2.1.1 Narrative
.
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:
4/21/2016: Site Restoration and Removal
Action Demobilization
-
September 22, 2015 - Validated data was released
to EPA from their contract laboratory. START was under task to draft an
Activity Based Air and Bulk Material Sampling Report.
-
December 8, 2015 – OSC requested Region 4
Technical Services Section (TSS) to review the ABS data and determine human
health exposure risk relevant to commercial/industrial reuse. The 10E-4 screening level, comparable to an
RML, is 0.01 f/cc. None of the
detections exceed that number.
-
December 21-22, 2015 – The OSC and START
conducted a site walk to evaluate site conditions and assess if any further
actions by EPA is warranted. The OSC
discusses EPA’s intentions to remove concrete barriers, steel cables,
high-visibility plastic fencing and warning signs with current property manager
(Mr. Larry Allen). The OSC advised Mr.
Allen that EPA would return in the Spring 2016 to conduct site restoration and
reopen the restricted areas on the property.
-
February 9, 2016 - Draft Activity-Based Air and Bulk Material
Sampling Report
Liberty Fibers Site released to OSC for review.
-
April 26 – 28, 2016
- EPA OSC and Emergency Rapid Response Services (ERRS) contractor (CMC, Inc.)
remobilized to the Site to remove 65 concrete jersey barriers from perimeter
locations on the Site and staged them next to the Power House or Grid F-13 per the START Grid Map (see Documents). Approximately 400-yds of steel cable and high
visibility fencing taken down and disposed.
Warning signage identifying areas of asbestos contaminations removed.
-
The Tennessee Department of Environment and Conservation (TDEC) concurrently conducts site investigation of surface water on the Lowland Complex on Nylon Branch and Flat Creek.
-
April 29, 2016 – EPA
OSC and ERRS contractor demobilized from the Site.
-
No further action by
EPA anticipated at the Site at this time
Previous Reporting Period:
POLREP No. 23 - PROGRESS - ACTIVITY BASED SAMPLING
| Date: |
5/30/2015
|
| Reporting Period: |
4/1/2014 to 5/30/2015 |
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.
**** Extended demobilization of personnel and equipment pending ABS data review. ****
POLREP No. 22 – REMOVAL OPERATIONS - PROGRESS
|
Date:
|
3/31/2014
|
|
Reporting Period:
|
10/01/2013 -
3/31/2014
|
Highlights during this period:
10/23/13 -Completed ACM removal from Power House and disposal in the on-site landfill.
11/11/13 - Completed reservoir dam modification next to landfill to allow for no more than 30 acre-feet of -water retention.
11/22/13 - CMC continued scraping surface soil to remove residual ACM and completed establishing stable vegetative cap over on-site landfill.
12/21/13 - Restored natural gas pipeline servicing the Site.
1/14/14 - Demobilized equipment and personnel pending ABS data review.
During this period TetraTech continued visual inspection and clearance of grids and provided perimeter air sampling and Site documentation.
POLREP No. 21 - REMOVAL
OF ACM FROM POWER HOUSE
|
Date:
|
11/6/2013
|
|
Reporting Period:
|
7/01/2013 to
9/30/2013
|
Removal of ACM debris continues
with the focus now on the partially-demolished Power
House. Remaining hazardous materials are being prepared
for disposal.
The Site was demobilized
for the Independence Day Holiday and the Labor Day Holiday in
this reporting period.
Highlights from this period:
CMC provided transportation and disposal of hazardous substances, pollutants or contaminants left in abandoned containers on-site.
During this period:
-
CMC provided transportation and disposal of hazardous substances, pollutants or contaminants left in abandoned containers on-site.
-
9/30/2013 - CMC completed disposal, recycling, or reuse of compressed gas cylinders including hydrogen and trichlorofluoromethane, a roll-off box of RCRA empty containers, a roll-off box of silica, talc, and other spent products, a roll-off box of caustic solids (sodium hydroxide), universal waste fluorescent bulbs, and a pallet of damaged lead acid batteries form a forklift battery.
-
July 10, 2013 - EPA received a letter dated July 10, 2013, from the City of Morristown Chief Building Official condemning the Power House and northeastern portion of the Rayon Filament Warehouse.
