UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 841 Chestnut Building Philadelphia, Pennsylvania 19107-4431
JUN - 2 «97
SUBJECTS Approval of a Funding Request for a Removal Action Taylor County Mercury, Site 'st Virginia PROM: Thomas Hazardous Waste Management Division (3HWOO) : TO Timothy Fields, Acting Assistant Administrator, Offic Solif eo d Wast Emergencd ean y Response (5101) THRU t Stephen Luftig, Director Offic Emergencf eo Remediad yan l Response (5201) ATTNs Thoma Sheckells. sR : , Director Regions III & VIII Accelerated Response Center (5201G)
ISSUE " The attached Funding Request under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) , as amended, pertains to the Taylor County Public Service District Mercury Site locate Graftonn i d , Taylor County, West Virginia. The Site consist Tayloe th f rso County Public Service District (PSD) public water treatment plant whic bees hha n contaminated with mercury. Region III performed a Removal assessment which identified the release of mercury, a hazardous substance, into a portion of the public drinking water treatment system. CERCLA fundin needes i g cleanu r fo d mercure repaid th pan f o ry contaminated portiodrinkine th f no g water plant. Because condition Site th e t smee a Remova e tth l criteria set forth in Section 300.415 of the National Oil and, Hazardous Substances Pollution Contingency Plan pursuan(NCPd an ), o t Delegation of Authority 14-1 -A, giving the Director of the Hazardous Waste Management Division authority to approve CERCLA Removal Actions with a total cost of less than $2 million and greater than 12-month duration ,approves Regioha I nCERCLII a d A Funding Request to conduct emergency response actions at the Site. The Project Ceiling is $678,600 of which approximately $616,000 are Extramural Costs. -~
Attahment: Reques Approvar fo tRemova. a f lo l e Actioth t na Taylor County Mercury Site
flRZOOOOl UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION ZZZ 841 Chestnut Building Philadelphia, Pennsylvania 19107-4431
JUN - 2 397
SUBJECT: Reques Approvar tfo Removaa f lo l Action Taylor County Mercury Site Grafton, Taylor County, West Virginia FROMt Q-Jac Downie. kL , On-Scene V^Removal Response Section (3HW31) TOi Thomas C. Voltaggio, Director Hazardous Waste Management Division (3HWOO) THRUs Abraham Ferdas, Associate Division Director Office of Superfund (3HW02) //MAlMjfa^A^ (/W ™ ^""^
X. OBJECTIVE The purpose of this Action Memorandum is to request approval fo CERCLra A Removal TayloActioe th t rna County Public Service District Mercury Site pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended. The Environmental Protection Agency (EPA) assessed the Site on Apri 1997, assessmene l24 Th . t reveale presence dth releasd ean e of mercury ,hazardoua s substance Site e release th Th .t , a f eo mercur threaa s yi publio t c health, environwelfare th d ean - ment. Cleanup response activitie dato st e have included cleanup measures performed by the Public Service District (PSD). These measures hav beet eno n totally successful. This action meete sth Removal criteria set forth in Section 300.415 of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R. § 300.415. 'The On-Scene Coordinator (OSC determines )ha d that funding amoune inth $673,60f to requires 0i conduco dt Removae tth l Action which is considered to be a time-critical Removal Action. ZZ. SITE BACKGROUND AND CONDITIONS A. Site Location Site Tygar e locateTh s base i th th d f te o an t dLak a m eDa immediately adjacent to the Tygart Valley River near Grafton, West Virginia Site Th .e consist Tayloe th f rso County Public Service District Water Treatmen source th s ei tD PS Plant e Th . of public drinkin gCite Graftonwatef th yo Taylo f r o rfo l r,al County and parts of Barbour and Harrison Counties.
&R200002 . . • • . B Site Background • ' •-T^ • : - . $;.i**, ' » The PSD draws water from the Tygart River through intake valves U.S e builth . y tArmb y Corp Engineerf so s whe Tygare nth t Dam was built in the 1930's. The PSD Water Treatment Plant was constructed in the late 1920's. In 1984, a new water filtration plant was constructed to replace portions of the old plant and to increase capacity. Surface water treatment includes coagulation and flocculation procedures followed by filtration and chlori- nation finishee Th . d water enter s120,00a 0 gallon clearwell originathae parth s ti f to l 1920's plant clearwele Th . d lha fouratd rol e controllers that contained approximately eight pound mercurf so controller ype countea s ra r weight. These flow rate controllers were removed by a contractor during the 1984 construction thert ! bu record y e an wer t seno found that indicat mercure fatth e eth f e o y durin 198 e prior gth o 4 o rt construction. In October of 1996, small amounts of free mercury were observe clearwele th n do l floo viewes ra d froe hatce th m th t ha top. Due to the emergency nature of .the discovery of mercury in systeme th clearwele ,th bypasses lwa service f takeo d dan t nou . Monitoring of mercury in the system was increased from a quarterly to a weekly basis. Even with the increased frequency of monitoring, mercury has still not been detected in the finished water at or above action levels* The situation was reported to the West Virginia Department of Environmental Protection Wes(WVDEPe th t d Virgini)an a Departmen Healtf to h (WVDOH), and work was started immediately to remove the mercury waste from the