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2.1.1 Narrative
The Site was discovered by the Solid and Hazardous Waste Division in the Utah Department of Environmental Quality (UT DEQ) during the course of an investigation into three electronics waste recycling facilities operated by Stone Castle in Clearfield, Cedar City, and Parowan, Utah. Stone Castle, the potentially responsible party (PRP) at the Parowan Site, was in the business of scrapping used and donated cathode-ray tube (CRT) television sets on behalf of non-profit organizations and municipalities along the Interstate 15 corridor in Utah. Stone Castle operated at the Site from approximately August 2013 to March 2014, when there was a fire at the Site. After the fire, the electronic waste materials at the Site were abandoned.
The storage of these materials outside led to multiple fires at the Stone Castle facilities throughout Utah, potentially caused by projection television lenses concentrating heat from solar radiation onto flammable materials. The CRT stockpile left outside at the Site caught fire on March 2, 2014, following a fire at the Stone Castle facility in Clearfield, UT, in 2008, and preceding fires at the Stone Castle facilities in Cedar City, UT, on July 8, 2014 and Clearfield, UT, on November 2, 2014. During the fire at the Site, the Parowan Fire Department used heavy equipment to push containerized CRTs and electronic wastes away from the waste materials engulfed in the fire to create a fire break. As a result, there are three discrete piles of material at the Site: burned electronic waste debris containing approximately 340 cubic yards of material, mixed electronic waste debris containing approximately 830 cubic yards of material, and 640 cubic yards of intact CRT televisions in deteriorating corrugated cardboard boxes.
2.1.2 Response Actions to Date
Week of September 29, 2014
On September 29, 2014, after Stone Castle failed to comply with the UT DEQ enforcement order deadline for removing wastes, the property owner contacted the OSC and agreed to provide legal access to the EPA. The OSC immediately tasked the Superfund Technical Assessment and Response Team (START) contractor to perform an assessment and treatability study on the wastes at the Site to determine if a removal action was warranted and feasible. The OSC also issued EPA’s Emergency and Rapid Response (ERRS) contractor a pre-planning delivery order to begin making logistical arrangements for the Site, including gathering recycling and disposal quotes.
Week of October 6, 2014
START received the TDD and provided EPA with a draft work plan for review and comment. START then began to develop the treatability study approach by researching technical literature for viable treatment options for lead-laden substrates. The technical literature and review of the RCRA provisions indicated that some combination of stabilization and solidification techniques might be appropriate and cost-effective for the wastes present at the Site. START developed a Site-specific geospatial information system viewer to display sampling data, field data, and photographs for the assessment. START also developed the Health and Safety Plan and the Sampling and Analysis Plan.
EPA led a teleconference with the project team to discuss the deliverables, the plan for the assessment work and sampling activities, the treatability study and disposal options, and the plan for the Action Memorandum. Following the meeting, EPA coordinated with the property owner regarding the planned assessment visit.
Week of October 13, 2014
On October 13, 2014, EPA’s START contractor mobilized personnel and equipment to Parowan, UT, to conduct the Removal Site Evaluation at the Site. On October 14, 2014, START collected soil samples and samples of each of the debris piles for laboratory analysis and use in a treatability study. START also evaluated the time required to disassemble CRT televisions at the Site to determine the weight of the components. START collected photographic documentation and geospatial measurements of the features present at the Site. START also conducted limited soil metals analysis using a portable XRF instrument. Representatives of the UT DEQ from the Division of Solid and Hazardous Waste were present at the Site during a portion of these activities. START demobilized from the site on October 15, 2014, and submitted samples of the soils and the waste materials collected to laboratories for analysis, once they arrived back in Denver, CO.
Week of October 20, 2014
EPA held a follow-up call with the project team on Tuesday, October 21, 2014, to discuss the treatability study, data collected in the field, and the status of samples submitted to the analytical laboratories. START explained that prior to evaluating the leachability of the waste samples collected at the Site during the Removal Site Evaluation, the materials would need particle size reduction so that the materials could pass through a 3/8” sieve for the Toxicity Characteristic Leaching Procedure (TCLP) method. START sent the samples of electronic wastes to Hazen Research in Golden, CO, to have the materials processed using industrial grinding equipment which was decontaminated after each sample. Some of these processed samples were then treated with monoammonium phosphate (MAP) fertilizer according to the initial approach START developed for the treatability study and submitted to an analytical laboratory for TCLP analysis.
Week of October 27, 2014
START received results from the laboratory for the soil samples collected at the Site which indicated that lead and trace amounts of other metals had migrated into the soils from the electronic wastes present at the Site. The debris samples confirmed that lead present in the CRT glass was leachable and prone to migrate. It also confirmed that the hazardous debris and contaminated soils would need chemical treatment to bind the metals, and that the treated wastes could pass the TCLP in some circumstances, which enables disposal in a solid waste landfill.
EPA held a follow-up call with the project team to discuss the results and validate the deliverables received from START, including the HASP, the SAP, and the Treatability Study SOP. On the call, the team discussed the TCLP results, noting that there were inconsistencies related to treatment that could pose operational and disposal issues in the field. EPA asked START to evaluate potential solutions that would make treatment more effective. ERRS reported on the potential disposal and recycling options for the debris and waste streams at the Site.