-
CMC began demolition of the remaining Power House structure. ACM was disposed of in the Class III landfill on-site and scrap metal was deconned and recycled.
-
CMC had completed removing overhead pipes wrapped in TSI from the Rayon Filament Warehouse. Additional removal of TSI had to be conducted on or about August 26 and September 13, 2013.
-
CMC continued removal of ACM from trenches and shallow channels associated with the Power House.
-
CMC continued scraping surface soil to remove residual ACM.
-
TetraTech continued visual inspection and clearance of grids. TetraTech also continued to provide perimeter air sampling and Site documentation.
POLREP No. 20 – REMOVAL
OF TSE FROM WAREHOUSE AND T&D OF DRUMMED WASTE
|
Date:
|
10/31/2013
|
|
Reporting Period:
|
4/01/13 to 6/30/13
|
ERRS began removing overhead pipes
wrapped in TSI from the Rayon Filament Warehouse. Removal of
the pipes was completed on June 28, 2013.
ERRS asbestos abatement subcontractor performed glove-bag removal of
TSI from warehouse downspouts and completed it on May 23, 2013.
ERRS provided hazard categorization and bulking of over 300 staged
drums and containers. CMC provided disposal, recycling, or reuse
of twenty-one refrigerant cylinders, damaged lead acid
batteries, a drum of a hydrofluoric acid solution, a drum of
potassium persulfate, three drums of sodium hydroxide, and numerous other
drummed waste, a pallet of PCB ballasts, and a roll-off box of hazardous
solids.
ERRS continued removal of ACM from trenches and shallow channels
around foundations.
ERRS continued scraping surface soil to remove residual ACM.
ERRS continued decontamination and recycling of scrap metal.
Lynne McCoy with Wildlife Rehabilitation was on-site June 19, 2013, to
identify the bird of prey nesting on a structure next to the Power House.
She identified it as an Osprey.
START continued visual inspection and clearance of grids. START
also continued to provide perimeter air sampling and Site documentation.
POLREP #19 – ACM DEBRIS REMOVAL CONTINUES
|
Date:
|
9/26/2013
|
|
Reporting
Period:
|
1/01/2013 -
3/31/2013
|
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 ERRS work on the elevated pipe
runs.
The Site was demobilized for the Easter Holiday. There is also a
lack of funding due to the budget sequestration.
Highlights during this reporting period:
ERRS continued removal of ACM from basement sub-structures to the
landfill.
ERRS began cutting segregated rebar pile for recycling.
ERRS asbestos abatement subcontractor began erecting scaffolding around
the afterburner in preparation for gross removal of deteriorated TSI from the
afterburner on January 22, 2013. Gross removal began on February 7 and
was completed on February 14, 2013.
START continued visual inspection and clearance of grids.
ERRS began removing partially demolished portions of the Rayon
Filament Warehouse, mostly consisting of detached steel beams and other
structural members on January 31, 2013.
ERRS began removal of 20 foot sections of overhead pipe bearing TSI on February
12 and completed removal on March 27, 2013.
ERRS continued removal ACM from trenches and shallow channels around
foundations.
POLREP #18 – ACM DEBRIS REMOVAL CONTINUES
|
Date:
|
8/8/2013
|
|
Reporting Period:
|
9/29/12 to 12/31/12
|
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 ERRS work on the elevated pipe
runs.
Highlights during this reporting period;
ERRS 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.
ERRS deconned drums and containers and staged them outside the asbestos
exclusion zone for sampling and bulking activities.
ERRS 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.
ERRS began ACM and debris removal within the partially demolished Rayon
Filament Warehouse on
November 7, 2012.
ERRS asbestos abatement subcontractor began glove-bag work in the partially
demolished Rayon Filament Warehouse on November 28, 2012.
ERRS 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.
POLREP No. 17 – DEBRIS
REMOVAL PROGRESS AND CEILING INCREASE
|
Date:
|
7/24/2013
|
|
Reporting Period:
|
6/9/2012 to
9/28/2012
|
Removal of ACM
debris and glove-bagging every 20 feet and plastic wrapping of the
elevated pipe runs that are identified as asbestos-containing TSI
continues. ACM debris in close proximity to basements is being
pushed into the basements to minimize exposure in anticipation of a funding
shortfall.
