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Scrub-A-Dubb Barrel Co.

All POL/SITREP's for this site Scrub-A-Dubb Barrel Co.
Lubbock, TX - EPA Region VI
POLREP #5
Sorting, Seperating Sampling, and Shredding 		Printer Friendly  |   PDF
 
U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Scrub-A-Dubb Barrel Co. - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region VI
Subject: POLREP #5
Sorting, Seperating Sampling, and Shredding
Scrub-A-Dubb Barrel Co.
A6Z3
Lubbock, TX
Latitude: 33.6118227 Longitude: -101.8358266

To:
From: Greg Fife, OSC
Date: 10/12/2011
Reporting Period: 10/1-12/2011

1. Introduction
  1.1 Background
   
Site Number: A6Z3    Contract Number: EP-S6-07-01
D.O. Number: 0701-097    Action Memo Date:  
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category:
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 8/29/2011    Start Date: 8/30/2011
Demob Date:      Completion Date:  
CERCLIS ID: txd097054878    RCRIS ID:
ERNS No.:    State Notification:
FPN#:    Reimbursable Account #:


1.1.1 Incident Category
Time Critical Removal

1.1.2 Site Description

 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 continued to dump drums, as well as remove a few drums for burn drums or waste drums.

 

1.1.2.1 Location

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



 
2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative

Drum Shredding Progress by Week:
Dates Weekly Poly Drums Shredded Total Drums Shredded
9/8/2011 thru 9/10/2011 1,677 1,677
9/12/2011 thru 9/17/2011 3,678 5,355
9/19/2011 thru 9/24/2011 3,018 8,373
9/26/2011 thru 10/1/2011 2,710 11,083
10/3/2011 thru 10/8/2011 2,477 13,560
10/10/2011 thru 10/15/2011    



2.1.5 Air Monitoring and Removal Documentation ActivitiesDuring the drum shredding operations START monitors site air quality for CO, H2S, VOCs, O2 and LEL levels via wireless and handheld RAE multigas detectors. MultiRAE Plus and AreaRAE detetctors along with a RAElink wireless remote system have been utilized for monitoring the air quality parameters on this project. A perimeter consisting of 4 AreaRAE detectors was established around the exclusion zone fence line on the East tract where the Shredder was operating in order to monitor the air quality leaving the site. Additionally, a hand held MultiRAE Plus detector was used to monitor air quality throughout the site with specific targets including: ERRS shredder operator, ERRS drum gathering worker, shredded plastic stockpile and shredder proximity. START monitors the air quality in real time with streaming data that is available for examination wirelessly from the detectors through ProRAE Remote software. To assess the influence of wind direction and weather on air quality parameters associated with the drum shredding operation, START has employed the use of a Climatronics 102603 Weather station onsite. The wind direction is monitored simultaneously with any vapor releases to determine best mustering location in the event of an evacuation.

In addition to monitoring air quality in and around the drum shredding operation, START has been tasked with documenting site activities and real progress in the removal and cleanup process. A GPS enabled camera is used to document system flow and provide photo documentation of the entire process. 


2.1.6 Waste Stream Generation and Drum Content BulkingDrums identified to contain more than half an inch (< ½ in) of content were staged and categorized. Drum content was categorized using litmus paper, visual assessment and miscibility with water. Drums contents were categorized into; Acidic (pH 0-3), Neutral (pH 4-10), Basic (pH 11-14), Oils, Flammables, Solids and unknowns. Similar category content drums were set on a drum drain rack and contents consolidated into a common drum. Full drums were then sealed and staged for later pick-up by waste transporter. After drums were emptied of contents they were moved to the shredder loading area for shredding. 2.1.7 Shredded Drum Materials Disposal as Non-Hazardous WasteThe Mobile Rotary Shear Shredder has the capacity of processing 80 drums per hour. The drum shredding unit is equipped with a conveyor belt that deposits the shredded drum materials (either HDPE or steel) into a stockpile inside poly containment. After shredded drum materials are stockpiled they are loaded into 30 or 40-yard steel roll-off dumpsters via a Caterpillar 315 excavator with a claw and thumb attachment.  Full roll-off dumpsters are then transported by Republic Services and disposed at Southwest Landfill LP in Canyon, Texas.   Shredded Drum Materials are classified as RCRA empty containers. Since various drum content residues remain on shredded drum materials proper disposal involves handling as Non-Hazardous waste at an appropriate landfill.  As of 10/4/2011 twenty five (25) full roll off boxes have left the site with the appropriate manifest documentation.

 

 

 

 

 

 
  2.2 Planning Section
    2.2.1 Anticipated Activities

Recover and stage drums with contents.

Identify the contents.

Consolidate, bulk, or otherwise handle the contents of the drums for disposal.

Recover, shred, and dispose empty drums.

Soil sampling to determine the extent of contamination.

Soil excavation and disposal.

Maintain air monitoring and sampling.
  2.3 Logistics Section
    No information available at this time.
  2.4 Finance Section
    No information available at this time.
  2.5 Other Command Staff
    No information available at this time.
3. Participating Entities
  No information available at this time.
4. Personnel On Site
  No information available at this time.
5. Definition of Terms
  No information available at this time.
6. Additional sources of information
  No information available at this time.
7. Situational Reference Materials
  No information available at this time.