First Environment was retained by Meritor, Inc. – a successor to Rockwell International Corporation – to provide expert advice regarding the former Randall Textron Plant Site in Grenada, Mississippi. The work at the site originally stemmed from an Administrative Order issued by the Mississippi Department of Environmental Quality (MDEQ) in 1990. The Order required the delineation and characterization of the extent of contaminants in soils, surface water, and groundwater emanating from the waste sludge disposal area (on-site landfill). Additional areas of concern were identified while delineating the lateral and vertical extent of contamination associated with the landfill. Additional delineation work was performed at the direction of MDEQ, leading to a determination of the extent of contamination from the additional sources and a chemical characterization of these areas.
Because of the hazardous waste disposal operations associated with the on-site landfill, site-related remedial activities transitioned to a Resource Conservation and Recovery Act (RCRA) corrective action study under U.S. Environmental Protection Agency (EPA) and State of Mississippi hazardous waste management regulations. The appropriate RCRA documents were developed, including a Facility Investigation that was consistent with EPA RCRA guidance. As the site shifted to RCRA program authority, the remedy selection was conducted in accordance with the requirements for a Corrective Measures Study and the terms of the facility’s RCRA permit. EPA has subsequently determined that the site qualifies for inclusion on the National Priorities List (NPL) because it is considered a serious uncontrolled or abandoned hazardous waste site that requires further investigation and comprehensive cleanup.
First Environment was brought into the matter to assist in the defense of Meritor after a number of toxic tort actions were filed to recover property damages allegedly committed against the plaintiffs’ homes and properties. The plaintiffs are residents or former residents of a neighborhood that is located adjacent to the site. The complaints filed in this case alleged that the site manufactured wheel covers for major automobile manufacturing companies such as Ford, General Motors, and Chrysler. The wheel covers manufactured by Rockwell in Grenada were produced through a series of operations that included chrome flashing the wheel covers in a pool of chromic acid (hexavalent chromium). The complaints allege that the operations resulted in a chromic acid mist that was harmful to workers and the plaintiffs’ homes and property. The complaints also allege that the manufacturing process for the wheel covers also included significant use of trichloroethylene (TCE) and other solvents and substances that were harmful to individuals and the environment. Specifically, hexavalent chromium and TCE (and its degradation products including vinyl chloride) were discovered in and around the plant. It was also alleged that several off-site disposal areas were contributing to the contamination at and around the site.
First Environment reviewed the historic operations at the site and assisted the client in determining the ground water flow direction around the site. Our expert review also included the GIS mapping of the area to help identify potential sources and receptors of the chemicals discharged at the plant. We summarized numerous depositions transcripts from former employees to determine the use and disposition of the TCE wastes. We also evaluated the potential for a vapor intrusion pathway inside the plant and into the neighboring homes. First Environment also assisted the litigation team with the scientific and factual issues raised by plaintiffs and their experts.