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Circle Environmental #1

All POLREP's for this site Circle Environmental #1
Dawson, GA - EPA Region IV
POLREP #3 - Interim POLREP
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On-Scene Coordinator - James Webster 9/19/2007
Emergency - Removal Action Pollution Report (POLREP) #3
Start Date: 9/11/2007
Pollution Report (POLREP) #3
Site Description
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.


Current Activities
During this reporting period, the response team mitigated releases from containers that had originally been overfilled by the generator.  Temperatures in the 90s lent to liquids seeping from the containers.  The team also staged drums according to anticipated waste streams.  The waste streams were determined based upon visual inspection and field chemistry conducted during the previous reporting period.  The staging of drums was a Level 'D' PPE activity.  START conducted air monitoring inside the warehouse and along 5th Avenue to ensure safe conditions.

Once the drums were appropriately staged, the team conducted sampling of the various waste streams to facilitate the profiles necessary to provide for proper treatment and disposal of the wastes.  This activity required Level 'C' protection as the drums were again opened to collect the samples.  Air monitoring was conducted by START and EPA OSCs.


Planned Removal Actions
During the next reporting period, the response team will begin to overpack all drums filled with liquids to prevent additional releases.

Next Steps
Once all available site work is completed and threats minimized or eliminated, the response team will demobilize while awaiting analytical data and bids for treatment and disposal.  ERRS will provide for site security during the demobe period.  Once the succesful T&D contractor has been identified, the final load out of wastes will be scheduled.

Key Issues
The key issue will be to continue to update the community regarding site status until final project completion.