clearwell system. A consultant vas contracted to assis determininn ti action ga mercure n th pla r ynfo cleanup. followine Th g wor completes kwa d OSHwit n hela e Ahf th p o traine d hazardous waste cleanup contractor: initial dry upper floor cleanu wated pan r removal, piping'and valves removal, secondary dry upper floor cleanup, remova ton5 3 saturate f so f lo d filter media, pressure washin clearwelf go effluend lan t line, bottom concrete sampling and testing, and waste disposal. The mercury cleanup project has been in progress for five months and has not been successful. The mercury appears to have entered cracks and joints of the concrete floor of the clearwell. The concrete floor was not a continuous pour. There are joints which were sealed durin 1920*e gth s construction which have failed allowing migration of mercury into the joints. The concrete is very old, has:a rough surface and mercury is impregnate porese th levele n .di Th mercurf so y remainine th n gi concrete (as high as 5,461 mg/kg) warrant further cleanup. Given the nature of the problem and the lack of resources available at the local level to correct the problem, the PSD has declared the mercury cleanup projec emergencn t a aske s emergencr ha dfo d yan y assistance Aprin O 1997., l10 , WVDEP requested emergency assistance froSuperfune mth d Remova publie lth Branco ct e hdu health dange environmentad ran l threat releas e poseth y db f e o mercury at this Site. On April 6, 1997, Senator Byrd requested
AR200003 assistance for this mercury cleanup project. These requests followe unsuccessfue dth l attemp Tayloe th y trb Counto t D yPS correct the problem. . C. Quantities and Types of Pollutants or Contaminants Present Free elemental mercur contaminane th s yi concernf to . WVDEP documented,. through sampling and visual observation, the presence of mercury in the cracks, joints, and porous surface of the clearwell. Mercury is a hazardous substance as defined in Section 101 (14) CERCLA, as amended 42 U.S.C. I 9601 (14). The quantity of mercury present in the clearvell is not known, however, it is visible as free mercury in cracks, joints, and concretee pore bees th ha f n so t documenteI * WVDEy db t Pa concentrations as high as 5461 mg/kg in concrete joints of the knowt ye clearwellnt whetheno s i t rI . mercur presens yi n ti other portions of the treatment or distribution system. Mercury has not been detected in the finished drinking water at levels Safe abovth e e Drinkineth g Wate Maximut rAc m Contaminant Level for mercury which is 2 ug/1. D. National Priorities List Status The Taylor County Mercury Site is not listed or proposed to be Nationalistee th n do l Priorities List. . B Stat Locad ean l Authorities1 Roles Wese Th t Virginia Departmen Environmentaf to l Protection (WVDEP) e Wes,th t Virginia Departmen Healtf to h (WVDOH)d ,an Tayloe th r County Public Service District have been very active throughout all phases of this project. These agencies have now requested that the EPA assume the site-lead as far as cleanup is resourcee concerneth o t e sd du require significane th d dan t resources already expended. WVDEP, WVDOH locad ,an l authorities will continue working with EPA and assisting in response activities wilC OS l e continuTh . coordinato et e activities with State and local officials. III. THREAT TO PUBLIC HEALTH Oft WBLTARB OA THB BH7IROHMEHT Section 300.415 of the NCP lists the factors to* be considere determininn di appropriatenese gth Removaa f so l Action. Paragraph (b)(2)(i), (ii), (v)(viid , an Sectio f )o n 300.415 directly apply as follow to the conditions at the Taylor County Mercury Site2 300.415 (b)(2)(i) "Actua potentiar lo l exposur nearbo et y human populations, animals or the food chain from hazardous substances or pollutants or contaminants"
AR20000U The Taylor County Mercury Site currently pose potentias« l for exposure to*the customers of the'.public water system in the City of Grafton, most of Taylor'County, and parts of Harbour and Harrison Counties. If the clearwell were put back in operation without being adequately cleaned of mercury potentiae ,th exposurr lfo mercuro et y would become very high levels ,a mercurf so y have been documentey db WVDE higs Pa 546s ha 1concrete mg/kth n gi e jointe th f so clearwell. - The Taylor County Mercury Site also poses a potential threat to the food chain associated with the immediately adjacent Tygart River which is a very popular fishing and recreation area flore strea e .faund Th th a an f mao which constitute eth bottom and most important tier of the food chain for fish, humans, and other animals are potentially being exposed to toxic concentrations of mercury by the possibility of mercury leaching intgroune oth d wate thit ra s Site. 300.415 (b)(2)(ii) "Actual or potential contamination of drinking water supplies or . sensitive ecosystems* mercure Th y presen Site th e t trepresenta s actual contaminatio portio a Taylo e f nth o f rno County Public Service District Water Treatment System, * public drinking water syste define s Safme a th e y Drinkindb g Water Act. This water treatment onle systeth ys sourcm.i publif eo c drinking wate Taylor rfo r county. Approximately 5,400 Taylor County households receive drinking water from this water treatment system. Part Harrisof so n Countd yan Harbour Count alse yar o served through resale agreements. Mercury has been found in the concrete of the clearwell at levels as high as 5461 mg/kg. The contaminated clearwell portio treatmene th f no t plan bees tha n removed from service for repair. The supply of drinking water is not contami- nated watet ,bu r passing throug plane hth t could potentially become contaminated if contact with the contaminated clearwell were clearwelallowee th d dan l wer cleanedt eno . The Site also poses a potential threat to sensitive ecosystems associated with the immediately adjacent Tygart River which is a very popular fishing and recreation area. The flora and fauna of the stream is potentially threatened by the possibility that mercury could leach from the clearvell, which is in the flood-plain, into the ground wate eventualld ran y reac Tygare hth t Rive baseflowy rb . 