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Gulf States Steel

All POLREP's for this site Gulf States Steel
Gadsden, AL - EPA Region IV
POLREP #16 - Gulf States Steel, Removal Update
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On-Scene Coordinator - Jordan Garrard, On Scene Coordinator 11/16/2009
Time-Critical - Removal Action Pollution Report (POLREP) #16
Start Date: 8/1/2007
Pollution Report (POLREP) #16
Site Description
Gulf States Steel, Inc. began operations at the site on February 1, 1986, although the facility was previously operated and owned by other entities since its construction since 1902.  Gulf States Steel was a fully integrated steel manufacturing facility that manufactured a diversified product line including steel plates, hot and cold rolled steel sheets, and galvanized steel sheets.  Major process operations occurred at the coke and by-product plant, the blast furnace area, and at the basic oxygen plant.  The coke and by-product plant at the Gulf States Steel site produced metallurgical coke, and coke oven gas, coal tar, ammonium sulfate, light oil, and naphthalene through the distillation of coal with a high volatile organic content in the absence of air.  There are four waste oil lagoons which are unlined surface impoundments that were apparently used to reclaim waste oil form wastewaters generated by steel finishing processes.

Gulf States Steel was listed in the CERCLIS database with a discovery date of August 1, 1980; however, the site is currently not on the NPL.  Gulf States Steel entered the RCRA program as a treatment, storage, and disposal facility (TSDF) on September 25, 1990.  The Site was listed as a large quantity RCRA generator.  On September 27, 1994 Gulf States Steel entered into a Consent Decree with the USEPA.  Due to sampling results of sediments in Black Creek the Superfund Remedial Branch began RI/FS activities.

On July 1, 1999, Gulf States Steel filed a voluntary petition for bankruptcy under Chapter 11.  After a lengthy attempt to reorganize and emerge from bankruptcy, on November 14, 2000, the Chapter 11 reorganization bankruptcy was converted to a Chapter 7 liquidation bankruptcy.  As part of that liquidation, the United States was able to recoup approximately $2 million which has been placed into a special account to be used to conduct and/or finance response actions at the Site.  By Order dated December 5, 2006, the U.S. Bankruptcy Court closed the GSS bankruptcy.  The funds received through the bankruptcy settlement have been tentatively allocated to address the ecological impacts emanating from the sediments in the 4 waste water lagoons

On January 22, 2007, EPA conducted a Site Assessment at the Site, by RPM Jordan Garrard.  During site assessment several items were observed including bulging drums, leaking aboveground storage tanks (ASTs) containing listed hazardous wastes, and oil spills.  RPM contacted the Removal Section of the ERRB to initiate a Removal Site Evaluation (RSE).  RPM Garrard continued with site assessment activities, including waste stream sampling of drums and ASTs, and surficial soils in the coke plant area.  On February 21, 2007, OSC Randy Nattis conducted a RSE.  Based on analytical results from waste stream samples and field observations; including unsecured drums, leaking ASTs, and evidence of trespassing, pose an immediate hazard to human health and the environment.  OSC Nattis identified along with RPM Garrard and START, 8 different tasks that warranted time critical removal action based upon those factors listed under Section 300.415(b)(2) of the NCP.

A limited RSE was conducted in July 2008 on the Powerhouse building.  The RSE identified multiple leaking transformers containing PCBs, leaking ASTs, and unsecured drums which contained hazardous substances, and exposed asbestos insulation within the building.  There is visible evidence of trespassers scraping metal from the powerhouse exposing PCBs, hazardous substances, and asbestos insulation to the environment.    

The slag piles are the source of continued release of characteristic hazardous waste.  The caustic leachate containing pH values greater than 12.5 from the slag piles is directly discharging into Black Creek, an adjacent wetland area, and a residential neighborhood from drainage ditches outside the Site fence.  Sloughing of slag from the piles has been observed on both the northern and southern piles.  The sloughing allows for the production of more leachate due to the increase in surface area of new unweathered slag.  Based on the results of the Powerhouse RSE and the leachate release from the slag piles a time critical removal action was warranted based upon those factors listed under Section 300.415(b)(2) of the NCP.



Current Activities
Sampling of the remaining insulation, transformers, drums, and above ground storage tanks was completed on Oct. 30, 2009.  Asbestos abatement of the external scrubber systems has begun.  
The excavation of the clay cap over Lagoon 1, which was backfilled during the previous removal action, is expected to be completed by Nov. 17, 2009.  Clay is being stockpiled on site for future use.    
The drainage ditch surrounding the southern slag pile was excavated to prevent offsite sheet flow discharges and improve leachate flow into Lagoon 3.


Planned Removal Actions
The excavation of the drainage ditch surrounding a Lagoon 1, and installation of culvert piping will begin the week of Nov. 16th 2009.  The installation of culvert piping is expected to take four (4) weeks.  

The demolition of the external scrubber system will begin the week of Nov. 16th, 2009.