Pollution Report Profile - EPA OSC Response

Tennessee Wheel & Rubber
Nashville, TN - EPA Region IV
POLREP #6 - Final POLREP (Revised)

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On-Scene Coordinator - Leslie Sims	12/7/2007
Time-Critical - Removal Action	Pollution Report (POLREP) #6
Start Date: 5/22/2006	Completion Date: 6/28/2007

Site Description
Tennessee Wheel and Rubber Site, a defunct wheel assembly and caster manufacturing company is located at 817 18th Avenue North in Nashville, TN. The company filed for bankruptcy and ceased operations in February 2005. The property has been abandoned since that time. At the request of TDEC, EPA responded to the site to investigate reports of an oily substance entering an offsite sanitary-sewer system from the property. Upon arrival, the FOSC observed a sheen in runoff bisecting a debris pile and entering a nearby catch basin. Additionally, during the reconnaissance, an estimated 400 containers (suspected of containing hazardous substances), varying in size, content and integrity were observed throughout the property.

Refer to previous POLREPs for more detail.

Current Activities
During the previous reporting period START and EPA completed an environmental sampling program to determine the degree and extent of contamination at the site. The sampling program included the collection of oil, soil and aqueous samples at various target locations throghout the property. With the exception of the oil/oily-water samples collected from two (2)onsite USTs, all of the samples were submitted to the EPA laboratory for analysis. Analyses included, but was not limited to, flashpoint, pH, RCRA metals, PCBs, VOCs, and SVOCs. The oil/oily-water samples, collected from the USTs, were submitted under chain-of-custody to an EPA-approved commercial laboratory for analysis. Analyses included flashpoint, pH, PAH, BTEX, TRPH, PCBs and RCRA metals.

Analytical data related to that effort was received by EPA during this reporting period, and included the following results:

Drum No. TWR-BR-016 revealed a pH of less than 1, indicating a potential D002 wastestream. Drum nos. TWR-BR-005, TWR-BR-018, TWR-BR-020 and TWR-BR-118 revealed flash points below 67°F, indicating potential D001 wastestreams. These drums were included with the wastesteams disposed during the previous reporting period. The oil samples collected from the USTs indicated the tanks contained, what appeared to be, degrading non-RCRA fuel oil (diesel). Laboratory analysis of the soil samples revealed low or non-detectable levels for all analytes tested.

A total of Ninety-six (96)containers of waste were shipped for offsite disposal and included the following waste streams:

    • Flammable liquids (19 each 55-gallon drums)
    • Tetrachloroethylene (1 each 55-gallon drum)
    • Toluene diisocyanate (2 each 55-gallon drums)
    • Toluene diisocyanate (1 each 5-gallon pail)
    • Sulfuric acid (1 each 55-gallon drum)
    • Phosphoric acid (1 each 55-gallon drum)
    • Caustic liquids (1 each 55-gallon drum)
    • Non-RCRA materials (70 each 55-gallon drums)

Additionally, an estimated 450 empty containers recovered from around the site were crushed and staged onsite within the south building.

On June 28, 2007, EPA's START contractor and TDEC returned to the Site to remove the diesel fuel oil from the two USTs. A total of 625 gallons of oil was removed from the tanks and transported offsite for recycling. The tanks appeared to be in good condition and there were no visible signs of leaking or soil staining observed during this removal action. TDEC secured all inlet valves and drains following evacuation of the diesel fuel. However it should be noted that all UST piping/appurtenances remain connected and; therefore, some residual product may still be present in these lines.

Based on the findings from the sampling program and disposal of all waste streams identified during this removal action, no further action (NFA) is planned for this site by EPA ERRB.

Planned Removal Actions
NFA

Next Steps
NFA

Key Issues
None

Disposition Of Wastes
All wastes were properly documented, labeled, loaded, and shipped via Robbie D. Wood, Inc. (ALD067138891) to Chemtron Corporation (OHD066060609) in Avon, OH. A total of 96 containers of waste were shipped on Manifest Number 001753967 and consisted of the following waste streams:
o Flammable liquids 19 each 55-gallon drums
o Tetrachloroethylene 1 each 55-gallon drum
o Toluene diisocyanate 2 each 55-gallon drums
o Toluene diisocyanate 1 each 5-gallon pail
o Sulfuric acid 1 each 55-gallon drum
o Phosphoric acid 1 each 55-gallon drum
o Caustic liquids 1 each 55-gallon drum
o Non-RCRA oils, resins, etc. 70 each 55-gallon drums

Waste Stream	Quantity	Manifest #	Disposal Facility
Flammable liquids 19 each 55-gallon drums Tetrachloroethylene 1 each 55-gallon drum Toluene diisocyanate 2 each 55-gallon drums Toluene diisocyanate 1 each 5-gallon pail Sulfuric acid 1 each 55-gallon drum Phosphoric acid 1 each 55-gallon	96	001753967	Chemtron Corporation (OHD066060609) in Avon, OH
Dielsel Fuel Oil	625 Gallons	Recycler	Universal Environmental Services, LLC in Mulfreesboro, TN