Highlights
during this reporting period;
ERRS moved the perimeter snow fence on the northeast side to encompass the
overhead pipe racks leased by Mike Ball on June 14, 2012. Access was
obtained by EPA.
ERRS continues to move ACM to the landfill and glove-bag deteriorated TSI
A fire occurred at the Alumasal, LLC, plant on June 15, 2012
START collected wastewater and sludge samples from on-site clarifiers on
June 21, 2012
START collected sediment samples from NPDES Outfalls on June 27, 2012
START logged drums and containers in remaining structures on-site beginning
July 10, 2012
START collected surface water samples at NPDES Outfalls on July 12, 2012
ERRS began removing ACM from vegetated areas beginning with the northwestern
portion of the Site
EPA meets on-site with TDEC, CMC, and Tetra-Tech to discuss the path forward on
July 18, 2012
START began visual inspection and clearance of grids on July 30, 2012
ATMOS cut off gas service to Alumasal, LLC, due to delinquency on July 30, 2012
OSC provided a site tour to the Morristown Fire Department on-site July 31 and
August 1, 2012
START collected bulk asbestos samples from the Alumasal, LLC, plant on August
14, 2012
ERRS began ACM removal next to the partially demolished Rayon Filament
plant on August 16, 2012
ERRS began to remove ACM from trenches and shallow channels around foundations
running throughout the Site on September 19, 2012
EPA approved a Ceiling Increase and Change in Scope Action Memo on September
26, 2012
ERRS began removing accumulated ACM from basement structures on September 27,
2012
POLREP No. 16 – ONGOING
ACM DEMOLITION DEBRIS DISPOSAL
|
Date:
|
6/8/2012
|
|
Reporting Period:
|
4/21/2012 to
6/8/2012
|
Removal
is ongoing with primary focus on transfer of ACM demolition debris,
bagged ACM material located in Electrical Shop building, and
glove-bag or plastic wrapping of the elevated pipe runs that are identified as
ACM insulated wrap to the on-site landfill/repository for ACM waste.
In lieu of a possible funding shortfall or
operations demobilization, the recommendations that the Bureau of Reclamation
(BOR) provided from their March 2012 site visit/assessment was a contingency to
reduce the ACM source contamination in the three primary areas:
- A) Remove the bagged waste contained in the
Electrical Equipment building and dispose in the on-site landfill
(repository).
- B) Seal and remove the elevated pipe runs that are
thermos-insulated with ACM that are identified as weathered or
deteriorated, and
- C) Remove as much of the remaining ACM demolition
debris, as practical, and present the remaining debris away from the fence
line that cannot be transported to the on-site landfill.
POLREP No.15- ONGOING
REMOVING ACM DEMOLITION DEBRIS AND BAGGED ACM
|
Date:
|
4/20/2012
|
|
Reporting Period:
|
3/22/2012
to 4/20/2012
|
Removal ongoing with primary focus on
removal of ACM demolition debris to on-site disposal and removal and
on-site disposal of bagged ACM material located in Electrical Shop
building.
EPA initiated emergency response action in April 2010 to stabilize site and
control access. Subsequent ceiling increase action memorandums (June 2011
& March 2012) have maintained EPA presence to complete removal of source
contamination (ACM contaminated debris, bagged ACM insulation from RP
abatement), and existing pipe runs wrapped with insulation (in deteriorating
condition) that is ACM.
POLREP No. 14 – REMOVAL
CONTINUES UNDER FUNDING INCREASE
|
Date:
|
3/21/2012
|
|
Reporting Period:
|
2/4/2012 to 3/21/2012
|
ERRS continues transferring ACM
debris to the on-site landfill (See Progress Metrics below).
START continues to manage 8 perimeter air monitoring for asbestos
around the immediate hot-zone of the former plant structures. The
perimeter of the hot-zone is approximately 1.25 miles and includes the power
house and the former rayon manufacturing buildings which are 90% demolished or
partially demolished and the rubble piles contain asbestos.
On March 13, 2012 the Region 4 Superfund Division Director and Deputy Director
was briefed on the current status of the removal action, site issues and
proposed removal strategies moving forward. The briefing was hosted
by the OSC and attended by members of the Enforcement Team, ERRB Chief, and a representative
from the Agency for Toxic Substances and Disease Registry (ATSDR).
