**Addendum: An Assessment of**

**Environmental Problems Associated with Recycling of Hazardous
Secondary Materials**

**Appendix 1: Additional Damage Cases from Recycling of**

**Hazardous Secondary Materials**

**Appendix 1 Contents**

Additional Damage Cases from Recycling of

Hazardous Secondary Materials

+---------------------------------+------------------------------------+
| **Site Name**                   | **State**                          |
+=================================+====================================+
|                                 |                                    |
+---------------------------------+------------------------------------+
|                                 |                                    |
+---------------------------------+------------------------------------+
| **Part A: Additional Damage     |                                    |
| Cases from Hazardous Materials  |                                    |
| Recycling Operations**          |                                    |
|                                 |                                    |
| **Cited in Public Comments on   |                                    |
| the 2007 Supplemental Proposed  |                                    |
| DSW Rule**                      |                                    |
+---------------------------------+------------------------------------+
| Chemical Recovery (EQ Resource  | Michigan                           |
| Recovery/Michigan Recovery)     |                                    |
+---------------------------------+------------------------------------+
| Many Diversified Interests      | Texas                              |
| (Can-Am)\*                      |                                    |
+---------------------------------+------------------------------------+
| Waste Research & Reclamation    | Wisconsin                          |
| Co.\*                           |                                    |
+---------------------------------+------------------------------------+
| **Part B: Additional Damage     |                                    |
| Cases from Hazardous Secondary  |                                    |
| Materials Recycling**           |                                    |
|                                 |                                    |
| **at Mining and Mineral         |                                    |
| Processing Operations**         |                                    |
+---------------------------------+------------------------------------+
| Phelps Dodge New Cornelia       | Arizona                            |
| Branch Facility                 |                                    |
+---------------------------------+------------------------------------+
| Allied Signal Hydrofluoric Acid | Louisiana                          |
| Plant                           |                                    |
+---------------------------------+------------------------------------+
| U.S. Antimony Corporation Mine  | Montana                            |
| and Smelter                     |                                    |
+---------------------------------+------------------------------------+
| ASARCO Zinc Oxide Production    | Ohio                               |
| Facility                        |                                    |
+---------------------------------+------------------------------------+
| **Part C: Other Additional      |                                    |
| Damage Cases from Hazardous     |                                    |
| Secondary Materials Recycling   |                                    |
| Operations**                    |                                    |
+---------------------------------+------------------------------------+
| Union Foundry                   | Alabama                            |
+---------------------------------+------------------------------------+
| Halaco                          | California                         |
+---------------------------------+------------------------------------+
| Recyclights West                | California                         |
+---------------------------------+------------------------------------+
| Hydromex                        | Mississippi                        |
+---------------------------------+------------------------------------+
| Newark Processing               | Ohio                               |
+---------------------------------+------------------------------------+
| College Grove Battery Chip\*    | Tennessee                          |
+---------------------------------+------------------------------------+

**\*** Damage cases are cited in *An Assessment of Environmental
Problems Associated with Recycling of Hazardous Secondary Materials*
(2007) and updated with new information per public comments.

Site Information

  --------------------- -------------------------------------------------
  **Site Name:**        EQ Resource Recovery (also known as Chemical
                        Recovery System Inc. and Chemical Recovery
                        Systems Inc.)

  **EPA ID No.:**       MID060975844

  **Address:**          36345 Van Born Road, Romulus, MI 48174

  **County:**           Wayne

  **NPL Site**          No

  **In CERCLIS          0502571
  Database:**           
  --------------------- -------------------------------------------------

**Site History and Description of Recycling Operation:** The EQ Resource
Recovery site is a hazardous waste facility that has been in operation
since 1957, and is licensed by Michigan Department of Environmental
Quality (MI DEQ). The site was assessed and inspected by USEPA in 1983,
and then archived in 1991. The "archive" designation indicated that the
site had no further interest under the Federal Superfund Program based
on available information. EQ Resource Recovery blended liquid waste
solvents to create fuel used to fire industrial operations such as
cement kilns.

On August 9, 2005, an accidental combination of hazardous liquid wastes
caused a storage tank to explode and then set off a chain reaction of
fires in 29 surrounding tanks and a building containing 400 55-gallon
drums of flammable liquids. USEPA Region 5 responded to the explosion
and fire, approximately 900 residents were evacuated, nearby businesses
were closed, and Van Born Road was closed. Of the facility's
approximately 50 above-ground storage tanks, ranging in size up to
15,000 gallons, 32 were impacted by the fire/explosion.  In addition, a
propylene glycol re-boiler and a drum pad with overhead canopy and
approximately 400 drums of various products were destroyed.  Nearby
residents reported that metallic debris fell into their yards and pools.
As of August 2006, sources indicate that the cause of the fire was still
unknown.

The site was reopened as a CERCLA site in the aftermath of the fire in
August 2005. On October 20, 2005, USEPA issued a Settlement Agreement
and Order on Consent executed by EQ Resource Recovery, Inc. Under the
agreement, EQ Resource Recovery performed cleanup activities and paid
\$34,843.93 for costs incurred by USEPA as of September 13, 2005, and
agreed to pay response costs paid by USEPA after that date.

**Description of Contamination:** Workers and nearby residents reported,
through the media and Michigan's Toxics Hotline, immediate and acute
health effects from the flames and smoke, such as smoke inhalation and
burning skin. However, the effects were not deemed to be lasting or
chronic health effects. A health consultation report by theU.S.
Department of Health and Human Services concluded: "The explosion and
fire at the facility posed an urgent public health hazard, warranting
the evacuation that was ordered by local officials. Concentrations of
volatile organic compounds (VOCs) in the air, polycyclic aromatic
hydrocarbons (PAHs) in soot, and metals in soot and debris posed no
apparent short-term public health hazard. Additionally, any residual
contaminant concentrations pose no apparent current or future public
health hazard." Further explanation indicates that "when compared to
acute exposure screening levels ... all detected chemicals were well
below acceptable levels, indicating that no harm would be expected
during short-term exposure." However, the consultation states that three
patients were receiving follow-up medical care from the incident as of
October 2005.

A Potentially Responsible Party (PRP) Emergency Removal was started
August 9, 2005, and completed September 16, 2005. On September 12, 2005,
EQ contractors worked on clearing debris from the drum pad and tank
containment area.  On September 13, 2005, EQ contractors continued to
remove debris from the drum pad and began power washing the remaining
concrete pads with water. On September 14, 2005, EQ contractors
completed the removal actions on-site.  Power washing of the concrete
pad was completed, and all damaged tanks were cut up and placed into
rolloff boxes for disposal.  

USEPA conducted air monitoring during their response efforts on August
9, 2005, and continued air monitoring on August 10-14, 2005 using a
variety of methods. USEPA tested for VOCs, hydrogen sulfide, carbon
monoxide, oxygen and lower explosive limit. Air monitoring was concluded
at the end of the day on August 14, and once all samples were analyzed,
all contaminant levels were found to be below health concern limits.
Analysis of metallic debris samples found metals contaminant levels to
be below health concern limits.

**Sources of Information:**

Michigan Department of Environmental Quality (MI DEQ). "Understanding
the Results of Sampling from the EQ Fire in Romulus, Michigan." 26
September 2005. 15 February 2008.
<http://www.michigan.gov/documents/EQ_Data_Results_Factsheet_137513_7.pdf>

Tetra Tech EM, Inc. "EQ Resource Recovery Fire Site: Romulus County,
Michigan." Prepared for USEPA Region 5 Emergency Response Branch. 7
September 2005. 14 February 2008.
<http://www.epa.gov/Region5/sites/eqfire/pdfs/romulus-fire-report20050907c.pdf>

US Department of Health and Human Services. "Health Consultation: EQ
Resource Recovery Explosion and Fire." 1 March 2006. 19 February 2008.
[http://www.michigan.gov/documents/EQResourceRecoveryHC030106_153643_7.pdf]{.underline}.

