request for a time-critical removal action at the smt drum site, 2721 highway b, poplar bluff,...

8/13/2019 Request for a Time-Critical Removal Action at the SMT Drum Site, 2721 Highway B, Poplar Bluff, Missouri

1/13

o ^- -° ^t:.\V̂ lZi U N I TE D S T AT E S E N V IR O N M E N T A L P R O T E C T IO N A G E N C Y

^ t P R f t ^ REGION901 NORTH 5TH STREET

KANSAS CITY KANSAS 66101

P R 2 6 2012ACTION M EMORANDUMSU BJEC T: Request for a Time-Critical Removal Action at the SMT Drum Site, 2721 Highway B,Poplar Bluff, MissouriFR OM : J. Heatii Smitii, On-Scene Coordinator \ ^ ^ ( U ^ p \ O J ^ A S ̂ LEmergency Response and Removal South Branch 1 /TH RU : Scott D. Hayes, Chief (D^Ut^ P . P U M A ̂ UEmergency Response and Removal South Branch w ^TO: Cecilia Tapia, Director

Superfund DivisionSite ID: B746

I. PURPOSEThe purpose of this Action Memorandum is to request and document approval of the proposedremoval action at the SMT Drum site (Site) located at 2721 Highway B, Poplar Bluff, Missouri. OnMarch 1 6,201 2 , the U.S. Environmental Protection Agency along with the Missouri Department ofNatural Resources (MDNR) performed an inspection at the Site. Approximately 350 abandoned 55-gallon drums and other containers were identified at the Site. These containers are accessible to thepublic and exist in an unsecured, unmanaged and deteriorated state. Drums at the Site contain hazardoussubstances as defined by the Comprehensive Environmental Response, Compensation and Liability Act(CERCLA). Through the action proposed, the EPA will secure, stabilize and remove hazardoussubstances from bulk storage containers at the S ite. The proposed action will eliminate the immediatethreat to human health and the environment that exists at the Site.

IL SITE CONDITIONS AND BACKGROUND30245174A. S i.eD e.c rip« .n | | | | | | | , | |

1. Removal Site EvaluationOn March 1 6,2 012 , iie EPA along witii MDNR responded to the SMT facilitylocated at 2721 Highway B, Poplar Bluff, M issouri, due to a citizen complaint that leaking drums werepresent at the Site. Ms. Sue Fisher of Poplar Bluff w as identified as the current owner ofth e property.On March 1 6,2 01 2 , Ms. Fisher met with the EPA and MDNR at the Site and consented to an inspection

R E C Y C L E DF I B E R


2/13

ofth e property. Drums labeled as herbicides, sodium cyanide, mineral spirits, metal working fluidconcentrate, solvent and flammable iquid were observed at the S ite. Many drums w ere not labeled orlabels were inaccessible during the inspection. Drums were observed to be toppled over, bulging andleaking. Sheds that once protected the drums have fallen, creating additional hazards at the Site. Whatappeared to be emulsified oil was observed on the ground. A sheen was observed in standing water atthe Site. Stained soil was observed near upright drums. Solid precipitate was observed around the bungof a fallen plastic drum (Attachment A).SMT w as registered in Jime 1991, as a generator of DOOl (Ignitable) hazardous waste withMDNR. MDNR reports the company never submitted details ofwaste disposal activity. Due toinactivity, MDNR deactivated the permit in January 2 003. According to Sue Fisher, the companyoperated at the facility from 1983 through 2 002 , when the company declared bankruptcy. The companywas first created in 1 968. Mr. Ted J. Fisher (deceased) was the President and owner. Ms. Sue Fisher,wife of Ted J. Fisher, was listed as the company Vice President and Secretary.On March 2 6,2 01 2 , the EPA returned to the Site to inspect the manufacturing building andperform field screening on accessible containers. Field screening and laboratory results confirm thatCERCLA hazardous substances have been abandoned at the Site. Wastes were identified that meet the

hazardous waste characteristic of corrosivity. Laboratory samples confirmed the presence ofconcentrated Trichloroethene (TCE) as well as frace amoimts of Tetrachloroethene (PCE ), and cis 1,2-Dichloroetiiene (1 ,2 DCE).2 . Physical location

SMT is located at 272 Highway B, Poplar Bluff, Butier County, Missouri. Thecoordinates, centered on the administrative building at the Site are: latitude 36.767 57 7 N, longitude090.327 1 47 W. Per county records, the Site occupies 1 4.4 acres. It is bounded along the eastern boarderby the Poplar Bluff M unicipal Airport and to the south by M issouri Highway B. The north and westboundaries of the Site adjoin agricultural land and residential lots. Elevation o fthe area isapproximately 325 feet above sea level with little relief, typical ofthe southeastem lowlands of Missourithat fall within the Mississippi embayment (Bootheel Region). SMT is composed of a large intact metalbuilding that housed the administrative and process functions o fthe facility. Ruins of several largesheds exist at the Site. The sheds have fallen on drums and materials that they once protected.