The proposed budget and ceiling increase was approved by the Director and is
the fourth (4th) modification to date on Task Order No. 115 and issued on March
20, 2012 that will continue to fund the ongoing removal work. The Scope of
Work was expanded to include removal of deteriorating jacketed (ACM
containing) insulation on elevated pipe/plumbing runs that are located in
and around exposed partially demolished buildings. There is also bagged
asbestos and asbestos contaminated material (ACM), staged in the
former electrical shop by former contract workers for the responsible
party (RP). ERRS was tasked to transferred the bagged ACM waste to the on-site
landfill. The debris removal that began in January
2012 has allowed easy and safer access to the pipe/plumbing
runs. However, debris removal will continue as access
to deteriorating and damaged pipe/plumbing runs are still
limited in several areas of the site. The Emergency and Removal
Branch (ERRB) Branch Chief and two representatives from the U.S. Bureau of
Reclamation (BOR) conducted a site walk with the OSC to observe site
operations and discuss removal goals and production efficiencies to
be implemented under the new funding modification. The ERRB Health and
Safety OSC also conducted a follow up site visit to address
the February 2012 health and safety audit and also advise ERRS and
the Superfund Technical Assessment and Response Team (START) contractor
on the technical details regarding future (high hazard) removal
operations involving the ACM pipe/plumbing removal.
POLREP No. 13 – LANDFDILL
OPENS/ ACM DEBRIS DISPOSAL OPERATIONS BEGINS
|
Date:
|
2/3/2012
|
|
Reporting Period:
|
11/30/2011 to
2/3/2012
|
November 30 through
December16: ERRS completed the final phases of the
on-site disposal cell construction. Perimeter berms were shored and
installation of a subsurface drainage (approximately 700-feet) was
completed. The drainage line (26-in diameter) was a diversion of a
concrete line that runs diagonally under the middle of the former pond.
TDEC regulations prohibit plumbing/drainage structures under landfills.
Additionally, 200-yards of access road was amended from the powerhouse and into
the landfill to accommodate heavy equipment traffic and delivery of debris
scheduled to begin within the first few weeks of 2012. START and
ERRS continued final review and modification of the site work plan
specific to asbestos work and the "clean grid strategy" that will
take work across the site from west to east closing out grids (200-ft X
200-ft.) as each area is cleaned.
January 10 to present: ERRS began debris hauling operations
to the landfill. The START initiated perimeter (8-locations) air
monitoring for asbestos around the immediate hot-zone of the former plant
structures. The perimeter of the hot-zone is approximately 1.25 miles and
included the power house and the former rayon manufacturing buildings which are
90% demolished or partially demolished and the rubble piles contain asbestos.
The OSC is currently working on a Ceiling Increase & Change of Scope
Action Memorandum to request additional funding to continue the removal operations. The
change of scope will focus the removal operations more heavily on the
concentrated areas of ACM debris and elevated pipe-runs that are jacketed with
asbestos insulation and borders the businesses on the south side of the
Lowland Complex.
POLREP No. 12 – LANDFILL CONSTRUCTION
|
Date:
|
11/29/2011
|
|
Reporting Period:
|
7/7/2011 to
11/29/2011
|
August 8-12, 2011: ERRS subcontractor Resolution, Inc. conducted training in
Nicholasville, KY (CMC) to comply with 29 CFR 1926.1101 for
asbestos workers.
August 15, 2011: With verbal access from the RP, EPA and ERRS (CMC, Inc)
conduct initial mobe to site under the Action Memorandum - Request for a
Ceiling Increase and Exemption from the Twelve Month Statutory Limit and $2
Million Exemption for a Time-Critical Removal Action (signed June 20,
1011).
August 15 - Sept 15: Complete installation of site offices,
utilities infrastructure and decontamination trailers &
bays. TDEC, RPPs (Mark Sawyer and Eddie Whelan) & EPA OSC come
to an agreement that the retention pond area is the best choice for the on-site
landfill. Grubbing and preparation work begins in proposed landfill
area. ERRS dewaters pond.