USEPA. "EQ Resource Recovery Fire." [CERCLIS]{.underline}. 16 October
2007. 14 February 2008.
<http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0502571>

USEPA. "EQ Resource Recovery." [On-Scene Coordinator
Profile]{.underline}. (n.d.). 15 February 2008.
<http://www.epaosc.net/site_profile.asp?site_id=1785>

USEPA. "EQ Resource Recovery." [Pollution Report Profile]{.underline}.
(n.d.). 15 February 2008.
<http://www.epaosc.net/polrep_profile.asp?site_id=1785>

USEPA Region 5. "EQ Resource Recovery Fire Site." 28 March 20071. 4
February 2008. <http://www.epa.gov/Region5/sites/eqfire/index.htm>

USEPA Region 5 Regional Counsel. "Enforcement Action Summary FY 2006 --
November." 21 November 2005. 16 February 2008.
<http://www.epa.gov/Region5/orc/enfactions/enfactions2006/week-1105.htm>

**Site Information**

  --------------------- -------------------------------------------------
  Site Name:            Many Diversified Interests\*

  EPA ID No.:           TXD008083404

  Address:              3617 Baer Street, Houston, TX 77020

  County:               Harris

  NPL Site:             Final: 1/19/1999

  In CERCLIS Database:  0605008
  --------------------- -------------------------------------------------

**Site History and Description of Recycling Operation:** Steel casting
operations began at the 36-acre site in 1926 under the company name
Texas Electric Steel Casting Company (TESCO). Primary operations
included manufacturing specialty molds and casting specialty steel
parts. During the 1980s, the southern portion of the site was leased to
Can-Am Resources Group (Can-Am) to operate a spent catalyst recycling
operation. Can-Am reportedly purchased 4,236 drums of spent catalyst
material from refineries and chemical plants, and stored the drums on
the leased portion of the site. By 1988, the catalyst recycling
operations ceased, and the stored drums were abandoned on site. In
February 1991, TESCO ceased operations. Many Diversified Interests (MDI)
foreclosed on the site and later reopened as the San Jacinto Foundry
(SJF), a subsidiary of MDI. MDI filed Chapter 7 bankruptcy on May 20,
1992, and SJF ceased facility operations on approximately June 1, 1992.
The on-site facilities were demolished as a salvage operation under
order of the U.S. Bankruptcy Court between March 1995 and January 1996.
USEPA is currently performing a Remedial Investigation and Feasibility
Study (RI/FS) at the Site.

**Description of Contamination:** Poor housekeeping practices and site
abandonment led to environmental damage. In the north and south drum
storage areas, 5,355 drums, reportedly containing spent catalyst from
chemical companies and refineries, were found to be deteriorating and
leaking. In 1994, soil samples taken revealed elevated concentrations of
arsenic, chromium, cobalt, copper, lead, and nickel in the drum storage
areas. (Other damage not related to recycling included elevated
concentrations of arsenic, chromium, cobalt, copper, lead, and nickel in
the landfill located in the southern portion of the site, which
reportedly received inorganic slag and foundry sand; approximately 41
acres of contaminated soil located within the MDI property boundary; and
contaminated soil at 64 nearby residences.)

In 1998 and 1999, the PRPs performed an extensive drum removal action
under EPA oversight. The action included removal of more than 4,000
drums containing spent refinery and petrochemical catalysts from the
Can-Am operation and visibly contaminated soils. Following removal, EPA
undertook remediation activities. According to the Record of Decision
(ROD) for the site, remediation of the site was estimated to cost EPA
more than \$6.6 million, which includes costs for remediation of
contaminated on-site soils and ground-water due to recycling and
landfilling activities.

**Sources of Information:**

USEPA. "Many Diversified Interests Inc Fact Sheet." 13 January 2006. 20
January 2006. <http://www.epa.gov/earth1r6/6sf/pdffiles/0605008.pdf>

USEPA. "Many Diversified Interests." [On-Scene Coordinator
Profile]{.underline}. n.d. 20 January 2006.
[http://www.epaosc.net/site_profile.asp?site_id=06FE.]{.underline}

USEPA. "Many Diversified Interests Facility Detail Report." [Envirofacts
Data Warehouse]{.underline}. (n.d.). 20 January 2006.
<http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?p_registry_id=110005037361>

USEPA. "Record of Decision: Many Diversified Interests, Inc." 30 July
2004. 25 February 2008.
<http://www.epa.gov/superfund/sites/rods/fulltext/r0604098.pdf>

Number range CHAPTERUSEPA. "Superfund Site Progress Profile: Many
Diversified Interests Inc." [CERCLIS]{.underline}. 11 September 2006. 23
October 2006.
[http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0605008]{.underline}

\* Damage case is cited in *An Assessment of Environmental Problems
Associated with Recycling of Hazardous Secondary Materials* (2007) and
updated with new information per public comments.

**Site Information**

  ---------------------- ------------------------------------------------
  Site Name:             Waste Research & Reclamation Co.\*

  EPA ID No.:            WID990829475

  Address:               Route 7, Eau Claire, WI 54701

  County:                Eau Claire

  NPL Site:              Deleted: 2/5/1993

  In CERCLIS Database:   0505256
  ---------------------- ------------------------------------------------

**Site History and Description of Recycling Operation**: This site was
occupied by a roofing company from 1970 to 1981. Since 1975, Waste
Research & Reclamation Co. has recycled oil and solvents from industrial
sources at the 19-acre site in Eau Claire, Wisconsin. Hazardous wastes
were also treated and stored on the privately owned and operated site.
It is located about 0.5 miles east of Lowes Creek, a tributary of the
Chippewa River.

The techniques used to handle and store drums allowed wastes to spill on
the site. Runoff from waste processing was collected in unlined
impoundments. Organic solvents from the site contaminated ground water,
according to analyses conducted by the state. However, to date, no
residential wells are contaminated. This operation was primarily a
reclamation and recycling facility for hazardous liquid waste. Waste
materials handled included solvents and flammables. The site received
RCRA permits in September 1988 and August 2003.

On June 22, 2007, a fire erupted at the Waste Research & Reclamation
site. The Wisconsin Department of Natural Resources (DNR) said the fire
was accidental. Waste Research & Reclamation will not face any fines,
but they are responsible for cleaning up the site. The DNR and federal
and state agencies will work with the company to help supervise the
clean-up. On July 18, 2007, the DNR received the Site Investigation
Workplan which states the objectives of the investigation to determine
the degree and extent of the contamination.

**Description of Contamination:** The groundwater, soil, and surface
water are contaminated with volatile organic compounds (VOCs) due to
poor waste handling and storage procedures.

This site was addressed in a long-term remedial phase, focusing on
cleanup of the entire site. The site was divided into six solid waste
management units for investigation and cleanup purposes: drum storage
sheds; trailer parking, product warehouse, and abandoned drum storage
area; pole barn-cooling water discharge area and abandoned drum storage
area; abandoned lagoon, existing holding tank and existing collection
sump for surface water runoff; a reclamation area, known as the LUWA
area, located in the central and western portions of the site; and a
reclamation area, known as the Kontro area, located in the south central
portions of the site.

The potentially responsible parties (PRPs) for site contamination
conducted an investigation into the nature and extent of groundwater,
surface water, and soil contamination at the site. In 1983, the state
signed a consent order with the PRPs to implement a long-term monitoring
program. After adding this site to the NPL, USEPA performed preliminary
investigations and determined that no immediate actions were required at
the site while studies were taking place. These investigations
determined that the site should be managed under the authority of RCRA,
instead of CERCLA. Therefore, the site was deleted from the NPL on
February 5, 1993. Clean up costs at the site for the remedial phase
amounted to \$6,470.32.

