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 Carolina Department ofEnvironment 

and Natural Resources 

401 Oberlin Road, Suite 150 

1646 Mail Service Center 

Raleigh, North Carolina 27699-1646 

Dear Mr. Matthews: 

The purpose ofthis letter is to solicit the support ofthe State ofNorth Carolina on the 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 of evaluating the Site for releases of 

hazardous substances, pollutants or contaminants under the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA). Based on our assessment of such releases at the Holcomb 

Creosote Company site, EPA believes the Site poses a significant threat to public health or the 

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 out of business 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 southern portion 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 of sludge 

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 pit containing 

creosote sludge and wastewater treatment sludge remained on Site. Visible creosote contamination of 

soils and sediments across the property was observed. At the request ofNCDENR, EPA began an 

emergency removal action in January, 2011 to address the immediate threats posed by the Site. 

' 

Creosote contains carcinogenic polynuclear aromatic hydrocarbons (P AHs ), specifically, 

benzo(a)pyrene, benzo(a)anthracene, chrysene, dibenzo(a,h)anthracene and indeno(1,2,3-cd)pyrene. 

Elevated concentrations ofthese types ofP AHs 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 P AHs. EPA has not detected P AHs in the bank sediments of 

Dobbins Pond. 

Internet Address (URL) • http://www.epa.gov 

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The ground water is contaminated with creosote-related P AHs. 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 other members ofthe community. The PAHs found in the 

upgradient wetlands are a potential threat to fish and members ofthe community who eat the fish. 

The EPA emergency 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 evaluation process. To further coordinate with the State, 

we are soliciting the State's written support for EPA to proceed with the NPL listing process for this 

Site. This letter, therefore, solicits from the Governor ofthe State ofNorth Carolina, or the State 

Environmental Director, the State's position on proposing 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 

order to stay on schedule to propose the Site in the next NPL update (scheduled for March 2012), we 

must receive state concurrence by December 8, 2011. EPA hopes to continue working closely with 

NCDENR to ensure that our common goal ofprotecting human health and the environment is fully 

realized. Should you require additional information, please do not hesitate to contact me at 

(404) 562-8599 or have your staff contact Cathy Amoroso, Region 4 Acting NPL Coordinator, at 

(404) 562-8637. 

Sincerely, 

cc: Mr. Jack Butler, NCDENR 

Mr. Jim Bateson, NCDENR 

Mr. Tony Raia, EPA-OCIR 

Ms. Terry Jeng, EPA-OSRTI 

Mr. Robert Myers, EPA-OSTRI