300.415 (b)(2)(v) "Weather conditions tha causy tma e hazardou, • s substance r spollutanto s r contaminanto . migrato st e b r eo released"
AR200005 Site locates Th ei d immediately adjacen Tygare th o tt River Tygare base th th f teano t Riveda r Reservoir. Significant fluctuation Riven si r levels occu thit e ra th s o point e tdu proximity of the flood control dam. Sudden surges in River waters occu thiopenint e ra th s closin d o point g an e tf du go flood gates necessary to maintain various reservoir levels for water conservancy, flow augmentation, and flood control in anticipatio changinf no g weather conditions. This sudden and rapid chang riven ei r level causes corresponding raising or lowerin groune th f dgo water table whic causn hca e mercur leao yt k clearwelthr e flooe th u th f r o migrat d lan e toward the river. 300.415 (b)(2)(vii) "The availabilit othef yo r appropriate Federa statr lo e response mechanisms to respond to the release" wvDEP's Assistant Chie Compliancf fo e Monitorind gan Enforcement requested the assistance of the EPA, on behalf reques e PSDe th mitigat th o , t t a f t o d othreae fan e th t pose thiy db s Site because West Virginia doe currentlt sno y have the resources to address the Site. No further State or local resources are available to correct the situation at the Site. However Tayloe ,th r Count wilD yPS l continuo et operat watee eth r plant afte rehabilitatios rit EPAy nb e .Th State th ed Healtan D PS h Department will continu monitoo et r for any trace levels of mercury that may remain after this emergency clean-up. 300.415 (b)(2)(viii) "Other situations or factors that may pose threat publio st c health welfar r Uniteo e th f deo Stater so the environment." While the site is presently temporarily stabilized, the dange publio rt c health, welfare environmene th d ,an t will continue and worsen if no action is taken or is delayed. While the mercury contaminated clearwell is shut down and out of service, the water plant will continue to operate at diminished capacity whic puttins hi communite gth rist ya k due to- decreased fire flow and loss of summer-month peak capacity. This will then adversely affec welfare e tth th f eo community due to the increased operating cost. Meanwhile, the contamination will continu clearwelremaie o et th n ni l migratany dma e int groune oth d water system posin threaga t to sensitive ecosystems. Significant cost beine sar g incurre alreade th y db y financially strappee th do t PSD e ,du inefficient manner in which the treatment system must be operated in the absence of the clearwell. Significant public harm is likely in the three county area in the event ofirefa , pipeline break equipmenr ,o t malfunction.
&R2QOQ06 . ENDANQERKENIV : T DETERMINATION Actual or threatened release of mercury, a hazardous substance from the^te addresset no f ,i implementiny db e gth response action selecte thin di s Action Memorandum preseny ,ma t an imminent and substantial danger to the public health and - welfare environmentth d ean * . V PROPOSED ACTION COSTD SAN S . A Proposed Actions The actions proposed for the Taylor County Mercury site are designe permanentlo dt y mitigat danger.posee eth publie th o cdt health as a result of the release of mercury at the Site. The proposed actions are as follows: o Continue and expand where necessary the extent of contamination survey begun by EPAs SATA Contractor. Other drinkine areath f so g water system foun havo dt e level mercurf so levelt ya concerf so n Wil addee lb o dt the scope of work. . v o To the extent practicable, remove all residual mercury contamination where it is or has been detected in the joints, cracks, and pores of the concrete surface of the clearwell by cutting and removing those portions contaminated with mercury. o Arrang quicr efo k turnaroun laboratorf do y sampler sfo . . mercury analysis to verify that all mercury has been removed extene th o ,tt practicable, frosurfacee mth , joints, and subsurface of the clearwell. The Jerome Mercury Meter will als utilizee ob rear dfo l tim- e delineatio areacleanedf e no b o st . t Althougno s i t hi expected, other areas of the PSD system will be checked for residual mercury contamination. In the event that mercury at harmful levels of contamination has migrated froclearwele mth l system, these areas will alse ob cleaned to safe levels by appropriate means. o Repai restored ran necessarys ,a areal ,al s that have been disturbe mercury db y • removal* o Install a suitable liner in the clearwell chamber to ensure that any residual mercury contamination does not enter the drinking water system. o Dispos mercurf eo mercurd yan y contaminated debrit sa RCRa A permitted treatment, storage and/or disposal facility.
