Pollution Report Profile - EPA OSC Response

American Drum & Pallet
Memphis, TN - EPA Region IV
POLREP #2 - Second & Final Polrep

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On-Scene Coordinator - Steve Spurlin	4/3/2008
Emergency - Removal Action	Pollution Report (POLREP) #2
Start Date: 7/11/2007	Completion Date: 1/18/2008

Site Description
The American Drum and Pallet site is located at 806 Walnut Street in Memphis, Shelby County, Tennessee.  The Site is a operational pallet and drum recycling facility located on a multi-parcel property.  According to the owner, the facility receives RCRA empty drums for reconditioning.

The approximate geographic coordinates of the site are 35.12519 degrees north latitude and -90.03385 degrees west longitude in an area of Memphis that is generally considered industrial; however, residential properties and a small church are located adjacent to the site.

According to the Shelby County Registrar of Deeds, the site is currently owned by Mr. Johnnie Williams and American Drum and Pallet, Inc., of Memphis, Tennessee.  The site is composed of two parcels totaling 2.78 acres and is improved and currently includes four buildings.  One parcel (Parcel ID: 032012 00022) is listed at 1.76 acres and includes buildings 3 and 4; the other (Parcel ID: 032012 00009) is listed as 1.02 acres and includes buildings 1 and 2.

The site is bordered on the north by Heiskell Place, on the east by Lucas Alley, to the south by the Illinois Central Railroad, and on the west by Louisa Street and Suzette Street.  A large debris pile was discovered immediately south of building 2.

On February 22, 2007, personnel with the Tennessee Department of Environment & Conservation (TDEC)Division of Solid Waste Management (DSWM) in the Memphis Environmental Field Office (MEFO) received a complaint from a building inspector with the Memphis Fire Department regarding American Drum and Pallet Company (ADPC), located at 806 Walnut Street, Memphis, TN, 38106.  The complaint pertained to the storage of unknown materials and concern about conditions observed at the facility.  Specifically, the inspector mentioned observing an estimated fifty 15-gallon plastic containers stored at the site.  At least one of these containers was labeled with a DOT “Poison – 6” label for “Methyl Parathion.”  Additionally, the inspector mentioned an estimated fifty drums with labels describing a herbicide product, “Rice Shot.”

DSWM personnel visited the site on March 19, 2007, to conduct a hazardous waste inspection.   A walk through was conducted within the buildings and outside areas.  During the inspection, DSWM staff observed three piles of material (referred to as Debris Piles 1, 2, and 3) placed on the ground outside of the buildings.  Materials observed within these piles included plastic 55-gallon and 200-gallon totes, fiberboard drums, metal 55-gallon drums, lids, rags and wooden pallets.  Facility personnel indicated that these piles were present at the facility as a result of a facility clean up.  In addition to the debris piles, DSWM personnel observed an estimated 118 containers holding material stored at several areas inside of the buildings and within a trailer.  At the time of the site visit, facility personnel were not certain of the contents of the containers and material contained in the debris piles.

A brief description of the site features, and the suspected waste initially discovered follows:

Building 1 is an approximately 8,700-square-foot, dilapidated metal and wooden-framed, tin-covered structure apparently used for storage.  The building contained 159 drums, and 74 drums were staged immediately outside to the west.

Building 2 is an approximately 1,400-square-foot, dilapidated metal-framed, tin-covered structure apparently used for storage.  Debris is piled through missing portions of the south wall and extending beyond.  The building contained approximately 43 drums.

Building 3 is an approximately 4,900-square-foot, metal-framed, tin-covered structure adjoining the north side of building 4 and is used to store drums awaiting processing.  The building contained 53 drums.

Building 4 is an approximately 38,000-square-foot, concrete block and brick building that houses the majority of the facility operations, including office space, a small loading dock on the west, container emptying and rinsing areas, and container storage.  The building contained 44 drums.

The Debris Pile is located directly south of building 2.  The pile contained numerous containers, including 16 drums.

The TDEC Division of Solid Waste Management (DSWM) received a complaint on February 22, 2007, from Mr. Kevin Dulin, building inspector for the Commercial Anti-Neglect Department of the Memphis Division of Fire Services, pertaining to improper storage of unknown materials at the site.  Mr. Dulin estimated that 50 approximately 15-gallon plastic containers were stored at the site, including at least one labeled as “methyl parathion,” an acutely hazardous waste.

TDEC DSWM officials contacted Mr. Williams of American Drum and Pallet, Inc., to inquire about the containers described in Mr. Dulin’s complaint.  According to TDEC, Mr. Williams stated that all containers were empty and that the 15-gallon container had been sent off site to be ground by CBS Polymers of Greenfield, Tennessee.  Mr. Williams further told DSWM officials that many of the drums at the site had been left by the previous site owner.  According to the Shelby County Registrar of Deeds, the previous owner of the site was the Southern Mill Work and Lumber Company.

