United States Environmental Protection Agency
Region VI
POLLUTION REPORT

Subject: 

Diaz Intermediates Corporation (Diaz) is located in a rural industrial area at 301 Wyanoke Road in West Memphis, Crittenden County, Arkansas (AR).  Diaz was a supplier of high purity, halogenated, fine organics to the chemical industry, using bromine as the primary raw material in the formulation of their products.  In late July 2007, Diaz shut down the facility and in August they filed for Chapter 7 bankruptcy, in the Eastern District of Arkansas.

The Site contains approximately 2,200 containers of varying sizes (from 5 gallon pals to 550 gallon plastic totes), 8 above ground storage tanks, and 7 railroad tank cars.  The contents  of these containers varies from finished products, to off-specification/intermediate products, and raw materials.  In addition, material remains within some of the processing equipment including vessels and piping.  On September 12, 2007, the Arkansas Department of Environmental Quality (ADEQ) requested assistance from EPA for a potential removal action at the Diaz Site.

During late October 2007, EPA conducted a removal site assessment at the Site.  All containers were inventoried and 42 samples were collected from representative containers for hazard categorization (HazCat®) field chemistry testing.  The results of the field chemistry testing showed that most of the drums were either corrosive or flammable.

On December 4, 2007, ADEQ requested that EPA Region 6 return to the Site to abate the releases or threaten releases to protect public heath and the environment, due to deteriorating conditions of the drums, that included several minor leaking drums, and the presence of pooled storm water in the secondary containment areas.

EPA, START-3, and ERRS mobilized to West Memphis, AR on July 21,2008.  During July 22 - 24, 2008, EPA conducted removal stabilization activities at the Site that included inspecting all containers, and securing or replacing approximately 103 broken drum bungs.

On July 25, 2008, materials (DBFB/Dibromotoluene Mix and m-Bromofluorobenzene, technical)from eight collapsed drums were transferred to separate on site totes for storage. In addition, one drum, contents unknown, was placed in an Overpack drum, which was then placed in the Receiving Warehouse for temporary storage.

Storm Water had not accumulated in the Old Tank Farm due to the lack of rain.  The debris inside the Old Tank Farm secondary containment area was cleaned out and placed in a 55-gallon, plastic-lined, steel drum.  

The Site was secured on July 25, 2008 and personnel demobilized on July 25 and 26, 2008.

Current planned removal activities include coordinating with ADEQ, and local officials and to continue with site stabilization activities as warranted.

Currently, the secued lender bank and a potential buyer are coordinating with EPA in a potential sale/purchase of the site.  The next step will be to determine if the site can be sold as is or is the site to remain abandoned.

If warranted, EPA will return to the site to continue with stabilization activities.

The Site is currently abandoned and will continue to deteriorate if the site is not sold as is or the EPA does not continue with stabilization activities and/or a removal action involving the off-site transportation and disposal of the container contents.