SMC Demolition Work Plan Response

Pi-Pa-TAG, Inc.

Pinellas & Pasco Counties Technical Assistance Grant

1015 Wideview Ave.

Tarpon Springs, FL 34689

___________________________________________________________________________________

Phone (727) 937-2968 Email: chimal@flasuncoast.net Fax (727) 942-3978

The Board of PiPaTAG, Inc. has reviewed the Stauffer Management Company Work Plan Demolition Project as well as the analysis of that plan performed by Drs. R. Kevin Pegg and Mary Starnes Saunders. We concur fully with the concerns expressed by Drs. Pegg and Saunders as specified in their October 12, 2000 letter to you. By appending a copy of that letter to this communication, we make it an official part of PiPaTAG, Inc.'s comments on the proposal, thus assuring that the affected community will have access to that information.

Additionally, we note that D. Michael Flanery and Bonnie Bergen, Pinellas County Unit of the Florida Department of Health, have informed you that one effect of the demolition project, as proposed, would be (paraphrased) the obliteration of several reference points that have been used as markers for describing various significant aspects of the site. Their concern is similar to one expressed by PiPaTAG, Inc., in our letter of September 12, 1996 (Pi-Pa-TAG, Inc. Comments to EPA / Stauffer Chemical Plant Superfund Site Feasibility Study), in which we pointed out (paraphrased) that, because of changes in the site (removal of buildings, construction of berms, etc.), the location of significant points on the site were being blurred. The Board of PiPaTAG, Inc. fully supports Flanery and Bergen's request that, before any buildings or other landmarks are removed, a professional survey of the site be done, as follows. "This site plan should, at the least, provide re-obtainable longitudes and latitudes that would allow one to relocate areas of potential concern. Specifically, the site plan should identify building structures, hazardous material storage locations, equipment areas, etc. Currently, since the ponds are not readily visible, bearings from existing buildings are used to verify their general locations. With Lat-Longs readily available, future visitors to the site could use a handheld GPS unit to locate the sites of structures that have been removed." (Flanery 9/29/2000 communication to Blanchard, copy to PiPaTAG, Inc.) By inclusion in this letter, the concerns of Flanery and Bergen are a part of PiPaTAG, Inc.’s official comment on the Stauffer Management Company Work Plan Demolition Project

The Board of PiPaTAG, Inc. is disappointed that the proposed work plan for demolition of existing structures is of such poor quality that we cannot accept it. We urge Region 4 EPA to provide PiPaTAG and other affected parties with a response to all of the questions posed in the report of Drs. Pegg and Saunders and that corrections or adjustments be made before Stauffer Management Company attempts to implement their flawed plan. We also need a guarantee that the eventual implementation of any demolition plan will not proceed until the site is surveyed in such a manner as to comply with Flanery and Bergen's concerns.

At the request of Pi-Pa-Tag we have reviewed the Stauffer Management Company Work Plan Demolition Project. Our comments, questions, and remarks are below.

The Demolition Workplan provided by Region 4 EPA is one of the most poorly written and least detailed plans provided for review. There are no engineer seals on any of the Scope of Work documents. The plan did not have the appearance or depth of a professionally peer-reviewed plan, as is customary for Superfund. There was a complete lack of detail in critical sections regarding sampling, analysis and erosion control. The single figure— which contains hand-drawn components without scale—did not match the text descriptions and was practically worthless for evaluation purposes. Descriptions of operations were so incompetently done that it is unclear if the plan can meet State of Florida ARAR’s, and the possibility exists that neighborhoods close to some operations may be exposed to dust, fumes, runoff, or toxic mist from overspray. It seems likely that contaminated waste, or waste-contaminated equipment or refuse, will leave the site under this plan.

Since the plan was so lacking in detail, we cannot recommend that Pi-Pa-Tag accept the Plan as provided for review.

There does not appear to be any requirement for a progress or closeout report, or, for that matter, any formal report during this process. Analytical data appears only to be targeted to “waste-disposal services.”

This section only pertains to temporary staging of “containerized liquids, chemicals, etc. gathered from building areas.” There is no mention in this plan of temporary storage of soils, wall debris, foundation rubble or potentially contaminated materials.

