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L53g) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, Ca. 94105-3901
SFUND RECORDS CTR
4660-00003
SFUND RECORDS CTR
88220011
AR0008
MEMORANDUM
DATE: June 29, 1993
SUBJECT: Request for a Removal Action at the Charleston ^DRMO Site, Las Ve<^ajg, Clark County, Nevada
FROM: I^LCf^rd WfT Mar^yn/Vosc, Emergency Response Section
TO: Jeffrey Zelikson, Director, Hazardous Waste Management Division (H-l)
THRU: Don White, Chief Field Operations Branch (H-8)
I. PURPOSE
The purpose of this Action Memo is to request and document approval of the proposed removal action described herein for the Charleston DRMO Site located at 6274 East Charleston Blvd., Las Vegas, Nevada.
II. SITE CONDITIONS AND BACKGROUND
Site Status: Non-NPL
Category of Removal: Time-Critical CERCLIS ID: NVD986776359 SITE ID: 7K
A. Site Description
l. Removal site evaluation
The Charleston site is located in the City of Las Vegas, Nevada. The site, a ten acre parcel, contains a large variety and amount of D.O.D. marked pesticides (DDT), herbicides (CHLORDANE), Lead acid batteries, compressed gas cylinders, bulging drums, numerous areas of stained soils and potentially shock sensitive compounds.
In June 1992, potentially hazardous materials were first reported to the Clark County Fire Department (CCFD) after a portion of the
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Printed on Recycled Paper
property fence was destroyed by a roadway construction crew. With the fence removed, the potentially hazardous substances were seen by neighbors and passing cars and pedestrians and was subsequently reported to CCFD.
In July 1992, an assessment was conducted by the CCFD at the property which revealed the following hazardous materials: thirty-five 5 gallon containers labelled as "5% DDT", five 5 gallon containers labelled "chlordane", two 55 gallon drums of old "C-D" batteries, suspected piles of friable asbestos, and pallets of containers labelled as hydraulic fluids, lube oils and grease. CCFD issued an Inspection Record report to one of the principal landowners, giving him 30 days to begin cleanup operations at the property with a licensed contractor.
The property owners did not comply with CCFD's mandate. They did however, obtain a bid for cleanup from a-Florida consulting firm. They also contacted Nellis Air Force Base (AFB), because it was alleged by the current owners that the former owner had purchased the hazardous materials from auctions held at Nellis AFB.
In August 1992, Nevada's Division of Environmental Protection (NDEP) was informed of the situation at the Charleston property by the CCFD, and in September 1992, the NDEP issued a Warning Letter to the property owners directing them to:
a) submit a cleanup schedule to the NDEP by September 30, 1992, and
b) have all hazardous materials removed to an authorized hazardous waste management facility by November 30, 1992.
The property owners contracted with a local environmental consultant to assess the materials on the property. A report was prepared which included options for the removal and disposal hazardous materials and site soils which were found to be contaminated with DDT (levels as high as 6954 mg/kg) . The NDEP concurred with the proposed schedule for implementation, however, as of March, 1993, no efforts towards cleaning the site had been undertaken by the property owners.
NDEP contacted the U.S. Defense Reutilization and Marketing Service (DRMS) to solicit their support in the cleanup activities. DRMS replied that it was willing to investigate the situation, and in March, 1993, Nellis AFB personnel, after assessing the materials on the property, disavowed any responsibility for the cleanup, although it is negotiating an agreement with property owners whereby it will accept for processing and/or disposal certain substances and materials identifiable as originating with the military.
On April 29, 1993, NDEP contacted the U.S. EPA Emergency Response Section (ERS) and requested assistance with PRP enforcement with
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regards to the cleanup of the property. The NDEP views the type and condition of the materials on-site as an emergency situation.