Week of November 3, 2014
EPA received word from UT DEQ that the Stone Castle Recycling outdoor CRT storage facility in Clearfield, UT, caught fire and partially burned on November 2, 2014. Regional management engaged and inquired about the status of the treatability study and the potential for a removal action at the Site. The OSC met with representatives from the RCRA and CERCLA enforcement program during which the legal approach for conducting a removal action at the various Stone Castle Recycling sites was discussed.
EPA held another follow-up call with the project team to discuss additional treatability study options for the hazardous debris at the Site. During the call, a second round of treatability study was proposed that included evaluating Portland cement alone and in combination with the MAP fertilizer to see whether more consistent TCLP results could be achieved. Following the call, EPA amended the START TDD to permit the second round of treatability study with the Portland cement. START conducted the second round of treatment on November 7, 2014, and submitted the samples to the laboratory for TCLP analysis.
Week of November 10, 2014
While awaiting the TCLP results, EPA was in contact with ERRS and the Basel Action Network (BAN) regarding recycling and disposal options for the debris at the Site. BAN issued a press release following the fire in Clearfield, UT, that brought additional media attention to the planned EPA removal action in Parowan. As a result, the OSC engaged Public Affairs Officer Rich Mylott and also began coordinating with Community Involvement Coordinator Jennifer Chergo to draft a Fact Sheet for distribution to local stakeholders. The OSC also began drafting the Action Memorandum for the removal action.
Week of November 17, 2014
The OSC completed the Action Memorandum and routed it for review and approval. Regional management made a request for additional funding to EPA HQ for an advance on the FY15 regional removal allowance due to the continuing resolution and other competing projects. There was a follow-up meeting with the RCRA and CERCLA enforcement programs to discuss all the Stone Castle Recycling sites and to give management a clearer picture of the planned removal action in Parowan, UT. RCRA stated that they were working directly with UT DEQ in an attempt to formulate an approach to address the other sites. RCRA and CERCLA enforcement also finalized and sent General Notice Letters to the property owners and the operator at Parowan.
EPA held another follow-up call with the project team to discuss the results from the second round of treatability study, to finalize the operational approach for treating the wastes present at the Site, and to schedule a visit with the property owner and other stakeholders prior to initiating the removal action. During the call, the TCLP results indicated definitively that the combination of MAP and Portland cement at 3% w/w with the hazardous debris was sufficient to meet the regulatory limits and remove the toxicity characteristics from the wastes at the Site (See Section 2.1.4 Progress Metrics). ERRS, START and EPA agreed to pursue the removal action using a horizontal grinder to reduce the particle size of the waste, add necessary moisture, and mix in the MAP, followed by the addition of Portland cement into a pug mill mixer to achieve micro-encapsulation. ERRS initiated the coordination with the necessary vendors, anticipating funding from EPA.
On November 18-19, 2014, the OSC, UT DEQ, and the ERRS Removal Manager visited the Site to discuss the planned removal action with the property owner and provide local stakeholders with information about what to expect. The property owner provided EPA guidance on what materials could be removed and his expectations on the restoration and revegetation of impacted soils. The OSC and UT DEQ representative went door-to-door in the neighborhoods surrounding the Site to talk with homeowners and business owners about the upcoming removal action and provide them with the website address and Fact Sheets. Overall, the community was very supportive of the plan.
Following the Site visit, EPA held a conference call with UT DEQ and RCRA experts to discuss whether there were viable disposal facilities closer to the Site that might be eligible for the CERCLA Off-Site Rule designation. Unfortunately, the closest, the Washington County Landfill, was ineligible since they were not presently filling a lined cell and UT DEQ indicated that was preferable for this waste. EPA and UT DEQ also held a conference call with the Parowan City Manager about the removal action to inform him about what to expect, discuss Site logistics and traffic patterns, and request assistance in gaining access to water supplies for dust suppression. Parowan City officials all expressed support for the plan to conduct the removal action on December 1, 2014.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
2.1.4 Progress Metrics
| Treatability Study |
Sample ID (SCOU1_ _ _) |
| T01 |
T02 |
T03 |
T04 |
T05 |
T06 |
T07 |
T08 |
T09 |
T10 |
T11 |
T12 |
| Size (in) |
3/8 |
3/8 |
3/8 |
3/8 |
3/8 |
3/8 |
3/8 |
3/8 |
3/8 |
3/8 |
3/8 |
3 ** |
| Portland (% w/w) |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
3 |
10 |
3 |
0 |
| MAP (% w/w) |
1 |
3 |
1 |
3 |
1 |
3 |
3 * |
0 |
0 |
0 |
3 |
3 |
| Waste Matrix |
Glass |
Glass |
Burned Debris |
Burned Debris |
Mixed Waste |
Mixed Waste |
Mixed Waste |
Glass |
Glass |
Glass |
Glass |
Glass |
| TCLP Lead Concentration (mg/L) *** |
3.9 |
8.5 |
3.2 |
1.8 |
8.1 |
0.6 |
0.7 |
16.8 |
6.4 |
1.7 |
0.1 |
10.9 |
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| * MAP agent was added in pellet form, without grinding in mortar and pestle** Batch was mixed prior to size reduction
*** Italicized underlined values exceed RCRA regulatory limit (5.0 mg/L) for TCLP Metals
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