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Site Number: |
10KF |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
5/31/2011 |
Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
Response Lead: |
PRP |
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Incident Category: |
Removal Action |
NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
8/1/2011 |
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Start Date: |
8/1/2011 |
Demob Date: |
9/29/2011 |
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Completion Date: |
9/29/2011 |
CERCLIS ID: |
AKN001002918 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
The Site is a fenced storage lot located within a commercial and industrial area within the municipality of Anchorage.
1.1.2 Site Description
1.1.2.1 Location
The Site latitude is N 61.22346 and the longitude is W 149.86130.
Several businesses are located in close proximity to the Site. A public use trail “Ship Creek Trail” passes within a hundred feet of the Site and lies adjacent to Ship Creek. The nearest residential neighborhood is within one half mile of the Site. Stacks of drums and containers at the Site are situated in tight groups on and around trailers and abandoned equipment. The Site occupies an area contained by a chainlink fence with the dimensions of approximately 90 feet by 100 feet. No advisory or warning signage exists on any of the fenced area.
1.1.2.2 Description of Threat
The contaminants of concern are wastes that meet the RCRA characteristic for ignitability based on flashpoint and oxidizer analyses, and wastes that meet the RCRA characteristic for toxicity, including benzene, chromium, and lead. The containers have been stored in the out-of-doors since 2005 or 2006, and many of the containers are of questionable structural integrity.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
In early November 2010, EPA received a citizen complaint regarding several 55 gallon drums that appeared to be abandoned at the Site. The complainant also alleged that many of the drums were leaking hazardous liquids onto the ground.
On 10 November 2010, EPA visited the Site and walked the Site perimeter. From the fenceline, an estimated 400 containers, mostly 55-gallon drums and a few 5-gallon pails, were observed to be precariously stacked on vehicles, trailers or the ground and were scattered about the Site. Labels stating “flammable liquid” and “organic peroxide” were observed on many containers, and many of the drums appeared to be in poor condition.
From 15 December through 17 December 2010, EPA and START contractor personnel returned to the Site and conducted a Removal Site Evaluation (RSE). Many of the containers were in various states of deterioration as evidenced by bulging, corrosion, and other physical damage such as dented or distorted surfaces. Access to the Site was obtained under both a signed access agreement and a warrant. Once on-Site, 183 containers were staged and inventoried, including 178 55-gallon drums, 4 5-gallon pails, and 1 presusurized paint vessel. Additionally, an estimated 160 55-gallon drums, 130 5-gallon pails, 2 250-gallon storage totes, and 1 pressurized paint vessel were not inventoried or sampled because they were inaccessible due to safety considerations and field time constraints.
A representative sample of approximately 50 of the 178 staged 55-gallon drums were opened to visually examine their contents. Many drums contained liquids resembling yellow and white paint materials though these liquids were more viscous than normal given the sub-zero conditions. Container content levels varied from near-empty to near-full. During the drum inspection process, air monitoring readings were taken over the openings utilizing a photoiononization detector (PID) instrument. Instrument readings varied from non-detect to several hundred parts per million (ppm) in close vicinity of the open drums, thus indicating the presence of Volatile Organic Compounds (VOC’s). Individual grab samples were collected from three of the 50 representative 55-gallon drums for on-Site Hazard Categorization Screening (HCS). Results indicated that the contents of two of the three drums exhibited a flash point of less than 140 °F, which meets criteria for the hazardous waste characteristic of ignitability under EPA’s RCRA regulation (40 CFR § 261.21). One of the HCS drums along six other 55-gallon drums were chosen for confirmation laboratory analysis. These drums were selected based on HCS results, the representativeness of the different drum identification markings, the representativeness of the differrent types of materials observed in the drums, and a bias towards those containers exhibiting higher PID readings. Results indicated: three of the seven drums meet RCRA hazardous waste criteria for ignitability based on flashpoint and oxidizer testing; three of the seven drums indicated levels of benzene at 100 milgrams per kilogram (mg/kg), 2,700 mg/kg and 960 mg/kg, respectively; and two of five samples analyzed for “Total Metals” showed chromium at 10,000 mg/kg and 1,600 mg/kg and lead at 37,000 mg/kg and 15,000 mg/kg.
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