lANCER. LEFLEUR RoBERT J. BENTLE1 

DIRECTOR ACJEM 
 GOVERNOF

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 


December 2, 20 I I 

Ms. Gwendolyn Keyes Fleming 

Regional Administrator 

US Environmental Protection Agency 

Region 4 

61 Forsyth Street, SW 

Atlanta, Georgia 30303-3104 

RE: 	 EPA Letter dated October 19, 2011 

State's Position on Finalizing Alabama Plating Company Site on the National Priorities List 

Alabama Plating, Shelby County, Alabama 

EPA I.D. No. ALD 004 022 448 

Dear Ms. Fleming: 

The Alabama Department of Environmental Management (ADEM or the 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 of the proposed National Priorities List (NPL) listing of the Alabama Plating 

Company. EPA notes that Alabama Plating was proposed to the NPL in August 2000, but EPA did not 

finalize the Site on the NPL at that time due to the lack of State support for the listing. Actions taken at 

the Site since that time were also described in the letter. 

However, the subject letter did not mention the December 30, 2009 EPA letter to the Department 

requesting the deferral of the listing for the Alabama Plating Company Superfund Site. The Department's 

April 5, 20 II response acknowledged that concerns related to groundwater contamination still exist with 

the Alabama Plating facility, and opined that the Site appears to warrant further oversight, but without 

placement on the NPL. 

In addition, ADEM notes that EPA conducted groundwater, sediment and depositional sampling at the 

site and its surrounding areas in August 20 II in response to ADEM's previously stated concerns 

regarding data gaps at the site. ADEM is awaiting the results of this sampling event to determine if 

sutlkient data exists to establish whether groundwater contamination 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. Once provided, the Department will review the 

results and determine if its position regarding the need for further remediation and/or monitoring should 

be amended. 

[n order to meet EPA's December 8, 2011 requested response date and for the above reasons, the 

Department's response remains that although continued oversight under an appropriate mechanism may 

be warranted, the Department cannot support EPA moving forward with the NPL listing process at this 

time. 

Birmingham Branch Decatur Branch Mobile Branch Mobii&-Coastal 110 Vulcan 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 

December 2, 2011 

Page 2 of2 

Also in the Department's April 5, 20 II letter, ADEM noted that it did not currently have funding to 

pertorm the oversight under the Alabama Hazardous Substance Cleanup Fund (AHSCF) or to provide the 

required I 0% 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 the NPL and the new site owner must enter the 

VCP and be willing to carry out any required monitoring and remediation of the site. 

If you have any questions or concerns regarding this matter, please contact Mr. Stephen A. Cobb at 334­

271-7739 or via 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