AR200007 B. Estimated Costs Extramural Costa Regional Allowance Costs ERCS $425,000 20% Contingency 85,000 Other Costs not Funded from the Regional Allowance SATA 50,000 Subtotal $560,000 10% Contingency 56,000 Total Extramural $616,000 Intramural Costa Direct Costs $ 20,000 Indirect Costs 42,600 Total Intramural $ 62,600 ESTIMATED TOTAL PROJECT CBXLZXa $678,600
. c Contributio Remediao nt l Performance The Taylor County Mercury Site is not listed or proposed to be Nationae listeth n do l Priorities List (NPL). Howevere ,th action is consistent with the remedy envisioned by the WVDOH, and whic requires hi d pursuan Safe th e o tDrinkint g Wate t (SDWArAc ) which regulates public water treatment plants proposee Th * d Removal Actio consistens ni t with accepted Removal practice anexpectes i d permanentlo dt y abat mitigatr eo identifiee eth d threats pursuan NCPe th .o tt . D compliance with ARARs The proposed Removal Action shall attain applicable and relevan appropriatd tan e environmental requirements (ARARs) to the extent practicable considering the exigencies of the situation pursuan NCPe th * o tt coordinates ha ThC eOS d wit WVDEe h th ensur o Pt e thal tal State ARAR sens identifiede ARARn ha sar t a C sOS requese Th . t letteState th Wes f eo o rt t Virginia 1997 , e date6 Th y * dMa West Virginia ARARs are expected to include limitations for air emissions, erosion, sedimentation wated ,an r discharge. Operations at this Site will comply with these suggested ARARs extene toth t practicable durin phasel gal thif so s Removal Action. Representative WVDEe WVDOth d Pan f s o H n wila e lb
fiR200008 8 integral part of the decision making process during all phases . of this Removal Action. ".?***%*..' VI. EXPECTED CHANGES IK THE SITUATION SHOULD NO ACTION BE TAKEN OR ACTION DELAYED If no action is taken or the action is delayed, the danger to public healt welfard han e will continu worsend ean Site Th .e is presently temporarily stabilized doe A complett EP s no f .I e eth cleanup action, the clearwell will remain shut down. .' This will require that the water plant operate at diminished capacity whic communite h th wil t decreaseo l t pu ris t ye a kdu d fire flow and loss of summer-month peak capacity, and it will adversely affect the welfare of the community due to the increased operating cost contaminatioe Th . n will continu remaio e et th n ni clearwell and may migrate into the ground water system posing a threa sensitivo tt e ecosystems. Significant cost beine sar g incurred by the already financially strapped PSD, due to the inefficient manne whicn ri treatmene hth t system mus operatee tb d absence iclearwelle nth th f eo . Significant public hars i m likely in the three county area in the event of a fire, pipeline break equipmenr ,o t malfunction. VII. OUTSTANDING POLICY ISSUES The use of Superfund monies to cleanup and rehabilitate a regulated public water treatment withou t planno s ti t precedent. The OSC sought and received the guidance of EPA management. While the evaluation of the Site, pursuant to the NCP, as a potential Removal Sit performes e wa OSC e determinae th ,th y db - tioSuperfun f seeo o n t e k us approvae d th monie r l fo thi n si s instance was confirmed in discussions with Section and Branch management. Base presentln do y available information doe,t i s appeat no r tha release tth deterioratioo t mercur f e o du s yi f no the public drinking water system through ordinary use, and there- fore the EPA is authorized to conduct this Removal Action at the Site. See 42 U.S.C. f 9604(a)(3)(C). VIII. ENFORCEXENT See the attached Confidential Enforcement Addendum. IX. RECOMMENDATIONS Because conditions at the Taylor County Mercury Site meet the criteria set forth in Section 300.415 of the NCP for a Removal Action, I recommend your approval of the Request for a Removal Action at the Site in Grafton, Taylor County, West Virginia. On-Scene Asth e Coordinator (OSC) hav,I e determined that funding in the amount of $678,600 of which $510,000 will be funded froRegionae mth l Removal Allowance y indicatna u Yo .e your approval or disapproval by signing below.
RR200009 APPROVED! SU-*L KTTW lA.\M£JUJto~ 1W______DATBf
DISAPPROVED!
Attachments: 1. Confidential Enforcement Addendun 2. Letters 3. Photo Documentation 4. Data Summary Tables and Location Maps
AR2000IO DIVISIO ENVIRONMENTAF NO L PROTECTION CECIL H. UNDERWOOD 1356 Haosford Street LAIOICY ELI MCCOY, PM>. GOVERNOR Charleston 25301-140V ,W 1 DIRECTOR April 10,1997
Chartic Kleeman, Chtef Supertund Removal Response Section U.S.EPA Region III 841 Chestnut Building . PhIiadelphia,P ' A 19107 Taylo: RE r Count ClearwelD yPS l Dear Mr. Kleeman: Wase Th t Virginia Divisio Environmentaf no l Protectio V DEPn(W ) recently receive facilitda y request for emergency assistance wit cleanue hth removad pan mercurf lo y contaminatio watea t na r treatment plant in Taylor County, West Virginia. Their request is enclosed• , The PSD attempted to dean up the mercury; however, to date, the levels remaining In concrete Joints have reported to be as high as 5461 pprri Total Mercury. The situation, we believe, te beyond the PSD's resource capability. It n dirD ePS neee assistancTh f do e with this situatio proteco nt t pubfi environmence healtth d han t If there is anything your section can do to assistant them, It would be greatly appreciated.
