In early November 2010, EPA received a citizen complaint regarding several 55 gallon drums that appeared to be abandoned at the Site. The complainant also alleged that many of the drums were of leaking hazardous liquids onto the ground.
On November 10, 2010, EPA visited the Site and walked the Site perimeter. From the fenceline, an estimated 400 containers, mostly 55-gallon drums and a few 5-gallon pails, were precariously stacked and scattered about the Site. Labels stating “flammable liquid” and “organic peroxide” were observed on many containers. Many of the drums appeared to be poor condition.
On December 10, 2010, EPA and START contractor personnel returned to the Site to conduct a Removal Site Evaluation (RSE). Many drums were double stacked in a precarious position both on a flatbed trailer and on the ground. Many were in various states of deterioration as evidenced by bulging, corrosion, and other physical damage. Access to the Site was obtained under both a signed access agreement and a warrant.
A representative sample of approximately 50 drums were collected and staged in an open area where their contents could be visually examined and inventoried. Many of the drums contained liquids resembling yellow and white paint materials though these liquids were more viscous than normal given the sub-zero conditions. During the drum inspection process, air monitoring readings were taken over the openings utilizing a photoiononization detector (PID) instrument. Instrument readings varied from non-detect to several hundred parts per million (ppm) in close vicinity of the open drums, thus indicating the presence of Volatile Organic Compounds (VOC’s).
Grab samples were taken from three drums for Hazard Categorization Screening. Results indicated that the contents of two of the three drums exhibited a flash point of less than 140 °F, which meets criteria for the hazardous waste characteristic of ignitability under EPA’s Resource Conservation and Recovery Act (RCRA) regulation (40 CFR § 261.21).
A representative selection of seven drums were chosen for laboratory analysis. Results indicated that the contents of three of the drums meet RCRA hazardous waste criteria for ignitability based on flashpoint and oxidizer testing. One of these three drums which tested positive for flash point was not incuded in the field Hazard Categorization Screening.
Three of the seven drums sampled for laboratory analysis indicated levels of the VOC benzene at 100 mg/kg, 2,700 mg/kg and 960 mg/kg respectively. Two of five samples analyzed for “Total Metals” had chromium- at 10,000 mg/kg and 1,600 mg/kg and lead at 37,000 mg/kg and 15,000 mg/kg.
Benzene, chromium, and lead are hazardous substances defined by Section 101(14) of CERCLA, 42 U.S.C. §9601(14).
Based on the site conditions and analytical results of the removal evaluation a time critical removal action was recommended. The removal action started on 1 August 2011 and was completed on 29 September 2011.
