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The Dixie Barrel and Drum Site ("Dixie Barrel" or the "Site") is located at 2120 Jones Street in Knoxville, Knox County, Tennessee. The Site is located in a light-industrial area south of downtown Knoxville, TN and approximately one-half mile to the south of the Tennessee River. Additionally, the Site is located on the northern fringe of a residential neighborhood and about several blocks south of an elementary school. At the time of the December 2003 assessment there was evidence of trespassing and vandalism.
From approximately 1976 to 2002, the Site operated as a plastic and steel drum recycling and reconditioning facility. The facility was permitted to accept used drums that contained less than 1 inch of product ["RCRA Empty"]. The reconditioning process [steel drum] involved several stages: The first stage involved manually removing the residues from the drums. The residues were bulked into other "waste drums" that were later shipped off site for disposal; The second stage was a series of corrosive rinses (concentrated acid & caustic); The third stage was a anti-corrosion treatment and preparation for paint; At some point in the processes, each drum went through a DOT specified integrity test in order to be legally sold as a "reconditioned" drum; The final step is repainting the drum and parking the drum into the inventory of the warehouse. Additional storage was located on adjacent property to the south and in a small house structure known as the "Dixie House".
During their operational years, Dixie Barrel maintained a contract with a waste disposal company that managed the waste generated from their reconditioning operations. Dixie Barrel also operated a system that recycled their process waste-water for reuse in their reconditioning processes and also treated their effluent prior to discharge to the City of Knoxville's POTW. Dixie Barrel was subject to City inspections of their effluent and also received periodic inspections by EPA’s Resource Conservation and Recovery Act (RCRA) program. Dixie Barrel was cited for various RCRA violations. The Tennessee Department of Environment and Conservation (TDEC) issued a RCRA enforcement order to the facility in April 2002. The facility failed to comply with the requirements of the order, ceased operations, and filed for bankruptcy.
TDEC's Division of Superfund referred the site to the EPA Emergency Response and Removal Branch in August 2003 and requested a site assessment be performed. EPA conducted a removal assessment in October 2003. Samples collected during the assessment revealed numerous hazardous substances including lead, chromium, ethyl benzene, and trichloroethylene. Drums stored on site were found in poor condition and stored next to other incompatible chemicals thus elevating the risk of fire and explosion. Treatment vats containing concentrated acid and caustic were found open and posed a serious release and injury risk. The removal assessment data and other information laid the foundation to support a removal action by EPA.
On December 15, 2003 EPA and it’s Emergency Rapid Response Service (ERRS) contractor responded to the site under an Emergency Action Memorandum to mitigate a release from a number of drums on the site and to secure areas of the site where the fence-line was breeched by vandalism. On April 12, 2004 EPA, ERRS, and the Superfund Technical Assessment & Response Team (START) re-mobilized to Site under the existing Emergency Action Memorandum (amended March 10, 2004) to conduct a time-critical removal action to remove waste, threats of release, and effectively secure the Site from vandalism.
* Grub site and set up field operations trailer for EPA, START & ERRS.
* Crush and dispose empty steel drums. Cut and dispose poly-fiber drums. Make room to work on site.
* Perform compatibility testing on drumed waste [bulked residues], chemicals found in and around the process/drum-treatment line, and waste water treatment sludges.
* Consolidate or bulk complatible waste streams and ship off-site for treatment/disposal.
* Transport and dispose of all waste streams at EPA-approved facilities. Recycle waste or demolition debris when applicable.
* Demolish and dispose of the annex storage ["Dixie House"] next door.
* Assess soil contamination under the main building and in the turn-a-round area behind (east side) of building.
* Coordinate with Community Involvement Branch and notify surrounding community of removal activities.
* Work with TDEC representative and resolve issues with the site as neccessary.