In order to evaluate ADPC’s compliance with applicable requirements of the rules and regulations promulgated pursuant to the Hazardous Waste Management Act, T.C.A. 68-212-101, the DSWM issued an Information Request, dated April 5, 2007.  To date, the DSWM has not received a response that adequately addressed all questions contained in the Information Request.

On June 27, 2007, the Tennessee Department of Environment & Conservation (TDEC) contacted EPA regarding conditions at the facility.  Citing concerns about a potential release to the environment from the containers and the uncontained waste on-site, TDEC requested EPA conduct a Removal Site Evaluation.

On July 11, 2007, EPA On-Scene Coordinators, Steve Spurlin and Subash Patel, with EPA START contractor TTEMI initiated a Removal Site Evaluation at the facility.  During the site walk through, the OSCs observed numerous 55 gallon drums. Many drums were leaking and in poor condition.  Stained soils and pooled oily liquids were noted at several areas near the drums.  Dead vegetation was noted along the drainage pathway leading off-site from the property.  Flammable and corrosive stickers were noted on many drums.  Many of the drums were stored outside and exposed to the weather.  The facility fencing was significantly damaged allowing easy site access.  The drums were within 50 feet of a residential home where young children were observed playing nearby.  Air monitoring of the drums indicated high levels of volatile compounds.

Because the Site meets the criteria for a time critical removal under 40 CFR 300.415, and the owner was unable to undertake the necessary actions, the OSC initiated an emergency response under the OSC's warrant authority.

Current Activities
Site activities are sumamrized in the following:

WEDNESDAY, JULY 11, 2007

Tetra Tech START members Mr. Chuck Berry (site manager), Mr. Didi Fung, and Ms. Shanna Davis arrived at the site at 0900 hours.  Tetra Tech START members met with OSC Spurlin and OSC Subash Patel to discuss the assessment and inspection as required by TDD TTEMI-05-003-0026.  EPA and Tetra Tech START personnel met with Mr. Williams and American Drum and Pallet representatives, who provided a tour of the site and described its operations.  Mr. Jason A. Simpson and Ms. Angela Horton of TDEC arrived at 0915 hours and participated in the inspection.

According to Mr. Williams, American Drum and Pallet, together with the Community Development Center, was attempting to clean up the site.  Approximately 50 drums had been staged within a berm of absorbent socks along the west side of building 1.  Mr. Williams said that, in an effort to improve the community, five drums had been sampled in May 2007 and analyzed for metals via the Toxicity Characteristic Leaching Procedure; however, no effort to dispose of the waste or characterize the balance of waste at the site was evidenced.  An additional 14 drums discovered within a nearby trailer were subsequently staged within the berm.  The berm, however, was upgradient from the drums and was ineffective at containing site runoff, allowing suspected waste materials to migrate off site and, possibly, affect vegetation in its path.

USES personnel were tasked by OSC Spurlin to stabilize the site and stage waste containers in centralized locations.  Tetra Tech START was tasked to begin documenting waste containers and prepare for sampling and hazard categorization of 30 drums selected by OSC Spurlin from throughout the site.  Tetra Tech START established a support zone, calibrated monitoring equipment, and prepared sampling supplies.  Because of the extreme summer heat, a strict work-rest schedule was established.

At 1500 hours, Tetra Tech START personnel began sampling the selected drums in level B PPE.  Samples were collected and sealed to await hazard categorization.  Of the 30 drums selected, three were empty, two contained monolithic solids, and three were inaccessible.  At 1716 hours, hazard categorization field screening began on the 22 samples collected.    Operations were completed for the day and personnel demobilized at 1845 hours.

THURSDAY, JULY 12, 2007

Tetra Tech START members Berry, Fung, and Davis arrived at the site at 0700 hours.  Tetra Tech START was tasked by OSC Spurlin to open and quickly field screen the drums staged within the berm on the west side of building 1.  Although the assessment was conducted in level C PPE, establishment of a work-rest schedule and physiological monitoring of personnel were necessary because of the extreme heat.  OSC Spurlin used the results of the screening to determine appropriate laboratory analyses, if any.

USES continued to locate and centrally stage waste containers.  Tetra Tech START assigned drum numbers to all staged drums.  Empty drums were neither numbered nor sampled.  OSC Spurlin tasked Tetra Tech START to provide a cursory inventory of the containers discovered at the site, including their location, contents, and hazardous characteristics, if any.

