Pollution/Situation Report Profile

Battery Reclamation, Inc.
Pecos, TX - EPA Region VI
POLREP #1
Battery Reclamation, Inc., (Initial)

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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Battery Reclamation, Inc. - Removal Polrep
Initial Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region VI

Subject:

POLREP #1
Battery Reclamation, Inc., (Initial)
Battery Reclamation, Inc.
A6G1
Pecos, TX
Latitude: 31.4020670 Longitude: -103.5242390

To:

From:

Mike McAteer, OSC

Date:

8/14/2010

Reporting Period:

8/10 - 14/2010

1. Introduction

1.1 Background

Site Number:	A6G1	Contract Number:
D.O. Number:		Action Memo Date:	8/6/2010
Response Authority:	CERCLA	Response Type:	Time-Critical
Response Lead:	EPA	Incident Category:	Removal Action
NPL Status:	Non NPL	Operable Unit:
Mobilization Date:	8/9/2010	Start Date:	8/10/2010
Demob Date:	9/30/2010	Completion Date:	9/30/2010
CERCLIS ID:	TXR988077640	RCRIS ID:
ERNS No.:		State Notification:
FPN#:		Reimbursable Account #:

1.1.1 Incident Category

Time-critical removal action

1.1.2 Site Description

BRI is approximately 15.36 acres in size and comprised of four tracts of land, three of which were permitted for industrial solid waste management and an adjacent Five (5) Acre Tract that was permitted for universal waste handling. The original three tracts of land that make up the BRI site consist of the following: an administrative office, a maintenenace shop, a Mechanics Shed, a Sorting Building (A-1), a Pyrolysis Unit (A-2), a Hammermill Bldg., (A-3), a Lithium Battery Building (Li), a (TCEQ-permitted, Container Storage Area (CSA), a Top Plant (Z-2), two Saw Plants (Z-1 and Z-3), three warehouses (W-1, W-2, and W-3), a Shipping and Receiving Bldg. (S-1), two fire water tanks, two 18-wheel truck trailers, and two Yards containing numerous supersacks (Yard 1) and two types of wooden crates designated as Taiwan and Holland Crates(Yard 2).

A set of railroad tracks are located in the southern section of the site and separates the BRI process and operational areas from the Five Acre Tract. The railroad tracks enter from the east property line and traverse in a westerly direction towards Warehouse 2. A railroad track spur breaks off from the main line after passing the Pyrolysis Building and proceeds north toward Yards 1 and 2. The railroad tracks are no longer in use. This portion of the site is surrounded by a chain-linked fence and the gates are locked with padlocks. The site is currently inactive or has been inactive since 2005. The exact date when the facility ceased operations and abandoned the facility is not currently known. According to the TCEQ representative, the site was abandoned due to lack of revenue and the breakdown of the hammermill and magnet that separated the processed batteries into ferrous and nonferrous materials.

The chain-linked fence is damaged along Western Avenue, between the Maintenance Shop and Warehouse No. 3. No other site security was observed and documented during the EPA removal site assessment activities. The Five Acre Tract, also known as the “Universal Waste Handler Site”, is located in the southeast section of the site. The Five Acre Tract has been divided into sections A through H. Sections A, C, E, and G contain the drum repackaging and staging area, or Drum Storage Area (DSA), untreated batteries in both Taiwan and Holland Crates, and drums containing the lithium batteries. Sections B, D, F, and H of the Five Acre Tract contain the receiving area, industrial iron (Fe) and nickel-cadmium (NiCd) batteries, zinc-manganese (ZnMn or ZM) and non-ferrous materials (NFe) in Holland and Taiwan Crates, drums containing lime (solids), empty universal waste battery boxes, and Holland Crate lids. This portion of the site is surrounded by a chain-linked fence, which was damaged at the time of mobilization for conducting the removal activities. The Five Acre Tract is accessible from the BRI operational areas, as there is no locked gate between the Five Acre Tract and the BRI operational Areas. The south portion of the Five Acre Tract is located within 500 to 750 feet of Interstate-20. No other site security was observed and documented at the Five Acre Tract during the EPA removal site assessment activities.

1.1.2.1 Location

BRI is located at 2001 Western Avenue in Pecos, Reeves County, Texas, approximately one block northwest of the intersection of Texas Highway 17 and Interstate 20. Geographical coordinates of the site are: 31.402067º N latitude and 103.524239 º W longitude The site is located outside the city limits of Pecos and is situated in an industrial/agricultural sector of southwest Pecos.

1.1.2.2 Description of Threat

According to the TCEQ, the recycling process at BRI generated 35 waste streams, 15 of which are classified as hazardous. Most of the on-site hazardous wastes consist of the different type of spent batteries. Additional wastes generated at BRI include KOH (Potassium Hydroxide) solution (corrosive and hazardous for mercury), Zinc manganese (ZnMn), and ferrous (Fe) and non-ferrous (NFe) materials. The ZnMn, Fe, and NFe materials are considered as Class 1 or 2 hazardous materials. The identified waste streams are currently being stored in high density polypropylene (HDPE) and steel drums, tanks, totes, supersacks, and wooden (Taiwan or Holland) crates located throughout the facility grounds.

