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COMMONWEALTH of VIRQINIADEPARTMENT OF ENVIRONMENTAL QUALITY

Easl Main Sue*. Richmond Virgim* 23219PO Boi 10009. Richmond Virgini» 23240> 698-4500 TDD (8W) 698-1021hup://wv,w.d«i.H»le,va.u»

June 10, 1997

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Thomu LDh[eaor

,80*) 69fMOOO1-800.592-3482

Mr. Mike GiurannaRCRA State Programs Branch (3HW60)United States Environmental Protection AgencyRegion IH841 Chestnut BuildingPhiladelphia, PA 19107-4431

Dear Mike:

As we discussed, the Virginia Waste Tire Management Program has made tremendous in-roads in solving the waste tire management problem in Virginia. We have 13 processors in ornear Virginia, 75 registered waste tire transporters and 32 end users of Virginia tire material. Theinfrastructure is in place and most of our "current flow" (daily generation tires) are being handledcorrectly. Now, we need lime and money to clean up remaining tire piles through these newlycreated resources.

If funding was available, we would be interested in having EPA participate in the clean upof the Keeling Tire Dump in Roanoke County, Virginia (Virginia pile #161001), estimated tocontain over 3,000,000 tires, most located in deep mountainous ravines, covered with dirt andvines; clean up cost is now estimated at 53,300.000. Our resources are such that we could neverpay for such a costly clean up.

Enclosed are several documents concerning the Keeling pile. Please call me at (804) 698-4215 to discuss this matter in more detail.

Thank you for your consideration of this project.

Sincerely,

R. Allan Lassiter, Jr.Manager, Waste Tire Program

enclosures

An Agem.y of ihe Natural Resources Secretariat B R U 0 0 0 0

HAZARD PREVENTION PLAM< KEELING .

I. Site Description:

A. Physical Attributes

Willie Keeling owns several pieces of property in RoanokeCounty. Willie Reeling's property is zoned AG-l, agricultural, ishilly with a ravine at the entrance and two unnamed tributariesthat run through the middle of the property and empty into BackCreek. Back Creek runs into the Roanoke River which flows intoSmith Mountain Lake. There are a few subdivisions which connect tothe east side of willie Keeling's property. Brandervood and KingsChase, with approximately 70 building lots in Kings Chase,subdivisions, are both located on Buck Mountain Road. Wil-lieKeeling owns a total of 139.41 acres of land, which eithersurrounds the property where the tires are located or contains tirepiles. The estimated population within a half mile radius is 549people/sq mile. The property is mainly wooded with several clearedareas. There are a few areas where buildings are located. Lot t97.04-1-6 and 97.04-1-7 contain buildings located off the entranceroad. There are other buildings located on lot / 97.04-1-3 whichcan be reached by the entrance road. The entrance to the propertyis located off starlite Rd. at a sign on left "Keeling 7092". Thisis a dirt road, with some gravel mixed in at places, which goes upand over the railroad tracks. A pipeline runs through the eastside of lot / 97.04-1-2 and on the south portion of lot / 97.04-1-3and 97.O4-1-5, the eastern section of the lot. The pipelineparallels tire pile 2 and an unnamed tributary, which is believedto run into another unnamed tributary that flows into Back Creek.A survey was completed of the site on 6-25-93 (Attachment 1) .

B. Past History

1. The previous owners of Parcels 97.00-1-4, 97,04-1-3, and97.04-1-2 were jointly owned by Walter Keeling (the deceasedhusband of Tobey Keeling) who owned the property Jointly with GreenWard, Laura Neil Keeling Blaney and John Calvin Blaney. Thisproperty was turned over to Willie Keeling on October 15, 1964 towillie Keeling. Parcel 97.04-1-7 was previously owned by John coleEdwards, and parcels 97.04-1-5 and 97.04-1-6 was owned by N.B.Hendrick and Mollie J- Hendrick. The parcels were originally zonedagricultural, but later after willie Keeling bought the property itwas changed to M-l, light industry, for a short time and than

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reversed back to AG-1, agricultural.