On May 5 1993, the EPA Federal On-Scene Coordinator (FOSC), and Technical Assistance Team (TAT) contractor conducted a preliminary assessment (PA) to determine if there was a threat requiring a removal action. The FOSC requested that one of the general partners representing the group of land owners be present for the assessment to discuss what actions had been taken or were envisioned to be taken. The FOSC also requested that DRMS personnel be on site for the assessment, which resulted in three Nellis personnel participating in the on-site assessment.
The PA concluded that the types of materials at the site, as well as the number of containers and their deteriorated condition, posed a potential threat to public health, welfare or the environment. The FOSC gave verbal Notice of Federal Interest to the military representatives from Nellis AFB and the representative of the property owners. Written notice was later given to the same parties. The owners of the property stated that it was their intent to clean the property, but were not sure if they had the resources to perform all that was necessary. They stated that they would pursue the cleanup, and a letter was sent to the FOSC stating their intent to comply on May 7, 1993. As of this date, not a single item has been removed from the facility for disposal.
Of particular concern, is the potential for a spill or fire involving DDT and Chlordane that could cause the release of poisonous gases or cause groundwater pollution. Other potential problems identified were fire/explosion hazards associated with over a dozen unmarked/unknown compressed gas cylinders, bulging drums and liquid and crystalline solids, improper storage of hazardous substances, soil contamination, groundwater contamination and inadequate security.
2. Physical location
The site is located in the City of Las Vegas and is situated in a residential setting, with one residence just 100 feet from the site. Las Vegas is a community of approximately 800,000 people. Residential areas are present to the north, northwest, east northeast and west of the site. There are numerous schools and child care centers within one mile of the site.
The local Tortoise Group has reported that the property in question is located within the probable desert tortoise habitat. The desert tortoise is a protected endangered species.
3. Site characteristics
The Charleston site is basically a fenced parcel of land 300 X 300 feet. It contains two small structures that were apparently used
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for assay or testing work conducted by the previous owner, and various trailers, open pits, cement and asphalt pads. There are power lines running throughout the property and there is a well located in the northeast corner of the fenced property.
There is a considerable amount of junk and debris scattered throughout the yard. There are piles of scrap metal, and friable asbestos pipes along hundreds of drums and containers containing hazardous waste solids,liquids and . sludges, pure products and unknowns which are haphazardly stored in several locations throughout the open yard. The condition of some of the drums and containers is poor. Of special concern are the threats posed by the organochlorine pesticides, compressed gas cylinders and bulging drums of unknown contents. Many of the drums, cylinders and other containers have military stenciling, and it has been alleged that a vast majority of the materials present on the site were purchased by the previous land owner from military surplus auctions, primarily those at Nellis AFB.
Site security is inadequate. The yard is fenced and the front gate locked. However, no signs or warnings have been posted on the fence.
4. Release or threatened release into the environment of a hazardous substance, or pollutant or contaminant
DDT and Chlordane:
A large quantity (over thirty 5 gallon containers) of DDT (dichloro-diphenyl-trichlorethane) was found on site.. The containers are in a very deteriorated condition and some have spilled their contents on the ground. Soil samples have confirmed soil contamination in and around these containers.
DDT has an assigned EPA hazardous waste code of U061. It is tasteless, odorless, white crystalline powder, but is often stored in liquid organic solvents. It is toxic to humans by ingestion and skin absorption, and primarily affects the peripheral nervous system and the liver. It is also a suspected human carcinogen.
There are numerous 5 gallon containers of chlordane (a chlorinated cyclodiene) in suspect condition. Chlordane has an assigned EPA hazardous waste code of U036. As an insecticide it is primarily used for termite control. Chlordane is a clear, colorless, odorless liquid, usually stored in an organic solvent. It is toxic to humans through inhalation, ingestion or skin and eye absorption. It is a probable human carcinogen.
DDT and Chlordane, are hazardous substances as defined by Section 101(14) of CERCLA.
