The Circle Environmental #1 Site is located at 170 5th Street in downtown Dawson, Terrell County, Georgia. The facility consists of a brick/wood-construction warehouse measuring approximately 120 by 60 feet in size.
USEPA received a request from the Georgia Environmental Protection Division to take action at the Site, on September 10, 2007. Reports from the State indicated is an inactive waste management facility that cleaned oil and solvent tainted wipe rags. The FOSC responded to the faciliy on September 10, 2007, met with local officials, and noted the following either through direct observation or through city and county officials:
• Approximately 300+ drums (later inventory fixed number at 532)of suspected wastes stored within the subject warehouse.
• Many of the drums carried labels indicating waste oil and oil sorbents, flammable materials, and tetrachloroethylene (PCE) wastes.
• Total airborne volatile organic compound (VOC) readings at the warehouse doorway were on the order of 8 to 10 parts-per-million (MultiRae).
• The warehouse is located within the downtown business district of Dawson, immediately adjacent to the City Hall and actually abutted a number of active businesses.
• Residential buildings are located within three city blocks of the warehouse.
• Local officials indicated that heavy solvent odors emeniating form the warehouse was one of the factors that had brought the site to local and state attention.
The primary chemicals of concern, based upon container labels and from information gained from local and state officials and the former operator of the Site are believed to be waste oil, and tetrachloroethylene. Tetrachloroethylene is a CERCLA hazardous substance. Waste oil is treated as a hazardous substance for purposes of response actions under CERCLA.
Based upon his observations and findings, the OSC determined that conditions at the Site met NCP Part 300.415(b)(2) criteria for initiating a removal action. The action was initiated as a CERCLA fund-lead event.
During the reporting period, START and ERRS inventoried, documented, and staged all drums within the warehouse into preliminary waste catagories. A total of 532 drums were identified. Afterward, START and ERRS began systematically opening and inspecting the contents of the drums and collecting samples for hazard catagorization.
Drum opening activities took place under Level-B level of protection. The Rapid Assessment Tool (RAT) was employed as a stationary monitor at the exclusion zone / contaminant reduction zone boundary or within the exclusion zone, depending upon the nature of the work taking place and the level of respiratory protection being employed. Hand-held monitoring was performed within the exclusion zone during drum opening and inspection actvities.
Planned activities include continuation of drum inspection and sampling activities; sorting and staging of drums into final waste-stream catagories; sampling for transportation and disposal profiles; and off-site shipment of all wastes for treatment, recycling, or disposal.
Work was halted briefing on 09/15/2007 due to elevated carbon monoxide (CO) levels in the exclusion zone. The source of the CO was identified as a fork-lift that was being used to move and stage drums. The work zone was ventilated to lower CO levels and the level of protection was elevated to Level-B for all work activities within the exclusion zone until CO levels were brought back below the PPE upgrade threshold.
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