I. Michael Dorsey, Assistant Chief Compliance Monitoring and Enforcement HMD/Xw Enclosures Hayem Pa ccs:
Offic Wastf eo e Management, Compliance Monitorin Enforcemend gan t Telephone: (304) 858-6988 Fax: (904) 858-1423 or (304) C584256 TDD: 1-800-422-6700 AR2000I I *i~rrM*0 COCMtMC M»bUl»H »ai3 SLrtlaD*TUM.W«MlMBTe»l *0*lS IWMMif*. MtATfSM 'I'AnitTll ^ifflfrtt MMvtft«!Mi^-^^i^«l *-*•»•».»!(*•*%' I COMMITTE APPROPRIATIONN EO S t*KNtf-j Ma. Lynne Rosa Director Congr«*»ional Liaison Division Environmental Protection Ag«ncy 8th Floor, W*»t Tow»r 401 M Strett, SW. Washington/ O.C. 20460 Dea Rosa. rMa : Enclosed ia correspondence that J have received from Mr. Robert Xnotte, Chairman, Tayler County Public Sarvice District (PSD), Grafton, west Virginia, relaying tha PSD'a need to obtain assistanc mercura r efo y cleanup project. I would appreciate your reviewing this matter and providing me information about ways in which the U.S. Environmental Protection Agency mighassistancef o e tb . Thank you in advance for your assistance in this matter. With kind regards, I am Sincerely yours, . *#* Robert C Byrd^ RGBd ;ca (/ HR200012 yjr\ flPR-17-1997 11:28 * EfERGENCY RESPONSE 215 S6S 3254 P.08/09 V April 1,1897 MfiKIM IW ttlWW IteCUICU HUNTER !Goyemof Cecil Undervwod !omc triaf o e Governor iCapitol Complex Charleston, W«*t Virgin** 25305 'Dear Govomor Underv*ood: Attached please fin tettede r fro Taylow mtt r Counfy Public Sarviea Dlstlrcl detailing their Mercury Rvnwdlitfon Project enwrgwicy. other o Pleasu r Slatyo w ee advisho agencien a o e m assis n sca t in addressing this emergency. Ion Blalr Hunter r :JBH/IC AR2000I3 7-l997 li:27v- EPfl EMERGENCY RESPONbt - TAYLOR COUNTY Darle Seeler. ,jr Plant Manager . X^™"""V / James W. Riggleman-Treas. Phone: 304-265*5569 Edvard Beavers March 24. 1997 Joyce Moore, Inspector . - • Offic Wastf eo e Management , . .""• -. ' *• " 1304 Goos n RoaeRu d Fai^rent, WV 26554 , : EmergencRE y Assistanc Mercurr efo y Cleanup Project DeaMoore. rns : The Taylor County Public Service District (PSD) serves ovar 7.0OO customers including all of Taylor County and pacts of Barbour and Harriaon Counties, we discovered mercury contamination in our clearvell which holds the finished drink- ing water prior to distribution' We started a Mercury Cleanup Project by hiring an Environmental Engineer and advising your problemoffice th f eo . Despiteffortsr ou l recene eal , th t confir.^^io samples indicate that the clearvell is still contaminated with mercury as shown on the attached sketch. Our financial resources have now b*«n exhaustad and more uock is neede completo dt cleanue eth returd pan clearvele nth serviceo lt - progrese Th expensed san followss a dat o *e t ear : Stage I Initial Dry Upper Floor Cleanup and Water Removal 15/178 Stage II Piping and Valves Removal • -4- Stage III Secondary Dry Upper Floor Cleanup 12/331 Stag V eI Roraova Ton5 3 Filtef so f lo r Media 19,863 Stage v Pressure Hashing Clearvell and Effluent Line Bottom Concrete samplin Testind an g g 6,235 Stag j ev Wtste Disposal Costs 32,400 Initial costs to change piping, modify system using pump well and over- time for expanded schedule 40/563 $126/570 This project has been in progress for 5 months new and has pub * burden on the Plant Operator Boarde operatinveith r s s a Ou s .la g timbees eha n extended tcpm eleven hours to twenty one hours a day. He feel an urgent need to return to norml- productio soos n a possible s na . P O BOX 202 • GRAFTON. WV 263 -17-1937 11!27 EPft EMERGENCY RESPONSE "* 215 566 3254 P.B5/09 Joyce Moore Pag<*2 Marph 24, 1997 Given the nature of the problem and the lick of resources available to correct it, ve declare that our Mercury Remediation Project is an emergency. We respectfully request emergency assistance and that you help us in securing this, assistance. *• . Sincerely, • Robert C. Knotts* Chairman Taylor County PSD enclosure: : Governor'CC s Office Senator fiyrd : Senator Rockefeller Congressman Hollonan State Senator Hunter State Senator Mincar Delegat Colemam eTo n AR2000I5 TAILOR COUNTY PUBLIC SERVICE DISTRICT WATER TREATMENT PtANT P.O. B0;<2 20 " GRAFTON 25J5V ,W 4 EMERGENCY CLEARWELL MERCURY CLEANUP PROJECT INTRODUCTION A water treatment plant has been located on the Tygart Valley River near Grafton, West Virginia for over 70 years. In the 1.930's, the U.S. Army Corps of Engineers built a flood control and water supply dam just upstream o£ the water treatment plane. The current water treatment plant is owned and operated by the Taylor County Public Service District for treating about 2 million gallons of water per day for sale to the City of Grafton, and other Public Service Districts for distributio otheo t n r part f Tayloso r County. e TayloTh r County Public Service Distric source th r s efo i t entire th wate r e rfo County 1984n watew I .ne r,a filtration plant was construction to replace portions of the old plant and to increase capacity. Surface water treatment includes coagulatio flocculatiod nan n procedures followe filtratioy db n