Numerous supersacks containing ZnMn, Fe/NFe, LiFeMn and other recycled products were identified in Yard 2, Warehouses 1 – 3, and the Shipping and Receiving Building. The supersacks that were identified in the various buildings appeared to be in good condition; however, those supersacks located outside in Yard 2 were in a deteriorated condition, as they were being exposed to various weather conditions.

Numerous Taiwan and Holland crates were located throughout the site.These crates are being used to store a variety of materials associated with BRI, such as unused and used batteries, unprocessed and processed batteries, Fe materials, NFe materials, Fe/NFe materials, and ZnMn powder, etc. Conditions of the crates vary. Those crates located inside building structures tended to be in better condition than those crates located outside and exposed to the various weather conditions. Numerous crates located in the Five acre Tract had disintegrated and released their contents onto the ground surface.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

Solid waste samples were collected from Warehouse 3, Yard 1, and Yard 2, surface soil samples in the area between the Hammermill Bldg (A-3) and the Pyrolysis Unit (A-2);in the north drainage ditch located between the facility fence line and Western Avenue, collected waste samples from the Five Acre Tract DSA, the KOH vats located outside the Sorting Bldg. (A-1), and a drum located inside the TCEQ-permitted CSA. The samples collected from the KOH vats and the CSA were bi-phased.

TCLP analysis of three solid waste samples (SW-YD107-Fe/NFe, SW-YD208-LiFe, and SW-YD209-ZM) collected from Yards 1 and 2 indicated the presence of barium, cadmium, lead, mercury, and silver in concentrations greater than the corresponding laboratory reporting limits; however, the detected concentrations of cadmium and mercury in Sample No. SW-YD209-ZM exceeded the EPA TCLP regulatory limits for those two analytes.

TCLP analysis of seven solid waste samples (SW-9801-ZM, SW-9802-FE, SW-9703-ZM, SW-9704-UN, SW-9905-ZM, SW-9906-LiZM, and SW-9710-ZM) collected from supersacks located inside Warehouse 3 indicated the presence of arsenic, barium, cadmium, chromium, lead, mercury, and silver in concentrations greater than the corresponding laboratory reporting limits. TCLP analysis indicated exceedances of the EPA regulatory limits for cadmium in all seven samples and mercury in six of the seven collected samples, thus, classifying the contents of these supersacks as toxic by 40 CFR § 261.24 (a).

TCLP analysis of six solid waste samples (SW-5AT11-D1, SW-5AT12-H15, SW-5AT13-F12, SW-5AT14-C9, SW-5AT15-DSA, and SW-5AT16-F12) collected from Holland and Taiwan crates located in various sections of the Five Acre Tract indicated the presence of arsenic barium, cadmium, chromium, lead, mercury, and silver in concentrations greater than the corresponding laboratory reporting limits. TCLP analysis indicated exceedances of the EPA regulatory limits for cadmium four of the six samples and mercury in three of the six samples, thus, classifying the contents of these supersacks as toxic by 40 CFR § 261.24 (a).

TCLP analysis of the two liquid samples (LW-DSA01-KOH and LW-DSA02-KOH) collected from the 35-gallon, poly drum labeled #212 in the Five Acre Tract DSA, indicated the presence of arsenic, cadmium, and lead in concentrations exceeding the laboratory reporting limits. Comparison of the TCLP analytical results to the EPA regulatory limits indicated an exceedance of cadmium. Based on the TCLP results, the liquid material associated with the sample collected from the 35-gallon, poly drum can be classified as toxic for cadmium by 40 CFR § 261.24 (a). In addition, the samples were analyzed for pH. The pH for the samples was reported as 14.4, which classifies the liquid as hazardous by corrosivity 40 CFR § 261.22 (a) criteria.

2. Current Activities

2.1 Operations Section

2.1.1 Narrative

2.1.2 Response Actions to Date

EPA/ERRS mobilized to the site on August 9, 2010, followed by START on August 10, 2010. ERRS began brush and weed clearing, repaired the damaged fence along Western Avenue, began to arrange the supersacks in Warehouses 1 - 3 for waste characterization activities utilizing XRF units. In addition, representives from two battery recycling companies arrived at the site to determine potential disposal options for the ERRS contractors.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal

2.2 Planning Section

2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities

1. ERRS will continue to arrange supersacks from Warehouses 1 - 3 for XRF waste characterization.
2. ERRS will collect samples from each supersack and START will obtain metal concentrations from the contents of each supersack utlizing XRF technology.
3. ERRS will begin to package the lithium watch batteries identified in the Five Acre Tract according to Department of Transportation (DOT) regulations for off-site transport to the designated disposal facility or recycling center.
4. ERRS will seek bids from disposal facilities for offsite recycling or disposal of all onsite wastes/products.
5. START will begin to conduct perimeter air monitoring activities in the vicinity of the Five Acre Tract.
6. EPA OSC will meet with City officials, including the Pecos Fire Department, to discuss our planned removal action and seek input from the City.

2.2.1.2 Next Steps

2.2.2 Issues

Heat stress conditions due to temperatures reaching 108 degrees F may force ERRS to change the work schedule from 7:00 am - 7:00pm to 12:00 am - 12:00 pm; or have two shifts conducting the removal activities.

EPA/ERRS/START has been informed by a representative of a battery recycling company that a MESP Minuteman Missile silo battery may be located at the site. Should this battery be located during the removal activities, the U.S. Air Force may need to be called in to take possession of the MESP battery due to the highly explosive nature of the battery.

2.3 Logistics Section