At approximately 1200 hours, Tetra Tech START began preparing to collect samples from drums for laboratory analysis, as directed by OSC Spurlin.  A soil sample was collected (ADP-SS-01) from a drainage area that flowed to a ditch along the eastern side of Suzette Street west of building 1, where distressed vegetation was evident.  The area was directly downgradient from the failed berm that had been placed around the drums staged outside of building 1.

The samples were sent to Analytical Environmental Services, Inc. (AES), of Atlanta, Georgia.  A portion of one sample was subcontracted to TestAmerica Analytical Testing Corporation (TestAmerica), of Tallahassee, Florida, under for analysis for organophosphorus pesticides by EPA SW-846 Method 8141A.
Operations were completed and Tetra Tech START demobilized from the site at approximately 1830 hours.

WEDNESDAY, JULY 25, 2007

OSC Spurlin visited the site to check conditions.  Several trailers were staged at the loading dock.  When questioned about the contents of the trailers, Mr. Williams indicated the trailers contained empty drums.  Upon further inspection, the OSC discovered approximately 23 drums in two trailers which contained liquid residues of unknown materials.  Additional drums suspected to contain hazardous material where also located in the trailers, but were inaccessible by OSC Spurlin during the visit.  OSC Spurlin directed Mr. Williams to move all drums containing residues of suspected hazardous material into building 4 pending sampling by EPA.

THURSDAY, AUGUST 22, AND FRIDAY, AUGUST 23, 2007

Tetra Tech START site manager, Mr. Chris Draper, mobilized to the site to observe and assist USES personnel tasked to collect samples necessary to characterize all wastes for disposal.  Samples were to be collected for a WRS chemist to characterize the waste for disposal the following week.  Mr. Draper arrived at 0852 hours and met with Mr. Andy Watkins of USES.  At approximately 0900 hours, Mr. Draper met with Mr. Williams to explain the sampling operations.

Samples were collected from 212 drums over the next 2 days.  There were 59 containers that could not be opened and sampled, that contained obvious trash or debris that was not sampled, that contained monolithic solids that could not be sampled, or that were empty.  Sampling operations were completed and all personnel demobilized from the site at approximately 1400 hours on August 23, 2007.

MONDAY, DECEMBER 17, 2007

Tetra Tech START member Draper remobilized to the site and arrived at 0929 hours.  Tetra Tech START and USES were tasked to finalize drum and waste inventories as necessary for transportation and disposal.  Additionally, USES was tasked to replace bungs and chimes on drums where possible to minimize costs and to overpack drums as necessary for safe transportation.  Mr. Draper met with OSC Spurlin and Mr. Spinner Vaughn of USES to discuss operations.

At approximately 1215 hours, OSC Spurlin discovered that three tractor trailers parked at the loading dock on the western end of building 4 were stacked to the roofs with 15-gallon containers.  OSC Spurlin asked Mr. Williams to unload the trailers.  Mr. Williams agreed to unload the trailers and further stated that the containers were slated to be shipped to CBS Polymers in Greenfield, Tennessee, where they were to be ground up and shipped to China.  According to the labels, the containers in two of the trailers contained residual liquids of various herbicides, including Tordon K, Arsenal, Garlon 3A, Accord XRT, and Accord Concentrate.  The containers had not been emptied or rinsed.  The third trailer contained 144 containers labeled as methyl parathion, an acutely hazardous waste, which also held residual liquids.  According to Mr. Williams, the containers came from Asplundh Tree Expert Co., which uses the herbicides to maintain railroad rights-of-way.  OSC Spurlin directed USES to triple-rinse the drums of methyl parathion and stage them for disposal.

OSC Patel, Ms. Horton, and Mr. Simpson arrived on site at approximately 1415 hours.  A site walk-through was conducted to observe facility conditions.  Residual liquids, assumed to be product, were noted in numerous 110-gallon spray tanks along the southern wall of building 4.  Many of the tanks were labeled as containing the herbicides diquat or paraquat.  OSC Spurlin asked OSC Patel to identify the generators of the waste, contact them, and afford them an opportunity to retrieve the tanks with residue.  Mr. Williams informed OSC Patel that he would review records and identify the generator of the tanks.

START and USES continued to verify container inventories and staging drums for transportation and disposal.  Operations were completed for the day and personnel demobilized at 1713 hours.

TUESDAY, DECEMBER 18, 2007

Tetra Tech START site manager Draper arrived at the site at 0700 hours and met with OSC Patel.  Mr. Vaughn conducted a safety briefing and discussed the operations to be conducted.  Two ERRS crews were to continue inventory and container operations; a third crew was to triple-rinse and stage the 15 gallon drums of methyl parathion pending disposal.