d chlorinationan e finisheTh . d water normally entera s 120,000 gallon clearwell constructe e 192th s 0tha' n i dt connects with a newer 48,000 gallon purnpwell that has high service pumps that pumps water to hilltop tanks for distribution. The original clearwell had four old float controllers that contained abou pound8 t mercurf o s eacr ype h controllea s ra counterweight. These flow rate controller were removed during the 1984 construction t ther,bu y recorde an wert eno s found that indicated the fate of the mercury. CURRENT SITUATION A. The Taylor County PSD draws water from the Tygart River through intake valves Cor e builEngineerf th po y tb s when the Tygart Dam was built just upstream and recently upgraded e TygarTh . tonle Riveth y s sourci r f wateo e r e entirth r e fo county e sourcTh .s excellen i e t with exceptionall turbidityw ylo source Th *adequats ei r efo current and any conceivable future needs of tne system. B. The 19SO Census population of Taylor County is 15/J44. Ther e 5,77ar e 8 households f thosO . e nearly 5,40e 0ar serve publiy db watece waterth rl servinAl . g residents of Taylor County comes from Taylor County Public Service District, Onlresidential8 y19 commercial,8 thred ,an e industrial customers are served directly by the PSD. The remaining customer servee sar d through resale agreements with four Public Service District 's and a Water Association. All customers of Taylor County PSD are metered customers. RR2000I6 Only r.he ClearveJ associated /an d pipin tfc; ga e treatment sice are involved in this project. £ sire .-nap and project locatio c attachedar p nma * : , The Taylor County PSD water system consists of a 2.5 mgd treatment plant/ approximately 13,970 L.F. ductile iron g star.dpipem f 6/30/96o 5 C pipans 1. PV d (a eg )a a , 181,000 g clearwell, a 40/000 clear-well at the pump house/ five electric pumps (three 250 HP, one 30 HP, one 89,00o tw 0clarifiers) g HP 3 251,00a d ,an 0settling g basine systea duaTh s .li m media filtratiod an n chiorination system e wateTh .r treatment plans wa t upgrade excellenn i s 198i n di d 4tan condition Core Th p. of Engineers upgraded intake valves in 1996 per a 1937 agreemen constructioo t e tdu Tygare th f to n Dam. In recent 'months small amounts of free mercury were observe uppee th rn di clearwel lsomn i floo ed rareaan s of the bottom of the elearwell as viewed from the hatch at the top. The cl carve 11 vas plugged and taJcen out of servic Octoben eI r 1996, Due to the emergency nature of the discovery of mercury the consultane service th engineere s th wa f so n o to wh , the current water system upgrade and line extension project, were acquired* The PSD requested quotations from three area contractor instalo t s- by w pip ne o lt e pass the clearwell. finished wate s therwa n directe pumpwele th o t d l which a muc d h ha smaJier capacity that reduce e timth de that .the water treatment plant coul unattendeo dg nightt da . e changTh capacitn i e y reduce floe th dw froplane th m t from 3,500 gallon minutr spe 2,00o et 0 gallon minutr spe e which could be very critical during an emergency such as a fire or water line break in Graftcn or any of the Public Service Districts in Taylor County. The PSD was force hiro dt additionan a e l employee becaus plane eth t had to be utilized for longer periods at the reduced . .. \ flow. Although elemental mercur e clearweli s founth ywa n i d / finished water testing has never shown any detection of dissolved mercury which drinkina s ,ha g water standarf do 0.002 mg/L maximum concentration a tes leved tan l detection .limi f 0.000o t 2 mg/L.- Wercury is listed as a hazardous waste by the U.S. EPA. Federa Statd lan e regulations require thadiscovere th c y of any hazardous waste constituent must be reported and that che waste be removed as soon as possibie. As a resul findinf o t physicae gth l presenc f freeo e mercury in the clearwell and the need to remediate this problem/ LarryA. ParXer A Associates/ Inc./ Environmental Chemist AR2000I7 r/ i Engineers, Wheeling, West Virgini s conrjccevj a d an d asked for assistance in determining a;; accio/; plan /or the mercury cleanup. A visi mads twa t/io et e Taylor Count D WateyPS r Treatment Plan y Larrb e . ParkerA y , P.E n Octobe.o , 19925 r o 6t meet with the PSD Commissioners and Manager to discuss possible cleanup procedures. A mercury remediation plas designewa n d wite knowth h n possiblt no s completelo wa t e t timee i fact t th ,bu t sa y design a plan or determine its costs since there were several unknowns tha te determineb coul t no d d until certain operations were completed. The initial remediation pla divides nwa d stagesw intfe oa thest ,bu e vere modifie wore th k s progressedda , WasteTron, Inc., Poca, West Virginia vas contacted to do the Stage I work. As the cleanup effort continued, WasteTron was asked to perfor e serviceth m s since thed equipmenha y d an t experienced personnel with 40 hour OSHA training certificates e variouTh . s e projecstageth f o st with costs as known