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, Alabama Department of 

Environmental Management 

1400 Coliseum Boulevard 

Montgomery, Alabama 36110 

Dear Mr. 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 Alabama Plating Company (the Site) on the 

National Priorities List (NPL). The Site is located in Vincent, Shelby County, Alabama. By this letter, 

EPA is seeking the concurrence ofthe State ofAlabama on adding the Site to the NPL. 

From 1956 to 1996, Alabama Plating Company operated an electroplating facility at the Site and later 

expanded its activities to include hot-dip galvanizing processes. Currently the Site is vacant and inactive. 

Wastewater generated from these processes contained cadmium, chromium, nickel, and cyanide. 

Alabama Department ofEnvironmental Management (ADEM) conducted several investigations of 

ground water, soil, sediment, and surface water between 1985 and 1998. Elevated levels of arsenic, 

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 in the 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 brought the Site to EPA's attention and prepared CERCLA Site Assessment reports in 1998. In 

1999, EPA began a time-critical removal action at the Site. The removal action included 

characterization, removal and disposal ofvisible surface soil contamination, excavation and disposal of 

sludge in the backfilled lagoons, removal and disposal of abandoned 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 than 46,000 tons ofnonhazardous soil, 11,000 tons ofhazardous soil, 165 tons of zinc dross, 3,100 tons of cyanide-saturated 

soil, 135 tons of cadmium-saturated soil, and various other hazardous materials from the Site. EPA 

response costs to 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 proposed the Site to the 

NPL. However, EPA did not finalize the Site on the NPL at that time due to lack of State support for the 

listing. 

In November 2002, EPA conducted the first phase ofthe remedial investigation that included the 

installation and sampling of seven monitoring wells and sampling of an existing monitoring well. 

Surface and subsurface soil, surface water, and sediment samples were also collected during the 

investigation. Soil samples indicated the presence of arsenic, chromium, copper, lead, nickel, selenium, 

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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 continued periodic sampling of site ground water since 2004. Data from 2006 and later 

continue to show violations 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 collection point that is located about 0.5 miles southwest ofthe Site. VWW 

provides water to approximately 2,916 people. Sampling data obtained by ADEM, EPA, and the VWW 

during monitoring activities conducted since 1995 indicate that there have been no detections ofsiterelated hazardous substances above detection limits in the raw water supply. Because the Site lies in an 

area ofkarst geology, however, the threat to this water supply remains. 

The EPA and ADEM staffhave had numerous discussions and have exchanged correspondence 

considering how to 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's belief that 

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 on the 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 work to finalize the Site on the 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 EPA to proceed with the NPL listing process. This letter, therefore, solicits from the 

Governor ofAlabama, or the State Environmental Commissioner, the State's position on finalizing the 

Site on 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 include the Site in the next NPL update (scheduled for March 2012), we 

must receive the State's reply by December 8, 2011. If the State's position 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 objection to this 

course of action, and we will proceed with the listing process. 
EPA hopes to continue working closely with ADEM to ensure that our common goal of protecting 

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 or have your staff contact 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