UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION HI

1650 Arch StreetPhiladelphia, Pennsylvania 19103-2029

jnvi'smSUBJECT: Approval of a Funding Request for Removal Action

at the Allied-Pulaski Site, Pulaski, Pulaski County, VA

FROM: Abraham Ferdas, DirectorHazardous Site Cleanup Division (3HSOO)

TO: Timothy R. Fields, Assistant AdministratorOffice of Solid Waste and Emergency Response (5101)

THRU: Stephen D.Luftig, DirectorOffice of Emergency and Remedial Response (5201)

ATTN: Thomas R. Sheckells, DirectorRegion 3/8 Accelerated Response Center (5201Q)

LISSUE s-/The attached CERCXA Funding Request pertains to the AlU

located in Pulaski, Pulaski County, VA ("Site"). An assessment performed inaccordanccwith the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) bymy staff and Virginia. Department of Environmental Quality (VADEQ) personnel hasrevealed a threat to human health and the environment at the Site due to the presence ofuncontrolled hazardous substances. . . . • '•

Because the conditions at the Site meet the removal criteria set forth in Section300.415 of the NCP and pursuant to EPA Delegation 14-1-A (February 18,1999) givingthe Region HZ Director of Hazardous Site Cleanup Division authority to approveCERCLA removal actions lasting less than twelve months, and costing less than $2million, Ihave approved the use of CERCLA fonds in the amount of $1,601,517 of whichS1,098,793 are Regional Allowance Costs, to remove/contain the hazardous substanceson the Site and to mitigate the threat to public health and the environment

Attachment: Initial Funding Request

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION in

1650 Arch StreetPhiladelphia, Pennsylvania 19103-2029

SEP 81999SUBJECT: Request for Approval of a Funding Request for a Removal Action

ic Allied-Pulaski Site, Pulaski, Pulaski County, Virginia

FROM: CypSrah L. Caspar, Enforcement On-Sloval Enforcement and Oil Section1

TO: * Abraham Ferdas, DirectorHazardous Sites Cleanup Division (3HSOO)

THRU: Dennis P. Carney, Chiefy\,_Removal Branch (3HS o)

L PURPOSE

An assessment performed in accordance with the National Oil and HazardousSubstance Pollution Contingency Plan (NCP) by the On-Scene Coordinator (OSC)icveals that a serious threat to human health and the environment is presented by therelease of hazardous substances and/or pollutants and contaminants at the Allied-PulaskiSite located in Pulaski, Pulaski County, Virginia ("Site"). Analyses of samples collectedat the Site demonstrate the presence of high levels of total lead found in surface coils andasbestos containing materials hi abandoned buildings on the Site. There are two smallcompanies operating on-Site. The employees working at these companies may beexposed to airborne asbestos and lead. A shopping center is located directly to the northof the Site. The shopping center was built on top of process waste piles from the Site.Tne waste piles release acidic/corrosive liquid wastes which cause the transport and therelease of hazardous substances to Peak Creek, which is adjacent to the Site. As a resultof these conditions, immediate removal action pursuant to Section 104 of theComprehensive Environmental Response, Compensation and Liability Act (CERCLA) asamended, 42 U.S.C. § 9604, is needed at the Site.

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II. BACKGROUND "

A. Site Description

The Site is located south of State Route 99 in Pulaski, Pulaski County, VA. TheSite, which originally included approximately 90 acres, now includes approximately 30acres. There are several buildings in various states of disrepair. The Site is located in anarea of mixed commercial and industrial properties. The ground surface generally slopesupward and to the north across the property from the railroad toward the shopping centerlocated to the north, but there are a few low spots where standing water accumulates. Theshopping center, and its parking lot are suspected to be built upon kiln waste produced atthe Site.

There is a wetlands area between the kiln and boiler houses on-Site. Althoughthere was no standing water at the time of EPA's assessment on October 1 3 and 1 4th,1998, outlines left by pooled water were evident and cattails were observed on the northside of the boiler house. Both run-off and groundwater from the Site drain into PeakCreek which borders the property to the south. Wooded properties border the Site to theeast and west Peak Creek empties into Claytor Lake on the New River, a sensitiveecosystem and recreational resource, approximately six (6) miles downstream. The creekis used by area residents for swimming, fishing and boating. Approximately ten thousand(10,000) people reside within 0.5 mile of the Site. The Norfolk Southern Railroad runsthrough the southern part of the Site.