September 22, 2011: Access Letter formally signed by PRP Mr. Mark
Sawyer
September 26 - 30, 2011: Geotechnical work (soil borings) conducted in
the area of the proposed landfill.
November 7 - 9, 2011: Subcontracted survey crew conducts work
on-site in landfill area.
November 14 - 18, 2011: START conducts background sampling in work
areas.
November 21 -25, 2011: Personnel demobilization for Thanksgiving
POLREP No. 11 - 7/6/2011: ADDITIONAL
REMOVAL FUNDING APPROVED
|
Date:
|
7/6/2011
|
|
Reporting Period:
|
6/2/2011 to 7/6/2011
|
During the week of June 27th, the OSC received
concurrence and approved Regional funding from EPA Headquarters to continue
removal operations at the site. Approval was necessary under current EPA
regulations governing asbestos removals of “national significance”.
A Task Order and Scope of Work to continue site operations was recently issued
to the ERRS contractor. On site meetings are scheduled for the week of July
11th with the ERRS project manager and TDEC officials to discuss plan of action
including the pending approval of on-site disposal.
Site security continues on a 24/7 basis
POLREP No. 10 – ADDITIONAL
SITE FUNDING AND EPA HQ CONCURENCE
|
Date:
|
6/1/2011
|
|
Reporting Period:
|
3/11/2011 to 6/1/2011
|
During the week of May 23rd, the OSC
drafted an Action Memorandum to include a funding increase to continue site
operations. The OSC and Enforcement Team briefed the Region 4 Superfund
Director and funding was approved pending concurrence from EPA headquarters
under current regulations governing asbestos removal projects.
Site security continues on a 24/7 basis pending future site work.
POLREP No. 9 – EPA CONTINUES TO EVALUATE
LANDFILL OPTIONS
|
Date:
|
3/10/2011
|
|
Reporting Period:
|
2/3/2011 to 3/10/2011
|
During the week of March 7th, the OSC requested that TDEC review closure plans
from the existing landfills immediately adjacent to the site and found that the
former Lenzig Fibers landfill apparently has three acres of usable capacity for
asbestos and demolition debris. The OSC
and TDEC met with the City of Morristown officials to discuss future plans for
the site.
Region 4 Office of Regional Counsel continues review of PRP bankruptcy review
and enforcement.
Site security continues on a 24/7 basis pending future site work.
POLREP No. 8 – EPA REGONAL COUNSEL
REVIEW BANKRUPTCY & DEED INFORMATION
|
Date:
|
2/2/2011
|
|
Reporting Period:
|
12/14/2010 to
2/2/2011
|
START releases Final Assessment Removal
Report on January 17, 2011 (January 18-22, 2010 multi-media sampling
event). Supports asbestos within debris
piles at the site and identified contents of orphan drums/containers throughout
the site. Raw data from this report was reviewed by the Region 4 Technical
Services Section (TSS) during the Emergency Response Action in April 2010.
The OSC continues to coordinate the next
step of landfill placement and construction with TDEC and Morristown officials.
Region 4 Office of Regional Counsel (ORC) is currently reviewing the potential
responsible parties (PRPs) deed and bankruptcy information from the Liberty
Fibers Bankruptcy Decree during the late 1990's. Placement of the desired ACM
landfill is dependent on the ownership of available land on the 400 acre site
and working with Region 4 Enforcement Branch to come to an amenable and desired
resolution for all parties.
Site security continues on a 24/7 basis pending future site work.
POLREP No. 7- SITE STABILIZATION
& SECURITY CONTINUES
|
Date:
|
12/13/2010
|
|
Reporting Period:
|
11/30/2010 to
12/13/2010
|
ERRS continued spraying asbestos
contaminated debris piles with polymer based lock down agent. Errs also
replaced weathered polyethylene frame windows of the asbestos containment
building with reinforced polyethylene in preparation for winter weather. ERRS
also continued enhancing security measures along the perimeter of the site with
additional steel cable and high visibility fencing. Approximately 5000 feet of
high visibility fencing has been used to delineate asbestos contaminated areas.
In preparation for colder weather, ERRS insulated waterlines to the
decontamination trailer and above ground waterline connections and backflow
regulators. ERRS also continue to assist the OSC with asbestos disposal options
by pursuing possible disposal at local landfills in the area. The cost of
disposing of approximately 400,000 cubic yards of friable asbestos off site
will most likely be prohibitive from preliminary estimates from those disposal
facilities.
