UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960

OCT 1 9 2011

Mr. Dexter Matthews Director, Division ofWaste Management North CarolinaDepartment ofEnvironment

and Natural Resources 401 Oberlin Road, Suite 150 1646 Mail Service Center Raleigh, North Carolina 27699-1646

DearMr. Matthews:

Thepurpose ofthis letter is to solicitthe support ofthe State ofNorthCarolina onthe listing ofthe Holcomb Creosote Company site (the Site), located in Yadkinville, on the National Priorities List (NPL). The U.S. Environmental Protection Agency is in the process ofevaluating the Site for releases of hazardous substances, pollutants or contaminants under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Based on our assessment ofsuch releases atthe Holcomb Creosote Company site, EPA believes the Site poses a significant threat to public health orthe environment.

The Site is located at 5016 US Hwy 601 in Yadkin County. It is a 3-acre, unfenced, former creosote wood treating facility. The Site began operations in the 1950s and closed in February 2009. Holcomb Creosote Company is outofbusiness and unable to comply with the North Carolina Department of Environment and Natural Resources (NCDENR) corrective action requirements.

Until 1983, creosote wastes were stored in an 80,000-gallon capacity unlined surface impoundment in the southernportion ofthe Site west ofthe tributary. A 0.75-acre land treatment unit (landfarm), also unlined, was constructed east ofthe tributary and filled with approximately 250 cubic yards ofsludge excavated from the surface impoundment. In 2009, underground and aboveground tanks, numerous 55-gallon drums (containing creosote sludge, diesel fuel and oil), and an open concrete pitcontaining creosote sludge and wastewatertreatment sludge remained on Site. Visible creosote contamination of soils and sediments across the property was observed. At the requestofNCDENR, EPAbegan an emergency removal action in January, 2011 to address the immediate threats posed by the Site.

' Creosote contains carcinogenic polynuclear aromatic hydrocarbons (PAHs), specifically, benzo(a)pyrene, benzo(a)anthracene, chrysene, dibenzo(a,h)anthracene and indeno(1,2,3-cd)pyrene. Elevated concentrations ofthese types ofPAHs have been documented in surface and subsurface soils and ground water. Sediments in the tributary wetlands and Deep Creek wetlands, which drain into Dobbins Pond, are contaminated with PAHs. EPAhas notdetected PAHs inthe bank sediments of Dobbins Pond.

Internet Address (URL) • http://www

.epa.gov Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)The ground water is contaminated with creosote-related PAHs. Both ground water and contaminated sediments are discharging to the surface water. Site contaminants continue to migrate into surrounding wetlands and pose a threat to the health ofthis sensitive environment. Dobbins Pond is a recreational pond fished by surrounding residents and othermembers ofthe community. The PAHs found in the upgradient wetlands are a potential threatto fish and members ofthe community who eatthe fish.

The EPAemergency removal action is currently ongoing. Significant amounts ofon-site waste material, including drums, tanks, sludge and contaminated soil, have been removed from the Site. However, EPA will be unable to address contaminated ground water, subsurface soils and sediments without inclusion

on the NPL.

EPA has completed a draft Hazard Ranking System (HRS) package for the Holcomb Creosote Company site, establishing that this Site qualifies for proposal to the NPL. EPA has maintained close communications with NCDENR throughout our evaluationprocess. To further coordinate withthe State,

we are solicitingthe State'swritten support for EPA to proceed withthe NPL listing process for this Site. This letter, therefore, solicits from the Governor ofthe State ofNorth Carolina, orthe State Environmental Director, the State's position onproposing the Site to the NPL. Please respond to:
Gwendolyn Keyes Fleming Regional Administrator U.S. Environmental Protection Agency Region4 61 Forsyth Street, SW Atlanta, Georgia 30303-3104

We appreciate a quick response so that EPA may move forward expeditiously in the listing process. In orderto stay on schedule to propose the Site inthe nextNPLupdate (scheduled for March 2012), we must receive state concurrence by December 8, 2011. EPA hopes to continue working closely with NCDENRto ensure that ourcommon goal ofprotecting human health and the environment is fully realized. Should you require additional information, please do nothesitate to contact me at (404) 562-8599 orhave your staffcontact Cathy Amoroso, Region 4 ActingNPL Coordinator, at (404) 562-8637.

Sincerely,

cc: Mr. Jack Butler, NCDENR Mr. Jim Bateson, NCDENR Mr. Tony Raia, EPA-OCIR Ms. TerryJeng, EPA-OSRTI 

### Mr. Robert Myers, EPA-OSTRI