This section states that there are monitoring stations, however, the section referred to for more detail, Appendix D, lacks even a rudimentary discussion of site monitoring events, procedures or locations.

Where are the “eight monitoring stations” located? Why is no map provided?

It is impossible to judge the efficacy of the monitoring plan with the information provided.

Does this refer to the maintenance “shop” shown on Figure 1-1, or is it a different structure?

2.7.1.1 Mercury lamps and fluorescent lights will be sent to a reclamation center “within 90-days.”

Will this comply with State of Florida requirements (potential ARAR’s) on handling refuse fluorescent bulbs?

Figure 1-1. This diagram is poor even by EPA Region 4 standards. It is merely a general drawing with some pen markings on it.

2.7.1.8 In cleaning the work pit, pressure washing will entail the use of an above ground temporary tank. The tank is apparently not described under temporary facilities (section 2.4).

What does “characterization” mean in reference to the contents of the poly tank? Why are there no references to Appendix D (Sampling and Analysis) for characterization of material from the waste pit?

Is there any possibility of “overspray” from the pressure cleaning carrying a toxic mist to an occupied residential area?

Will the sand be from the same areas of the site thought to be associated with the Native American Indian middens, or from off site? If the sand is from off site, is it placed somewhere on site to be used as needed? If so, where? If placed on site, will it be on a liner, or directly on the ground?

Is there the possibility that demolished areas could become contaminated if sand or other materials are staged in slag contaminated areas, then used as fill?

2.7.2.3 Mercury lamps and fluorescent lights will be sent to a reclamation center “within 90-days.”

Will this comply with State of Florida requirements (potential ARAR’s) on handling refuse fluorescent bulbs?

2.7.2.6 This section states “concrete masonry block wall will be stripped off…” and crushed with the crushed block to be “…used as fill in the sump.”

Is “the sump” the same sump pit shown in Figure 1-1 just above the hand written note “to debris pile?” If not, and the material is to be used somewhere else, where is it placed?

2.7.2.10 also refers to “the sump pit” stating that it is to be cleaned out and pressure washed with the wastewater pumped to an above ground poly tank. Several questions:

If so, how is it filled with crushed concrete block and then pressure washed clean in a later step? The opening line to this section reads, “The boiler house will be demolished in the following manner and sequence.” Clearly that does not seem logical given this sequence; there is much missing in this plan.

Is this the same tank as described under 2.7.1.8 regarding the “work pit?”

If not where is this tank staged for operation? Note, additionally, that this section refers to section D, Sampling and Analysis Plan for detail on wastewater characterization. However, there is no actual plan in Appendix D detailing any characterization, only vague references to characterization under RCRA, without specifying which RCRA guidelines must be met.

If the same tank is used, are the contents mixed, or is the tank emptied between jobs? If the tank is emptied, where is it emptied?

Will the sand be from the same areas of the site thought to be associated with the Native American Indian middens, or from off site?

If the sand is from off site, is it placed somewhere on site to be used as needed? If so, where?

Is there the possibility that areas could become contaminated if sand or other materials are staged in slag-contaminated areas?

We could not locate a “compressor building” on the Figure 1-1 provided by EPA Region 4.

2.7.3.1 reads, “All drums will be removed…and sent to the staging area…” No staging area is shown on Figure 1-1, the single reference to staging area in the Temporary Facilities section does not give a location. Please provide an accurate map.

2.7.3.4 refers to cleaning the sump with the wastewater contained in an above ground tank.

Is this the same tank as used in the Maintenance Building and/or Boiler House? There is no reference to analysis of wastewater contents under Appendix D.

Since the Compressor building does not appear on maps, is there the possibility of over spray from pressure washing affecting local residents?

2.7.3.5 states that concrete in the roof slab and block structure will be used as fill elsewhere on the site. Where will this crushed material be stored until use? What does "broken-up material" mean in terms of size-- gravel-sized, brick-sized, etc.? How will it be stored—is it covered or left exposed to the elements?

Are all of these areas co-located in the area marked "cooling towers" on Figure 1-1, or are they scattered around the site?

2.7.5.2 states “Hay bales will be installed around the down-slope end… to serve as adequate erosion control…”

There is a reference to Appendix E for Erosion Control, however there is no explanation or discussion of what erosion control means in Appendix E.

