lANCER. LEFLEUR RoBERT

### J. BENTLE1 DIRECTOR GOVERNOF 

# ACJEM

Alabama Department of Environmental Management adem.alabama.gov 1400 Coliseum Blvd. 36110.2400 • Post Office Box 301463 Montgomery, Alabama 36130-1463 (334) 271-7700 • FAX (334) 271-7950 December2, 20I I
Ms. Gwendolyn Keyes Fleming Regional Administrator US Environmental Protection Agency Region 4 61 Forsyth Street, SW Atlanta, Georgia 30303-3104


### RE: EPA Letterdated October 19, 2011 State's Position on FinalizingAlabama PlatingCompany Site on the NationalPriorities List Alabama Plating, Shelby County, Alabama EPA I.D. No. ALD 004 022 448
DearMs. Fleming:
The Alabama Department ofEnvironmental Management(ADEM orthe Department) received the Environmental Protection Agency's (EPA) October 19,2011 letter regarding the Alabama Plating Company site in Shelby County, Alabama. In its letter, EPA requests the Department's position regarding finalization ofthe proposed National Priorities List (NPL) listing ofthe Alabama Plating Company. EPA notes thatAlabama Plating was proposed to the NPL in August2000, but EPA did not finalize the Site on the NPL atthat time dueto the lack ofState support for the listing. Actions taken at the Site sincethat time were also described in the letter. However, the subject letter did not mention the December30, 2009 EPA letterto the Department requesting the deferral ofthe listing for the Alabama Plating Company Superfund Site. The Department's April 5, 20II response acknowledged that concerns related to groundwatercontamination still exist with the Alabama Plating facility, and opined that the Site appears to warrant further oversight, but without placementon the NPL.
In addition, ADEM notes that EPA conducted groundwater, sediment and depositional sampling atthe site and its surrounding areas in August 20II in response to ADEM's previously stated concerns regardingdatagaps atthe site. ADEM is awaiting the results ofthis sampling eventto determine if sutlkientdata exists to establish whethergroundwatercontamination is posing a risk to human health due to off-site migration. Although these results have not been provided to the Department to date, it is the Department's understanding that they are forthcoming. Onceprovided, the Department will review the results and determine ifits position regarding the need for further remediation and/or monitoring should be amended. [n orderto meet EPA's December 8, 2011 requested response date and for the above reasons, the Department's response remains that although continued oversightunderan appropriate mechanism may be warranted, the Departmentcannot support EPA moving forward with the NPL listing process at this time.

Birmingham Branch Decatur Branch Mobile Branch Mobii&-Coastal 110Vulcan Road 2715 Sandlin Road, S. W. 2204 Perimeter Road 4171 Commanders Drive Birmingham, AL 35209-4702 Jecatur, AL 35603-1333 Mobile, AL 36615-1131 'vloblle. AL 36615-1421 (205) 942-6168 (256) 353-1713 r251) 450-3400 (251) 432-6533 (205) 941-1603 (FAX) (256) 340-9359 (FAX) 12511 479-2593 !FAX) (251) 432-6598 (FAX)

### Ms. Gwendolyn Keyes Fleming December2,2011 Page 2 of2

Also in the Department's April 5, 20II letter, ADEM noted that it did not currently have funding to pertorm the oversight under the Alabama Hazardous Substance Cleanup Fund (AHSCF) orto provide the required I0% State cost share for a fund-lead NPL site. These conditions still exist. One option may be to enroll the site into the Department's Voluntary Cleanup Program (VCP). However, as required by the VCP Statute and regulations, the site must not be listed on theNPL and the new site owner must enterthe VCP and be willing to carry outany required monitoring and remediation ofthe site.
Ifyou have any questions orconcerns regarding this matter, please contact Mr. Stephen A. Cobb at 334­ 271-7739 orvia email at sac@adem.state.al.us. Sincerely,

WGH/SAC/TPS/Iac

cc: Mrs. Tracy P. Strickland/ADEM Mrs. Brandi Little/ADEM Mr. Franklin Hill/US EPA, Region 4