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Liberty Fibers

All POL/SITREP's for this site Liberty Fibers
Morristown, TN - EPA Region IV
POLREP #14
Removal Continues Under Funding Increase
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Liberty Fibers - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV

Subject: POLREP #14
Removal Continues Under Funding Increase
Liberty Fibers
B457
Morristown, TN
Latitude: 36.1493481 Longitude: -83.2048083


To:
From: David Andrews, On Scene Coordinator
Date: 3/21/2012
Reporting Period:

1. Introduction
  1.1 Background
   
Site Number: B457    Contract Number: EP-S4-07-02
D.O. Number: # 0115 (Mod 4)    Action Memo Date: 6/30/2011
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 4/21/2010    Start Date: 4/21/2010
Demob Date:      Completion Date:  
CERCLIS ID:    RCRIS ID:
ERNS No.: NRC 937191    State Notification: 4/15/2010
FPN#:    Reimbursable Account #:

1.1.1 Incident Category
Time-Critical Removal Action
Primary Tasks: Consolidate and dispose of demolition debris (and associated waste) containing asbestos. 

1.1.2 Site Description
The Liberty Fibers site (Site) is located at 4855 Enka Highway, Morristown, Hamblen County, Tennessee.  The geographic coordinates for the Site are 36.15580 degrees north latitude and -83.20645 degrees west longitude.  The Site is bordered to the north by a railroad, tree line, and a small residential neighborhood; to the east by a landfill and a retention pond; to the south by the Nylon Staple Plant; and to the west by farmland.  The Site is approximately 1,050 feet above sea level.  The topography of the site is relatively flat.

1.1.2.1 Location
The site is located at 4855 Enka Highway approximately one mile south of Interstate 81 (off Exit 12) in Morristown, Tenn in the Lowland Community.

1.1.2.2 Description of Threat
During recycling activities on April 19th, a debris pile along the southern perimeter caught fire and the Morristown Fire Dept responded. In order to minimize such future events, and to minimize the chance of asbestos exposure, the OSC elected to serve the owner with a Notice of Federal Interest in order to initiate site containment and mitigation measures. The site contains numerous construction debris piles interspersed with friable asbestos.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
Concurrent to the April 19th fire and recent activities on site, the OSC requested that Region 4 Technical Services Branch evaluate asbestos sampling conducted in Jan 2010 to determine if a threat to human health and the environment existed on site. The OSC concluded that the threat exist and preceeded forth with an emergency response action.

2. Current Activities
  2.1 Operations Section
    2.0 Current Activities

ERRS  continues ACM debris disposal operations 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 stratagies moving forward. The briefing was led by the OSC and attended by associated ERRB personnel and management, Cost Recovery, Office of Environmental Accountability, and the Agency for Toxic Substances and Disease Registry (ATSDR). 

The proposed budget and ceiling increase was approved by the Director and the fouth (4th) modification to Task Order No. 115 was issued on March 20, 2012  and will support the ongoing removal work that will include removal of deteriorating asbestos jacketed 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 that was not properly disposed by the responsible party (RP) that will be transferred by ERRS to the on site landfill.  The debris removal that began in January 2012 has allowed 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 from the U.S. Bureau of Reclimatation 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.

 
2.1 Operations Section

2.1.1 Narrative

2.1.2 Response Actions to Date

The Liberty Fibers site is a former rayon fiber manufacturer located in Morristown, Hamblen County, Tennessee.  According to briefing memorandum prepared by the Tennessee  Department of Environment and Conservation (TDEC), Liberty Fibers filed for bankruptcy in September 2005.  A&E Salvage Company (formerly J&N Salvage Company) bought the salvage rights to the Liberty Fibers property in October 2006.  The salvage rights include any and all equipment and materials located on the property and the option to purchase the property.