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Compressed Gas Cylinders:
The discovery of at least sixteen compressed gas cylinders poses a complex threat to the site. The cylinders identified during the preliminary assessment were old (pre-1964) , in poor to fair condition, and contain unknown contents, as there are neither content markings on the cylinders nor records to indicate their contents. Industry recognizes that unknown compressed gas cylinders represent one of the most dangerous waste materials to discover on a site. Many potential hazards are associated with compressed gas cylinders. These include the energy of compression, chemical and physical properties and instability. Handling waste compressed gas cylinders poses unique hazards and must be done by experienced personnel. Failure of the cylinders and/or valves can create projectiles capable of causing serious injury and property damage. Extremely toxic gases, flammable gases, corrosives and reactive materials such as fluorine are commonly stored in compressed gas cylinders. Lethal concentrations of toxic materials have been found in cylinders thought to be empty.
Bulging Drums:
At least a half-dozen bulging drums were found at the property, without visible labels or markings. These drums pose a significant danger to the site, and to cleanup personnel. The drums evidently are bulging due to their containing chemicals with low boiling points. These drums of volatile chemicals have been exposed to a very hot Las Vegas climate for a number of years, encouraging the chemical vapors to expand, the drums to bulge, and the structural integrity of the drums to be greatly compromised.
These drums are very susceptible to rupturing, precipitating a release of unknown chemical vapors and liquids.
Soil and Groundwater Contamination:
There is evidence of potential soil contamination. Site soils are visibly stained, and the vegetation is stressed or non-existent. There are several areas where it is obvious that spills or dumping have occurred. Leakage from the DDT drums has already been documented as contaminating the site soils.
Site Security: As previously mentioned, site security is inadequate. In addition, the property is vacant and it is unknown if the owners will provide adequate security. Because of the instability associated with bulging drums, leaking DDT and chlordane containers, and a vast array of compressed gas cylinders sitting in the open environment and subjected to the increasing summer heat, the site should have better security. It does not seem likely that the owners will conduct adequate inspections, nor make necessary corrections to prevent an incident.
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5. NPL status
This facility is not on the NPL.
6. Maps, pictures and other graphic representations
See Appendices to this Action Memo.
B. Other Actions to Date
All actions to date have been discussed in Section A.
C. State and Local Authorities's Roles
1. State and local actions to date
There is a long history of regulatory compliance actions taken against this facility over a the past year.
2. Potential for continued State/local response
Neither the State nor local agencies have sufficient funds to perform stabilization arid cleanup activities.
NDEP is lead State agency for remedial actions. NDEP will assist and support EPA in any short-term removal actions. The OSC will coordinate with NDEP in all on-site activities and other actions to ensure that the information will be consistent with their needs. Representatives from State and local response organizations support EPA actions to mitigate the site hazards. These agencies have agreed to assist and coordinate with the OSC in various tasks including contingency planning, traffic control, community relations, and expediting the issuance of necessary permits. The City FD has been requested to monitor site conditions on a regular basis until EPA mobilizes to begin the removal action.
III.THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, AND STATUTORY AND REGULATORY AUTHORITIES
A. Threats to Public Health, or Welfare or the Environment
Appendices to this Action Memo include a map of the facility which identifies the locations of hazardous substances, a listing of the hazardous substances present, drum/container inventories and cylinder inventories.
The substances of concern are:
DDT and Chlordane
The contaminants identified during the preliminary assessment, DDT and Chlordane, are hazardous substances as defined by Section
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101(14) of CERCLA. Organochlorine pesticides' toxic characteristics' come from their ability to affect the delicate balance of sodium and potassium within the nerve cells of insects, preventing the cells from conducting nerve impulses in their normal fashion and- killing the insects. The environmental hazard associated with these pesticides is due to their persistent presence in ecosystems. Organochlorine pesticides tend to be very stable substances, and as such they remain both in the environment and in fatty tissues of creatures who feed on insects poisoned by the pesticides.
