The Site is a commercial property allegedly leased to Stone Castle Recycling, LLC (Stone Castle) and owned by both the Wheeler Family Trust and the Carr Family Trust.  There are two separate buildings on the property: an office/garage building that formerly served as a used car dealership and a smaller garage at the rear of the property used for outdoor recreational vehicle repair.  Stone Castle leased the used car dealership portion of the property in August 2013 for use as a recycled technology resale storefront. From August through September of 2013, Stone Castle employees moved cathode-ray tube (CRT) televisions and other electronic waste materials to the Site.

When it functioned as an operating entity, Stone Castle dismantled electronics, sold the component parts, and recovered raw materials. During this dismantling procedure, Stone Castle removed the cathode-ray from the leaded-glass vacuum tube inside CRT televisions. Stone Castle segregated, crushed, and sent this glass to other leaded glass makers to melt down and create new leaded-glass CRTs. Following the move from analog to digital broadcasting, and the corresponding shift from CRT televisions to plasma and liquid-crystal display (LCD) high-definition televisions, the market for leaded glass collapsed.  Stone Castle had large volumes of nearly worthless CRTs and recovered raw materials without sufficient revenue to properly process electronic waste, to pay employees and facility leases, and to dispose of the electronic wastes.  Large quantities of stockpiled and newly-received electronics wastes were moved around between four discrete properties at the three Utah facilities.  These wastes, placed into corrugated cardboard “Gaylord boxes” were frequently stored outside of already full warehouse storage areas, where they rapidly deteriorated and failed, spilling their contents onto the ground, subjecting the contents to further weathering.

The electronic wastes brought to the Site were placed in the garage and stockpiled in corrugated cardboard boxes on the ground at the northwest corner of the Site.  Once placed, they were abandoned and left to weather and burn.  The burned hazardous debris pile now covers approximately 0.10 acre, ranges from one to two feet high, and contains roughly 400 tons of material.  The mixed electronic waste pile covers approximately 0.09 acre, ranges from two to 10 feet high, and contains roughly 600 tons of debris.  The intact CRT pile covers 0.11 acre, is roughly eight feet high throughout, and contains roughly 250 tons of material.

The electronic wastes and the leaded-glass CRTs, which have been left on the ground and exposed to the elements, have already caught on fire and burned. They may catch fire again since curved CRT panel glass and projection screen television lenses can concentrate solar radiation onto combustible materials in the debris piles. Burning electronic waste poses a significant threat to exposed populations and the environment because harmful quantities of toxic combustion byproducts, volatilized metal, and respirable particulates would likely be present in the smoke plume, threatening populations downwind and facilitating the rapid migration of contaminants.

On August 13, 2014, acting on information provided by both the EPA Region 8 Resource Conservation and Recovery Act (RCRA) Program and the Solid and Hazardous Waste Division of the Utah Department of Environmental Quality (UT DEQ), the OSC conducted a preliminary assessment of the Site to determine whether a Removal Site Evaluation was warranted.  At the time of this visit, UT DEQ was pursuing all available enforcement remedies available under the Utah Solid and Hazardous Waste Act and RCRA to have Stone Castle Recycling complete a clean-up of the Site by September 28, 2014.  EPA agreed to postpone activities until after the September 28, 2014 deadline.  

On September 29, 2014, after Stone Castle failed to comply with the UT DEQ enforcement order deadline for removing wastes, the property owner contacted the OSC and agreed to provide legal access to the EPA. The OSC immediately tasked the Superfund Technical Assessment and Response Team (START) contractor to perform an assessment and treatability study on the wastes at the Site to determine if a removal was warranted and feasible.  A detailed discussion of the treatability study can be found in POLREP1 for this Site.  

On October 14, 2014, the EPA mobilized the START contractor to begin a formal Removal Site Evaluation at the Site. As part of this assessment effort, START collected soil samples and samples of each of the debris piles for use in a treatability study. The soil sampling data revealed the presence of lead and trace amounts of other metals that had migrated into the soils from the electronic wastes present at the Site.  The debris samples confirmed that lead present in the CRT glass was leachable and prone to migrate.  Findings from the investigation revealed:

• In-situ soil lead values ranged between 6.1 mg/kg and 81.2 mg/kg in areas where CRT glass was present on the surface.  The OSC also noted that there were areas where CRT glass had been pulverized and driven into the soil profile, likely further elevating lead levels in the impacted soils.

• Toxicity Characteristic Leaching Procedure (TCLP) results from the leaded-glass indicated that the leachate contained between 27 and 444 mg/L of lead, well exceeding the RCRA toxicity characteristic regulatory limit of 5 mg/L.

