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$250,000 Emergency Action Memorandum

SUBJECT: Action Memorandum for an Emergency Response Removal Action at the Hi-Temp Site pursuant to the On Scene Coordinator's delegated authority under CERCLA Section 104

FROM: Steve Spurlin, On-Scene Coordinator Emergency Response and Removal Branch

THRU: James Webster, Chief Emergency Response and Removal Branch

TO: Site File

I. Purpose

The purpose of this memorandum is to document the decision to initiate emergency response actions described herein for the Hi-Temp Site (the Site) located in Humboldt, Gibson County, Tennessee pursuant to the On Scene Coordinator's delegated authority under CERCLA Section 104.

II. Site Information

A. Site Description Site Name: Hi-Temp Superfund Site ID (SSID): B42D NRC Case Number: 1051772 CERCUS Number: TNN00041 0983 Site Location: 703 Etheridge Street, Humboldt, TN Lat/Long: 35.49 31.7,-88 55 23.5 NPL Status: Non-NPL Removal Start Date: June 26, 2013

B. Site Background

1. Removal Site Evaluation

In May 2013, On-Scene Coordinator (OSC) Spurlin was contacted by the Tennessee Department of Environment & Conservation (TDEC), Jackson Field Office. As a follow-up to a complaint, TDEC conducted a visit to the former Hi-Temp facility in Humboldt, Tennessee. TDEC observed a dilapidated, unsecured building which contained leaking

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containers of suspected of hazardous substances. TDEC provided the inspection photographs and site background infonnation to the U.S. Environmental Protection Agency (EPA). TDEC expressed concern about the leaking containers and requested EPA evaluate the Site for a possible removal action. Container label information in photographs indicated some containers contain sodium hydroxide, a corrosive hazardous substance. Labels indicate other containers contain hydrogen peroxide and flammable liquids.

Records indicate the property taxes have not been paid since 2007, the year the facility is believed to have ceased operation. Additional investigation into the facility indicates the business has been dissolved, and the individuals listed on the deed are likely deceased. Efforts to date to identify and contact owners or individuals responsible for the property have been unsuccessful.

Due to the ongoing release of suspected hazardous substances, the unsecured nature of the building, and the lack of responsible parties to address the hazardous substances, OSC Spurlin contacted the EPA Duty Officer to initiate an emergency response to address the drums. Further delay in addressing the hazardous substances will result in additional releases and potential threats to human health and the environment; therefore, OSC Spurlin initiated an emergency response on June 26, 2013.

2. Physical Location and Site Characteristics

The Site is located at 703 Etheridge Street, Humboldt, Gibson County, Tennessee. The Site is an abandoned, accessible former industrial facility located in a densely populated neighborhood. The facility manufactured ceramics used in the foundry industry. Evidence of use of the property by homeless and trespassers was noted. It appears unknown persons are using the unsecured nature of the building to dump old tires and waste oil.

3. Release or threatened release into the environment of a hazardous substance, pollutant or contaminant

The sodium hydroxide, a corrosive liquid, poses a direct contact threat to anyone coming in contact with the material. Based on the pH of the material, a Resource Conservation & Recovery Act (RCRA) hazardous waste designation of D002 would be applied to the material. By definition, any RCRA waste is a CERCLA hazardous substance. Several pallets of stacked poly-containers with estimated capacity of 8 gallons were documented in the building. These estimated 40 containers of sodium hydroxide are suspected to be the source of the pooled liquids noted on the floor during TDEC's inspection. Another 16 similar sized containers, also stacked and staged on pallets adjacent to the sodium hydroxide, were observed. Label information indicated this material is hydrogen peroxide. These poly-containers become brittle over prolonged exposure to heat and cold, increasing the likelihood of additional releases. An estimated 5 tons of unknown white solids, mostly in sacks and on pallets, are located in various areas of the building. Several bags of the material are damaged, and the unknown material has released to the floor area.

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The buildings' doors are damaged and open. The roof is deteriorated which allows rain to enter and potentially transport hazardous substances on the floor into the environment.