A large quantity (over thirty 5 gallon containers) of DDT (dichloro-diphenyl-trichlorethane) was found on site. DDT is an organochlorine pesticide that was used extensively during World War II to fight typhoid fever, malaria and typhus, all transmitted by insects. The use of DDT is currently severely restricted by the EPA as it has been found to threaten predators at the higher end of the food chain. DDT accumulation in tissues of such predators as eagles, peregrine falcons, and pelicans has been isolated as the cause for weakening the shell casings of the birds' eggs, greatly inhibiting the reproduction of these species and imperiling them to the point of extinction.
DDT has an assigned EPA hazardous waste code of U061. It is tasteless, odorless, white crystalline powder, but is often stored, as is the case with the DDT at the Charleston site, in liquid organic solvents. It is toxic to humans by ingestion and skin absorption, and primarily affects the peripheral nervous system and the liver. It is also a suspected human carcinogen.
A few 5 gallon containers of chlordane (a chlorinated cyclodiene), another bio-persistent organochlorine pesticide, were also found on-site. Chlordane has an assigned EPA hazardous waste code of U036. As an insecticide it is primarily used for termite control. Chlordane is a clear, colorless, odorless liquid, usually stored in an organic solvent. It is toxic to humans through inhalation, ingestion or skin and eye absorption. Chlordane acts as a convulsant, and also affects the liver, kidneys, skin, lungs, and central nervous system. It is a probable human carcinogen.
Compressed Gas Cylinders
The discovery of at least sixteen compressed gas cylinders poses a complex threat to the site. The cylinders identified during the preliminary assessment were old (pre-1964) , in poor to fair condition, and contain unknown contents, as there are neither content markings on the cylinders nor records to indicate their contents.
Their pre-1964 age identification is evidenced by the cylinders ICC (Interstate Commerce Commission) alphanumeric markings. The ICC changed its name to the Department of Transportation in 1964.
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The age, condition and unknown nature of the cylinders make them difficult to sample. Valves may not operate, may rupture if opened, or may not close if opened. Identification of contents at this time is impossible without a very rigorous sampling regime set in place. This identification of contents must be performed to safely and legally transport and dispose the cylinders and their contents. There are limited options in safely and effectively handling unknown gas cylinders and it is a very costly endeavor.
Bulging Drums
At least a half-dozen bulging drums were found at the property, and none had visible labels or markings. These drums pose a significant danger to the site, and to cleanup personnel. The drums evidently are bulging due to their containing chemicals with low boiling points. These drums of volatile chemicals have been exposed to a very hot Las Vegas climate for a number of years, encouraging the chemical vapors to expand, the drums to bulge, and the structural integrity of the drums to be greatly compromised.
These drums are very susceptible to rupturing, precipitating a release of unknown chemical vapors and liquids.
Soil and Groundwater Contamination:
There is evidence of potential soil contamination. The soils are visibly stained, and vegetation stressed, in several areas where spills or dumping may have occurred. Leakage from the drums stored throughout the property has spilled onto the ground, potentially contaminating the soils.
1. Actual or potential exposure to hazardous substances or pollutants or contaminants by nearby populations or the food chain
The most serious threat is the uncontrolled reaction between highly incompatible and acutely toxic chemicals. Large quantities of chlorinated pesticides in solvent solutions in deteriorating drums, compressed gas cylinders, bulging drums, and hundreds of unknown compounds lie in close proximity to each other. There is a significant risk of failure of the drums, which would cause a subsequent release. A fire involving the organochlorine pesticides could cause a poison gas release that would be a major public health threat in this populated area. A fire spreading to the bulging drums and compressed gas cylinders would severely impact the surrounding public. Heavy rain and windy conditions may spread the DDT contaminated soils off-site to the adjacent residences, walkways and streets, causing impact to both human and animal populations.
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2. Actual or potential contamination of drinking water supplies
Soil samples taken during the preliminary assessment did detect elevated DDT, and chlordane contamination in surface soils. There are numerous areas of visibly stained soils and pits filled with debris. At present the extent and magnitude of soil contamination is unknown, however, a more through investigation will be undertaken during the clean-up. There is a well on the site which is adjacent to bulging drums and soil staining which will also be investigated during the cleanup.
