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1. Introduction
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1.1 Background
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Site Number: |
B4W3 |
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Contract Number: |
EP-S4-07-03 |
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D.O. Number: |
TO-0132 Mod 2 |
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Action Memo Date: |
2/25/2013 |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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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: |
10/2/2012 |
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Start Date: |
10/2/2012 |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
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RCRIS ID: |
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ERNS No.: |
1026286 |
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State Notification: |
ADEM |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Time-Critical Removal Action
1.1.2 Site Description
The Reef Environmental Services facility in Sylacauga, Alabama was a centralized waste treatment facility. The facility was permitted to accept industrial waste water (waste water and oily contact water) for treatment and discharge to the Sylacauga public operated treatment works (POTW) waste water treatment plant. Shortly after the first waste deliveries began, reports indicate that numerous odor complaints were received by the local and state government. Within the past few years, the facility has filed for bankruptcy. The State has taken various actions and had limited success in getting the wastes at the Site to be properly disposed. On October 1, 2012, after receiving information that totes were being removed from the facility and numerous odor complaints, Alabama Department of Environmental Management (ADEM) personnel investigated the Site. ADEM personnel could not make entry into the facility but did observe an oily sheen in a stream near the facility as well as a large bulge in the tarp covering the Biological Treatment Basin at the facility. Later in the day on October 1, ADEM requested assistance from the Environmental Protection Agency to assess the Site and to assist with implementation of emergency stabilization measures. On the morning of October 2, 2012, OSCs Francendese and Harper were mobilized from Birmingham, Alabama to meet with ADEM and assess the situation. Upon initial assessment, OSC Francendese secured the Site and ceased removal of on-site totes by private party contractors. In addition, he verbally notified the PRPs of potential hazards which included the accumulation of hazardous substances (including hydrogen sulfide) under the tarps/liners covering the basins. While the PRP provided verbal access, he indicated that he was not able to perform the necessary stabilization actions required by EPA. OSC Francendese requested the dispatch of the on call responder. EPA OSC Neal was dispatched to the scene. Assessment activities continued throughout the day and evening of October 2, 2012.
1.1.2.1 Location
71 Twin Street, Sylacauga, Talladega County, Alabama
1.1.2.2 Description of Threat
The abandoned facility has several priority issues that will be addressed under a phased approach. The first phase involved the emergency response action that mitigated the trapped gases under the 3 million gallon biological reactor tarp/liner of Equalization Basin No. 2 (EQ 2). An additional 3-million gallons treatment basin, Equalization Basin No. 1 (EQ 1) also has a failed tarp/gas retention system that was not under high pressure, but required mitigation work. Trapped gases exist under this liner and will be addressed under the emergency phase of the response action. The trapped gases total approximately 175,000 cubic feet contained dangerous elevated levels of volatile organics and hydrogen sulfide and presented a release and explosion risk. This facility exists within 1000 feet of a residential neighborhood.
Additional threats exist in the form of an oily sheen release to the nearby creek as well as abandoned chemicals onsite.
The first phase addressed the release threat of the trapped gases and release of EQ 2 to Shirtee Creek followed by a series of chemical treatments of EQ 1 & 2 to stop the emissions of H2S.
The second phase will involve an analytical assessment of the waste water inventory of the Site. Based on the technical review of the analytical a treatment and disposal sheme will be implemented for the estimated 14-million gallons of waste water in the three major waste water basins and two clarifiers.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
The initial assessment identified the trapped gases under the tarp/liner as well as the oily sheen being released to the creek. The rotten egg odor was later identified to be both elevated volatile organics and hydrogen sulfide. Subsequent site walkthru identified abandoned hazardous substances at the facility both on the facility grounds proper and within the lab.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
The facility is an abandoned former waste treatment facility that was referred to the EPA ERRB by ADEM. Subsequent assessments identified unstable conditions relating to accumulating gases (organic and hydrogen sulfide) under the containment tarp/liner covering Equalization Basins 1 & 2.. Additional assessments identified an oily sheen being released from the facility as well as abandoned hazardous chemicals both on the facility grounds and in the onsite facility lab.
2.1.2 Response Actions to Date
Week of Mar 4, 2013 - Emergency and Rapid Response Services (ERRS) continued to empty and clean the frac tanks on-site. The OSC worked with the site engineer on a viable treatment solution for the waste water. A waste water specialist was requested thru WRScompass to aid in a treatment solution. The OSC continued to work with the Alabama Department of Environmental Management (ADEM) on discharge parameters.
Week of Mar 11, 2013 - Emergency and Rapid Response Services (ERRS) continued to clean the frac tanks in order to remove them off-site. A waste water specialist from WRSCompass mobilized to the site to help formulate a viable treatment solution for the waste water. Alabama Department of Environmental Management (ADEM) continued to offer support for treatment solutions into Shirtee Creek. The On-Scene Coordinator (OSC) and ADEM met with the Mayor of Sylacauga and discussed a future site visit.
Week of Mar 18, 2013 - Emergency and Rapid Response Services (ERRS) completed cleaning the frac tank rentals. All frac tank rentals have been called off rent. The WRSCompass waste water specialist conducted several bench tests with various flocculant to determine a viable treatment solution for the various metals in the waste water. Analytical data from those tests revealed that flocculant is not a viable option for treatment. The OSC, along with input from Alabama Department of Environmental Management (ADEM) and waste water specialists from ERRS and START has decided to forgo flocculant and/or polymer treatment and focus solely on physical filtering with peroxide treatment while using the existing facility aerators for nitrification. The OSC and ADEM gave a site tour for the Mayor of Sylacauga.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The Office of Environmental Accountability (OEA) is pursuing enforcement.
2.1.4 Progress Metrics
Currently, Initial oxidative treatment listed below is 35% hydrogen peroxide to control hydrogen sulfide gas emissions.:
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| Aeration Basin |
Water |
7-mil gal |
N/A |
Oxidation |
TBA |
| Equalization Basin No. 2 |
Water |
3-mil gal |
N/A |
Oxidation |
TBA |
| Equalization Basin No. 1 |
Water |
3-mil gal |
N/A |
Oil Removal |
TBA |
| Clarifier No. 1 |
Water |
250K gal |
N/A |
TBA |
TBA |
| Clarifier No. 2 |
Water |
1-mil gal |
N/A |
Oxidation |
TBA |
| Oily Sluge |
Soil |
600 tons |
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Stabilize |
Started |
| Drums |
Liquid |
15 drums |
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TBA |
| Lab Packs |
Liquid |
13 packs |
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TBA |
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2.2 Planning Section
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2.2.1 Anticipated
Continue coordination with ADEM and Local officials.
2.2.1.1 Planned Response Activities
Begin treatment of the approximately 14-million gallons of waste water and discharge it to Shirtee Creek per parameters established by ADEM.
2.2.1.2 Next Steps
Initialtion of Phase II.
2.2.2 Issues
- Media and public relations have been positive during the end of Phase I
- Need a viable treatment solution for TKN and COD in order to begin disposal into Shirtee Creek.
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2.3 Logistics Section
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N/A
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer
2.5.2 Liaison Officer
2.5.3 Information Officer
Ms. Kerisa Coleman (Region 4 CIC)
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3. Participating Entities
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3.1 Unified Command
EPA
ADEM
3.2 Cooperating Agencies
City of Sylacauga
Talladega County EMA
Alabama EMA
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4. Personnel On Site
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- START (Tetra Tech) - 1 (for off site sampling on Shirtee creek)
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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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None available at this time
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