• Lead concentrations from the TCLP tests of the three waste pile composite samples collected by START at the Site ranged from 3.6 mg/L to 50.1 mg/L, again well in excess of the toxicity characteristic regulatory limit of 5 mg/L.

The Site was discovered by the Solid and Hazardous Waste Division in the Utah Department of Environmental Quality (UT DEQ) during the course of an investigation into three electronics waste recycling facilities operated by Stone Castle in Clearfield, Cedar City, and Parowan, Utah.  Stone Castle, the potentially responsible party (PRP) at the Parowan Site, was in the business of scrapping used and donated cathode-ray tube television sets on behalf of non-profit organizations and municipalities along the Interstate 15 corridor in Utah.  Stone Castle operated at the Site from approximately August 2013 to March 2014, when there was a fire at the Site. After the fire, the electronic waste materials at the Site were abandoned.

The response action will involve mechanical processing, on-Site chemical treatment, and off-Site transportation and appropriate landfill disposal of all wastes present at the Site.  The mechanical processing will consist of crushing the hazardous debris with a horizontal grinder to reduce particle sizes, maximize particle surface area, and homogenize the material for more effective chemical treatment.  The chemical treatment, which will apply the approach recommended by the data from the treatability study, involves adding water and commonly used and readily available reagents, such as Portland cement and phosphate fertilizers, to the wastes in an effort to stabilize the mixture and permanently immobilize leachable metals in the hazardous debris.

During the mechanical processing and chemical treatment of the wastes, START will provide oversight and technical support to ensure the specifications developed in the treatability study are met.  START will provide personal air sampling and dust monitoring to minimize exposures to airborne dust and metals during operations, in accordance with OSHA regulations.  START will also conduct perimeter air sampling and respirable dust monitoring to ensure compliance with NESHAPs and to ensure that there are no off-Site exposures from the treatment process to neighboring populations.    

• Receive and install replacement 4” screens in the horizontal grinder.
• Crush remaining hazardous debris and consolidate with waste treatment stockpile.
• Crush remaining non-hazardous debris and consolidate with local landfill stockpile.
• Receive and install 2” screens in the horizontal grinder
• Amend waste treatment stockpile with MAP and process with horizontal grinder a second time.
• Sieve the processed and amended wastes to characterize the particle sizing and density for proper chemical treatment.
• Decontaminate and demobilize horizontal grinder.
• Setup and load the silo of the pug mill with Portland cement.
• Scrape up and stockpile remaining impacted soils from the Site.
• Mix impacted soils and the MAP treaded hazardous debris together in a stockpile.
• Feed this mixed stockpile into the pug mill, adding moisture if needed, to coat these materials with the Portland cement.
• After treatment with Portland cement and sufficient contact time, treated wastes will be loaded into dumpsters and covered with tarps. 
• START will collect composite samples of each treated waste batch, arrange for TCLP analysis of prior to shipment to ensure compliance with RCRA and with the Off-Site Rule from 40 CFR §300.440. 
• Wastes will be transported to an approved RCRA facility for final disposal.  
• Topsoil will be placed in the excavation area, amended with fertilizer, and reseeded.
• Take metal and motors removed from debris to a recycling facility for scrap value.
• Properly dispose of oil, automotive fluids, paints, solvents, and chemicals found at the Site. 

The horizontal grinder is proving to be an invaluable tool for both waste volume reduction (up to 70%) and homogeneous mixing of the MAP into the previously crushed hazardous debris.  However, the metallic screens installed around the hammer wheel that ensure adequate particle size reduction are not robust enough to withstand the impacts from some of the materials we are sending through the grinder.  Specifically, fan motors and hardened steel components are breaking the screens inside the grinder after they collide with the hammers on the hammer wheel, reducing the effectiveness of the horizontal grinder and causing delays as we await repairs or shipments of replacement screens.  It remains to be seen whether this will delay the final disposal.

• Skid-Steer and Forks
• Stakebed Pickup Truck
• RM Pickup Truck

• Excavator
• Front-End Wheel Loader
• Water Truck
• Vermeer BG6000 Horizontal Shredder
• Aran ASR 280B Pug Mill

• Monoammonium Phosphate
• Portland Cement

• DataRAM 4000 Dust Monitors and Air Sampler – 4 
• Niton XRF Soil Metals Instrument
• VIPER Rapid Deployment Kit
• Digital Sound Level Meter

Parowan City
Parowan Public Works
Parowan Volunteer Fire Department