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Wolftever Creek Tote

All POL/SITREP's for this site Wolftever Creek Tote
Ooltewah, TN - EPA Region IV
POLREP #2
Final
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Wolftever Creek Tote - Removal Polrep
Final Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV

Subject: POLREP #2
Final
Wolftever Creek Tote

Ooltewah, TN
Latitude: 35.0893030 Longitude: -85.0695860


To:
From: David Andrews, OSC
Date: 7/1/2010
Reporting Period:

1. Introduction
  1.1 Background
   
Site Number: B467    Contract Number: EP-S4-07-04
D.O. Number: 0704-F4-0083    Action Memo Date:  
Response Authority: CERCLA    Response Type: Emergency
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 4/28/2010    Start Date: 4/28/2010
Demob Date: 4/29/2010    Completion Date: 7/23/2010
CERCLIS ID:    RCRIS ID:
ERNS No.: 938451    State Notification: TDEC on 4/28/2010
FPN#:    Reimbursable Account #:


1.1.1 Incident Category
Potential CERCLA release
1.1.2 Site Description
250-gallon tote containing approximately 50-60 gallons of unknown liquid.
1.1.2.1 Location
5030 Hunter Road  (cleared property)
Ooltewah, TN  37363
Approximately 1/2-mile west of I-75 Exit 11 (Ooltewah, TN)
on the north bank of Wolftever Creek (see coordinates and map).
1.1.2.2 Description of Threat
Abandoned/unlabeled tote on a creek bank containing unidentified liquid product
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
It is suspected that the tote may have washed down stream from a DOT work site during area flooding in the Fall of 2009.  Tote contents were tentatively identified (HazMat ID) as a herbicide.  A sample was collected by ERRS for laboratory analysis, identification, and disposal coordination.  During the response, ERRS transferred product from the tote to two (2) 55-gallon poly drums and transferred the drums and tote across the creek to the south and to a staging area in the clearing next to the retention pond.

2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative
On the afternoon of April 28, 2010 (Wed), a representative from the Tennessee Department of Environment and Conservation (TDEC) Chattanooga Office contacted Reg 4 REOC to relay a report from the Collegedale Fire Department of an abandoned tote located on the northern bank of Wolftever Creek in the commnity of Ooltewah off of Exit 11 (I-75).  The discovery took place during a traffic accident investigation.  Contents were a brown-opaque liquid and the tote had minimal or illegible markings.  Collegedale Fire Department responders collected a sample and evaluated the material with HazMat ID Spectrometric instrumentation.  The material  wastentaively identified as an herbicide (>50% match).  The area surrounding the tote was obviously impacted by flash-flooding (possibly by the flooding from the Fall '09 flash-floods) and the tote was lodged in the brush along the bend of the bank.  It was speculated that the tote may have washed away from a nearby TDOT work site(s) that are located in the vicinity and area along the I-75 coridoor in northern Hamilton county near Ooltewah. 

2.1.2 Response Actions to Date
  • EPA and ERRS (Environmental Restoration, LLC) mobed to Ooltewah, TN late afternoon on April 28, 2010 to meet with a representative of Hamilton Co. FD to locate the tote and plan for extraction on the following morning. 
  • April 30, 2010 ERRS accomplished removal of the tote from the brush pile (see Images) by dividing the tote contents between two 55 gallon poly-drums and float the drums and tote across the creek to the southern bank.  A sample was collected from the tote for analytical testing and evaluation for disposal.  The containers were secured on site until disposal coordination was completed and a return to the site to collect the drums and tote.
  • On June 25, 2010, OSC Andrews (on response to the MC 252 incident in Mobile, AL) reviewd the analytical and signed two disposal profiles for Greenleaf Treatment Services (Macon, GA) for fixation and Subtitle-D disposal under a Non-Hazardous Manifest. The material passed TCLP and categorized the material as RCRA Non-Hazardous.  However, the material is suspected to be possibly a waste product from machine shop and a cooling oil with high-water content.
  • June 27, 2010, OSC Andrews discussed an additional approach to disposal of the approximately 60-gallons of non-haz liquid with the ERRS RM.  The OSC directed ERRS to construct a dehydration container or "pit" approximately 10-feet by 10-feet (100 sq feet) and up to one-foot deep. The pit was lined with visqueen (dense plastic liner).  The OSC wanted to take advantage of the recent heat-wave in the South and believed that the cost to simply dehydrate the material (>99+% water) and dispose of the solids (estimated < 2-pounds) rolled/wrapped in the visqueen was a considerable less expensive option than for a vendor to solidify the 60-gallons (approximately 500-pounds pre-solidified).
  • July 15, 2010 ERRS constructed the dehydration pit and transfered material into the pit. 
  • July 23, 2010 ERRS is scheduled to dispose of the solids at a significantly less weight and volume.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
No enforcement or PRP search conducted at this time.
2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
Non-Haz Liquid             liquid/water-based  65 gal
<2 lbs solids
 TBA/ BOL  Dehydration &
  Sub Title DLF
 Subtitle-D
           
           



  2.2 Planning Section
   

2.2.1 Anticipated Activities
No further action anticipated under this Task Order.
2.2.1.1 Planned Response Activities
N/A
2.2.1.2 Next Steps
The non-hazardous solids (wrapped in visqueen) to be disposed by vendor the week of July 19, 2010 at a significantly less expense than using off-site fixation and disposal.
2.2.2 Issues
None.

  2.3 Logistics Section
    N/A

  2.4 Finance Section
    No information available at this time.

  2.5 Other Command Staff
    2.5.1 Safety Officer
N/A

2.6 Liaison Officer
N/A

2.7 Information Officer


2.7.1 Public Information Officer
N/A
2.7.2 Community Involvement Coordinator
N/A

3. Participating Entities
  3.1 Unified Command
N/A

3.2 Cooperating Agencies
N/A

4. Personnel On Site
  Richard Jardine, OSC  & Subash Patel, OSC : REOC Phone Duty Officer(s) dispached OSC Andrews.

April 28 & 29, 2010 On-Site Personnel
David Andrews,        OSC (Region 4)
Martin Jones,           ERRS RM (Environmental Restoration, LLC)
Antonio Sanders,     ERRS FCA
Ernest Relf,             ERRS Laborer
Chauncey Walker,   ERRS Laborer
Cliff Sanders,           ERRS Equipment Operator

5. Definition of Terms
  Dehydration Methodology :  Baking the liquid by exposing the material (over a large surface area) to sun/heat to remove moisture and accomplish a significant reduction of weight.  This prevents the need for off-site treatment using fixation additives (portland cement) that would add to the overall weight of the waste-stream and additional costs for disposal.

ERRS:  Emergency Rapid Response Service

RCRA: Resource Conservation and Recovery Act

TCLP: Toxicity Characteristic Leachate Procedure



6. Additional sources of information
  6.1 Internet location of additional information/report
None

6.2 Reporting Schedule
N/A

7. Situational Reference Materials
  None


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