U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Barrio Carreras Abandoned Drum - Removal Polrep
Initial and Final Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region II

Subject: POLREP #1
Initial and Final, Completion of Fund-Lead Removal Action, RV1
Barrio Carreras Abandoned Drum
A22V
Anasco, PR
Latitude: 18.2928200 Longitude: -67.1238500


To:
From: Geoffrey Garrison, OSC, CIC
Date: 9/20/2013
Reporting Period: 12/21/2012 - 09/13/2013

1. Introduction
  1.1 Background
   
Site Number: A22V    Contract Number: EP-S2-10-03
D.O. Number: 0063    Action Memo Date: 1/10/2013
Response Authority: CERCLA    Response Type: Emergency
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 1/10/2013    Start Date: 1/8/2013
Demob Date: 2/21/2013    Completion Date: 9/13/2013
CERCLIS ID: PRN000206680    RCRIS ID:
ERNS No.:    State Notification: 12/21/2013
FPN#:    Reimbursable Account #:

1.1.1 Incident Category

Emergemcy response actions taken to address corroded drums containing hazardous substances that were abandoned adjacent to a residence and a stream.

1.1.2 Site Description

The site consists of ten steel 55-gallon drums with unknown contents located in a secluded farm.  The condition of the drums varied but they all showed the effects of corrosion due to exposure to the elements.  The labeling and shipment information on the drums had been removed with the exception of the Flammable Label.  The drums were inside a rooster training area of the farm (for rooster fighting) behind the garage and within 20 feet of a stream.

1.1.2.1 Location

the Site is located on a private farm, off PR Road 405, Km 2.0, Interior, Barrio Carrera, Anasco, Puerto Rico, 00610.

1.1.2.2 Description of Threat

Release of a hazardous substance, in this case a flammable sludge containing Hexane, Heptane, Xylene and mineral spirits, to the environment due to the corroded nature of the containers.  There is also the actual or potential exposure to nearby human populations and animals due to the location of the drums on the farm.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

The EPA Removal Support Team (RST2) conducted a Removal Assessment sampling event on January 8 and 14, 2013.  The results are shown in the sampling trip report dated March 5, 2013, and can be found in the documents section of the website for this SIte at www.epaosc.org/bocarrerasdrum .  The resulting analysis showed that the drum contents met the definition of a hazardous substance and would require disposal as a hazardous waste D0001. 


2. Current Activities
  2.1 Operations Section
    e2.1.1 Narrative

According to the owners of the farm, they had been in the U.S. mainland for approximately 5 years during which time the farm was unattended.  Upon their return, they discovered the ten drums had been abandoned on the property behind their garage.  They notified the municipality of Anasco, Emergency Management office (OMME), on October 18, 2012, due to the odors emanating from the corroded drums.  The local office of the PR Evironmental Quality Board (EQB) was notified on November 2, 2013.  PR EQB notified EPA and together the two agencies conducted a site visit on December 21, 2012, (date of state notification) at which time EQB requested assistance with the removal action.

The most probable scenario for the "dumping" of the drums at location of the isolated, and unoccupied (at the time) farm, is that the drum contents were off-spec or expired materials that were transported/abandoned at the secluded location in order to avoid disposal fees.

2.1.2 Response Actions to Date

The initial site survey by EPA and EQB took place on December 21, 2012.  The Removal Assessment Sampling took place on January 8 and 14, 2013, which also required ERRS activation on January 10, 2013, (ERRS mobilization date) to assist RST in gaining access to four of the six drums.

ERRS mobilized to the site for a second time on January 29 and 31, 2013, to receive the overpacks, stabilize the site, overpack the corroded drums and stage them for shipment.  Once the analytical results were received and the disposal profiles generated, the drums were transported for disposal on February 21, 2013, at which time ERRS was demobilized from the Site.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

The PR EQB conducted a PRP search along with EPA.  Due to the lack of labeling and shipment information, EPA has been unable to identify a potentially responsible party (“PRP”) for this Site.

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
Flammable Sludge - D001 Sludge  3,000 lb 008557948JJK-1,
008920979JJK
  TSDF - Cycle Chem Inc., Elizabeth NJ; Ross Incineration Services Inc., Grafton OH
Flammable Sludge - D001 & D035 Sludge  1,500 lb 008557948JJK-2,008920979JJk   TSDF - Cycle Chem Inc., Elizabeth NJ; Ross Incineration Services Inc., Grafton OH
Flammable Sludge - D001 & D035 Sludge  500 lb  008557948JJK-2,010409116JJK   TSDF - Cycle Chem Inc., Elizabeth NJ; Ross Incineration Services Inc., Grafton OH


  2.2 Planning Section
    2.2.1 Anticipated Activities

None, the soil sampling did not show impacted soils, no restoration activities needed, the Removal Action is complete.

2.2.1.1 Planned Response Activities

None

2.2.1.2 Next Steps

Monitor manifests to ensure proper disposal via Cycle Chem.  Close out of final 1900-55.

2.2.2 Issues

None

  2.3 Logistics Section
    Nothing Significant To Report (NSTR)

  2.4 Finance Section
    No information available at this time.

  2.5 Other Command Staff
    2.5.1 Safety Officer

NSTR

2.5.2 Liaison Officer

NSTR

2.5.3 Information Officer

NSTR

3. Participating Entities
  3.1 Unified Command

Unified Command was not stood up for this Removal Action.

3.2 Cooperating Agencies

PR EQB

4. Personnel On Site
  EPA - 1
ERRS - 4
RST - 3
EQB -1 (During assessment only)

5. Definition of Terms
  No information available at this time.

6. Additional sources of information
  No information available at this time.

7. Situational Reference Materials
  No information available at this time.