2. The following was obtained from the Roanoka countyDepartment- of Planning and Zoning, which is a chronology ofenforcement action, which they are aware of, list dating from 1964to 1992: i

10.

11.

1964

1970

1972

1974

1975

1975

1975

1975

1981

1983

1984

1985

1985

14. 1985

Mr. Keeling'a property approved for M-l, light industryzoning to permit tire recapping and sales.

Property downzoned and returned to A-l, agriculture;use became non-conforming

Lawful non-conforming use status expired

First tire fire reported on November 28

Second tire fire reported on March 18

Third tire fire reported on June 10; State Air PollutionOffice issued first notice of violation (Due to the 1985flood many of the records throughout the area were lost.Evidence shows that the Notices of Violation may havebeen issued by the RoanoXe County Air Pollution controlOrdinance, and not by the State Air Pollution Office.)

Fourth tire fire reported on September 24

Fifth tire fire on December 8; State AirOffice issued second notice of violation

Pollution

County Engineer ordered Mr. Keeling to obtain Countypermit for erosion control and landfill operation.

In December, the zoning administrator inspected propertyand notified Mr. Keeling of dumping violation; referredto State Air Pollution Office.

In January, ,state Air Pollution office referredviolation to State Division of Solid Waste Managementwho informed Mr. Keeling of the need for a State permitto dump.

In February, the zoning administrator inspected propertyand notified Mr- Keeling of continued violation.

In August, Mr, Keeling applied for a special permit tooperated a landfill (not including tires)

State passed legislation authorizing Board of Health toprovide technical assistance to localities in

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regulating the stockpiling; Board passed resolution inApril requesting assistance from Stata

15. i985r__In September, the County asked the State Division ofSolid Waste Management, to provide guidelines for a localordinance and to assist with Mr. Reeling's dumpingviolation; State implied that guidelines areforthcoming and that tire dumping violations depend onlocal ordinance and enforcement actions.

16. 1985 In October, Mr. Keeling's special permit was first heardby the Board and continued until Board could confer withstaff

17. 1985 In October, State Water Control Board informed ofvarious tire dumping violations; County was referredback to Division of Solid Waste Management.

18. 1985 In October/ Mr. Keeling applied for business license tosell and recap tires; permit denied for improper zoning

19. 1985 In November, Mr. Keeling's request for a Special UsePermit in order to operate a landfill was denied by theBoard of Supervisors

20. 1986 In April, Mr. Keeling was notified by ainil of the zoningand permit history of his property. The followingmonth, the Revenue Commisioner confirmed the absence ofrequired business licenses.

20. 1986 In April, Mr. Keeling was notified by mail of the zoningand permit history of his property. The followingmonth, the Reyenue Commissioner confirmed the absence ofrequired business licenses

21. 1986 In May, Mr. Resoling was cited for illegally operating alandfill, unlawfully disposing of rubbish, andmaintaining a public nuisance

22. 1986 In July, Mr. Keeling was convicted on all counts, fineda total of $1600 and received a suspended six-month jailsentence. He was ordered to allow no further dumpingand to engage in no tire sales, manufacturing orrecapping.

23. 1986 In December, Mr. Keeling failed to appear on his ownappeal to Circuit Court. Judge Clemens orderedforfeiture of prior bonds and ordered Mr. Keelingarrested in liau of posting a $5000 security bond

24. 1937 in May, following several court continuances, staffmeetings with Mr. Keeling, his attorn*/, and state wastemanagement officials, Judge Clemans ordered SlOOO-53000

_____ be spent by Mr. Keeling on tire removal and generalcleanup.

25. 1987 By August, Mi:. Keeling claimed to have removedapproximately 4000 tires. He also had receipts andinvoices verifying expenditure of several hundreddollars.