From 1904 until 1976, Allied produced sulfuric acid and ferrous sulfide byreducing pyirhotite ore in a kiln and vanadium pentoxide which was used as a catalyst inthe process. By-products (ash and slag) from the kiln were disposed of on-Site. There isalso ash and sulfur ore piled on the norm side of the kiln building. The manufacturingprocess generated six hundred to seven hundred tons per year of inorganic and acidwastes from 1904 to 1976. The wastes generated from the operations were disposed ofon-Site for a minimum of sixty-four years.

The Site was sold in 1968 to Downtown East Incorporated ("DowntownEast"), a predecessor to DELP.L.L.C., the current owner of the Site. Fromapproximately 1962-1965, pesticides and herbicides were blended at the Site. Themanufacturing facility was leased by Allied from Downtown East in 1968 and Alliedcontinued to operate until 1 976. Since that time, the property has been used sporadicallyfor different purposes including ammunition manufacturing and storage. There are twosmall commercial operations currently existing on Site. A contractor occupies an area inone of the buildings and stores and operates an equipment repair and restoration shop on-Site. An auto repair shop operates in the western portion of the Site. There are severalunlabeled drums, debris and junk in the area of the auto repair shop.

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i During the period between 1976 and 1980, the Virginia State Water ControlL / Board received at least two complaints of red discoloration in Peak Creek. According to

State records, no permit had been issued by the State permitting Allied to dispose ofwastes on-Site. On March 14,1976, the State Water Control Board issued a Notice ofViolation to Allied, for the unpermitted discharge of industrial wastes into State watersand requested submission of a removal or containment plan for the Site. On May 12,1976, a letter was sent to Downtown East, Inc,. citing the same violation. Noenforcement action was taken by the State.

i . In 1983, in response to the complaints and the State's suspicions that thesource of the red discoloration in Peak Creak was attributable to the run-off from the\ raste piles at the Site; EPA conducted a Site Investigation. Several on-Site samples werec ollected as well as sediment and pH samples from the four culverts carrying run-off fromt ic Site. Three of the four culverts had high levels of lead contamination and a pHringing from 4 to 6. On-Site samples collected by EPA also contained high levels ofli*ad. Soil samples collected underneath the tanks previously used for storing the sulfuricacid and later used by Downtown East for storing oil contained poly aromatict ydrocarbons. The State requested that it take the lead in addressing the contaminationat the Site, but no State action was taken. L

On May 11,1990, EPA was again notified by the Virginia Department ofvironmental Quality ("VADEQ") of growing concern about run-off from slag piles atformer Allied Site. The State Water Control Board had sampled Peak Creek upstream

d down stream of the Site and verified it as the source of discoloration into the Creek.On May 16,1990, EPA conducted a preliminary site assessment The waste piles thatwere observed during EPA's 1983 Site Investigation were even more severely eroded andexposed in 1990, permitting migration. The State had requested that Downtown East cap

waste piles or remove them.

On October 13th and 14th, 1998, EPA conducted an assessment as requestedby the State because of continuing concerns regarding red discoloration in Peak Creek.The OSC met with VADEQ in the Roanoke Regional Office prior to accompanyingVADEQ to the Site for the assessment The OSC later returned to the Roanoke RegionalOffice to review their Site files. VADEQ participated in both the October 1998 andMarch 10,1999 assessments.

In the meantime, conditions at the Site have deteriorated. The on-Site erosioncontinues causing continuous releases from the Site's contaminated soils and waste piles |which continue to threaten the environment and human health.

. Quantities and Types of Substances Present

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On October 13 and 14th, 1998, EPAperfbrmed a Removal Assessment at theSite. Lead was identified in seven soil samples in concentrations ranging from 155 parts , ,per million ("ppm") to 1250 ppm, 519 ppm of lead was identified in the wetland area nearthe furnace, 1250 ppm in the east sediment pond, 1180 ppm in the west sediment pond,674 ppm and 750 ppm in the ore dump, 155 ppm in the east culvert which drains intoPeak Creek and 258 ppm in the west culvert which also drains into the Creek. Totaldepth of the soil with high lead concentration is unknown. Lead is a listed hazardoussubstance found in C.F.R. 40 § 302.4. Other listed hazardous substances identified at theSite include aluminum, beryllium, cadmium, chromium, cobalt, copper, manganese,vanadium and zinc.