[]{.mark}

Well sampling performed shortly after the 2007 fire at Waste Research &
Reclamation indicated that there were ketone and alcohol constituents in
wells near the areas where fire suppression water was released. Two
weeks later, further sampling indicated that there were no longer ketone
and alcohol contaminants in groundwater from wells on the site.
Wisconsin Department of Natural Resources is not aware of any residual
effects in aquifers; however, residual effects in confined aquifers are
yet undetermined. The only costs associated with the contamination from
the fire are the sampling costs which were paid for by Waste Research &
Reclamation.

**Sources of Information:**

Schoen, Jill. Wisconsin Department of Natural Resources, (715) 839-2788,
Interview: 25 February 2008.

USEPA Region 5. "NPL Fact Sheets for Wisconsin: Waste Research &
Reclamation Co." January 2004. 18 January 2006.
[http://www.epa.gov/region5/superfund/npl/wisconsin/WID990829475.htm]{.underline}

USEPA. Integrated Financial Management System (IFMS). 30 September 2004.
18 January 2006.

USEPA. "NPL Site Narrative for Waste Research & Reclamation Co." 7
October 2004. 18 January 2006.
<http://www.epa.gov/superfund/sites/npl/nar727.htm>

USEPA. "Permit Series List." [RCRAInfo]{.underline}. 19 January 2006.

USEPA. "Superfund Site Progress Profile for Waste Research & Reclamation
Co." [CERCLIS]{.underline}. 12 October 2006. 23 October 2006
[[http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0505256]{.underline}](http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0505256)

WEAU Channel 13. "WRR Fire Environmental Impact." 22 June 2007. 20
February 2008.
[[http://www.weau.com/home/headlines/8142612.html]{.underline}](http://www.weau.com/home/headlines/8142612.html)

Wisconsin Department of Natural Resources Bureau for Remediation and
Redevelopment Tracking System (BRRTS). "WRR Environmental Services
Remediation Activity Details." 28 November 2007. 22 February 2008.
<http://botw.dnr.state.wi.us/botw/GetActivityDetail.do?detailSeqNo=33784&siteId=1529200&crumb=1&s=B>

Willcom, Mae. Wisconsin Department of Natural Resources, (715) 839-3748,
Interview: 27 February 2008.

\* Damage case is cited in *An Assessment of Environmental Problems
Associated with Recycling of Hazardous Secondary Materials* (2007) and
updated with new information per public comments.

Site Information

  --------------------- -------------------------------------------------
  **Site Name:**        Phelps Dodge New Cornelia Branch Facility

  **EPA ID No.:**       AZD081687063

  **Address:**          HWY 85 South; Ajo, AZ 85321

  **County:**           Pima

  **NPL Site**          No

  **In CERCLIS          No
  Database:**           
  --------------------- -------------------------------------------------

**Site History and Description of Recycling Operation:** The Phelps
Dodge New Cornelia Branch Facility is a copper mine in the vicinity of
Ajo, Arizona, approximately 130 miles west of Tucson. On May 23, 1994,
the Sheriffs Department investigated a complaint about smoke rising from
the Phelps Dodge Slag Pile. Officers observed two piles of burning wire.
Phelps Dodge had an independent contractor that performed various
salvage activities, such as recycling and disposing of scrap metal,
including insulated copper wire.

**Description of Contamination:** On June 22, 1994, at the request of
the County Attorney's Office and the Sheriffs Department, Arizona
Department of Environmental Quality (ADEQ) staff conducted a hazardous
waste inspection at the Phelps Dodge Slag Pile. ADEQ collected nine soil
samples from the burn areas, all from within six inches of the surface.
Three contaminants of concern were identified; cadmium, chromium, and
lead. Six of the samples collected demonstrated levels of Toxicity
Characteristic Leaching Procedure (TCLP) for lead over the regulatory
limit, and one sample demonstrated levels of TCLP for cadmium over the
regulatory limit. Based on the analyses conducted, ADEQ determined that
there was reason to believe that the slag pile itself was contaminated
from the open burning and open dumping of insulated copper wire.

On May 12, 1995, ADEQ issued a Notice of Violation to the independent
contractor working for Phelps Dodge that required removal of
contaminated soils to a licensed TSD facility and that the use of all
equipment used in copper wire burning be discontinued. Although Phelps
Dodge reportedly did not approve of the copper wire burning at the site,
the company agreed to address the residual impacts of the burning and
excavated additional material that was treated as hazardous waste,
stored in containers, and shipped to a TSD facility. Phelps Dodge
subsequently conducted sampling of the excavated areas, and submitted a
Voluntary Environmental Mitigation Use Restriction to ADEQ because the
soil remediation levels were not considered to be protective of
residential use.

Phelps Dodge determined that there was no likelihood that ground water
could be impacted due to the absence of ground water in the area. The
nearest ground water drinking wells are five miles from the site. Phelps
Dodge pumps ground water from a depth of 800 feet from a well field six
miles north of the site.

**Sources of Information:**

USEPA. "Damage Cases and Environmental Releases from Mines and Mineral
Processing Sites." 1997. 28 January 2008.
<http://www.epa.gov/epaoswer/hazwaste/ldr/mine/damg3-97.pdf>

Site Information

  --------------------- -------------------------------------------------
  **Site Name:**        Allied-Signal Hydrofluoric Acid Plant

  **EPA ID No.:**        LAD041519067

  **Address:**          5525 Highway 3115 at State Route 30, Geismar, LA
                        70734

  **County:**           Ascension

  **NPL Site:**         No

  **In CERCLIS          No
  Database:**           
  --------------------- -------------------------------------------------

**Site History and Description of Recycling Operation:** Fluorogypsum
generated from the production of hydrofluoric acid was slurried with
process water as it was removed from the furnace. The resulting slurry
was transferred through a conduit system to an impoundment on the top of
a fluorogypsum stack. Seepage and runoff from the fluorogypsum stack was
collected in clay-lined ditches and flowed into an impoundment referred
to as the clearwell. Some water from the clearwell was recycled into
various plant operations, while excess water was discharged as needed
into the Mississippi River via a NPDES permitted outfall after passing
through a wastewater treatment plant.

Within the time period from 1986 to 1987, in an effort to find a
profitable use for the large quantities of gypsum waste accumulating at
Allied Signal\'s facility, an on-site contractor Louisiana Synthetic
Aggregates, Inc. (LASYNAG) began marketing the gypsum as a road base
material. The gypsum was reportedly processed by milling (excavating and
screening) the material from the fluorogypsum stockpile located at the
Allied-Signal hydrofluoric acid plant in Geismar, Louisiana. Once
processed, the fluorogypsum was marketed and shipped as \"Florolite.\"
In 1989, a damage case was reported that was associated with the use of
fluorogypsum without neutralization from Allied Signal's facility as an
embankment material.

**Description of Contamination:** In 1987, LASYNAG had the milled
fluorogypsum used as road construction material analyzed by several
laboratories. One laboratory reported that, with a resistivity of 500
ohms-cm and a pH of 5.2, the material was considered very corrosive for
most iron and steel products. The laboratory also stated that the high
sulfate content and the low pH would likely make the material corrosive
to concrete as well.

During 1987, after several rounds of requests and data submittals, the
Louisiana Department of Transportation and the Louisiana Department of
Environmental Quality (LADEQ) Office of Solid and Hazardous Waste
authorized the use of Florolite on various road shoulders, embankments,
and base courses. At least some of these approved projects were
completed, including road work at a mobile home park.

