1.1.1 Incident Category - Removal Action, EPA Lead

1.1.2 Site Description – The Diaz Intermediates Corp. manufactured high purity, halogentated, fine organics for the chemical industry, using bromine as the primary raw material.  The facility is located on the south side of West Memphis, Arkansas, and consists of a process building, two tank farms, several staging pads pads, a boiler room, equipment shop, warehouse, loading dock, a laboratory, railroad spur, and offices. 

The Site also contained approximately 2,000 containers, drums, and totes; 8 above ground storage tanks (ASTs); and 2 railcars.  These all contained various different corrosive, flammable, and halogenated chemicals with varying quantities.  

The site was initiated by the Arkansas Department of Environmental Quality (ADEQ) in September of 2007 requesting assistance from the EPA. ADEQ has monitored the site regularly and called into the EPA for assistance anytime there was a release or threat of release from the drums, totes, AST's, or any equipment or containments at the facility. 

1.1.2.1 Location - The Site is located at 301 Wyanoke Road, West Memphis, Crittenden County, Arkansas 72301 in a rural industrial area near the Mississippi River. (35.107083 N / -90.193000 W)

1.1.2.2 Description of Threat - The facility manufactured high purity, halogenated, fine organics for the chemical industry, using bromine as the primary raw material. Characteristically, the threats include Toxics, Flammables, and Corrosives.

2.1.1 Narrative

This EPA Lead Removal Action was a teaming effort between EPA and ADEQ.  The field activities were conducted from July 14, 2011 to September 30, 2011. The railcars, tanks, totes, drums, and smaller containers were inventoried and assessed, and it was determined that approximately 1,728 containers and approximately 100,715 gallons of liquids were abandoned at the Site. Samples were collected from approximately 5% of the labeled known drums and 100% of the unknowns, and field screened by Hazardous Categorization (HazCat) standard protocols to determine the characteristics of the materials.

During the course of the Removal Action, the drums and totes were consolidated, segregated, and staged in appropriate areas according to compatibility and like substances.  Incompatibles were segregated apart and staged in different areas.  Containers not in shippable condition were either bulked together or repackaged into shippable containers. 

Daily air monitoring was conducted to monitor percent oxygen, explosive atmospheres, toxic, and volatile organic atmospheres around the Site, the warehouse, Exclusion Zone, and specific areas of operation prior to and during daily Site activities.  Site activities were documented daily and Daily Progress Reports (DPRs) were completed and posted to the website (www.epaosc.org/DiazRemoval).

Efforts were made initially to get as much of the materials as possible back on the market.  For the purposes of this POLREP and all Site documentation made on the website, in the Site logbook, on the DPRs, and in the files, the term "recycle" was used to imply getting the materials back on the market and not sent for disposal.  The drums and totes were packaged into shippable containers, and efforts were made to obtain vendors for recycling materials.  Out of the initial inventory on July 2011, total liquids recycled were approximately 24,815 lbs or 20,990 gallons (See table 1 in section 2.1.4).  The remaining 86,545 gallons of waste were shipped for disposal in drums, totes, and in bulk (See table 1 in section 2.1.4).

All drums and totes previously emptied of their hazardous substances were decontaminated to “RCRA empty” condition, resized into smaller pieces, and disposed of off-Site. Total decontaminated and resized containers during the removal activities were (1,381) poly and (405) steel 55-gallon drums, and (18) 275-gallon totes.  Nine (9) 30 cubic yard roll-off boxes were filled with the resized 1,804 containers and transported for disposal.  

General maintenance was conducted throughout the Site daily.  A final Site walk was conducted by the EPA OSC and ADEQ on September 30, 2011.  An additional Site walk was also conducted with the EPA OSC and the local West Memphis Fire Department Hazmat.  The mayor was notified of the project completion.  The Site was secured and transferred back to ADEQ on September 30, 2011.  During this Removal Action, approximately 1,323 containers of over 551,437 pounds or 107,535 gallons of hazardous substances, pollutants, or contaminants were removed from the Site.   

2.1.2 Response Actions to Date
EPA has conducted several stabilization efforts at the abandoned Site between October 2007 and March 2011 and monitored the removal of approximately 40,070 gallons of hazardous substances by the security holding bank in April of 2011. The Site was monitored monthly by ADEQ, who contacted EPA in the event conditions at the Site warrant response stabilization efforts.

In April of 2011, the security holding bank sold some hazardous substances (See table 2 in Section 2.1.4) to a vendor. The vendor hired contractors and removed the estimated volumes of chemicals listed between April 10 and April 15, 2011. The chemicals listed and the volumes are estimates from the vendor. The EPA OSC and ADEQ Representative mobilized to the site to monitor this action and make sure there was no release of hazardous substances, which was separate and apart from the EPA Lead Removal Action.

During the EPA Lead Removal Action, conducted between July-September 2011, the remaining containers, drums and totes and contents were removed and either disposed or recycled off-Site. Contents of the above ground storage tanks were also removed and disposed of (See table 1 in Section 2.1.4).

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The Potentially Responsible Party at this time is Diaz Intermediates Corp.

2.1.4 Progress Metrics

During this EPA Lead Removal Action, the following hazardous substances, contaminants, or pollutants were removed from the Site and recycled or disposed of appropriately.

Table 1. EPA Lead Removal Action Waste Log

Table 2. Security Holding Bank Removal Action Waste Log