At approximately 1700 hours on 17 March 05 ADEM contacted the National Response Center (NRC) and EPA’s Region 4 Duty Officer concerning three drums of potential herbicides being dumped in a roadside ditch. The drums were on their sides and leaking. Markings on the drums indicated that they may contain herbicide materials. ADEM requested EPA’s assistance in removal and disposal of the drums.
The Site is located in a roadside ditch near 4845 Grist Mill Road in Alpine, Talladega County, Alabama. The site is across the road from a private residence and approximately 100 feet from an un-named tributary which flows into Talladega Creek.
OSC Adams with the Region 4 Emergency Response and Removal Branch (ERRB), initiated the emergency response action at the site. EPA tasked WRS Infrastructure and Environment to assist with the removal and sampling of the drums, excavate contaminated soils, and transportation and disposal as appropriate. EPA tasked Weston Solutions to provide over-sight of the response, conduct air sampling, assist in sampling of the drums, and take confirmation samples and analyze the samples after removal of contaminated soils was completed.
On March 17, 2005, OSC Adams and WRS Project Manager (PM) Ingle mobilized to the site to meet with ADEM and local responders. By the time the OSC and PM arrived on site, the drums had been re-staged and each covered with a polyethylene drum liner. After discussions with ADEM and local responders, concerning future site activities, it was decided to start further site activities on the morning of March 18th.
On the morning of the 18th, the OSC, START, ERRS, and ADEM investigated the drums and determined that all three drums contained the same material due to labels present, various handwritten markings on the drums, and the characteristics of the contents. During the abandonment of the drums, two of the three drums had the majority of their contents spilled out onto the ground. Because of this, it was determined that only one drum needed to be re-packaged and the contents of the other two drums would be transferred into this drum for disposal purposes. Upon completion of over-packing and consolidation activities, the drum was sampled in order to characterize the waste. The empty drums were placed in a polyethylene drum liner and over-packed in steel drums pending procurement of T&D services. These drums were transferred, via local emergency management personnel escort, to a secured recycling facility in the city of Childersburg, AL, a few miles southwest of the Site.
Impacted soils were then excavated, sampled, and staged in a pre-lined roll-off pending RCRA characteristic analysis and procurement of T&D services. The area where the soils were excavated were also sampled to ensure the excavation was adequate. Backfill soil was delivered to the Site by Talladega County personnel and the excavated area was refilled with clean soil. Upon completion of backfill activities, the impacted area was re-seeded and hay was laid down to prevent erosion. After cleaning up the site and securing the roll-off, the Site was demobilized on the late afternoon of March 18, 2005.
Upon receipt and review of sample analytical data of soil and liquid waste, the soil in the roll-off was determined to be non-RCRA regulated. However, since the liquid waste was determined to be regulated as RCRA toxic, the EPA and ADEM decided that further investigation should be conducted and the drum of waste liquid would need to remain in the staging area in case an additional sample was needed.
WRS was given permission to arrange for the removal of the roll-off from the Site in early April. WRS coordinated with its Transportation and Disposal (T&D) subcontractor (Greenleaf Environmental Group) and the roll-off was removed from the Site on April 20, 2005. After completion of the investigation, WRS received permission to proceed with the T&D of the liquid waste drum. This drum was transported off-site on May 27, 2005.
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