In July 1988, the City of New Orleans Department of Streets concluded
that the material would be acidic and corrosive for iron, steel, and
concrete products and deemed inadvisable the use of Florolite as a road
base material in the City.

On June 7, 1989, LASYNAG began construction of a test embankment for the
\"U.S. Highway 90 relocation construction project\" through a stretch of
wetlands in southern Louisiana near Amelia. After three weeks, LADEQ
responded to complaints of dying biota and found \"extremely acidic pH
and high conductivity in water adjacent to the roadbed.\" Construction
was ceased immediately.

Ambient surface water samples collected adjacent to the embankment
exhibited elevated levels of pH, sulfates, salinity, and specific
conductivity, as well as arsenic, cadmium, chromium, and lead. The
elevated concentrations in comparison to the more remote ambient surface
water sampling locations were attributed by LASYNAG to leaching and/or
runoff from the "Florolite" embankment. Under a LADEQ Compliance Order,
LASYNAG undertook remedial measures to remove the environmental hazard
posted by Florolite at the Amelia test site.

**Sources of Information:**

USEPA. "Human Health and Environmental Damage from Mining and Mineral
Processing Wastes." December 1995. 29 January 2008.
<http://www.epa.gov/epaoswer/other/mining/minedock/damage/index.htm>

USEPA. "Report to Congress on Special Wastes from Mineral Processing,
Chapter 9: Hydrofluoric Acid Production." July 1990.

> <http://www.epa.gov/epaoswer/other/mineral/chapter9.pdf>

Site Information

  ---------------------- ------------------------------------------------
  **Site Name:**         U.S. Antimony Corporation Mine and Smelter

  **EPA ID No.:**        MTD050261833

  **Address:**           1250 Prospect Creek Road; Thompson Falls, MT
                         59873

  **County:**            Sanders

  **NPL Site:**          No

  **In CERCLIS           No
  Database:**            
  ---------------------- ------------------------------------------------

**Site History and Description of Recycling Operation:** U.S. Antimony
Corporation (USAC) operated a mine and smelter on Prospect Creek, about
18 miles southwest of Thompson Falls, Montana. Until 1984, USAC was
mining and processing its own ore and generated "old slag" that went
into tailings ponds just below the smelter. The facility beneficiated
antimony concentrates by leaching ore in a solution of sodium
hydrosulfide and caustic soda. Spent barren solution was regenerated and
recycled before being discharged to one of three tailing ponds. Due to
poor current efficiency in the electrowinning circuit, as well as
precautions against the potential generation of stibine gas (a deadly
poison), high solution concentrations (6,000-10,000 mg/L) of antimony
were deposited in the flotation mill tailings ponds. The tailing ponds
were located on U.S. Forest Service land under a Forest Service special
use permit. While most of the antimony and arsenic was precipitated as
stable sulfides, soluble antimony concentrations of 10-150 mg/L remained
in the tailings.

The facility closed in 1984, and reopened in 1987, under a NPDES permit
stipulating a new method for processing antimony and handling process
wastes. This method precipitated any soluble arsenic or fugitive
antimony as environmentally stable sulfides. In addition, when the
facility re-opened, it began processing antimony from other sources
instead of mining its own ore and this "new slag" was shipped to a
refinery in British Columbia. In consultation with the Montana
Department of Environmental Quality, USAC agreed to address
environmental concerns about the "old slag" in the tailings ponds that
had continued to feed into the creek bottom. USAC cleaned up the site by
digging up the "old slag" and reprocessed it through the smelter and
then shipped it to a refinery in British Columbia.

**Description of Contamination:** Tailing pond water containing soluble
antimony and arsenic leached into the underlying aquifer, which
recharged Prospect Creek. The U.S. Forest Service inspected the site in
1984, and discovered that the tailings piles were accessible to game
animals, especially elk and deer, due to damage to the wildlife fence
surrounding the affected area. The Forest Service determined elk, deer,
and other animals, attracted by mineral salts in the tailings, were
ingesting antimony and arsenic, thus exposing humans and other predators
to contamination. The Forest Service inspection also revealed windblown
tailings being deposited beyond the permitted tailings disposal area.

**Sources of Information:**

USEPA. "Human Health and Environmental Damage from Mining and Mineral
Processing Wastes." December 1995. 29 January 2008.
<http://www.epa.gov/epaoswer/other/mining/minedock/damage/index.htm>

USEPA. "United States Antimony Corporation." [Envirofacts Data
Warehouse]{.underline}. (n.d.) 25 March 2008.
<http://oaspub.epa.gov/enviro/multisys2.get_list?facility_uin=110000497472>

Site Information

  --------------------- -------------------------------------------------
  **Site Name:**        Former ASARCO Zinc Oxide Production Facility

  **EPA ID No.:**       OHD056743933

  **Address:**          1363 Windsor Avenue, Columbus, OH 43211

  **County:**           Franklin

  **NPL Site:**         No

  **In CERCLIS          0507513
  Database:**           
  --------------------- -------------------------------------------------

**Site History and Description of Recycling Operation:** American Zinc
Oxide owned the smelter from 1918 to 1970, when ASARCO purchased the
property and operated it until ceasing production in 1986. The facility
produced zinc oxide from sphalerite ore by oxidation, reduction, and
back oxidation. Information in Ohio EPA's files regarding the ASARCO
operations at the Windsor Avenue facility indicates that from
approximately 1986 through early 1989, around 38,000 tons of zinc slag
from two large piles on the site were reported to have been shipped from
the Columbus facility to facilities in New Jersey and Missouri for
processing. Additional information about final use of the transported
zinc slag is not reflected in Ohio EPA's files.

Runoff from the ASARCO property drained to an open ditch near Joyce and
12th Avenues, referred to as the Joyce Avenue outfall. The receiving
ditch, referred to as the American Ditch, flowed about one mile through
an industrial and residential area and entered the City of Columbus
combined sewer system. In June 1989, the American Ditch was diverted to
a storm sewer discharging to Alum Creek, classified as a primary
contact, warm fishery, public, industrial, and agricultural water
supply. Between 1971 and 1988, ASARCO exceeded Ohio EPA discharge limits
several times, and began to take action to ship their zinc slag
off-site.

From 1995-1997, ASARCO undertook remediation activities, which included
leaving in-situ the remaining zinc slag or clinker and covering it and
pre-remediation on-site drainage ditches with a compacted 1.5 foot thick
clay cap to prevent rainfall or surface water from infiltrating into the
clinker fill. A vertical clay barrier surrounding the perimeter of the
cap keeps shallow ground water in contact with the clinker from
migrating off-site. Shallow ground water within the clinker is further
remediated by a subsurface drainage system installed within the clinker
and a geomembrane barrier and pH stabilization tank in a below-grade
concrete vault. The treated surface water and shallow ground water
discharges to a storm water retention pond, and subsequently discharges
to American Ditch at an NPDES outfall.

On June 19, 2003, ASARCO submitted a No Further Action (NFA) Letter to
Ohio EPA under the Voluntary Action Program (VAP). In August 2005,
ASARCO filed a national bankruptcy under Chapter 11 of the Federal
Bankruptcy Code. Ohio EPA records indicate that, as of February 25,
2008, Ohio EPA's Covenant Not to Sue was still pending. If Ohio EPA
issues a VAP Covenant Not to Sue, it will not release ASARCO from
liability for the historical off-site contamination of sediment
downstream of ASARCO in American Ditch.

**Description of Contamination:** Prior to remedial activity under Ohio
EPA's VAP Program, slag area runoff sampling data for September and
October 1986, revealed zinc concentrations of 26 mg/L and 46 mg/L,
respectively. At that time, ASARCO agreed to begin removing the zinc
slag from the facility. In August 1987, the Ohio EPA described the
situation at this facility by stating that, \"\[d\]ue to past practices
over many years of dumping waste slag or clinker all over the site,
there was still a problem with contaminated runoff. There were
documented problems with high concentrations of zinc and cadmium in the
runoff.\" In November 1987, ASARCO notified the City of its shipment
off-site of 35,000 tons of zinc slag.