26. 1988 In April, Judge Clemens advised Mr. Keeling of a sixmonth period within which he could davisa and operate atire shredding machine

27. 1988- It became clear that the expense of building and1989 operating a shredder on even a small scale was beyond

Mr. Heeling's means.

28. 1991 In September, Mr. Glenn McCormick contacted the RoanokeCounty Department of Planning and Zoning stating hisintention to establish a partnership with Mr. Keeling inthe construction and/or operation of a tire shredder.Mr. McCormick hoped to acquire a grant from the VirginiaDepartment of Waste Management for the disposal andrecycling of scrap tires.

29. 1992 In January and February Mr. McCorraicJc expressed hisintent to acquire necessary approvals from RoanoXeCounty (including Us« Not Provided For and Special Usepermits to operate a tire shredding and recyclingfacility) and the State Department of Waste Management.Also at this time, a written temporary order regardingtire shredder testing and property cleanup was drawn upby the County Attorney at the request of Mr. McCormickand presented, to Judge demons. Neither Mr. Keeling norMr. McCormick has ever applied for the appropriatecounty permits nor have they revived any state grant

* List of convictions noted by the Roanoka Planning andZoning Department (Attachment 2).

c. Current Use

1. Owners of the property ara as follows

Lot if97.00-1-497.04-1-2

Acres6. 38

71.70

PropQ

A R 1 4 0 0 0 0 5

97.04-1-397.04*1-597.04-1-6

'—97.04-1-7

39.0710.265.796.21

Note: Et Als. refer to: C/0 W J Sutina Mary JulannKeeling

Adjacent Property Owners:Lot97. DO-97. 00-97. 00-97, GO-97. 00-97.02-97.03-97.03-97. OS-97. 03-97.03-97.03-97.03-97.04-97.04-

Nota:

Acres Property Owner•1-1•1-2•1-3•1-5•1-6•1-4•1-1•1-21-31-41-5•1-61-71-41-1 117.83

ET UX: refers to the husband or wife.Lot # 97.03-1-1 is an escheat property (propertyowners could not pay taxes, so land was taken away)and it will b« sold. There is nothing on theproperty at the present time.

* Current property owners as of 1-21-94 (Attachment3 & Map 1 & 2 (The location of the tire site on map2 has been plotted wrong, this map is to give ageneral overview of the surrounding area)).

Millie Keeling is the operator of the property and is using itto store tires on, which ha hauls in from the surrounding areabusinesses. Mr. Keeling's current mailing address and phone numberare 1113 Franklin Rd. Roanoke VA 24016 and (703J 342-6206.

2. The tires were brought to the property by Willia Keeling,who was paid to remove tha tires from businesses which accumulatedthem. He has been working on a tire shredder from about 1989, buthas failed to gat the shredder running. Keeling planned onshredding the tires, and using the shredded material to makesandals. Mr. Keeling applied for a business license in October,1985, to sell and recap tires, but he was denied for improperzoning.

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3. Mr.. Keeling has been picking up used tires from severalcounties throughout the, years. Known businesses that Keeling haspicked up tires from in' 1993 include: Economy Tires at 205 24thSt. NW Roanoke (Sam Webb is the manager, and it is owned by GeraldHarris) ; Ttoore Tire Company at 1860 S. Jefferson SW Roanoke ( Ownedby Clyde Moore Jr. , managed by Odee Hor.ton) ; Tire Center at PO Box240 Pulaski Co. (Owned by Emmry Price. Goodyear in Salem).(Attachment 5) .

D. Tire Pile survey results

1. It is estimated, by DEQ, that there are 2.8 million tiresat this site. There are several piles which are separate from eachother, and are located throughout the property. There is a pile oftires in a ravine located between the railroad tracks and thebuildings on top of the hill on lots * 97.04-1-2 and 97.04-1-7.This pile of tires contains some mixed waste. There are two otherpiles of tires, located on both sides of the dirt road leading backinto section 97.04-1-3. Piles on both sides of the road arestacked back into the woods, and the tires are placed on piles ofcrumb rubber. The crumb rubber runs parallel to the tires on theside of the road for about 200 feet. A list: of all the piles oftires and the number of tires in each pile is listed with the map,willie Keeling Site, Roanoke County, in the back (Map 3).

