The Scrub-A-Dubb Site (Site) is an inactive drum refurbisher.  The owner/operator began the business in 1975.  According to the permit and inspection files, Scrub-A-Dubb (SAD) would take drums from a variety of companies and sources, then clean, repair, and repaint the drums.  SAD would then sell the drums.  Drums that were in too poor of a condition to be refurbished or when the supply exceeded the demand, were stacked on the Site.  It is evident that not all drums were empty or even RCRA-empty (40 CFR §261.7) were brought to the Site.  It is estimated that more than 2,000 drums with significant quantities of hazardous waste are on the Site.  Some drums are completely full of liquid waste.  It is estimated that between 40,000 and 60,000 drums remain onsite.  At this time, is not possible to assess the number and condition of other drums that may be underneath the piles of drums.

A fire started as a result of unauthorized people cutting the tops off of drums to be used as waste drums. People continue to dump drums, as well as remove a few drums for burn drums or waste drums.

The Site is located at 1102 North Ash Avenue, Lubbock, Texas.  The Site is two separate tracts of land on opposite sides of North Ash.  The tract at 1102 North Ash is approximately 3.12 acres.  The frontage on North Ash is approximately 200 feet.  It extends approximately 700 feet to the east.  Single family homes are located to the north and a home and a salvage yard are located to the south.  Commercial businesses are across the street and to the west.  Agricultural land is to the east..

            The tract across the street is at 1201 North Ash.  This tract is approximately 2 acres with a frontage of about 300 feet.  The front gates face the same residential area that is adjacent to the primary tract.  Commercial businesses are on the other sides of the tract.

Latitude: 33° 36.66’ N,  Longitude:  101° 50.18’ W

            The walls of the vats of the waste water treatment system are eroding and falling apart. Large sections of the walls have broken loose and allowing the contents to come into contact with the soils surrounding and underneath the vats.  The potential for contaminating the ground water exists but it is unknown pending further investigation if the contamination is reaching a drinking water source.

3  Hazardous Substances or Pollutants or Contaminants in Drums, Barrels, Tanks or Other Bulk Storage Containers That May Pose a Threat of Release.   NCP Section  300.415(b)(2)(iii)

            There are more than 2,000 drums with hazardous substances in them.  TCEQ reports the presence of several underground storage tanks.  This action addresses the content of the vats within the waste water treatment system.  On at least two precious instances, releases from these vats resulted in responses to address the spill.  Hazardous substances overflowed the vats and flowed off the Site into nearby Blackwater Draw and subsequently through Mackenzie recreational park.  The runoff is easily accessible to children at play in the park, golfers, Frisbee golfers and the park’s wildlife.  There is minimal freeboard left in the vats.  The typical precipitation for Lubbock will cause the vats to overflow resulting in a release of hazardous substances.

  

4.  Weather Conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released.  NCP Section 300.415(b)(2)(v)

            The normal precipitation for Lubbock is enough to cause the displacement of the lighter contaminants from the vats.  The normal precipitation is highest in the spring and summer, with nearly 3 inches expected in June.  One day rain totals have surpassed 5 inches and snow has been reported at over a foot deep in a single day.    Similar events have occurred in the past.  The available freeboard is not adequate to contain the additional burden from the precipitation.  Releases and runoff could cause addition damage to the compromised and weakened vat walls leading to catastrophic failure of the vats.