**Sources of Information:**

Ohio EPA. "Summary of NFAs Received and Covenants Issued." 25 February
2008. 10 March 2008.
<http://www.epa.state.oh.us/derr/vap/docs/rptVAPNFASummary.pdf>

USEPA. "ASARCO." [CERCLIS]{.underline}. 11 January 2008. 10 March 2008.

<http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0507513>

USEPA. "Asarco Inc." [Envirofacts Multisystem Report]{.underline}.
(n.d.). 10 March 2008.
<http://oaspub.epa.gov/enviro/multisys2.get_list?facility_uin=110000906066>

USEPA. "Human Health and Environmental Damage from Mining and Mineral
Processing Wastes." December 1995. 29 January 2008.
<http://www.epa.gov/epaoswer/other/mining/minedock/damage/index.htm>

USEPA. "Report to Congress on Special Wastes from Mineral Processing,
Chapter 14: Primary Zinc Processing." July 1990. 27 February 2008.
<http://www.epa.gov/epaoswer/other/mineral/chapter14.pdf>

Site Information

  --------------------- -------------------------------------------------
  **Site Name:**        Union Foundry Company

  **EPA ID No.:**       ALD047158266

  **Address:**          1501 West 17^th^ Street, Anniston, AL 36201

  **County:**           Calhoun

  **NPL Site**          No

  **In CERCLIS          0400182
  Database:**           
  --------------------- -------------------------------------------------

**Site History and Description of Recycling Operation:** Union Foundry
produces ductile iron pipe waterworks fittings. The fittings are
manufactured from smelted scrap metal received from local dealers.

**Description of Contamination:** This site was brought to the attention
of EPA in 1981, and a subsequent site inspection and preliminary
assessment were conducted in 1985. The site was archived under CERCLIS
in 1994. In 2000, EPA sampled waste water outfalls near Union Foundry
and found low levels of PCBs. A Site Inspection Prioritization (SIP) was
completed, assigning a low priority for further assessment. After ADEM
issued consent orders to impose corrective measures related to RCRA
violations and problems in 2001 and 2006, the site was reopened in 2006.
In September 2007, the site was reassessed to resolve the site's
Superfund status, and the determination was made that no remedial action
was planned.

On September 6, 2005, Union Foundry was sentenced to pay a \$3.5 million
criminal fine, perform a \$750,000 environmental community service
project and serve five years probation by the U.S. District Court for
the Northern District of Alabama. The facility was sentenced to these
violations for pleading guilty to violating both RCRA and an OSHA
regulations.

The facility violated RCRA by knowingly allowing its employees to treat
toxic dust containing lead and cadmium, and considered hazardous waste
under RCRA, without a permit. The dust came from an air filtration
devise known as a "baghouse" that controlled pollution from scrap iron
melting.

In February 2008, Union Foundry agreed to pay a \$100,000 fine from the
Alabama Department of Environmental Management (ADEM) for improperly
disposing of dust in its non-hazardous waste landfill in May 2006. The
foundry did not determine if the dust needed treatment as a hazardous
waste before disposal. This action did not result in immediate
environmental damage; however, Union Foundry will submit a contamination
assessment and cleanup plan to ADEM as part of the cleanup process.

**Sources of Information:**

Holmes, Cory. Alabama Department of Environmental Management (ADEM),

\(334\) 270-5630, Interview: 21 March 2008.

The Birmingham News. "Alabama Department of Environmental Management
fines

Anniston company \$100,000." 9 February 2008. 20 March 2008.
<http://www.al.com/business/birminghamnews/index.ssf?/base/business/1202548520281220.xml&coll=2>

US Department of Justice. "Division of McWane, Inc. Sentenced to \$4.25
Million in

Criminal Fines & Community Service Related to Worker Safety,
Environmental Crime." 7 September 2005. 20 March 2008.
<http://www.usdoj.gov/opa/pr/2005/September/05_enrd_458.html>

USEPA. "Alabama Foundry Sentenced to Pay \$4.25 Million for RCRA and
OSHA

Violations." [EPA Newsroom]{.underline}. 22 September 2005. 20 March
2008.
<http://yosemite.epa.gov/opa/admpress.nsf/e51aa292bac25b0b85257359003d925f/7f96e142c9c124f285257084005671cf!OpenDocument>

USEPA. "Mead Corp./Former Union Foundry." [CERCLIS]{.underline}. 20
March 2008. 20 March

2008\.
<http://oaspub.epa.gov/enviro/cerclis_web.report?pgm_sys_id=ALD047154232>

USEPA. "Mead Corp./Former Union Foundry." [Superfund Site
Information]{.underline}. 16 October

2007. 20 March 2008.
      <http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0400182>

USEPA. "Union Foundry Company." [RCRAInfo]{.underline}. (n.d.) 20 March
2008.

[http://oaspub.epa.gov/enviro/rcris_web.report?pgm_sys_id=ALD047158266]{.underline}

USEPA Region 4. "Response to Public Comments: Section 122 Administrative

Agreement and Order on Consent for Removal Action." 13 January 2006.

24 March 2008.
<http://www.epa.gov/Region4/waste/sf/annistonsf/annistonsect112011306.pdf>

Site Information

  --------------------- -------------------------------------------------
  **Site Name:**        Halaco Engineering Incorporated

  **EPA ID No.:**       CAR000177709

  **Address:**          6200 Perkins Rd., Oxnard, CA 93033

  **County:**           Ventura

  **NPL Site**          Final: 9/19/2007

  **In CERCLIS          0901242
  Database:**           
  --------------------- -------------------------------------------------

**Site History and Description of Recycling Operation:** From 1965 to
2004, Halaco Engineering operated a secondary metal smelter, recovering
aluminum, magnesium, and zinc from aluminum cans, metal waste from other
smelters, and other scrap materials. Between 1965 and 1977, Halaco
received and processed an estimated 500 to 600 pounds of radioactive
magnesium thorium scrap per year. The facility held a California
Radioactive Materials License to handle magnesium-thorium alloy from
1965 to 1974.

The Halaco facility was built on top of an open dump for the City of
Oxnard. The site includes an 11-acre parcel containing the former
smelter and an adjacent 26-acre waste management area where wastes were
deposited. Immediately adjacent to the site is a portion of the Ormond
Beach wetlands, which are some of the few remaining wetlands in the area
and home to several endangered or threatened species.

During their 40 years of operation, Halaco produced a large quantity of
wastes, primarily non-target metals and metal salts remaining after the
smelting process (i.e., slag or dross). From approximately 1965 until
1970, Halaco discharged waste to an unlined earthen settling pond
adjacent to the Oxnard Industrial Drain. At some point, Halaco began
depositing dried waste material on the area north of the unlined earthen
evaporation pond, a 15-acre area of disputed wetlands. In 1977, theU.S.
Army Corps of Engineers issued Halaco a cease-and-desist order for this
dumping and, in 1980, the USEPA issued Halaco an enforcement order under
the Clean Water Act stating that the disposal site was a wetland and
required a NPDES permit for operation. The USEPA also obtained a
preliminary injunction prohibiting further disposal to the area. From
approximately 1970 until 2002, Halaco deposited wastes to unlined
earthen settling ponds east of the smelter.

In June 2000, the Los Angeles Regional Water Quality Control Board
(LARWQCB) estimated that 430,000 cubic yards of waste material were
present in the waste management unit at thicknesses varying between 20
and 40 feet.

