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Harrell Construction Abandoned Drums

All POLREP's for this site Harrell Construction Abandoned Drums
Johnson City, TN - EPA Region IV
POLREP #1 - Initial/Final POLREP
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On-Scene Coordinator - Alyssa Hughes 5/7/2009
Emergency - Removal Action Pollution Report (POLREP) #1
Start Date: 5/7/2009 Completion Date: 5/7/2009
Pollution Report (POLREP) #1
Site Description
The Tennessee Department of Environmental and Conservation referred the Site to the removal program in order to conduct a removal site evaluation.  OSC Garrard traveled to the Site and upon arrival noted numerous 55-gallon drums outside the fence.  Some of the drums were in poor condition, consisting of deteriorating steel, missing bungs, and/or large holes cut into them.  A total of fifteen drums were reported.  One of the open-top drums appeared to contain some type of petroleum product within 20 feet of a nearby creek.  In addition, OSC Garrard noted breaches in the fence which would allow trespassers to easily enter the facility.  Based on these observations and the recent severe weather, OSC Garrard determined the Site was unsecure and called the Region 4 phone duty officer OSC Rick Jardine to initiate an emergency response.

OSC Jardine mobilized responder OSC Hughes with ERRS Contractor Environmental Restoration and START contractor Tetra Tech EMI in order stabilize the Site.

Harrell Construction is located in a mixed residential/industrial use area of Johnson City, Tennessee.  The primary operation of the facility was the manufacturing and delivery of concrete.  The site appeared to be abandoned, but the property owners were contacted and were on-site by the time OSC Hughes arrived on-site.  OSC Hughes expressed concerns about the site conditions and communicated the steps necessary to secure the site.  Site conditions of concern included an open top 55 gallon drum containing some type of petroleum product approximately 20 feet from a nearby creek, several drums in poor condition, and a breach in the fence enabling access to trespassers.  

OSC Hughes served the property owners with a Notice of Federal Interest informing them that the observed concerns would require some sort of action to stabilize the Site.  The responsible party was willing to work towards securing the Site.


Current Activities
ERRS Contractor Environmental Restoration worked with the property owner to stage all drums at a centralized location under the cover of a maintenance shed.  A total of fourteen 55-gallon drums, both steel and poly, were found at various locations around the facility.  Two of the drums required overpacking.  Numerous 5-gallon buckets and smaller containers were also collected and staged under the cover of the warehouse.  The property owner stated the drums contain retardants, accelerants and surfactants, all used in the manufacturing of concrete.  The petroleum product was stated to be motor oil used for heavy equipment on-site.

START contractor Tetra Tech performed air monitoring of the facility and hazard categorization of the drums.  START contractor created a drum inventory log including an identification number, photograph, general description and hazard categorization results.  None of the hazard categorization indicated anything of concern in the drums and matched the description given by the responsible party.


Planned Removal Actions
The site was stabilized and secured and no additional removal actions are planned at this time.

Next Steps
TDEC officials from both hazardous and solid waste were on-site to discuss future actions with the responsible party.  After stabilization of the Site with overpack drums and overhead coverage, none of the material posed a threat to human health or the environment.  TDEC solid waste personnel will work with the RP regarding disposal of the material.  A report will be submitted to OSC Hughes upon completion.