Security continues to monitor the site during non-working hours and holidays.
POLREP No. 6 - SITE STABILIZATION
& SECURITY CONTINUES
|
Date:
|
12/1/2010
|
|
Reporting Period:
|
11/1/2010 to 11/30/2010
|
EPA continues to maintain presence and
security at the site in preparations for removal operations. ERRS continued
applying polymer based lock-down agent to ACM contaminated debris piles. ERRS
also continue enhancing security measures along the perimeter of the site with
steel cable and high visibility fencing and erecting warning signage.
EPA and ERRS continues to pursue on-site disposal options for the estimated
400-cubic yards of ACM debris. A local
newspaper reported that the owner of Lowland Recycling attempted to get
property behind the site approved for a landfill but that county officials
turned down his proposal.
POLREP No.5 - SITE
STABILIZATION & SECURITY CONTINUES
|
Date:
|
11/29/2010
|
|
Reporting Period:
|
9/15/2010 to
11/29/2010
|
EPA continues to maintain a presence at
the site with ERRS and security while pursuing and evaluating options for
on-site disposal of ACM debris. ERRS
continued ACM containment measures and completed construction of a waterline to
the site decontamination trailers. Local inspectors approved the waterline
installation after the backflow prevention box was raised to above ground
according to local code and ease for inspection.
ERRs contractors decontaminated an excavator on site which was owned by a Florida
equipment rental company and formerly operated by Lowland Recycling. After
confirmation of the ownership of the equipment, it was released back to the
owner for demobe.
POLREP No. 4 – SITE
STABILIZATION & SECURITY CONTINUES
|
Date:
|
9/14/2010
|
|
Reporting Period:
|
7/15/2010 thru
8/30/2010
|
In late July, 2010, a BASF landfill
trustee reported that the PRP’s contractor was suspected of performing work on
site during a temporary shutdown of site cleanup activities. The OSC received
additional funding to maintain security on site as well as continue mitigation
of the asbestos contamination operations.
Beginning on August 3rd, ERRS enhanced security at seven access points along
the perimeter of the 350 acre site. Concrete “jersey barriers” and steel cable
fencing were installed at vulnerable access points and security was reorganized
to more effectively manage access within the site and in/out of perimeter
fencing. ERRS also continued asbestos containment measures and completed
construction of a waterline to the site decontamination trailers. The local
municipality inspected and approved the water service after slight
modifications to the pressure reduction box were made.
ERRS continues to consult with the OSC over on-site and off-site disposal
options. At this time, off-site disposal
of an estimated 400,000 cubic yards of ACM waste from the debris field at the
site is cost prohibitive and focus continues on on-site disposal.
POLREP No. 3 - EMERGENCYASBESTOS
CONTAINMENT MEASURES CONTINUES
|
Date:
|
7/13/2010
|
|
Reporting Period:
|
6/01/2010 thru
6/30/2010
|
Throughout June 2010 ERRS contractors
continued applying a polymer based lock down agent (811E Lockdown Encapsulant®)
to piles of demolition/salvage debris identified as containing ACM. The lock down agent provides a film over the
piles that prevents asbestos fibers from becoming airborne effective for
several months. The OSC tasked ERRS,
with concurrence from the Tennessee Department of Environment and Conservation
(TDEC) to evaluate property located to the east of the Power House that was
formerly used by BASF for production waste landfill as well as coal ash
impoundment that may be further developed as a landfill to accommodate ACM
disposal.
POLREP No. 2 – EMERGENCYASBESTOS
CONTAINMENT MEASURES CONTINUES
|
Date:
|
7/13/2010
|
|
Reporting Period:
|
5/01/2010 thru
5/28/2010
|
Throughout May 2010, ERRS
contractors initially established a hot zone perimeter around the obvious areas
of demolition and debris piles in order to gain some control over potential
friable asbestos areas. This former rayon plant has several areas where
subsurface structures, manholes and sewer systems were established presumably
to run cooling and discharge water from production areas. ERRS were initially
tasked with marking those subsurface structures for safety purposes.