Numerous federal, state, and local agencies attempted to regulate
Halaco's operations, including the California Regional Water Quality
Control Board (Los Angeles), California's Department of Toxic Substances
Control, California Department of Health Services Radiologic Health
Branch, Ventura County Air Pollution Control District, USEPA, and the
Army Corps of Engineers. Halaco contested and/or litigated many of the
regulatory efforts by these agencies. The Ventura County District
Attorney and the Environmental Defense Center, a nonprofit public
interest organization, have also been in litigation with Halaco on
environmental matters.

In 2002, Halaco filed for Chapter 11 bankruptcy. After Halaco ceased
operations, the bankruptcy was converted to Chapter 7 (liquidation)
bankruptcy. In 2006, Alpha and Omega Development LLC purchased the waste
management area and assumed the lease to the former smelter property.
Future uses of the property remains uncertain.

**Description of Contamination:** EPA entered into a Consent Agreement
with the potentially responsible parties (PRPs) in mid-2006 to remove
the containerized hazardous substances from the smelter facility,
consolidate loose process solids in the smelter into one of the
buildings, and secure the smelter and waste management unit and place a
sediment runoff control measure. The PRP removal action, completed on
February 7, 2007, successfully removed all containerized hazardous
substances. Wetlands contaminated with thorium waste process solids were
cleaned up in March 2007.

An estimated 700,000 cubic yards of waste remains onsite in the waste
management area. This includes 5,000 cubic yards of process solids
stored at the smelter inside the smelter buildings, conex containers,
and quancet huts. Elevated levels of aluminum, barium, beryllium,
cadmium, chromium, copper, lead, magnesium, manganese, nickel, thorium,
and zinc are present in the wastes and onsite soils. Waste material has
moved into the underlying groundwater and into adjacent soils and
sediments.

From March to June 2007, EPA and its contractors implemented measures to
stabilize and secure the site and to limit offsite migration of
contaminated wastes. The work included regrading the waste pile to
reduce the steepness of the slopes, placing matting on the slopes to
reduce erosion, moving waste material from the smelter parcel to the
waste management area, and improving site security. Some of the Halaco
waste material in the wetland area to the south of the smelter parcel
was excavated and moved to the waste management area.

In June 2007, EPA discovered elevated levels of radiation coming from
waste materials buried in the southeast corner of the former smelter.

From 2007 through 2008, EPA began conducting a study of surface water
and groundwater movement at and near the site to better determine the
extent and movement of Halaco's wastes. EPA is also beginning
assessments of human health and environmental risks posed by site
contamination as part of the remedial investigation for the site. The
California Department of Human Health is also conducting a health risk
assessment. EPA is tentatively scheduled to evaluate options for
remediation of onsite and offsite contamination from 2007-2010. If
needed, EPA will implement additional interim measure to control offsite
movement of contaminated waste, groundwater, surface water, and air.

**Sources of Information:**

USEPA. "Halaco Engineering." [On-Scene Coordinator Profile]{.underline}.
11 November 2007. 3 March 2008.
<http://www.epaosc.net/site_profile.asp?site_id=2258>

USEPA. "Halaco Engineering Incorporated." [RCRAInfo]{.underline}. 3
March 2008. 3 March 2008.

<http://oaspub.epa.gov/enviro/rcris_web.report?pgm_sys_id=CAR000177709>

USEPA. "Superfund Site Progress Profile for Halaco Engineering."
[CERCLIS]{.underline}. 8 February 2008. 3 March 2008.

<http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0901242>

USEPA Region 7. "Halaco Engineering Co. Superfund Site: EPA Update."
PowerPoint Presentation. 24 September 2007. 6 March 2008.
[http://yosemite.epa.gov/r9/sfund/r9sfdocw.nsf/63d4ce17a198b2e3882573c5007fae76/15bfc11ebbb3d1fe8825737100512a03/\$FILE/EPA%20Presentation%20on%20the%20Halaco%20site%20-%20Sept%202007.pdf](http://yosemite.epa.gov/r9/sfund/r9sfdocw.nsf/63d4ce17a198b2e3882573c5007fae76/15bfc11ebbb3d1fe8825737100512a03/$FILE/EPA Presentation on the Halaco site - Sept 2007.pdf)

**Site Information**

  --------------------- -------------------------------------------------
  Site Name:            Recyclights West LLC

  EPA ID No.:           

  Address:              Glendora, CA

  County:               

  NPL Site:             No

  In CERCLIS Database:  No
  --------------------- -------------------------------------------------

**Site History and Description of Recycling Operation:** Robert J.
Roberts owned Recyclights West in Glendora, CA. Recyclights transported
used fluorescent light tubes and high-intensity discharge lamps and
advertised itself as a company that recycled \"hazardous waste lamps\"
in compliance with United States Environmental Protection Agency
regulations. Recyclights also promised customers, such as the Los
Angeles Air Force Base and Camp Pendleton, that it would issue a
Certificate of Recycling.

A grand jury indicted Robert J. Roberts on federal environmental and
obstruction of justice charges for offering to properly dispose of
fluorescent light tubes and other lamps that contained hazardous levels
of lead and mercury, and then simply dumping these materials in storage
lockers across Southern California. The indictment charges Roberts with
one count of storing hazardous wastes without a permit, two counts of
making a false statement to a criminal investigator with the Department
of Defense, one count of obstructing justice, and one count of making a
false statement to the United States Marine Corps Base, Camp Pendleton.\
\
The indictment alleges that, rather than recycling lamps, Roberts rented
self-storage units throughout Los Angeles and San Bernardino counties
and simply dumped the waste fluorescent tubes and lamps at the
self-storage locations. This case was investigated by the Office of
Inspector General for the Department of Defense, the California
Department of Toxic Substances Control and the United States Postal
Inspection Service.

**Description of Contamination:** When agents executed search warrants
at approximately 30 storage units, they found tens of thousands of
lights that contained hazardous levels of lead and mercury.
Investigators also learned that Roberts had stopped paying rent for the
units.

**Sources of Information:**

US Department of Justice. "Man Who Offered Hazardous Waste Recycling
Allegedly Only Dumped Material In Storage Lockers." Release No. 06-027.
3 March 2006. 5 March 2008.
<http://www.usdoj.gov/usao/cac/pressroom/pr2006/027.html>

**Site Information**

  --------------------- -------------------------------------------------
  Site Name:            Hydromex

  EPA ID No.:           None

  Address:              P.O. Box 1514, Yazoo City, MS, 39194

  County:               Yazoo

  NPL Site:             No

  In CERCLIS Database:  No
  --------------------- -------------------------------------------------

**Site History and Description of Recycling Operation:** Hydromex, Inc.
operated a pilot recycling plant in Yazoo, Mississippi. In June 2001,
U.S. Technology Corporation in Canton, Ohio, licensed Hydromex, Inc. to
use its spent blast media (SBM) to manufacture 18"x18"x48" blocks which
were to be used on levies. (Shipments of SBM were made prior to this
agreement beginning in 2000). The SBM is comprised of plastic, aluminum
oxide, garnet, silica and glass bead media, as well as, paint chips
which may contain lead, cadmium, chromium and barium. Shortly after
manufacturing the levy blocks Hydromex started to manufacture smaller
blocks for a demonstration home and concrete pads and trenches on the
property.

On November 14, 2002, the USEPA, investigative agencies within the
Department of Defense, Mississippi Department of Environmental Quality
(MDEQ), and the Federal Bureau of Investigation executed a search
warrant at the Hydromex facility. Also, on November 14, 2002, the
Mississippi Department of Environmental Quality issued a cease and
desist order in which Hydromex was cited for operating a hazardous waste
facility without a permit. According to information from USEPA and
Mississippi DEQ, Hydromex is reported to have accepted over 11,000,000
lbs (25,273 drums and 2,156 super sacks) of spent blasting media from
late 2000 to November, 2002. In November 26, 2002, USEPA cited Hydromex
for operating an illegal hazardous waste treatment, storage, and
disposal facility.