3. Hazardous substances.or pollutants or contaminants in drums, barrels, tanks, or other bulk storage containers, that may pose a threat of release
Drums and containers that have been stored on the property for many years are in very poor condition. Several drums are bulging and others are so highly corroded that failure is imminent. These substances are organochlorine pesticides, compressed gases, flammable materials, heavy metals and possibly asbestos. A combination of these chemicals in a fire can generate a lethal poisonous release.
Drums, containers throughout the property are in an unstable configuration and in very poor condition. Large quantities of hazardous materials are very close together. The soils are visibly stained and potentially contaminated from numerous chemical spills.
4. High levels of hazardous substances or pollutants or contaminants in soils at or near the surface, that may migrate
As stated above, limited soil sampling by the PRP's consultant has detected DDT in surface soils. Poor housekeeping and waste management practices as well as indiscriminate dumping activities may have contributed to soil contamination. This contamination could migrate to adjacent properties or to groundwater given the right weather combinations.
5. Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released
The property has barren soils, virtually void of vegetation. High winds could disperse contamination into neighboring residential properties. Rainfall could percolate into the exposed soils, causing the contaminants to migrate to groundwater. Heavy rainfall could cause localized flooding, resulting in contaminated runoff onto adjacent properties, the street and into sewers.
6. Threat of fire or explosion
A fire/explosion hazard exists due to the bulging drums and compressed gas cylinders present on-site. There are also suspected
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shock sensitive liquids and solids scattered throughout the property which could ignite the DDT and chlordane containers.
7. Availability of other appropriate Federal or State response mechanisms to respond to the release
The State has informed the OSC that they are unable to conduct site stabilization or other responses for the foreseeable future.
B. Threats to the Environment
The primary threat is to public health. The threat that could most adversely affect the environment is the release of contaminants (DDT) to soil, and the potential for degradation of groundwater resources. As mentioned above, there currently exists a threat to a portion of the desert tortoise habitat.
IV. ENDANGERMENT DETERMINATION
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the response action selected in this Action Memorandum, may present an imminent and substantial endangerment to public health, or welfare, or the environment.
V. PROPOSED ACTIONS AND ESTIMATED COSTS
A.Proposed Actions
The overall objective of the removal action will be to identify all situations which pose imminent and substantial endangerments to the public and the environment, and mitigate them in a cost effective manner consistent with NCP criteria.
1.Proposed action description
The major anticipated tasks that will be involved in the proposed response are as follows:
a. Provide an interim security program prior to mobilization. The OSC has requested the NDEP and City of Las Vegas FD to routinely patrol the area and perform periodic site inspections.
b. Provide security during removal operations.
c. Sample and characterize all hazardous materials.
d. Perform air monitoring and sampling in accordance with OSHA requirements during all phases of the removal action, especially when there is a potential for airborne releases of toxic air contaminants. Operational controls such as dust containment and/or suppression will be used to abate fugitive dust emissions.
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e. Remove or stockpile non-hazardous vehicles, equipment, and debris to provide adequate space for response operations.
f. Prepare all hazardous substances for proper transportation for disposal, or where feasible, alternative treatment or reuse/recycle options. The above may include bulking of compatible, direct shipment for reuse, recontainerization of materials into DOT specification containers, lab packing small quantities, solidification of liquid wastes, and neutralization or other on-site treatment of wastes.
g. Remove grossly contaminated equipment, structures and debris for proper disposal. An attempt will be made to decontaminate structures to non-hazardous levels and minimize the volume of hazardous wastes. The buildings may have to be partially, or even totally, demolished in order to access areas of contamination.
h. Conduct surface and subsurface soil sampling to determine the nature and extent of contamination.
i. The on-site well will be inspected and sampled. This well may have to be abandoned and surrounding materials and soils may have to be removed.
j. Dispose or stabilize grossly contaminated soils found at or near the surface.
k. Grade, cap and fence areas where contamination remains in the soils.