2. There is evidence of tire burning on the site, and theDepartment of Planning and Zoning has noted five separate tirefires on the property, but the Fire Department/Public Safety Officahas no records of these fires. Many of the records in the areawere lost in the 1985 flood, which may explain why the FireDepartment has no records of the fires at Willie Keeling'sproperty, willie Keeling may also have put the fires out himself.The first tire fire occurred on November 28, 1974; the second tirefire was reported on March 18, 1975. The Air Board letter to Mr.Keeling, dated March 21, 1975, indicates that according to the FireDepartment Mr. Keeling knew of the fire at 3:00 am, but neglectedto report it until 8:00 am (See Attachment 6). The third tire firewas reported on June 10, 1975. The fourth tire fire was reportedon September 24, 1975, and the fifth tire fire was on December 9,1975, at which time the Roanoke County Air Pollution Office issueda third notice of violation. The first two notices have not beenfound, probably due to th<a flood, but the third notice and a letteris in the back (Attachment 6) .

3. This is currently an active site, but in July 1986 Keelingwas ordered by the courts to allow no further dumping and to engagein no tire sales. Neighbors, however, have observed Mr. Keelingbringing tires onto the property and DEQ officials, during a siteinspection on June 25, 1993, observed a truck loaded with tires.Several businesses, which are noted in section II.C.4, haveconfirmed that Keeling continues to pick up their tires after thecourt order of July 1986.

II. Hazard Prevention Plan

A. Stakeholder t Motivations

If a plan of enforcement were to be implemented there is ahigh probability that the tires would be sat on fire, due to pastevidence. It is highly unlikely that Mr. Keeling would report thefire until several hours after initiation. According to R.w.Sanders of DEQ, Division Air, Mr. Keeling has also been known toset animal traps around the sita of the fire in order to preventany person or animal from getting into the area. This has been theexperience of a state trooper who responded to a fire call on hisproperty in 1975. Since Mr. Keeling has been actively dumping onthe property even after being informed that it was against stataregulations, a court order will probably be necessary to put a stophim from further dumping.

B. Property Value/Clean Up

It is unclear whether or not Mr. Keeling has the financialcapabilities to clean up the site. There are back taxes owed oneach piece of property owned by Mr. Keeling. As of 1/26/94 thefollowing property lots had accumulated back taxes:

Lot f

97.00-1-497.04-1-297.04-1-397.04-1-597.04-1-697.04-1-7

Accumulated Tax

S 589.332,635.411,932.21609.60

1,415.302,172.04

Land Value

5 7,20035,60026,8007,5006,90015,300

Building Value

MANAMANA

S 12,60014,900

c. Tire Fire By-Products

1. Tire composition generally contains natural and syntheticrubber polymers, oil, fillers, sulfur and sulfur compounds,phenolic resin, clay aromatic, naphthtnic and paraffinic oil,fabric, petroleum waxes, pigments such as zinc oxide and titaniumdioxide, carbon black, fatty acids, inert materials and fiber madefrom steel, nylon, polyester or rayon.

2. Uncontrolled burning of a scrap tire pile produces a denseplume of smoke, which contains many incomplete combustion productsincluding a wide range of pyrolytic hydrocarbons and ash residues.Concentrations are often above 1 ppra. Decomposition products of atire fire are extensive and varied and depend on such things as thetype of tire, burn rate, pile size, ambient humidity and other