B. Site characteristics1 . Release or threatene d release into the environm ent of a hazard ous substance,or pollutant or contaminant

A hazardous substance release is occurring at the Site. Unsecured drums havebeen identified to contain hazardous substances as defined by CERCLA. Specifically, corrosive wasteas defined by 40 Code of Federal Regulations (CFR) § 2 61 .22 as well as waste listed in 40 CFR §302.4and 40 CFR § 26 1 . Waste in drums at the Site has been observed to have leaked onto the groimd.Staining, sheening, apparent emulsified oil and solid precipitate are evidence drums have leaked or areleaking. The Site is located near residential properties. Contaminants have the potential to m igrate offofthe Site via surface storm water run-off.


3/13

2 . NFL StatusThe Site is currently not on or a part of a current National Priorities List (NPL ).

3 . M aps pic tures , and other graphic representat ionsA map d epicting the Site is attached (Attachm ent B).

C. Oth er Actions to Date1 . Previous actions

No know n actions or investigations have taken p lace previously at the Site.2 . Cu rren t act ions

The Site is currently abandoned but accessible to the public. No cu rrentenvironmental action is taking place.D. State and Loca l Authorities* role

1 . State and local actions to dateThe EPA is coordinating closely with MD NR. The EPA will continue tocoordinate with MD NR and other supporting agencies and local officials as the removal actionprogresses.

2 . Potential for continued State/local responseThere are no current plans for a State or local response at the Site. On March 1 9,2 0 1 2 , MDN R referred th e Site to the EPA and recomm ended action be taken.

III THREATS TO PU LIC HEALTH OR WELFARE OR THE ENVIRONMENTAL ANDSTATUTORY AND REGULATORY AUTHORITIESWhen the lead agency makes the determination, based on factors listed in 40 CFR§ 30 0.41 5(b)(2 ), that there is a threat to public health, welfare or the environm ent, the lead agency maytake any appropriate remov al action to abate, prevent, minimize, stabilize, mitigate or eliminate therelease or threat of release. The factors in 40 CFR § 300.415 (b)(2) that app ly to the Site are:• Haz ardou s substances or pollu tants or contam inants in drums, barrels, tanks or other bulkstorage c ontain ers that may po se a thre at of release: As noted previously, several hundredcontainers are present at the Site, most of which are 55-gallon drums. SMT w as a registeredhazardous waste generator of DOOl ignitable waste. During the March 2 6, 2 01 2 , Remo valSite Evaluation containers of hazardous substances w ere observed to be accessible to thepublic and unsecured. In addition, the drums and containers were found to be unmana ged,deteriorating and in some cases leaking.


4/13

• Weather conditions that may cause hazard ous substances or pollutants or contaminants tomigrate o r be released: Prior to the inspection on March 1 6,2 01 2 , rain fell across the area.Standing water was present across the Site. A small ditch on the westem bo undary oft heSite drained water to the south towards a road side ditch along Highway B . Apparentemulsified oil and a sheen was observed on standing water at the Site. The shed s, onceprotecting dmm s from the weather, had fallen. This has compromised the integrity of someofth e containers and allowed others to be exposed to the elements. If action is not taken,weather cond itions will cause additional materials to be released and migrate off-site.

• Th reat of fi re or explo sion: Drums at the Site are exposed, unmanaged and unsecured. Atleast one container was observed to have gun shot holes. Several 55-gallon drums at the Sitewere observed to be bulged indicating unstable cond itions. In addition to the drums andcontainers, the sheds which once protected the wa ste have fallen, creating additional hazards.Many o fthe dm ms and containers are not accessible for sampling. Solid waste and otherdebris littered around the Site would inhibit response efforts in the event of a fire. The Site isnot actively managed or operated and is overgrown w ith vegetation.• The availability of other appropriate fed era l or state response mechan isms to respond tothe relea se: On March 1 9, 2 01 2 , the state of Missouri through MDNR requested assistancefrom the EPA to take a response action at the Site.

IV . ENDANGER MENT DETER MINA TIONThe actual or threat of release of a hazardous sub stance at the Site, if not addressed byimplementing the response action selected in this Action M emorandum , presents an imm inent andsubstantial endangerment to the health of individuals w ho co me in contact with the Site and to publicwelfare and the environm ent.

V . PROPOSED ACTIONS AND ESTIMA TED COSTSA. Proposed Actions

1 . Proposed action descriptionThe EPA will stabilize containers that are known to be or likely to be leaking.

Debris (i.e., vegetation and dilapidated stmctures) will be removed to allow access to the dmm s andcontainers. W aste will be further characterized, segregated and bulked for disposal based on chem icalcharacteristics and compatibilities as well as waste streams. It is anticipated that a majority o fwa ste willbe dispose d of at an off-site facility.

2 . Con tr ibut ion to remedial per formanceThe flind-lead actions proposed in this Action M emorandum should not impedeany future remedial plans or other responses.