or estimated to date are shown below; The PSD employs four certified operators, two Class III, one Class XI and one Class I. An additional Class II operator was hired during the period when the plant had to run longer due to closing the clearwell. . E Letter e attachear s d e froDivisioth m f Naturalo n s Resource Departmend san f Healto t h documenting neer dfo this s crisiprojecit d san tnature . Also attachee ar d documentatio f curreno n t cost r removinfo s g pipd an e capping off the clearwell. A letter from the Corp of Engineers substantiates their denia f assistanco l e with the substantial costs of alternative temporary intake during the intake upgrade in 1996. Finally, the PSD has an existing bond of 1.4 million that will not mature until 2025 and a new revenue bond issued in late 1996 for an additional $295,00 o t Rura0 l Developmenr fo t construction of an extension. The Public Service a positio n i Distric t borroo t nno y additionas i tan w l funds at this time. Their average rate is $20.25 per 4500 gallons. This substantially exceeds $14.96/4,500 required e mediuminimu th r ce.i f pe mo tme baseon n o d income in the County. F. Division of Environmental Protection tfPDES permit exp. 1998, WV Department of Health. III. Future Situation RR200018 . A This sectio inapplicabls ni o thiet s project-in c/iae th c future situation of the facility with regard to capacity, number of customers and conditiQft fof tne facility will be substantially unchanged. The sole improvement is the reseatin e clearwellth f o g . This projec s beini t g submitted under Section 5.15 Crisis Situacion Funding Assistance. IV. Alternatives * . . . * As indicated in the attached letters from DEP and the Departmen f Healtto halternativ o n ther s actione ewa th o t es ; D BoardPS e take.th y nb V. In this situation public participation was not an applicable possibility. . EnvironmentaVI . l .-:•. Information This projec necessary'dus twa presence th hazardoua o et f eo s material withi treatmene th n t system requirel Al .' d Agencies were contacted and proper' procedures for Cleanup and disposal f hazardouo s waste were followed o furtheN . r mercury contamination is anticipated. As a result of research into D archivePS engineee th s d Boar an e rsatisfie ar d d thae th t work performed will eliminate the source of prior and future contamination. VII. Project combinedSummarl B f A y( ) The Various projece stageth £ o st with cost s knova s r o n estimate dat o e showt d ear n below: Stage 1 Investigated problem/ developed plan, reviewed situation with WV DBP, obtained necessary pennies/ devised vacuum system with Activated carbon impregnated with sulfur cleaned ,en d ground floor of all visible mercury and debris using special vacuum equipment. (Generated 5 drums of waste.) (November 12, 1996 * January J3, 1557; $14,616.00 Permi r dischargintfo g wateo rt Fairmon SysteT tKW m 500.00 Stag I I e Remove exposel al d d clearwell building pipind gan valve longeo sn r used. pric(Removee th f eo r fo d scra locaa y pb l contractor). (January 20-24, 1997) $ o.OO RR2000I9 Stage tit Conferred with wv D£? about project status, cleaned ground floor area with special vacuum system after pipin d valvean g s wera removed, removed 29,122 gallon f wateo s r from clearvel n loadte n si l using a vacuum truc d transportean k Fairmonte th o t d v ,w wastewater system, and sampled old filter media and debri n clearveli s 1 point1 r t mercura fo sl y concentration. (January 24 - February 14, 1997; $11,£71.00 Fairmont Charge for discharging water 660.00 Stag V eI Continued discussion wit DEPV W h , designe" "A n a d frame trolley and hoist for lifting drums out of clcarvel1, reviewed laboratory date filtefo a r media in clearwell, set up removal system/ removed free mercury and debris (6 drums), removed all old filter media found in clearvell (contents of 43 drum r abouo s 5 ton1 t s dumped into roll-oftw o f container r off-sitfo s e disposal;, cleaned clearvell floor with vacuum system d tooan , k appropriate waste samples for characterization* (February 15 - 21, 1597) est. 523,00.00 Stage VI Obtain temporary RCRA Hazardous Waste Generator ID number/ transport 10 drums of mercury laden debris roll-ofano dtw f boxe contaminatef so d filter media (15 tons) to an out-of-state approved hazardous waste facility, (March 1-7, 1997j est. $22,000,00 Stage VII Seal and finish ground floor and clearvell bottom. (March 8 - IS, 1997 $ 9,000.00 Stage viir Disinfect clearvel preparo t l returo t e activo t n e service. est. $ 4,800.00 ESTIMATED REMEDIATION COST: $ 94,109.00 In addition to the remediation plan and costs the PSD incurred cost hiro st diveea examino rt takd ean e sample f thaso t lead to laboratory testing and confirmation of mercury in the clearvell t thaA .t time certain immediate b eo t step d ha s tafcen by the PSD to eliminate any possibility of contamination e wateth rf o supply. Usin servicee e engineerth gth f o s , hired by the PSD using 5C procedures/ who vas completing an upgrade extension