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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 25, 2013 - Emergency and Rapid Response Services (ERRS) began the process of deconstructing and cleaning inefficient components of the old treatment system in order to remove off-site. A waste water specialist from Tetra Tech arrived on-site to assist in the construction a working treatment system given the current budgetary and time constraints. Additional components for the treatment system have been ordered. The VIPER system was requested to continuously monitor the air quality on and around the site while running the basin aerators. The OSC and Alabama Department of Environmental Management (ADEM) gave a tour of the site to the Mayor of Sylacauga..
Week of Apr 1, 2013 - Emergency and Rapid Response Services (ERRS) continued to clean the inefficient components of the previous treatment system in order to remove off site and off rent. The OSC and ERRS conducted a toxicity bench test of waste water from basin 3 to simulate using the smaller clarifier on-site in conjunction with a polymer. The OSC has decided to retreat basin 2 next week with 35% hydrogen peroxide in order to reduce hydrogen sulfide emissions and create an aerobic environment in the water. The OSC met with the president of the local environmental activist group and gave her a tour of the site.
Week of Apr 8, 2013 - Basin 2 was retreated with approximately 5,000 gallons of 35% hydrogen peroxide. The basin was monitored for Dissolved Oxygen (DO) levels and Oxidation Reduction Potential (ORP) numbers as well as air monitoring for hydrogen sulfide emissions while gradually bringing the aerators on to run continuously. Emergency and Rapid Response Services (ERRS) continued to clean the components from the previous treatment system. Early toxicity results from waste water in basin 3 showed 0% survival of all organisms at low concentrations. The OSC continued to talk with waste water specialists to determine the next course of action.
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 and Viper Support)
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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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