UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 OCT 1 9 2011

Mr. Lance LeFleur Director, AlabamaDepartment of

Environmental Management 1400 Coliseum Boulevard Montgomery, Alabama 36110

DearMr. LeFleur:
The United States Environmental Protection Agency, pursuant to its authority under Section 105 ofthe Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended, 42 U.S.C. Section 9605, is considering inclusion ofthe AlabamaPlating Company (the Site) onthe National Priorities List (NPL). The Site is located in Vincent, Shelby County, Alabama. By this letter, EPAis seeking the concurrence ofthe State ofAlabama on addingthe Site to the NPL.
From 1956 to 1996, Alabama Plating Company operated anelectroplating facility atthe Site and later expanded its activities to include hot-dip galvanizing processes. Currentlythe Site is vacant and inactive. Wastewater generated from these processes contained cadmium, chromium, nickel, and cyanide. AlabamaDepartment ofEnvironmental Management (ADEM) conducted several investigations of ground water, soil, sediment, and surface waterbetween 1985 and 1998. Elevated levels ofarsenic, cadmium, cyanide, chromium, lead, mercury, nickel, and zinc were found in sludge, soil, and sediment samples collected at the Site. A range ofmetals were detected inthe ground water samples at concentrations exceeding Primary Drinking Water Standards (PDWS) and Secondary Drinking Water Standards (SDWS). Arsenic, cadmium, chromium, lead, mercury, and nickel exceeded the PDWS.

ADEM broughtthe Site to EPA's attention andprepared CERCLA Site Assessmentreports in 1998. In 1999, EPAbegan a time-critical removal action atthe Site. The removal action included characterization, removal and disposal ofvisible surface soil contamination, excavation and disposal of sludge inthe backfilled lagoons, removal and disposal ofabandoned hazardous waste, building demolition, and debris disposal. During excavation activities, EPA uncovered many drums and other containers throughout the property. EPA removed and disposed ofmore than46,000 tons ofnonhazardous soil, 11,000tons ofhazardous soil, 165 tons ofzinc dross, 3,100 tons ofcyanide-saturated soil, 135 tons ofcadmium-saturated soil, and various other hazardous materials from the Site. EPA response coststo date are approximately $12,000,000.00. In August 2000, based on site conditions and the remaining environmental threat, and after consultation with ADEM, EPA proposedthe Site to the NPL. However, EPA did not finalize the Site onthe NPL at that time due to lack ofState support for the listing.

InNovember 2002, EPA conducted the first phase ofthe remedial investigationthat included the installation and sampling ofseven monitoring wells and sampling ofanexisting monitoring well. Surface and subsurface soil, surface water, and sediment samples were also collected during the investigation. Soil samples indicated the presence ofarsenic, chromium, copper, lead, nickel, selenium,

Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed wHh Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)and zinc. Arsenic levels exceeded the EPA Regional Screening Level for industrial-use soils. Surface water and sediment samples indicated elevated concentrations oforganic and inorganic constituents. Ground water samples contained elevated concentrations ofinorganic constituents exceeding PDWS maximum contaminant levels (MCL) or SDWS.

EPA has continuedperiodic sampling ofsite ground water since 2004. Datafrom 2006 and later continue to showviolations ofthe MCLs for lead, cadmium, chromium, cyanide and mercury. Ground water use within a 4-mile radius ofthe Site includes a municipal water supplier, the Vincent Water Works (VWW), which obtains its water from four springs located northwest ofthe Site. Water from the springs is pumped to a collectionpointthat is located about 0.5 miles southwest ofthe Site. VWW provides waterto approximately 2,916 people. Sampling data obtained by ADEM, EPA, and the VWW during monitoring activities conducted since 1995 indicate thatthere have been no detections ofsiterelated hazardous substances above detection limits in the rawwater supply. Because the Site lies in an area ofkarst geology, however, the threatto this water supply remains.

The EPA and ADEM staffhavehad numerous discussions and have exchanged correspondence considering howto address the Site. In his April5, 2011 letter to EPA Superfund Division Director Franklin Hill, ADEM Land Division Chief, Gerald Hardy, indicated agreement with EPA'sbeliefthat remedial action is needed to mitigate the risks posed by the contamination. EPA is only able to obtain funds for long-term remedial actions for sites onthe NPL. Since the initial site assessment in 1998, EPA and ADEM have worked cooperatively to address the Site thereby protecting public health and the environment. During future workto finalize the Site onthe NPL, EPA expects to continue working cooperatively with the State and local community.
EPA completed a draft Hazard Ranking System package and proposed the Site to the NPL in 2000. EPA
now seeks to finalize the listing. To further coordinate with the State, we are soliciting the State's written support for EPAto proceed with the NPL listing process. This letter, therefore, solicits from the Governor ofAlabama, orthe State Environmental Commissioner, the State'sposition on finalizing the Site onthe NPL. Please respond to: Gwendolyn Keyes Fleming Regional Administrator U.S. Environmental ProtectionAgency 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 include the Site inthe next NPL update (scheduled for March 2012), we mustreceive the State'sreply byDecember 8, 2011. Ifthe State'sposition is that listing is not appropriate, please identify in the response the reasons that listing is not appropriate. Should we not receive a response by the deadline provided above, we will assume the State has no objectionto this
course ofaction, and we will proceed with the listing process.EPA hopes to continue working closely with ADEM to ensure that ourcommon goal ofprotecting human health and the environment is fully realized. Should you require any additional information, please do not hesitate to contact me at (404) 562-8599 orhave your staffcontact Cathy Amoroso, Acting Region 4 NPL Coordinator, at (404) 562-8639.

Franklin E. Hill, Director Superfund Division

cc: Mr

. Gerald Hardy, ADEM Mr. Dave Davis, ADEM Mr. Tony Raia, OCIR Ms

. Terry Jeng, EPA-OSRTI Mr. Robert Myers, EPA-OSRTI