2.Contribution to remedial performance
The long-term cleanup plan for the site:
It is not anticipated that long-term remedial action will be required at this site. However, if there appears to be a much larger volume of soil contamination beneath the surface soils, the proposed removal actions will mitigate the most urgent threats. At the completion of the removal action, an orderly transition from removal to remedial activities will be accomplished. The transition will be coordinated with EPA and State remedial programs.
Threats that will require attention prior to the start of a long-term cleanup:
The immediate threats that have been identified in the Action Memo will be addressed by the proposed removal action.
The extent to which the removal will go to ensure that threats are adeguatelv abated:
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The removal action will mitigate the most immediate hazards, however residual contamination may remain on-site. The intent of the removal is stabilize, secure and minimize potential exposures by removing hazardous substances, treating or removing soil contamination "hotspots", controlling drainage and dust emissions, and improving site security measures. Additional measures may have to be taken to contain or remove contamination that has migrated onto adjacent properties.
Consistency with the long-term remedy;
The removal actions will be consistent, and will not interfere with any needed future remedial alternatives. In fact, the removal action will provide a suitable foundation for any and all future remedial work, if required, by removing hazardous substances, providing safe access, and collecting environmental data.
3.Description of alternative technologies
Alternative cleanup technologies will be considered for use in the removal action. For example, on-site soil washing, soil fixation, soil vapor extraction or other treatment technologies may be employed to treat heavily contaminated soils. Wastewaters that are generated during the removal may be treated by conventional wastewater treatment technologies.
4.Applicable or relevant and appropriate requirements (ARARs)
Federal ARARs: Potential Federal ARARs are RCRA, particularly the Land Disposal Restrictions (LDRs) - 40 CFR Part 268 will apply. CERCLA Off-Site. Disposal Policy is a "to be considered" criteria. In accordance with 40 CFR 300.415(i), this removal shall, to the extent practicable considering the exigencies of the situation, attain applicable or relevant and appropriate requirements under federal and state environmental laws.
State ARARs: The OSC has requested that NDEP provide EPA with potential State ARARs.
6.Project schedule
The estimated length of time needed to perform the cleanup actions is two months. Response activities are scheduled to commence if and when it has been determined that the PRPs have not complied with the EPA Administrative Order.
B.Estimated Costs
Cost Projection Scenario
Projection ID No.:7K Date: 6-22-93 Cleanup Contractor: CET Environmental TAT Contractor: E&E
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Cost Projection Summary
VI.EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN
The "worst-case" scenario should no action be taken would be that the bulging drums would rupture causing a vapor release and subsequent fire that would engulf the pesticides and compressed gas cylinders causing the formation of poisonous gases. A release of this nature is expected to be life-threatening to the adjacent residences.
The property is vacant, and the containers are in poor and deteriorated condition. The facility may become an attractive nuisance and arson or vandalism is a real threat. These events
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coupled with inadequate security and maintenance heightens the possibility of a catastrophic release.
VII.OUTSTANDING POLICY ISSUES
The removal action will require the opening, sampling, pumping off and bulking of large volumes of toxic and reactive chemicals. This action will also involve the opening and sampling of the unknown compressed gas cylinders. Due to the inherent risks associated with this type of operation, especially in a populated area, the OSC will Coordinate contingency planning with the NDEP and various City of Las Vegas agencies.
VIII. ENFORCEMENT
The Enforcement Addendum to this Action Memo contains confidential enforcement information.
IX.RECOMMENDATION
This decision document represents the selected removal action for the Charleston site, in Las Vegas, Nevada developed in accordance with CERCLA as amended, and not inconsistent with the NCP. This decision is based on the administrative record for the site.
Conditions at the site meet the NCP section 300.415(b)(2) criteria for a removal and I recommend your approval of the proposed removal action. The total project ceiling if approved will be $918,703.61. Of this, an estimated $870,538.61 comes from the Regional removal allowance.
Approval Signature fei/
Date to -SO
Disapproval Signature Date
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