Asbestos-containing materials were observed at various locations throughoutthe Site and its presence was confirmed by sample analyses. Open bags of asbestos arecontained in the former boiler house. The boiler house is in various stages of disrepair.A former employee of Downtown East stated that 2,200 sheets of "Transite" roofingmaterial, which is known to contain asbestos, were used on the buildings on the Site.Asbestos pipe wrap was also observed. Total quantity of pipe wrap is estimated to be lessthan one ton. Any building containing asbestos, whether hi pipe wrap or contained indisintegrating plastic bags poses a potential threat of release if the building is structurallyunsound.

On March 10,1999, during a structural investigation of existing buildings atthe Site, a pool of standing water between the furnace building and the crusher buildingwas sampled for pH and was determined to have a pH of 2, indicating significant acidity Jat the Site. The water is runoff from the ore-slag piles. A pH of 2-2.5 was identifiedwhen similar areas were previously sampled by the State Water Control Board. Theamount of standing water on Site varies widely, but its presence is common throughoutmuch of the year as evidenced by the existence of wetlands vegetation near the processbuildings. The low pH of the water released from the waste piles and surrounding soilsincreases the solubility of the metals in the waste piles and increases transport off site.The structural investigation also revealed significant deterioration of the buildings'integrity. The potential collapse of some of the structurally unstable buildings on Siteincreases the potential threat of release of any hazardous substances that may becontained within the buildings and the threat of fire and explosion. Both lead andasbestos are hazardous substances listed in 40 C.F.R.§ 302.4.

C. NPL Status

The Site has not been proposed for inclusion on the CERCLA NationalPriorities List ("NPL"), nor is it being evaluated for the NPL ranking at this time.

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D. State and Local Authorities* Role

Prior to conducting the removal assessment on October 13 and 14, 1998, theOSC coordinated with the VADEQ Waste Management Branch. Background' "ormation was provided by the State and the OSC reviewed the State files prior to thescssment Personnel from VADEQ accompanied the OSC during the removalsessment and the structural stability assessment conducted on March 10, 1999. TheSC continues to coordinate Site activities with the VADEQ.

II. THREAT TO PUBLIC HEALTH OR WELFARE AND THE ENVIRONMENT

Conditions at the Site pose an immediate threat to human health, welfare, and1 he environment Section 300.415 of the National Contingency Plan, 40 CFR Part 300,1 sts factors to be considered in determining the appropriateness of a removal action.Section 300.415, paragraphs (b) (2) (I), (ii), (iv), (v), (vi) and (vii) apply to the situation1 bat currently exists at the Site.

300.4 1 5 (b) (2) (I) "Actual or potential exposure to nearby human populations,animals, or the food chain from hazardous substances or

pollutants or contaminants**

Soil samples collected from the Site have revealed high concentrations of lead. Thiselement is toxic to humans, especially children, and is found in areas adjacent to ashopping center. Area shoppers routinely use the Site as a short cut from their residencesto the shopping center. In addition, some people hangout at the top of the waste pile.there are two small businesses located on-Site in areas known to have high levels of lead.One business repairs and restores large earth moving equipment Hie other businessappears to be involved with automobile repair. Hie number of employees is not knowntut exposure to lead occurs on a daily basis for employees working on the Site. Bulksamples have revealed the presence of asbestos-containing materials. Asbestos is toxic to .humans and is a suspected carcinogen. Asbestos poses a threat from the inhalation andingestion of airborne asbestos-bearing particles for persons who enter buildingscontaining asbestos. .

: 00.415 (b) (2) (ii) "Actual or potential contamination of drinking water supplies orsensitive ecosystems**

Kun-off from the Site flows directly into Peak Creek, which flows into Claytor Lake StatePark. The metals, which include lead, aluminum, cadmium, chromium, copper,manganese, and zinc, migrating in the run-off from the Site are harmful to fish andwildlife and threaten sensitive ecosystems. These same metals have been found hi fish

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from Peak Creek and Claytor Lake. Copper, lead, magnesium, manganese, selenium,silver, and zinc, found on the Site, have also been found in sediments in the creek andlake. Claytor Lake and Peak Creek are recreational facilities used for water sports andfishing and are considered a natural resource. The migration of contaminants into thePeak Creek and Claytor Lake are affecting this sensitive ecosystem.