A secondary containment area for the rinse operations was established on a concrete pad between buildings 1 and 3.  The area was double-lined with 6-mil polyethylene sheeting, and absorbent socks were used to berm the area.  Three additional drums labeled methyl parathion, including one that had been sampled and confirmed by laboratory analysis to contain organophophates, were added to the 144 drums discovered in the trailer.  Rinsing operations were conducted in level C PPE.  All rinse water, PPE, and polyethylene sheeting was collected and added to the inventory of materials for disposal.  Three drums of rinse water and two drums of solid PPE, bungs, and polyethylene sheeting were generated by the rinsing operations.  The rinsed, empty methyl parathion drums were staged for land disposal.

USES personnel began segregating all drums for disposal by waste stream and staging them in building 1.  Operations were completed for the day and personnel demobilized at 1735 hours.

WEDNESDAY, DECEMBER 19, 2007

Tetra Tech START site manager Draper arrived at the site at 0700 hours and met with OSC Patel.  Mr. Vaughn conducted a safety briefing and discussed the operations to be conducted.  Waste inventory and container operations were to continue.

At approximately 1036, START site manager Draper discovered two additional 15-gallon drums labeled as methyl parathion.  These drums were also triple-rinsed for disposal.

Mr. Draper and Mr. Vaughn procured additional bungs, rings, and chimes from a local vendor to reduce the number of overpacks necessary and limit costs.  Container inventories were verified.  It was necessary to overpack 112 drums.  The 149 empty drums of methyl parathion were covered with polyethylene sheeting and staged on the concrete pad between buildings 1 and 3 pending land disposal.  All other drums for disposal were staged in building 1.  Before crews demobilized, Mr. Draper informed Mr. Williams that operations were completed and that transportation and disposal was pending.  The site was secured to the extent possible and all personnel demobilized at approximately 1708 hours.

WEDNESDAY, JANUARY 16, THROUGH FRIDAY, JANUARY 18, 2008

Tetra Tech START site manager Draper remobilized to the site and arrived at 1335 hours.  Tetra Tech START and USES were tasked to prepare waste shipments and load waste for transportation to appropriate disposal facilities.  A Table summarizing waste disposal can be found in the EPA Removal Action Final Report prepared by Tetra Tech and in the waste disposal summary table in this document.

The EPA ERRB removed and disposed of 247 drums of varying sizes, including 112 overpacks, and two 30-cubic-yard roll-off containers with an approximate total weight of 25,000 pounds of solid trash and debris, including 149 triple-rinsed, empty 15-gallon drums that previously contained methyl parathion; various other crushed, empty drums; PPE, absorbent socks and boom, plastic sheeting, and miscellaneous debris generated by site operations.

With all identified hazardous waste safely characterized and removed from the site for appropriate disposal, EPA, ERRS and START personnel demobilized on 18 January 2008.

Next Steps
The final report and related information will be forwarded to TDEC

Disposition Of Wastes

Waste Stream	Quantity	Disposal Facility
RQ, Waste Environmentally Hazardous Substances, Liquid, N.O.S (Tetrachloroethylene), 9, UN3082, PG III (100 lbs.) D-039	28, 55 gallon drums	RINECO ARD981057870
Non-RCRA material	54, 55 gallon drums	RINECO ARD981057870
Waste Flammable Solids, Organic, N.O.S (Oily Sludge / Dirt), 4.1, UN1325, PG II D-001	96, 55 gallon drums	RINECO ARD981057870
Waste Flammable Liquids, N.O.S (Cadmium, Chromium, Lead), 3, UN1993, PG II D001, 006,007, 008	36, 55- gal. dms	RINECO ARD981057870
Waste Flammable Solids, Inorganic, N.O.S (Oily Sludge / Dirt), 4.1, UN3178, PG II D-001	21, 55 gals drums	RINECO ARD981057870
Waste Corrosive Liquid, Basic, Inorganic, N.O.S (Sodium Hydroxide Solution), 8, UN3266, PG II D-002	5, 55 gal. drums	RINECO ARD981057870
Waste Corrosive Liquid, Acidic, Inorganic, N.O.S (Inorganic Acid), 8, UN3264, PG II D-002	2, 55 g. drums	RINECO ARD981057870
Waste Flammable Liquids, N.O.S (Methanol, Methyl Parathion), 3, UN1993, PG II P-071, D-001	5, 55 gal. dms	Clean Harbors El Dorado, LLC ARD069748192
Non-Regulated Material (including 149 triple-rinsed, empty 15-gallon drums that previously contained methyl parathion; various other crushed, empty drums; PPE, absorbent socks and boom, plastic sheeting, and miscellaneous debris generated by site operatio	2, 30 cubic yd roll-offs	RINECO ARD981057870