5/13

3. Applicable or Relevant and Ap prop r ia te Requirem ents (ARARs)Section 300.415(j) ofthe National Contingency Plan (NCP) provides that fund-financed removal actions under section 104 and removal actions pursuant to CERCLA section 106shall, to the extent practicable considering the exigencies oft he situation, attain AR ARs un der federalenvironmental or state environmental facility siting laws. The following AR AR s have been identifiedfor this action:

Federal :• 42 U.S.C. 96 01 , et seq., CERCLA• 42 U.S.C. 69 01 , et seq.. Resource Conservation and Recovery Act including:o 40 CFR 25 8, et seq., Subtitie Do 40 CFR 2 60, et seq., Subtitie Co 40 CFR 2 61 , et seq.. identification and listing of hazardou s wasteo 42 U.S.C . 69 41 , et seq., state or regional solid waste plans• 2 9 CFR part 1 91 0, Occupational Safety and Health Act, will be applicable to all actions• 42 U .S.C. 7401 et seq.. Clean Air Act, including, 40 CFR part 50, the National Ambient AirQuality Standards• 33.U.S.C . 2 6, Clean Water Act, including, 40 CFR 1 2 2 .49, tiie National Pollution DischargeElimination System• 16 U.S.C . 1 531 , et seq.. Endangered Species Act• 16 U.S.C . 47 0, et seq.. National Historic Preservation ActState:The EPA h as requested that M DNR identify requiremen ts that the State would like considered aspotential ARAR s for this removal action. To qualify as ARA Rs, these requirements mu st b e: (1)

promulgated; (2) identified b y the state within the time period specified in the letter; and (3) morestringent than federal requ irements. Potential ARAR S from the state of Missouri include:• Hazardous Substances Emergencies Response, 10 CSR 2 4o 4.261 (A)( 1-2,4)- Identification of hazardous w asteo 5.262 - Generatorso 6.263 - Transportation of hazardous wasteo 7 .26 4(2 )(A-G, K-N, and/or S) - Facility and location standardso 7 .268 - Land disposal restrictions

4. Project ScheduleRespon se activities are anticipated to begin following th e authorization providedby this Action Mem orandum.


6/13

B. Estimated CostsThe estimated costs associated with this removal action are as follows:Extramural Costs:Removal Costs 2 31,7 1 42 0 Percent Contingency 46,343Removal Ceiling . 2 7 8,057The EPA d irect and indirect costs, although cost recoverable, do not count toward th e total removal projectceiling for this removal action. Refer to the enforcement section for a breakout of these costs.

VI EXPECTED CH AN GE IN THE SITUATION SHOU LD ACTION BE DEL AYE D O RNO T TAKEN

Delayed action will result in the spread of contamination from deteriorated, unsecured andunmanaged bulk con tainers of hazardous substances, increasing pub lic health risk to the adjacentpopulations.VII. OUTSTAN DING POL ICY ISSUES

None.V I I I . E N F O R C E ME N T

A potentially responsible party investigation is on going.The total EPA costs for this removal action, based on full cost-accounting practices are estimatedto be:Direct Exttamural Costs 2 7 8,057Direct Intramural Costs 50,000EPA hidirect (27 .52 percent of all costs) 90.2 81Total Project Costs 41 8,338Direct costs include direct extram ural costs and direct intra mu ral costs. Indirect costs are calculated based on anestimated indirect cost rate expressed as a percentage of site-specific direct costs, consistent with the full cost accountingmethodology effective Octobe r 2 ,2 000. These estimates do not include pre-judg ment interest, do not take into account otherenforcement costs, including Departm ent of Justice costs, and m ay be adjusted during the course of a removal action. Theestimates are for i l lustrative purposes only and their use is not intended to create any rights for responsible parties. Neither thelack of a total cost estimate nor deviation of actual total costs from this estimate will affect the United States' right to cost recovery.

I X . R E C O MME N D A T I O NThis decision docum ent represents the removal action for the contaminated soils at the Site. Theremoval action was developed in accordance with CER CLA , as amended, and is not inconsistent withthe NCP. This decision is based on the Adm inistrative Record for the Site. If approved, the removalproject ceiling of 2 7 8,057 will be funded from Regional Removal Allowance.


7/13

Conditions at the Site meet the NCP section 300.41 5(b) criteria for a removal and I recom mendyour approval ofthe proposed removal action.Approved:

director vy Da teDirector vy DateSuperfund Division

Attachments


8/13

Attachment A SMT Drum Site Action Mem orandum

D I R E C T I O N : W

DIRECTION: N DESCRIPTIONPHOTOGRAPHER Dilapidated shed fallen on drumsHeath Smitii DATE : 3/16/2012


9/13

Attachment A SMT Drum Site Action Memorandum


10/13

Attachment A SMT Dm m Site Action M emorandum

1 0


11/13

Attachment A SMT Dmm Site Action Memorandum

11


12/13

Attachment A SMT Dm m Site Action Memorandum

12


13/13

Attachment BSite MapSMT Dmm Site Action M emorandum

DIRECTION: N DESCRIPTIONPHOTOGRAPHER Metal Working FluidHeath Smith DATE: 3/16/2012

DIRECTION: N DESCRIPTIONPHOTOGRAPHER Solvent in overturned, bulged drumHeath Smith10DATE: 3/16/2012

request for a time-critical removal action at the smt drum site, 2721 highway b, poplar bluff,...

Documents