.300.415 (b) (2) (iv) "High levels of hazardous substances or pollutants orcontaminants in soils largely at or near the surface, that may

migrate***

Concentrations of lead as high as 1,650 ppm were found in surface soil samples collectedon Site. Because the Site lies within the flood plain of Peak Creek, there is a highprobability that the contamination will migrate to the creek through surface runoff fromprecipitation and during flooding.

300.415 (b) (2) (v) "Weather conditions may cause hazardous substances or •pollutants or contaminants to migrate or be released**

According to the National Oceanic and Atmospheric Administration (NOAA) records,the average annual precipitation in this area is 37.7 inches. This amount of yearlyprecipitation indicates that surface run-off will continue to cause the migration of lead-bearing particulates.

300.415 (b) (2) (vi Tlireat of fire or explosion"

One of the buildings on-Site caught fire a few years ago. The building is unstable and atrisk of collapsing. Crushed sulfur ore is also in piles nearby. This crushed sulfurpresents a fire and explosion risk. The collapse of any building could cause a threat of fireor explosion.

300.415 (b) (2) (vit) "The availability of other appropriate federal or statemechanisms to respond to the release"

VADEQ has requested the assistance of EPA in abating the threats posed at the Site.VADEQ does not have the resources available to mitigate conditions at this Site.

IV. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances and/or pollutants andcontaminants from this Site, if not addressed by implementing the response actionselected and described in this Action Memorandum, may present an imminent andsubstantial endangerment to public health, or welfare, or to the environment

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V. PROPOSED ACTION AND ESTIMATED COSTiA* Proposed Actions

The objectives of the proposed action are to mitigate direct contact,inhalation, and ingestion threats posed by asbestos and lead contamination at the Site. WeAlso want to address the threat of lead migrating to surface waters; fire and explosionthreats from the crushed sulfur ore; and the threat of asbestos emissions from the collapseof structurally unsafe ouildings on-Site. The proposed action consists of the following 'Activities:

1 . Mobilize personnel and equipment and establish Site command andsecurity facilities;

2. Install a fence to secure the areas of contamination and to reduce thethreat of exposure to the public posed by direct human contact with the •contaminants;

3. Minimize the release of hazardous substances into nearby surface watersby constructing/installing silt fencing in areas of heavy erosion and run-offand temporarily stabilizing piles with an appropriate covering and/or cap;

4. Determine the extent of contamination at and near the Allied property;

5. Conduct controlled demolition of buildings nos. 3, 5 and 7 which havebeen classified as unsafe and structurally unsound. Demolition of buildingsno. 1 and 6 is recommended as the cost effective method for removal ofmaterials contaminated with asbestos, lead dust and sulfur from the kiln(no.3) and crusher buildings; .

6. As feasible, remove from the Site hazardous substances, pollutants, orcontaminants from soils, tanks, pipes, vessels, pits, equipment, sumps, drams,floors, and other areas posing a threat of release and stabilize such hazardoussubstances, pollutants or contaminants to minimize releases and threats ofrelease, where it is not feasible to remove such substances, pollutants orcontaminants;

7. Conduct transportation and disposal of hazardous substances, pollutants,or contaminants (offsite disposal shall occur in accordance with theCERCLA and the orTsite disposal rule);

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8. Identity and properly dispose of all friable asbestos containing material;W

9. Remove all lead contamination above concentrations of 400 parts permillion (ppm); and,

10. Demobilize personnel and equipment from the Site.

B. Contribution to Remedial Performance

At this time, the Site is not on the NPL. There are no plans for long-termremedial action. Hie proposed removal activity is expected to eliminate the threats onSite that meet the NCP criteria for a removal. The proposed action will not impede futureresponses at this Site, based upon available information.