In September 2006, TDEC, in coordination with EPA, conducted a site visit in response to a tip that TDEC had received regarding demolition activities and the presence of hazardous materials, including polychlorinated biphenyls  (PCBs), on the site.  During the site visit, TDEC observed approximately 24 transformers and 80 capacitors that were labeled as containing PCB oil.  Also in September 2006, the Commissioner of TDEC received a letter from the Mayor of Morristown expressing his concern about the potential for a release of on-site PCBs, asbestos, and other chemicals during the ongoing salvage operations at the site.  During a discussion in October 2006 among representative from EPA, A&E Salvage, Liberty Fibers, the court-appointed trustee, and TDEC, A&E Salvage Company acknowledged that it was owner of the PCB containing equipment and that it would accept full legal responsibility for proper removal and disposal of the PCB equipment in compliance with applicable regulations.

A&E Salvage Company submitted a plan to EPA in January 2007 for sampling and removal of all transformers and capacitors located at the site.  A&E Salvage Company contracted SD Myers to sample the dormant on-site transformers and capacitors, and submit the samples for PCB analysis.  The energized transformers and capacitors could not be sampled until Morristown Utilities later powered-down the electrical lines to the site during renovation of the old lines servicing the site and adjacent properties.  SD Meyers sampled a total of 39 transformers:  4 transformers contained PCB oil, 12 units were found to have oil containing PCBs and the remaining 23 units did not contain PCB oil or residue.  A&E Salvage Company later contracted with Booher Industrial Company, located in Jasper, Georgia to remove and dispose of the transformers.  However, EPA later notified A&E  Salvage Company that Booher Industrial Company was not an EPA-approved treatment, storage and disposal facility for PCB waste in accordance with the Toxic Substances Control Act (TSCA).

In March 2007, A&E Salvage Company held a meeting with IPI Business and Morristown Utilities, during which the City of Morristown decided to annex the Liberty Fibers site and include the site as part of its Urban Growth Boundaries.  As a result, the City of Morristown would be responsible for providing utility services including power and water to the Liberty Fibers site.

In March 2008, the EPA Resource Conservation and Recovery Act (RCRA) and Oil Pollution Act Enforcement and Compliance Branches contacted Region 4 Emergency Response and Removal Branch (ERRB) regarding conducting a removal assessment of the facility.  An EPA On-Scene Coordinator (OSC) reviewed documents submitted by TDEC and scheduled a site visit.  On March 20-21, 2008 the OSC, supported by START,  conducted a site visit with representatives from TDEC, EPA Asbestos, EPA RCRA and EPA TSCA as well as representatives from Liberty Fibers and A&E Salvage Company.  During the site walk, the OSC and START observed several drums, totes, and tanks; bags labeled as “asbestos containing material” (ACM); a 50,000 gallon sulfuric acid tank containing approximately 8-inches of material; known and suspected PCB-containing articles and oils; and suspected ACM; as well as discolored soil throughout the property.  In addition, the Liberty Fibers representative identified the on-site concrete vault that, at that time, contained six 10,000-gallon tanks used to store carbon disulfide, and extremely flammable chemical used in the manufacturing of rayon.  To prevent fire and explosion, the vaults were typically filled with water, submerging the tanks.  The Liberty Fibers representative also identified a leak in the western wall of the concrete vault, which appeared to have left the carbon disulfide tanks only half submerged in water within the vault and, therefore, represented a significant hazard.  Samples collected during this site visit identified surface soil and water identified PCBs and concentrations between 300 mg/kg and 2,500 mg/kg.

In December 2009, an EPA OSC, START and TDEC conducted another site visit with a representative of A&E Salvage Company.  The representative of A&E Salvage Company advised the OSC & TDEC that the carbon disulfide tanks within the concrete vaults had not contained any product, had been removed from the vault sometime in the Spring 2009, and had been sold for scrap metal.  The tanks had been removed because of the potential for explosion.  During that visit, the water had submerged the tanks was still contained in the vault.   The Power Mechanical Shop contained bagged asbestos waste, and the Welding Shop contained PCB-contaminated transformers and capacitors.  Although the facility is partially demolished, the debris fields – mixed with ACM – remain.  Recycling and reclamation operations were ongoing, and at least one metals recycling business was operating on the site.

