The American Drum & Pallet Site is a operational pallet and drum recycling facility located on a multi-parcel property at 806 Walnut Street, Memphis, TN. According to the owner, the facility receives RCRA empty drums for reconditioning.
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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.”
Sometime after receiving the complaint, DSWM personnel contacted the owner/operator to inquire about the containers described by the complainant. The owner/operator stated that all of these containers were empty, and that the 15-gallon plastic containers had already been sent off-site to be grinded by a company called “CBS Polymers.” During this phone call, the owner indicated that there were drums on-site that contained material left behind by prior operators at the site.
DSWM personnel visited the site on March 19, 2007, to conduct a hazardous waste inspection. In addition to the building located at 806 Walnut, ADPC occupies two buildings on contiguous property located at 0 Heiskell Place. A walkthrough 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, fibreboard 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.
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. As of the date of this memo, 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.