project starte n laci d e 1995/ plans were pipf of e p frodrawclearwele ca th mo t n instald lan linw ne le froe linth me carrying treated water directl e pumth p o t y station clearvell. That engineer from the firm Vaugh, Coast, HR200020 £ Vaugh of wheeling recommended obtaining che .services of a firm experienced with hazardous waste removal. These preliminary cost included: Divers , *"*>'# "2,350 Engineering Plans £ Specs i,4JO Plug for Ciearweli 2,500 New Piping 28,953 Overtime Costs for Emp2oyees 5,999 0 35 Sampling/Testing 2. Existin H cost O& r g199 fo s 6 were $352,0*9. Excepr fo t inflationary increases this will remain substantially the same for the original system. There will be added costs due to the customersw ne additio 4 20 f . o n relatet no Thi s o thisi t d s application. 3, Current system debt includes; $1.4 million revenue bond maturing 2025. $295,000 Revenue Bond maturity date 2035. Both loans were issue Ruray db l Development $1.e Th 4. million loan was recently paid using a lower interest loan from One Valley Ban*. Details are not currently available in the audit since the transfer occurred after the end of FY 1996, There is no known record of delinquency on debt. 4. Becaus currenf eo t rates/ portion thif so s project with cost already paid by the PSD/ and existing outstanding debt/ the PSD is requesting a grant for the remaining cost in che amount of $94/109. 5. A copy of the PSD's existing tariff is attached. No new customers will be added as a result of this project* No change in rates is anticipated if the PSD is able to obtain : grant funds. anticipatee Th C. d project schedul includes ei d under combined . sectionBI d an sA D. N/A E. Removal of a potential hazardous contaminant/ raw mercury* F. - C. An engineer procured using 5C-1-1 was already performing design and construction services for the PSD when this problem was discovered. The Board did not feel that time was available for this process to be repeated. The recommendation e existinth f o g enginee n engineea r fo r r experienced wich handling hazardous waste was used. RR20002I DATE: 01 May 1997 PHOTO BY: Region III SATA DESCRIPTION: Photo shows SATA collecting a depth sample from the concrete floor of the clearwell. flR200022 DATE: 24 April 1997 . PHOTO BY: Region IHSATA DESCRIPTION: Photons the PSD facility from the top of the Tygart AR20002-3 Apri4 2 l DATE1997: PHOT : OBY Region III SATA DESCRIPTION: Photo D showfacilitPS e sth y from acros Tygare sth t Rivere .Th clearwell is underground and below the concrete structure. *'i -•- f Tayior County Mercury VSit !-Vi(,ie. V ' • Grafton, Tayior County, West Virginia TableI Analytical Summary for Samples Collecte D ContractoPS y dFebruarb 6 2 n ro y 1997 &$tiifi£lBa •PS^Si^iasSS:SHWTTS CS-1 Poin -Surfact1 e Concrete Mercury 16.7 mg/KG CS-2 Point 2-Surface Concrete Mercury 102.8;278.9 mg/KG CS-3 Point 3 -Surface Concrete Mercury - 4.3 mg/KG CS-4 Point 4-Surface Concrete Mercury 106.9 mg/KG CS-5 Point 5-Surface Concrete Mercury 128.1 mg/KG CS-6 Point 6-Surface Concrete Mercury 0.44; 1.98 mg/KG CS-7 Point 7-Surface Concrete Mercury 2.54 mg/KG CS-8 Point 8-Surface Concrete Mercury 36.72 mg/KG CS-9 Point 9-Surface Concrete Mercury 11.02 mg/KG Tayior County Mercury Site Grafton, Tayior County, West Virginia Table II Analytical Summary for Samples Collected by WVPEP on 28 February 1997 CS-A Point A-Surface Concrete Mercury 868.1 mg/KG CS-B Point B-Surface Concrete Mercury 1,211:0__ mg/KG CS-C Point C-Surface Concrete Mercury 5,461.0 mg/KG CS-D Point D-Surface Concrete Mercury 82.4 mg/KG CS-E Point E-Surface Concrete Mercury 27.4 mg/KG AR200025 Taylor County Mercury Site Grafton, Taylor County, West Virginia Table III Analytical Summary for Samples Collected by SATA on 01 May 1997 :s"ASKisaD» iIl^ffiDillii SDttlTS • TL-1 Lake' Tank10 p ,To Water Mercury 0.044 ug/L TL-2 Water-Planw Ra t Water Mercury 0.031 ug/L TL-3 Finished Water-Plant Water Mercury 0.054 ug/L TL-4 Garage Office Water Mercury 0.055 ug/L TL-5 Sewage Treatment Plant Water Mercury 0.050 ug/L CW1A Point 1-Surface Concrete Mercury 16.3 mg/KG CW1B Point 1 -Six Inches Concrete Mercury 487.0 mg/KG CW2A Point 2-Surface Concrete Mercury 39.8 mg/KG CW2B Point 2-Six Inches Concrete Mercury 172 mg/KG CW3A Poin -Surfact3 e Concrete Mercury 7.0 mg/KG CW4A Point 4-Surface Concrete Mercury 17.5 mg/KG CW4B Point 4-Six Inches Concrete Mercury 5.0 mg/KG CW5A Point 5-Surface Concrete Mercury 34.0 mg/K'" CW5B Point 5-Six Inches Concrete Mercury 12.8 mg/KG- CW6A Point 6-Surface Concrete Mercury 329.0 mg/KG CW6B Point 6-Six Inches Concrete Mercury 360.0 mg/KG CW7A Point 7-Surface Concrete Mercury 595.0 mg/KG CW7B Point 7-Six Inches Concrete Mercury 215.0 mg/KG CW8A Point 8-Surface Concrete Mercury 54.8 mg/KG CW8B Point 8-Six Inches Concrete Mercury 9.3 mg/KG CW9 Duplicate of Point 6B Concrete Mercury 484.0 mg/KG CW10 Duplicat Poinf eo B t7 Concrete Mercury 236.0 mg/KG CWW1 Crack in Concrete Water Mercury 8,700 ug/L CWW2 Adjacent to Effluent Pipe Water Mercury 63.7 ug/L Data Qualifiers: SR200026