activities

 During the implementation of the removal action, waste materials will be segregated and removed into the following categories:

• Non-friable asbestos-containing construction debris

• Friable asbestos-containing construction debris

• General building debris – building demolition activities

• Contaminated soils

• Empty drums

• Non-hazardous solid waste drums

• Liquid Mercury

• Hazardous drums (i.e., mineral spirits or phosphoric acid)

• Buried pipes associated to tar processing and storage

• Potential underground storage tank(s)

• Non-asbestos impacted scrap metal

• Asphalt pan materials

The majority of the wastes will be directly loaded into lined trucks or dumpsters/roll-off containers. Any debris that is too large for transport will be mechanically demolished prior to load out and transport. Depending on the location of removal activities, some wastes (i.e., debris, and/or contaminated soils) may be temporarily stockpiled prior to transport and disposal.

2.2.1.2 Next Steps

Continued site operations will abate ACM found in many areas at the site along with the removal of hazardous and non-hazardous waste and miscellaneous debris materials. 

2.2.2 Issues

None at this time. However, inclement weather has forced a site shut down of field removal activities until spring 2016.

Not applicable (NA)

2.5.1 Safety Officer

  All field work conducted at the site is under an approved Health and Safety Plan (HASP).

2.5.2 Liaison Officer

  NA

2.5.3 Information Officer

  NA

3.1 Unified Command

NA

3.2 Cooperating Agencies

Illinois EPA

USEPA                                                     1
EMA                                                         3
Cenpro Environmental Services, Inc.       7
Pioneer Environmental Services, LLC.     1
Farmer Environmental Services, LLC.      1
START                                                      1
Illinois EPA                                                2

6.1 Internet location of additional information/report

 epaosc.org/Pioneer_Asphalt_BTEX_and_Asbestos_Removal

6.2 Reporting Schedule