III. Threats to Public Health, Welfare or the Environment

A. Nature of Actual or Threatened Release of Hazardous Substances, Pollutants or Contaminants

The containers abandoned at the Site contain hazardous substances which threaten to release to the environment. Approximately 40 containers of sodium hydroxide, a corrosive hazardous waste (D002), approximately 16 containers of hydrogen peroxide, a hazardous oxidizer waste (D003), 2 containers of flammable waste paint (DOOJ ), and an estimated 5 tons of unknown waste solids remain accessible and exposed at the Site. Time and exposure to heat and cold causes the poly-containers and solids containers to deteriorate rapidly, increasing the potential for releasing a hazardous substance.

Sodium hydroxide can be very hazardous in case of contact to the skin or eyes, or if ingested. It is a corrosive which can irritate and permeate tissue. The amount of tissue damage depends on length of contact. Eye contact can result in corneal damage or blindness. Skin contact can produce inflammation and blistering. Inhalation of dust will produce irritation to gastro-intestinal or respiratory tract, characterized by burning, sneezing and coughing. Severe over-exposure can produce lung damage, choking, unconsciousness or death.

Hydrogen peroxide can be very hazardous in case of contact to the skin, eyes, or if ingested. It is a corrosive irritant to tissue. Inhalation can damage the lungs. Liquid or spray mist may produce tissue damage particularly on mucous membranes of eyes, mouth and respiratory tract. Skin contact may produce bums. Inhalation of the spray mist may produce severe irritation of respiratory tract, characterized by coughing, choking, or shortness of breath. Prolonged exposure may result in skin bums and ulcerations. Over-exposure by inhalation may cause respiratory irritation.

When decomposing, hydrogen peroxide can yield oxygen that supports combustion of organic matter and can cause overpressure if confined. Residual hydrogen peroxide that is allowed to dry (upon evaporation hydrogen peroxide can concentrate) on organic materials such as paper, fabrics, cotton, leather, wood or other combustibles can cause the material to ignite and result in a fire.

B. Applicable factors which were considered in determining the appropriateness of a removal action (40 CFR 30.415)

Actual or potential exposure to nearby human populations, animals or the food chain from hazardous substances or pollutants or contaminants [300.415(b)(2)(i)].

Several pallets of stacked poly-containers with estimated capacity of 8 gallons were documented in the building. These estimated 40 containers of sodium hydroxide are suspected to be the source of the pooled liquids noted on the floor during TDEC's inspection.

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Another 16 similar sized containers, also stacked and staged on pallets adjacent to the sodium hydroxide, were observed. Label information indicated this material is hydrogen peroxide. These poly-containers become brittle over prolonged exposure to heat and cold, increasing the likelihood of additional releases. An estimated 5 tons of unknown white solids, mostly in sacks and on pallets, are located in various areas of the building. Several bags of the material are damaged and the unknown material has released to the floor area. The buildings' doors are damaged and open. The roof is deteriorated which allows rain to enter and potentially transport hazardous substances on the floor into the environment.

When decomposing, hydrogen peroxide can yield oxygen that supports combustion of organic matter and can cause overpressure if confined. Residual hydrogen peroxide that is allowed to dry (upon evaporation hydrogen peroxide can concentrate) on organic materials such as paper, fabrics, cotton, leather, wood or other combustibles can cause the material to ignite and result in a fire.

Several homes are within 150 feet ofthe building with many more in close proximity. Potential exposure to hazardous substances by these residents exists due to the presence of the hazardous substances. Residents could come in contact with hazardous substances carried in storm water runoff, or risk inhalation of hazardous substances carried in a smoke plume if the hazardous substances in the building burn.