(\Rl400008

factors. The following are generally found In smoke plume samples

Sulphur Dioxidecarbon Monoxide coal Tar Pitch VolatilesBenzenesToluene Leadstyrene ZincXylenes CopperEthylbenzene ChromiumEthyltoluene CadmiumMethylene Chloride Iron1,1, 1-trichloroethane ChrysaneAcetone FluoreneHeptane AnthraceneHexene Phenanthren*Pentan* B«nzo(a)pyr«naNapthalene Pyrenepolychlorinated dibenxo-p-dioxinspolychlorinated dibenxofurans (PCDD/F's)

Incomplete combustion products, lower burn rates, would includemainly polyaromatic hydrocarbons. As the burn rate increases, theamount of CO, SO and unburned hydrocarbons also increases, but witha decrease in the burn rate there will be an increase in the amountof organics emitted. At high burn rates most of tha compoundsreleased are aliphatically, olefinically or acetylenicallysubstituted aromatics. The following are also identified:

cyclic and chained alJcanesalXenesdienessulfonatednitrogenated compoundssubstituted thiophenesisocyanobenzenebezodiazina

3. It is estimated that when a tire burns approximately .6 to2 gallons of pyrolytic oil from a passenger tire may be released.Therefore, a maximum release of 5,6 million gallons of oil runoffis possible. Fallout from the fire may rain down into surfacewaters with various organic compounds. Embers of burning rubbermay travel for great distances and will need to be controlled. Anywater used for suppression would likely be contaminated and effortsto collect run-off must also be made. Rain occurring during thetire fire will likely cause a fallout of potentially hazardousorganic compounds onto the area below the smokft plume.

f l R l j O Q O O S

Tire fire oil and run-off products in nearby streams at theWinchester tire fire were analyzed by the Virginia Division ofConsolidated Laboratory Services and the surface water downatr«amof the fire wag found to contain the following:

Benzonitrile N/N-DinethylbenzamideAcetophenone Benzoic Acidp-Tolunitrile 3-Toluic AcidNapthalene 3-Cyanobenzoic Acid2~(2-n-Butoxyethoxy) ethanol CaprolactanN-Methycaprolactam 2-M»thylb«nzothiazolaBenzothiazole

It was surmised that these water-soluble pollutants wereextracted from the oil by the water in the oil containment pondsand then spilled or leaked into the stream. There was a highlytoxic effect on all life in the stream to a point one kilometerdownstream and levels of pollutants tended to increase downstreamfollowing rain.

Other compounds identified at tire sites include:

cyanide xylenephenol ammoniapolynuclear aromatic hydrocarbons (PAH)polychlorinated dibenso-p-dioxinapolychlorinated dibenxofuransvolatile organic compounds

* Information for the TJre Fire By-Products was obtained from:

1. Analytical Chemistry in Hell: the 1990 Hagersville Tire Fire2. Background Information on Benzene, PAHs, Dioxins and Furans

and Review of the Potential Health Risks associated with the"Tyre King" Fire

3. Guildlines For The Prevention And Management of Scrap TireFires

D. Site Clean-up

1. Currently there is only one dirt road, which has somegravel mixed into the road, leading up to the property and tires.This road crosses railroad tracks and is fairly steep at theentrance. Leveling the road at the entrance would allow emergencyvehicles batter access to the site. The road leading east to piles1-6 will need to be improved and have adequate room for two wayvehicle access. The road should be 18 feet wide, and have a gravelbase for all weather emergency access and have nodes with a turningradius of 50 feet. An erosion sediment control plan, and a plandealing with the placement of road and culvert will need to besubmitted to the Roanoke County Planning and Zoning office. The

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improvement of this road from the entrance point on Rt 615 to thepipeline is approximately 7/10 of a mi la or 3,696 feet. A roadleading up above pile 2, on the vest side of the pile, will need tobe cut, _£ith a gravel base. This road should connect with thepipeline and have a second turning radius of 50 feet at the pointof connection with the pipeline (All roads and turning radius of 50feet will be based on specific site characteristic* such aslocations or tire pilas, buildings, obstructions, and sitetopography.)- The remaining soil, from cutting the road north ofpile 2, should be positioned at various points on the property foruse during a fire. The soil obtained from building th* road northof pile 2, should be placed near each entrance so that it can bereadily obtained in the event of a fire. If more soil is neededduring a fir« it can be obtained from different area on site. Thisdetermination will be made by the Fire Department. The road leadingwest of pile 2 will be approximately 4/10 of a mile or 2,112 feet.