ERRS contractors then established a decontamination zone outside the perimeter
and arranged to run a temporary waterline from Enka Road (approximately 100yds)
to the decontamination trailer. The primary threat driving this removal action
is the presence of friable asbestos, therefore our next step was to begin
applying a "lock down agent" to the debris piles containing friable
asbestos utilizing Level C protection. The vast majority of friable asbestos on
site is located near the former powerhouse and debris piles along the northern
third (approximately 100 acres) of the site. ERRS contractors have
estimated that the site contains 400,000 cubic yards of asbestos contaminated
building demolition debris.
POLREP No. 1 - INITIAL –
EMERGENCY ACTIVATION TO CONTAIN FRIABLE ASBESTOS
EPA, and contractor support from the
Emergency Rapid Response Service (ERRS) and Superfund Technical Assessment and
Response Team (START) mobilize to the site to investigate and stabilize the
scene involving piles of salvage debris containing asbestos containing
materials (ACM). Site security was also established 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.
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| Asbestos-Containing Material (ACM) |
Demolition Debris |
7,313 loads |
N/A |
Landfill |
Class III Landfill On-Site
|
| Bagged ACM (Electrial Equipment Building) |
Friable asbestos insulation from previous abatement activity |
20,561 bags |
N/A |
Landfill |
Class III Landfill On-Site
|
Glove-Bagged TSI
CMC |
Overhead Pipe Runs |
304 bags |
N/A |
Landfill |
Class III Landfill On-Site
|
Glove-Bagged TSI
NEO Corporation
|
Overhead Pipe Runs |
4,201 bags |
N/A |
Landfill |
Class III Landfill On-Site |
TSI Pipe Removed
|
Overhead Pipe Runs |
37,508 lf |
N/A |
Landfill |
Class III Landfill On-Site |
| Tires |
Solid |
|
N/A |
Landfill |
Class III Landfill On-Site |
| PCB Ballast |
Solid |
788 lbs |
0110488627JJK |
Landfill |
Lamp Environmental Industries (LEI), Inc. - Hammond, LA |
| Hazardous Waste, NOS |
Solid |
16,165 lbs |
011147706JJK |
Landfill |
American Environmental Services, Inc.
Calvert City, KY |
| Hazardous Waste, Acidic |
Liguid |
4 drums |
011147721JJK |
Neutralization |
American Environmental Services, Inc.
Calvert City, KY |
| Hazardous Waste, Basic |
Liquid |
3 drums |
011147721JJK |
Neutralization |
American Environmental Services, Inc.
Calvert City, KY |
| Hazardous Waste, Oxidizer |
Solid |
1 drum |
011147721JJK |
|
American Environmental Services, Inc.
Calvert City, KY |
| Compressed Gas Cylinders |
Gas |
32 cylinders |
010659334JJK |
|
Tradebe Treatment and Recycling, LLC
East Chicago, IN |
RCRA Empty Drums
|
Solid |
18 tons |
1028439 |
Landfill |
Carter Valley Landfill
Church Hill, TN |
Talc and silica powders and unused products
|
Solid |
18 tons |
1297220 |
Landfill |
Carter Valley Landfill
Church Hill, TN |
| Caustic Solids (Sodium Hydroxide) |
Solid |
12 tons |
00001 |
Landfill |
American Environmental Services, Inc.
Calvert City, KY |
| Recycleable |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| Scrap Metal |
Rebar and structural steel from demolition activity |
1,818.67 gross tons |
|
|
Recycle
Tennessee Metals Company
|
| Refrigerant |
Gas |
7 cylinders |
BOL
LF5212013 |
|
Southern Global Refrigeration
Morristown, TN |
| Propane |
Gas |
12 cylinders |
BOL 051613 |
|
Holston Gases
Morristown, TN |
| Used Oil |
Liquid |
1 tote |
011147720JJK |
|
American Environmental Services, Inc.
Calvert City, KY |
| Universal Waste (Fluorescent Lamps) |
Solid |
2,278 lamps |
BOL 4330218 |
|
USA Lamp & Ballast Recycling
Cincinnati, OH |
| Universal Waste (Lead Acid Batteries) |
Solid |
3,364 lbs. |
BOL K058673 |
|
Battery Solutions
Howell, MI |
|