On July 17, 2003, MDEQ and U.S. Technology entered into an agreed order
were U.S. Technology agreed to operate the Hydromex facility to make
split face construction blocks with the SBM in drums and super sacs, and
to recycle the products Hydromex produced. U.S. Technology received a
variance for needing a permit for the storage of hazardous waste at
Hydromex, but was prohibited from receiving SBM or shipping SBM offsite.
In late 2007, U.S. Technology had recycled all the containers of SBM and
blocks that were located at Hydromex into split face concrete blocks.
U.S. Technology is pursuing a RCRA closure for the concrete pads, which
will consist of a cap over the site.

**Description of Contamination:** The bricks produced by Hydromex
crumbled on contact and were soft, and the slabs would not support the
weight of a person; therefore, neither material could be used in
construction. An indictment of the facility operator alleged that the
products produced at the Hydromex plant were useless and made only to
create the illusion that the company was legitimately recycling
hazardous waste in accordance with federal and state environmental laws.

Hydromex buried millions of pounds of hazardous waste (PMBs and the soft
bricks and slabs) contaminated with heavy metals, cadmium, chromium, and
lead in trenches. The waste leached heavy metals into the surrounding
soil and groundwater.

On June 17, 2004,U.S. Technology agreed to pay a \$150,000 civil penalty
to Ohio EPA for operating an unpermitted hazardous waste storage
facility for 2000, 2001, and 2002 in Canton, Ohio. This is the period of
timeU.S. Technology shipped SBM to Hydromex.

On November 15, 2007, Hydromex operator Dennie Eugene Pridemore pleaded
guilty to a six-count federal indictment that charged him with operating
a sham hazardous waste recycling facility. Mr. Pridemore admitted to
illegally storing and disposing of hazardous waste at the Hydromex site
and to making false statements to regulatory officials and investigators
to conceal the illegal disposal. On February 7, 2008, the U.S. District
Court sentenced Mr. Pridemore to 41 months in prison and three years
probation.

**Sources of Information:**

Bailey, Steve (Mississippi Department of Environmental Quality). Digital
photos to Nyall McKenna (Ohio EPA). 23 August 2002.

Environment News Service. "Sham Mississippi Hazwaste Operator Jailed." 7
February 2008. 6 March 2008.
<http://www.ens-newswire.com/ens/feb2008/2008-02-07-095.asp>

FreePatentsOnline.com. "Process for the treatment of waste products."
(n.d.) 6 March 2008. <http://www.freepatentsonline.com/5630785.html>

McKenna, Nyall (Ohio EPA). Letter to Raymond Williams (President,U.S.
Technology Corporation). 1 May 2003.

McKenna, Nyall (Ohio EPA). Letter to Raymond Williams (President,U.S.
Technology Corporation). 17 December 2002.

McKenna, Nyall (Ohio EPA). Letter to Raymond Williams (President,U.S.
Technology Corporation). 21 May 2002.

Mississippi Commission on Environmental Quality. Agreement between
Mississippi Commission on Environmental Quality andU.S. Technology
Corporation (Order No. 4614_03). 18 July 2003.

Mississippi Commission on Environmental Quality. Cease and Desist order
issued to Hydromex (Order No. 4510_02). 14 November 2002.

Ohio EPA. Director's Final Findings and Orders, agreement between Ohio
EPA andU.S. Technology to resolve past violations and a civil payment of
\$150,000.00. 17 June 2004.

Supply and Recycle Agreement betweenU.S. Technology Corporation and
Hydromex, Inc. (n.d.).

The Clarion -- Ledger. "Federal, state agencies probe waste recycler."
15 November 2002.

United States Attorney's Office Southern District of Mississippi. "Yazoo
City Hazardous Waste Operator Pleads Guilty." 15 November 2007. 6 March
2008. <http://www.usdoj.gov/usao/mss/november15b2007.html>

Williams, Raymond (President,U.S. Technology Corporation). Letter to
Nyall McKenna (Ohio EPA). 19 June 2001.

**Additional Contacts:**

Jeffrey T. Pallas (EPA Region 4 RCRA Enforcement and Compliance Branch)
(404) 562-8616

Steve Bailey (Mississippi Department of Environmental Quality) (601)
961-5171

Nyall McKenna (Ohio Environmental Protection Agency) (330) 963-1272

Site Information

  --------------------- -------------------------------------------------
  **Site Name:**        Newark Processing

  **EPA ID No.:**       TRI ID: 43055NWRKP1367E; No RCRA ID

  **Address:**          1367 E. Main Street, Newark, OH 43055

  **County:**           Licking

  **NPL Site**          No

  **In CERCLIS          No
  Database:**           
  --------------------- -------------------------------------------------

**Site History and Description of Recycling Operation:** In 1980, Newark
Processing began operating a secondary aluminum recycling facility at
the 66-acre East Main Street facility adjacent to the Licking River. The
facility ceased operations due to bankruptcy in late 1996. 

Newark Processing processed aluminum dross from several aluminum
smelting companies. Dross, a by-product of primary and secondary
aluminum smelting, consists of varying concentrations of aluminum,
aluminum oxides, free metals, and salts. Newark Processing received two
types of dross on a tolling basis: (1) white dross, which contains a
high enough aluminum content to be fed directly into a rotary furnace
for smelting, and (2) black dross, which must be processed through a wet
mill to concentrate aluminum before smelting. 

Newark Processing's furnaces and wet mill generated saltcake and dross
fines as byproducts of the recycling process. The facility screened the
wet mill waste by size and recovered and reprocessed the larger
particles. The smaller particles flowed to a series of cement-lined
settling ponds, accumulating as a sludge called "dross fines." Newark
Processing periodically removed these dross fines and stockpiled them
on-site, claiming that the dross fines would either be re-processed or
sold. 

At the time of its bankruptcy, Newark Processing estimated that
approximately 374,000 tons of dross fines and 175,000 tons of aluminum
dross remained at the site. 

**Description of Contamination: I**n 1980, Newark Processing analyzed
the material stockpiled on site at the request of Ohio EPA. Despite the
detection of metals and ammonia in the sample, Ohio EPA concluded that
the stockpiled material did not require regulation. 

On February 28, 1991, Newark Processing sampled the dross fines for
total metals, pH, percent solids, and chlorides. Results indicated
relative high metal content with a pH of 9.6; however, no conclusions
were drawn from this data. On January 8, 1992, Newark Processing sampled
the aluminum dross fines for organics and metals using the toxicity
characteristic leaching procedure (TCLP) and found all organics to be
below detection limits and barium, cadmium, chromium, lead to be below
the TCLP regulatory limit. On April 29, 1994, Newark Processing sampled
dross fines for total metals. The results indicated high metal content;
however, no conclusions were drawn from this data.

In May 1999, at the request of Ohio EPA, Newark Processing contracted
URS Greiner Woodward Clyde (URS) to conduct an investigation of the
stockpiled material and ground water.  URS installed eight direct push
borings, collected surface and subsurface dross samples, and collected a
composite dross sample of the West Dross Pile. Analysis for metals
indicated high metal content in the waste material but all
concentrations were below the TCLP regulatory limit. High concentrations
of ammonia and chloride were detected, and the pH range was
7.9-10.5. URS analyzed the ground water samples for total and dissolved
metals, pH, ammonia, chloride, and fluoride. Ground water samples
indicated arsenic, barium, cadmium, nickel, selenium, and fluoride were
above their respective maximum contaminant levels (MCLs) for drinking
water. Also, high ammonia and chloride concentrations were detected.