From January 18-22, 2010, EPA conducted a removal assessment (RA) of the site.  The RA had six objectives: 1-) collecting bulk asbestos samples;  2-) conducting a geophysical investigation in an attempt to identify the location of possible buried transformers;  3-) collection of aqueous and solid waste samples from the carbon disulfide tank vault and surrounding area;  4-) collecting solid waste samples from two neutralization pits; 5-) collecting waste samples from on-site totes and drums; and 6-) collecting personal and area air samples for PCM analysis to evaluate the level of exposure of site personnel to airborne asbestos fibers during the assessment and to determine the concentration of airborne that might be migrating off site.

 

 On April 21, 2010, EPA and START conducted an emergency response site assessment in response to a debris fire on-site.  The fire occurred in the foundation of a demolished cooling tower located on the west side of the site.  An emergency removal action was initiated under the OSC’s warrant authority and   The OSC mobilized the Emergency Rapid Response Service (ERRS) contractor to the site on April 22, 2010. 

ERRS was initially tasked to concentrate on safety related elements of the site including marking and temporarily covering known asbestos containing debris piles and stacked thermal cast insulation from steam piping.  Several of the structures associated with the former rayon plant have been demolished.  However, several of these structures have basement areas which were not readily visible especially when dressed out in Level C and presented a significant safety threat to clean up workers.  ERRS was instructed to mark and fence off those basement containing structure.

In order to minimize the amount of airborne migration of friable asbestos across or off-Site due to windy conditions or during handling of the material, ERRS fixed the friable asbestos fibers in place via application of “lock down agent” on the debris.  This lock-down agent is a water soluble polymer which is a spray-application over debris piles and acts as an adhesive coating and temporarily resistant to weather or minimal disturbance of the material. 

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

EPA has initiated the enforcement process and has identified the RPs for this Site.

2.1.3 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
 Asbestos Containing Material  (ACM) Demolition Debris  1446 Loads  N/A LF Disposal On-Site Landfill
Bagged Asbestos  in Electrical Bldg.  Asbestos: Jacketed Insulation, etc.  25 Bags  N/A LF Disposal On-Site Landfill
 Scrap Metal  Rebar (primarily)  91 Loads  N/A Stockpiled Recycle



  2.2 Planning Section
    2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities

Maintian the landfill and access roads and dispose ACM and associated debris/materials in the landfill.

2.2.1.2 Next Steps

Complete Work Plan for removal of asbestos insulated pipe-run throughout the site within partially demolished buildings and disposal of the bagged asbestos waste staged within the Electrical Building.

2.2.2 Issues

None at this time.

  2.3 Logistics Section
    N/A

  2.4 Finance Section
    No information available at this time.

  2.5 Other Command Staff
    2.5.1 Safety Officer

The OSC (D. Andrews)

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

The Community Involvement Coordinator assigned to the site is Ms. Sherryl Carbonaro.

3. Participating Entities
  3.1 Unified Command

N/A

3.2 Cooperating Agencies

TDEC Department of Solid Waste (Knoxville Office) consults on the design and preparation of the on-site landfill.

4. Personnel On Site
  As of March 15, 2012:

1 EPA OSC  (Andrews/Buerki rotation)
1 START      (P. Prys & B. Erickson : Tetra Tech EMI)
16/17 ERRS  (CMC, Inc)  - 1 Project Manager, 1 Field Clerk, I Foreman, 12 Equipment Operators, 2 Laborers

5. Definition of Terms
  Asbestos - A generic name given to a number of naturally occuring hydrated mineral silicates that possess a unique crystalline structure, are incombustible in air, and separate into fibers.  Asbestos includes asbestiform varieties of chrysotile (serpentine); crocidolite (riebeckite); amosite (cummingtonite-grunerite); anthophyllite; tremolite, and actinolite.

NESHAP - National Emission Standards for Hazardous Air Polutants

AHERA - Asbestos Hazard Emergency Response Act.

6. Additional sources of information
  6.1 Internet location of additional information/report

No Information available at this time.

6.2 Reporting Schedule

7. Situational Reference Materials
  No information available at this time.


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