Where will the hay be placed, how much hay, and how is this amount determined to be adequate?

After demolition the hay is to be thrown over the leveled area. If the hay was placed in a contaminated zone, then contaminated hay may be thrown over the refilled site. Clearly more detail is necessary to evaluate this erosion control method.

Under which RCRA or Superfund rules does hay qualify as an adsorbent of toxic waste?

Where will the poly tanks be stored, and are these the same tank or tanks as previously described for the maintenance and other areas?

What does “characterization” mean, and why are there no references to Appendix D sampling and analysis?

2.7.6.2 “The atmosphere within each tank will be monitored for explosive characteristics.”

The “Lower Explosive Limit” calculation is not explained either within the Scope or in any Appendix.

Scale and sludge removal is to be by shovel or bucket, however there is no description as to the fate of this material.

2.7.6.5 Associated piping is removed in Step 5, after the tanks are sent to the scrap yard in Step 4.

2.7.6.8 describes containerization of tank contents. However, this step is given after step 2.7.6.4 where the tanks are “crushed or flattened.” The preamble to this section states that the tanks will be “dismantled according to the following procedure and sequence,” however the sequence makes no sense since the tanks are “flattened” and removed prior to containerization of any contents.

It is unclear if this is the same as the area shown on Figure 1-1, above the slag pits labeled “Miscellaneous Trash and Debris Removal.”

A properly marked map is essential to understanding this work plan and should be provided.

Portions of the “Miscellaneous Trash and Debris Removal” appear in Figure 1-1 to be within the slag processing area. Will slag or slag contaminated materials be removed? Since no testing is indicated in this section or Appendix D, how can SMC/EPA be sure that slag is not removed during this portion of the project?

The preamble states that there is danger from elemental phosphorus during this work, and a fire watch is indicated. Since the map is incomplete it is impossible to know if this work endangers the neighborhood or school.

This section is extremely vague and should be corrected, and correct maps and safety procedures indicated. There is no section detailing the firewatch procedures, or how the community will be contacted if phosphorus smoke is expected.

Will slag or slag contaminated materials be removed? Since no testing is indicated in this section or Appendix D, how can SMC/EPA be sure that slag is not removed during this portion of the project?

It is unclear if the “Elevated Water Storage Tank” is the same as the Water Tower shown in Figure 1-1.

A properly marked map is essential to understanding this cleanup and should be provided.

These areas are not shown on Figure 1-1. It is impossible to determine if they impact an area of known contamination.

A properly marked map is essential to understanding this cleanup and should be provided.

2.7.12.4 Oil-impacted soils are to be placed on plastic sheeting. However, there is no indication of where this material will be staged or stored. It would seem, based on previous remarks, that the material would be more properly drummed and placed in the temporary storage area described under Section 2.4.

The type of plastic sheeting should at least be described. Is the plastic sheeting window insulation quality or does it meet RCRA standards?

2.8 Waste Characterization Transportation and Disposal; and Appendix D Sampling and Analysis Plan

These sections are entirely inadequate. There are only vague indications of testing without any indication of the nature of testing. RCRA standards vary greatly and it does not appear at all likely that materials are being tested for toxicity under CERCLA/SARA, or even under OSHA. There appears to be a high probability that toxic waste may be removed during these operations.

Which RCRA protocols are being used? What types of toxicity tests are expected?

No maps are given for the placement of monitoring stations. May need to add surface water characterization when clarifier is analyzed.

Why is the Final Report not considered a Project Submittal and listed under section 2.1?

There are a number of structures shown that are not discussed in this workplan: the Carbon Blocks, Tank Pits, Slag Pit, Hot Water Tank # 1.

In addition, as noted, there are several areas that are ambiguously referred to in the plan, such as the Sump Pit, Water Tower, Maintenance shop; these areas need to be properly identified on maps and figures.

Our opinion, after reading the plan, is that EPA/SMC may be attempting to perform this cleanup under less restrictive RCRA rules, and with minimal Superfund compliance, since they were unable to move a Consent Decree through the Department of Justice. The plan as provided for review is highly suspect, potentially unsafe, and without more detail may entail endangerment of local residents.