In 2004, the city of Newark contracted Civil and Environmental
Consultants, Inc. (CEC) to complete a Phase II investigation of the
property using the \$300,000 in bankruptcy funds that had been awarded
to Ohio EPA. In addition, Ohio EPA contributed resources (personnel,
direct push technology, and monitoring well installation) through a
grant from USEPA. CEC and Ohio EPA collected samples of soil, dross,
dross fines, ground water, surface water, and sediment.  Ohio EPA also
assessed macroinvertebrate communities in the Licking River and Shawnee
Run. All environmental media were analyzed for metals, ammonia,
nitrate-nitrite, and volatile organic compounds and all dross stockpiles
were analyzed for dioxins.

The sample results were compared to the Ohio EPA Voluntary Action
Program generic standards, and it was determined that (1) no contaminant
detected in soil, dross, or surface water/sediment exceeded generic
standards; (2) ground water exceeded unrestrictive potable use standards
for ammonia, selenium, and nitrate-nitrite; (3) multiple chemical
adjustment indicated the dross and soil exceeded property-specific
applicable standards for some complete pathways (e.g., direct contact
with ground water and direct contact, inhalation, and ingestion of dross
and impacted soil); and (4) no biological impairment was indicated in
the Licking River and Shawnee Run.  Ohio EPA also evaluated sediment in
terms of freshwater quality and found that the metal concentrations in
the dross are much higher than the threshold effect concentration (TEC,
the concentration in sediment below which harmful effects will not
likely be observed) and probably effect concentration (PEC, the
concentration above which harmful effects are likely to be observed).
Ohio EPA determined that continued erosion of the waste dross will
increase the overall metallic concentration in the sediment and
adversely affect sediment dwelling organisms.

Ohio EPA is currently working with theU.S. Army Corps of Engineers
(USACE) concerning the erosion of the dross. A memorandum of agreement
was signed between Ohio EPA and USACE on December 14, 2006, and a
support agreement on March 14, 2007. On April 16, 2007, Ohio EPA
provided USACE \$2.8 million dollars for the stabilization project. The
project will stabilize about 1,600 feet of river bank. 

**Sources of Information:**

Ohio EPA. "Division of Emergency and Remedial Response\
Site Cleanup Summary: Newark Processing." May 2007. 6 March 2008.
<http://www.epa.state.oh.us/cdo/newark_processing.html>

USEPA. "Newark Processing Co Inc." [Envirofacts Multisystem
Report]{.underline}. (n.d.) 6 March 2008.
<http://oaspub.epa.gov/enviro/multisys2.get_list?facility_uin=110001628212>

**Site Information**

  --------------------- -------------------------------------------------
  Site Name:            College Grove Battery Chip

  EPA ID No.:           TNSFN0406979

  Address:              Arno College Grove and Horton Road, College
                        Grove, TN 37046

  County:               Williamson

  NPL Site:             No

  In CERCLIS Database:  0406979
  --------------------- -------------------------------------------------

**Site History and Description of Recycling Operation:** The College
Grove Battery Chip site is located in the College Grove Community and
the surrounding areas within Williamson and Rutherford Counties. The
site initially consisted of 14 private residential properties and two
commercial properties located within an 8-mile radius of the town of
College Grove, Tennessee. The properties are contaminated with lead,
which is leaching from waste battery chips that were used as an
aggregate substitute over the past 50 years at various locations
throughout the community. A local lead smelting operation provided the
chips to landowners for use as a fill or aggregate substitute in
driveways, around barns, and in other areas as fill material. The chips
were not treated to remove residual lead prior to their distribution,
creating a lead exposure risk to residents to contacting the chips or
the soil contaminated by lead washed from the chips.

**Description of Contamination:** In 1999, Tennessee Department of
Environment and Conservation (TDEC) identified battery casings on the
CSX Railroad property and on several residential properties. USEPA began
a Superfund removal on June 19, 2000, including extensive sampling of
each property to determine contaminated soil locations, excavation and
treatment of contaminated soil, transportation and disposal of materials
in a proper landfill, and restoration of the site (including backfill,
grade, and revegetation). The excavation of contaminated soil was
completed on January 19, 2002. The removal was expected to be completed
in January 2004, at an estimated cost of \$3 million. Elevated lead
levels were detected at 96 of the 109 properties. Prioritization of
properties was determined first by known exposures to lead, then on a
first-come basis. On virtually all properties the lead migrated no more
than 12 inches vertically. Horizontal migration was a function of
topographic slope and lead source concentrations.

The final project cost was approximately \$7.25 million. As of May 2003,
battery chips were confirmed at 109 of the 171 properties evaluated in
College Grove and the surrounding area. Previous sampling of some
properties indicated elevated levels of lead in the soil.

The January 2004 health consultation completed by the U.S. Department of
Health and Human Services' Agency for Toxic Substances and Disease
Registry (ATSDR) concluded:

*"No apparent public health hazard exists at the residence in College
Grove. Lead is present in the small area excavated by the homeowner. An
exposure pathway exists for the family at this residence, but is likely
to be limited. The children\'s blood levels are below the CDC
recommendation."*

While a community-wide adverse impact from lead exposure was not
evident, the contaminated battery chips and soil affected two residents
who have been confirmed to have elevated blood levels. USEPA conducted
removal actions at each of these properties, reducing lead to acceptable
levels. On one property, the Scales property/Spur Gas Station, the chips
were located among the underground storage tanks (USTs) that serve the
gas station. These chips were not disturbed as they are under several
feet of cover. Only the chips and lead-contaminated soil within the
first two feet were removed and replaced with clean fill material. The
side slopes were stabilized with a thick grass cover. The property owner
has agreed to maintain the cover.

In April 2005, an assessment funded by the state of Tennessee took
place, and an Administrative Order of Consent was entered on October 27,
2005. From August 7 to August 10, 2006, EPA funded a time critical
removal.

**Sources of Information:**

Federal Register (Volume 70, Number 207). Page 61974. "College Grove
Battery Chip Superfund Site; Notice of Proposed Settlement." 27 October
2005. 25 January 2006.
<http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/2005/05-21459.htm>

Tennessee Department of Environment and Conservation. \"EPA Closes
College Grove Field Office.\" May 2003. 20 January 2006.
<http://www.state.tn.us/environment/dsf/grovemay03.php>

Tennessee Department of Public Health. "College Grove Battery Chip
Health Consultation Report." (n.d.) 20 January 2006.
<http://www.atsdr.cdc.gov/HAC/PHA/collegegrove/cgr_p1.html>

US Department of Health and Human Services, Agency for Toxic Substances
and Disease Registry. "Health Consultation College Grove Residential
Lead Contamination (A/K/A College Grove Battery Chip Site) College
Grove, Williamson County, Tennessee." 8 January 2004. 3 March 2008.
<http://www.atsdr.cdc.gov/HAC/PHA/collegegrove/cgr_toc.html>

USEPA. "College Grove Battery Chip." [CERCLIS.]{.underline} 14 February
2008. 3 March 2008.
<http://cfpub1.epa.gov/supercpad/cursites/csitinfo.cfm?id=0406979>

USEPA Region 4. \"EPA Superfund Removal to Begin at College Grove
Battery Chip Site, College Grove, Tennessee.\" 14 June 2000. 20 January
2006. <http://www.epa.gov/region4/oeapages/00press/000614.htm>

USEPA Region 4. "College Grove Battery Chip Site, College Grove, TN
FINAL POLREP, 07/08/02." 8 July 2002. 3 March 2008.
<http://www.epa.gov/region4/waste/errb/CPdfs/tn/collgrv1_fin.pdf>

[]{.mark}

\* Damage case is cited in *An Assessment of Environmental Problems
Associated with Recycling of Hazardous Secondary Materials* (2007) and
updated with new information per public comments.