The roads will surround the outer perimeter of the tire pilesand the outer perimeter should be maintained for vehicle access.A second entrance should be cut into the property, by using a roadfurther south on Rt 615 (Starlight Lane). The second entrance isapproximately 1 mile south of wilie Reelings property entrance "andis on the east side of the road. The entrance looks like adriveway, and is located after crossing the second bridge. Thisroad should connect with the existing road which leads past thebuildings on tha Keeling property. To improve the existing roadand make a connection to the road on the Keeling property it isapproximately 3/4 to 1 mile (5,280 feet) from the entrance to thetire site. The road should have a 50 feet turning radius at thepoint of intersection with the Keeling property.

A petroleum pipeline runs east/west on the land sections97.04-1-2 and 97.04-1-3. The land over the pipeline is cleared,and has grass growing on it. Pile 2 is located adjacent to thepipeline easement/right of way. The pipeline easement/right of waymay be used as a road for entrance to the east side of the propertyif necessary. If the pipeline is to be used only light equipmentshould be allowed. No heavy dozer equipment should be used, suchas a DB or a D9. However, if the pipeline is used as a road, firstcontact the owner, Plantation Pipe Line Company, Atlanta GA (404)261-2165. The Roanoke Terminal number is (703) 774-2994, and forimmediate help call (910) 852-7333. (Pipeline is shown on map 3,Tire Map).

Emergency vehicles should have access a* close as 100 feet toall tire piles. Maintenance of the roads should be year round, andthere should be no obstructions in the road at any time. Avertical clearing of 14 feet should be maintained on roads forvehicle access.

2. The construction of an eight foot chain linked fence, witha 20 foot open width should be constructed at all entrances of the

10

AFHOQQ

property. Currently there is a main entrance on Rt 615 (StarlightLane), and future plans include an entrance approximately 1 milesouth of jtha main entrance which should also have a fenced gate. A20 foot clearing of all debris or vegetation from the railroadtracks west towards the tire piles should be maintained. Currentlythe railroad has a clearing of approximately 20-30 feet. Thisclearing should be maintained to prevent a brush fire. Allvegetation, within SO feet of all piles should be cleared,including trees and shrubs.

Warning signs or "No Trespassing" signs should b* placed every50 feet or in areas where a sign can't otherwise be seen. The localpolice should make daily random inspections of the property,especially at night, to inspect for violators. DEQ officialsshould make weekly random inspections of the site whil* the hazardprevention plan is being implemented.

3. Fire breaks should be constructed throughout the tirepiles such that individual cells contain no more than 100,000tires, and are no longer or wider than 250 feet. The firebreaksshould maintain a separation of at least 60 (but preferably 100)feet between adjacent cells of tires. The maximum height/depth oftha tiro pile should b« no more than 30 feet, but should not bemade any higher or deeper than it is at the present time.

4. There are no community (public) wells in the vicinity ofthe Keeling property that would be effected in the event of a tirefire. However, there are several private drinking water wellslocated within a range of 500 hundred feet to about 1/4 of a mileof the site. The closest well that is registered with theDepartment of Health or DEQ is located on parcel 97.03-1-14.2. Thawater table at this point was found at approximately 33 inches, andthe dominant soil was a brown sandy loan. This is not the averagedepth for the water table in this area. If runoff were to reachthis point percolation into 'the ground water would takeapproximately 1-3 days due to the sandy loam conditions. The depthof the water table will vary depending on the location. The slopeis estimated at 5 * with an estimated percolation rate at 35minutes/inch. There are several other residences along this roadand in this area that are receiving water from domestic wells, butare not currently recorded with either Department. A well isbelieved to be located on Willie Keeling's property, Section 97.04-1-7, but it is not registered with either Department, and iscurrently not being used. This information was obtained by Mr.Willie Keeling. The well ;is located to the north of piles 12 s, u,and before the first building. A well is located at EdwardKeeling's property, which is located to the west of WillieReeling's property. This well is recorded with DE£, and has acasing elevation of 1160 feet, and was installed to a depth of 175feet. The lithology in this area consists of shale. The nextparcel is 97.03-1-7 with overall soil ranging from brown to yellowloam and around 33 inches there is hard rock or hard shale. The