Several of the smaller containers were noted around the area positioned in a fashion that appeared they were used as chairs and tables for homeless persons or scavengers. Use of the containers in a similar fashion could result in exposure via direct contact with the corrosive sodium hydroxide. Sodium hydroxide can be very hazardous in case of contact to the skin or eyes, or if ingested. It is a corrosive which can irritate and permeate tissue. The amount of tissue damage depends on length of contact. Eye contact can result in corneal damage or blindness. Skin contact can produce inflammation and blistering. Inhalation of dust will produce irritation to gastro-intestinal or respiratory tract, characterized by burning, sneezing and coughing. Severe over-exposure can produce lung damage, choking, unconsciousness or death.

Threat offire or explosion {300.315(b)(2)(vi)]

When decomposing, hydrogen peroxide can yield oxygen that supports combustion of organic matter and can cause overpressure if confmed. Residual hydrogen peroxide that is allowed to dry (upon evaporation hydrogen peroxide can concentrate) on organic materials such as paper, fabrics, cotton, leather, wood or other combustibles can cause the material to ignite and result in a fire. Residents could risk inhalation of hazardous substances carried in a smoke plume if the hazardous substances in the building burn.

Weather conditions that may cause hazardous substances or pollutants to migrate or to be released [300.315(b)(2)(v)]

The building is open allowing the containers to be exposed to heat and cold temperature extremes. This weathering of the plastic containers causes them to crack and release their contents. Several leaking containers were discovered and had to be re-containerized to

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prevent further releases. The roof leaks allowing rainwater to impact the floor which could potentially transport hazardous substances into the environment. Water Incompatible???

The availability of other appropriate federal or state response mechanisms to respond to the release [300.415(b)(2)(vii)}

The Tennessee Department of Environment & Conservation and local agencies do not currently have funding to address abandoned hazardous material. The TDEC does not have available contractor resources to directly respond to an emergency incident, and referred the situation to EPA for evaluation and cleanup.

IV. Selected Removal Actions and Estimated Costs

A. Situation and Removal Activities to Date

1. Current Situation

EPA is currently offsite awaiting sample results. The waste material remains at the Site until disposal can be scheduled.

2. Removal activities to date

On June 26,2013, EPA's Emergency & Rapid Response Services (ERRS) contractor, WRSCompass, mobilized personnel to the location. The containers were moved into an open area of the building to allow evaluation of container integrity and inventorying of the materials.

3. Enforcement

Efforts to identify a viable responsible party were unsuccessful. All file information will be placed in the site file for future investigation of responsible parties.

B. Planned Removal Actions

1. Leaking and damaged containers will be re-packaged as necessary and samples collected for disposal analyses. Once sample data is available, disposal bids will be sought, and the waste will be disposed at an EPA approved facility.

2. Contribution to remedial performance

EPA does not anticipate any remedial actions associated with the Site.

3. ARARs

Removal actions conducted under CERCLA are required to attain ARARs to the extent practicable. In determining whether compliance with ARARs is practicable, the OSC may consider appropriate factors,

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including the urgency of the situation and the scope of the removal action to be conducted.

C. Estimated Costs*

Contractor costs (ERRS) $ 35,000 Contractor costs (START) $ 15,000 Other Extramural costs 0 Contingency costs 0 Total Removal Project Ceiling $50,000 *EPA direct and indirect costs, although cost recoverable, do not count toward the Removal Ceiling for this removal action. Liable parties may be held financially responsible for costs incurred by the EPA as set forth in Section 107 of CERCLA.

V. Expected Change in the Situation Should Action Be Delayed or Not Taken

A delay in action or no action at this Site would have increased the actual or potential threats to the public health and/or environment by increasing the opportunity to have direct contact with hazardous substances, and increasing the likelihood of releases to the environment from further deterioration of the containers.

VI. Outstanding Policy Issues

None

VII. Approvals

This decision document represents the selected removal action for this Site, developed in accordance with CERCLA as amended, and not inconsistent with the National Contingency Plan. This decision is based on the administrative record for the Site.

Conditions at the site meet the NCP section 300.41 5(b) criteria for a removal action and through this document; I am approving the proposed removal actions. The total project ceiling is $50,000 and this amount will be funded from the Regional removal allowance.

\- \.~--- \~ Steve Spurlin: Date On Scene Coordinator

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