C. Compliance with Applicable or Relevant and Appropriate Requirements

The proposed Removal Action set forth in this Memorandum will comply tothe maximum extent practicable with applicable or relevant, and appropriateenvironmental requirements. In regard to asbestos at the site, said material, whereappropriate, shall be handled and disposed of pursuant to 40 C.F.R. Part 61, Subpart M,Section 61.140-61.157. EPA contacted the Virginia Department of Waste Management'sSupervisor Aziz Faramond requesting that the State provide EPA with the State's ARARsby August 1999. ,

D. Estimated Costs

Extramural Costs

ERRS $955,472.00

15% Contingency $143,320.80Regional Allowance Costs $1,098,792.80

Other Costs not Funded from the Regional Allowance SATA $7,778.00(Roy F. Weston, Inc., Technical Assistance Team)Subtotal Extramural Cost $1,106,570.80

15% Contingency of Above Costs $165,985.62Total Extramural Costs $1,272,556.42

Intramural Costs $72,000.00Intramural Direct Costs ____________________$256,960.00

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TOTAL PROJECT CEILING ESTIMATE „ ' $1,601,516.42

VI, EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BERELAYED OR NOT TAKEN

If no action is taken or if action is delayed, the direct contact, inhalation, andingestion threats posed by the Site to the nearby populace will continue. Unlessmitigation of the source of contamination is conducted, continual infiltration of leachablelead and other hazardous metals (aluminum, cadmium, copper, chromium, iron,magnesium, manganese, and zinc) associated with the ore and waste piles into the watertiible will occur. Furthermore, should the surface material remain exposed anduncontrolled, contaminant migration will result from the erosion and runoff of the sourceareas.

iVII. OUTSTANDING POLICY ISSUES

i| There are no outstanding policy issues pertaining to the Allied-Pulaski Works

Site.

ENFORCEMENT STATUSVH.

Information available to pursue any and all Enforcement Action pertaining totlie Site is included in the attached confidential Enforcement Addendum.

1C RECOMMENDATION

Because conditions at the Allied-Pulaski Site meet the NCP criteria for aremoval, I recommend your approval of this request for $1,601,517, of whicha; jproximately $1,098,793 are regional allowance costs. Please indicate your approval ord sapproval by signing below. I recommend your approval to initiate response actionbecause of the nature of the threat described herein.

APPROVED O&Xfr/vvy, \1 jz X - DATE

DISAPPROVED ._____________DATE

Attachments: Site/Sampling MapsAnalytical Summary

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Analytical SummaryPhotographic Documentation

Attachment A

Site and Sample Location Maps

10

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Allied-Pulaski TDD No. 9808-011Piilaski, Pulaski County, VA_____________ EPA Contract No. 68-SS-3002

Sateli

Figure 1 - Site Location Map.

0 SITE ACTIVITIES

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Attachment B

Analytical Summary

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Attachment C

Photographic Documentation

12

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Allied-Pulaski Site

Structure No. 1Photo No. 1

Roof partially collapsed / I Wall sheeting damaged

Structure No. 2Photo No. 2

Cracks in external wall

Allied-Pulaski Site'\ Structure No. 3

General viewPhoto No. 3

Photo No.4

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Allied-Pulaski SiteStructure NoT 3

Photo No.5

Bowed wall supporting stack

Photo No.6

Cracks in the stack structure

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Allied-Pulaski Site

Structure No. 3Photo No.7

Collapsed bearing walls in stack building addition.

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Allied-Pulaski Site

Structure No. 4General view Photo No.8

Photo No. 9

Vertical crack in none bearingexternal wall

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Allied-Pulaski Sitef.' '*''

Structure No. 4Photo No. 10

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Vertical crack in none bearingexternal wall

Photo No.ll

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Allied-Pulaski Site

Structure No. 4Photo No. 10

Vertical crack in none bearingexternal wall

PhotoNo.ll

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Allied-Pulaski Site

;*'-'•:• Structure No. 4 | <VPhoto No.12

Cracks in the arch header

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Allied-Pulaski SiteStructure No.-5

Photo No.13

Unstable wall

Photo No.14

Unstable wall

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Allied-Pulaski Site''' s-

Structure No. 6

Photo No. 15

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sedroof

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Allied-Pulaski Site

Structure No. 7

Photo No.17

Collapsed external walls

Allied-Pulaski Site

Structure No. SGeneralview PhotoNo.18

Photo No.19

Weakened column

Allied-Pulaski Site

Structure No. 8

Damaged roof sheathing

Photo No.20

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W

Allied-Pulaski Site

Retaining wallPhoto No.21

Damaged retaining wallPhoto No.22

Cracks in retaining walls

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