1. Introduction
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1.1 Background
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Site Number: |
A6C4 |
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Contract Number: |
EP-S6-07-01 |
D.O. Number: |
0108 |
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Action Memo Date: |
7/6/2011 |
Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
Response Lead: |
EPA |
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Incident Category: |
Removal Action |
NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
7/13/2011 |
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Start Date: |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
ARR000005843 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category - Removal Action, EPA Lead
1.1.2 Site Description - The Site contains approximately 2,200 containers from 5 gallon buckets to 550 gallon totes, 8 above ground storage tanks (ASTs), and 5 railroad tanker cars. The contents in these containers, AST's, and railcars varies from finished high quality products to off-specification and/or intermediate products, substances, and raw materials. It is possible that some materials remain in the process equipment vessels and piping. From hazard categorization field chemistry testing conducted in October 2007, most of the drums were either corrosive or flammable. The site was initiated by the Arkansas Department of Environmental Quality (ADEQ) in September of 2007 requesting assistance from the EPA. ADEQ has monitored the site regularly and called into the EPA for assistance anytime there is a release or threat of release from the drums, totes, AST's, or any equipment or containments at the facility.
1.1.2.1 Location - The Site is located at 301 Wyanoke Road, West Memphis, Crittenden County, Arkansas 72301 in a rural industrial area near the Mississippi River. (35.107083 N / -90.193000 W)
1.1.2.2 Description of Threat - The facility manufactured high purity, halogenated, fine organics to the chemical industry, using bromine as the primary raw material. Characteristically, the threats include Toxics, Flammables, and Corrosives.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
EPA mobilized on 07/13/2011 with contractors to begin the EPA Lead Removal Action at the Diaz Removal Site. Preparations commenced to establish the Support Zone (SZ), Contaminant Reduction Zone (CRZ), the Exclusion (Hot) Zone (EZ), and the Command Post. Additional resources were brought on-Site during the first week's operations. The railcars, tanks, totes, drums, and smaller containers were inventoried and assessed. The drums and totes are being consolidated, segregated, and staged in appropriate areas according to compatibility and like substances. As drums and totes are in shippable condition, they are prepared for transport for disposal or recycling.
2.1.2 Response Actions to Date
EPA has conducted several stabilization efforts at the abandoned Site between October 2007 and March 2011 and oversaw a PRP Lead Removal in April of 2011. The Site is monitored monthly by ADEQ, who contacts EPA in the event conditions at the Site warrant response stabilization efforts.
In April of 2011, the security holding bank sold some hazardous substances (listed in Section 2.1.4) to a vendor. The vendor hired contractors and removed the estimated volumes of chemicals listed between April 10 and April 15, 2011. The chemicals listed and the volumes are estimates from the vendor. The EPA OSC and ADEQ Representative mobilized to the site to oversee that ER Removal Action, which was separate and apart from the current EPA Lead Removal Action.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The Potentially Responsible Party at this time is Diaz Intermediates Corp.
2.1.4 Progress Metrics
During the current EPA Lead Removal Action, to date no hazardous substances, contaminants, or pollutants have been removed from the Site.
The following table provides vendor estimated volumes of the substances removed in April of 2011 during an Emergency Response Removal conducted by the security holding bank's vendor of four 5,000-gallon tanker trucks and five box van trucks carrying 275-gallon totes, 55-gallon drums, and 5-gallon pails. The substances were not disposed of, but rather recycled and reused.
Waste Stream /
Hazardous Substance |
Medium |
Volume (gal)(estimate) |
Manifest # |
Treatment |
Disposal |
Hydrobromic acid |
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20,025 |
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N/A |
Recycled |
p-Dibromobenzene <.8% tetrabromobenzene |
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3,305 |
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N/A |
Recycled |
p-Dibromobenzene .8%-12% tetrabromobenzene |
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170 |
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N/A |
Recycled |
p-Dibromobenzene > 10% tetrabromobenzene |
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40 |
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N/A |
Recycled |
p-Dibromobenzene (blue pails) no % listed |
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60 |
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N/A |
Recycled |
p-Dibromobenzene (no lables) |
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15 |
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N/A |
Recycled |
p-bromochlorobenzene |
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70 |
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N/A |
Recycled |
p-Dibromobenzene (empty/cracked/bad) |
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125 |
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N/A |
Recycled |
Methanol |
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1,815 |
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N/A |
Recycled |
Aluminum Chloride |
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880 |
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N/A |
Recycled |
Ferric Chloride |
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90 |
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N/A |
Recycled |
n-propanol |
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2,365 |
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N/A |
Recycled |
fluorobenzene |
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440 |
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N/A |
Recycled |
2-bromopyradine |
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1,540 |
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N/A |
Recycled |
p-Fluoroanosole |
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330 |
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N/A |
Recycled |
n-propylbromide |
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825 |
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N/A |
Recycled |
fluorobenzene |
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7,975 |
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N/A |
Recycled |
empty tote |
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0 |
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N/A |
Recycled |
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2.2 Planning Section
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2.2.1 Anticipated Activities
Vendors will be lined up to receive the hazardous substances on-Site either for disposal or recycling. Unknown substances will be sampled and profiled.
2.2.2 Issues
There have been no issues associated to this Removal Action to date.
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2.3 Logistics Section
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No information available at this time.
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer Safety Officers:
EPA - OSC Adams
ADEQ - Michael Gates
START-3 - Noel Biscocho
ERRS - Don Edgington
2.6 Liaison Officer
2.7 Information Officer Information can be obtained at www.epaosc.org/DiazRemoval. Factsheets can been found in the documents section of this website, as well as at the Site and at the local repository on Avalon Street, just north of Broadway at the West Memphis library.
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3. Participating Entities
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3.1 Unified Command This EPA Lead Removal Action is a teaming effort between EPA and ADEQ.
3.2 Cooperating Agencies Agencies and organizations involved in this response effort include EPA, ADEQ, and EPA Contractors.
Additional local entities notified of the Site and this Removal Action:
City Hall - Mayor Johnson.
WMFD/Hazmat - Fire Chief Gately
Crittenden County Regional Hospital
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4. Personnel On Site
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Personnel on-Site during this response effort include EPA and EPA Contractors. ADEQ Representation is on-Site at their discretion and maintain daily communications with the EPA OSC.
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5. Definition of Terms
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No information available at this time.
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6. Additional sources of information
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6.1 Internet location of additional information/report Information can be obtained at www.epaosc.org/DiazRemoval.
6.2 Reporting Schedule Additional POLREPs will be provided as the Removal Action progresses. Additional details, photographs, and documentation will be posted to the website as the Removal Action progresses.
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7. Situational Reference Materials
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No information available at this time.
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