f l R i + 0 0 0 1 2

report did not indicate the depth of the water table. The HealthDepartment rejected the site because of insufficient depth ofsuitable _8pil over hard rocJc and to the seasonal water table.Parcel 97.03-1-17 reported a clay loam soil, with hard rocic atabout 33-66 inches depending on location. Between 55-245 feetgranite was observed by the State Water Control Board during theirinspection (Attachment 7). The overall percolation in this area isconsidered to be moderate with a percolation rate between i x 10 -4to 1 x 10 -6 cm/second. There are other domestic drinking waterwells in the area, but have not been registered with the Departmentof Health or DEQ. Parcels 97.03-1-1 through 16 are adjacent to theKeeling property, across the railroad tracks. It is expected thateach housing facility has a drinking water well which could beeffected in the event of a fire. Parcel 97.03-1-14.2 has well withreports from the Health Department which give an indication of thesurrounding soil and water table. This has already been statedabove and the reports ara located in the back in Attachment 7.

There is an unnamed tributary of Back Creek locatedapproximately 10 feet east of pile 2 and approximately parallelingthe pipeline. Runoff from this pile would flow into a secondtributary which lies east of the pile. Runoff into the secondtributary would need to be contained and treated, which will bedone by the Fira Department. There is another tributary betweenpiles 1 & 9 which flows into the tributary east of the house.Section 97.04-1-3. These tributaries flow into Back Creek whichflows into the Roanoke River and eventually empties into SmithMountain Lake. Runoff from the fire will also have to becontained.

5. All mixed and hazardous waste must be removed from thetire piles and within 20 feet surrounding each pile (Hazardouswaste has not been determined. Approximately 30 drums are on sitewhich must be tested to determine if they contain hazardous waste.There may be hazardous waste beneath the kudzu, but at the presenttime this can not be determined.)- Mixed waste, including the junkcar, empty rusted barrel, sheets of metal, and any other wastefound in pile 2 must be discarded properly. All hazardous andmixed waste must be removed from the buildings located within 20feet of piles 8-11. There are several drums, some are empty,others look like thay may be full. A f*w of tho drums, in thebuilding, are labeled "transmission lubricant". There are severalother drums located outside of the building and approximately 7underground storage tanks, 3 are located east of the ravine wherepile 12 is located and 4 tanks are located near pila 11. There maybe some mixed or hazardous waste surrounding the tires at pile 3,in the kudzu. It could not be determined due to the vegetationcover. The kudzu will have to be cleared away in order to bedetermine the type of waste present at this location. Waste mustbe removed from piles 12 & 13. There are sheets of scrap metal,parts of a chain linked fence, and a few barrels may be located inpile 12. All material removed from the site must have receipts to

12

R R U O O O I 3

verify proper disposal.

6. "-The removal of tires is estimated to cost S2.37/tire.There is estimated to be approximately 2.8 million tires, bringingthe total cost of tire removal to S 6,636,000. The estimate takesinto account the difficulty in retrieving the tires from suchplaces as the ravine.

7. The recommended fire prevention measures for the propertyand adjacent areas are as follows: No open burning should bepermitted within 100 feet of woodlands adjacent to the perimeterclear space. No smoking is allowed on the property or within 100feet of woodlands adjacent to the perimeter clear space*

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