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1. Introduction
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1.1 Background
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Site Number: |
B45A |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
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Response Authority: |
CERCLA |
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Response Type: |
Emergency |
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Response Lead: |
PRP |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
11/17/2014 |
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Start Date: |
11/17/2014 |
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Demob Date: |
11/19/2014 |
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Completion Date: |
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CERCLIS ID: |
TNN000402938 |
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RCRIS ID: |
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ERNS No.: |
1101204 |
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State Notification: |
11/16/2014 |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
The incident is an emergency response to the release of chromic acid liquids from a hard chrome plating facility. On the afternoon of November 16, 2014, local responders discovered an unknown liquid flowing into a drainage ditch. The liquid was tracked back to a hard chrome plating business.
1.1.2 Site Description
The Site consists of a hard chrome plating facility that experienced an overfill of a chromic acid plating vat. The chromic acid overflowed onto the floor of the facility and migrated outside the building. The chromic acid impacted several commercial properties and flowed to a roadside drainage ditch that discharges to a nearby creek.
1.1.2.1 Location
The release occurred at the Hard Chrome Platers facility at 310 Sand Hill Road, La Vergne, Rutherford County, Tennessee.
1.1.2.2 Description of Threat
Chromic acid is a hazardous substance. The acid is toxic due to both its very low low pH and high chrome metal content. The hazardous substance impacted several properties where workers could come in direct contact with the material. The chromic acid flowed to an unnamed tributary to Hurricane creek where aquatic life could be threatened.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
On November 16, 2014, local fire and police responded to the discovery of an uncontrolled release of chromic acid from a facility. The local fire department entered the building and discovered an overflowing chrome plating tank. The operator of the facility arrived at the facility and shut off the water hose causing the overflow of the tank. The exact quantity of the spill is unknown, but is estimated to be over 1000 gallons.
The U. S. Environmental Protection Agency (EPA) Duty Officer was notified of the incident by the National Response Center and the Tennessee Department of Environment & Conservation (TDEC). The operator of the facility hired an environmental contractor who covered the impacted areas outside the facility with plastic in an effort to minimize further migration. Since the material was covered, and no rain or additional cleanup work was anticipated during the night, OSC Spurlin mobilized on November 17, 2014.
2.1.2 Response Actions to Date
Upon arrival on-scene, OSC Spurlin met with representatives of the operator and TDEC. Chromic acid staining and pooled chromic liquids were observed on the facility property as well as on several nearby commercial properties. An estimated 1000' of drainage pathway from the facility to a creek was impacted by the release. EPA and TDEC discussed potential liability and needed cleanup actions with the operator. The operator declined to participate further in the cleanup citing financial inability to pay for the contractor.
EPA then met with the property owner, who agreed to hire an environmental contractor. The owner made the necessary arrangements to hire SWS Environmental Services (SWS), who started cleanup work at approximately 1200 hrs on November 18, 2014.
Activities conducted and completed by SWS during the period November 18-November 19th included excavation of contaminated soils on affected properties; collection of waste liquids via a vacuum truck; and flushing and water collection of roadside drainage pipes. EPA and START contractor Tetratech provided technical support and monitoring of the SWS cleanup work.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The PRPs for the incident have been identified as the operator and the property owner. An EPA Notice of Federal Interest letter of issued to both parties. Specific PRP contact information is available in the site files.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| chrome contaminated solids |
soil |
75 tons
est. (4 rolloffs) |
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TBD |
| chrome contaminated liquids |
wastewater |
1000 gals. est |
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TBD |
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2.2 Planning Section
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2.2.1 Anticipated Activities
On November 21, 2014 SWS will return to the site to collect waste disposal samples for the soils and wastewaters. Also, confirmation sampling in the excavation areas will be collected to determine if any residual chrome remains at levels of concern.
2.2.1.1 Planned Response Activities
2.2.1.2 Next Steps
All sample data will be shared with TDEC for their evaluation regarding the need for further assessment of the site. TDEC is discussing internally to determine wether the TDEC Solid Waste Program or the TDEC Remediation Program will be the lead for follow-up with the facility.
2.2.2 Issues
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2.3 Logistics Section
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No information available at this time.
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2.4 Finance Section
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2.4.1 Narrative
An EPA site number and accounting string was established for the incident. A task order for START support was issued in the amount of $10,000.
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Budgeted |
Total To Date |
Remaining |
% Remaining |
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Extramural Costs
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| TAT/START |
$10,000.00 |
$1,000.00 |
$9,000.00 |
90.00% |
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Intramural Costs
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| Total Site Costs |
$10,000.00 |
$1,000.00 |
$9,000.00 |
90.00% |
* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.
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2.5 Other Command Staff
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No information available at this time.
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3. Participating Entities
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No information available at this time.
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4. Personnel On Site
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No information available at this time.
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5. Definition of Terms
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No information available at this time.
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6. Additional sources of information
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No information available at this time.
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7. Situational Reference Materials
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No information available at this time.
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POLREP #1 Last Updated 3/17/2015
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