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U.S. ENVIRONMENTAL PROTECTION AGENCY$250,000 EMERGENCY ACTION MEMORANDUMDate:
22OCT04
Subject:Initial POLREP and NOTIFICATION OF $ 250,000 ACTIVATION
Altamount Road Drums 
From:
Rick Jardine, PE, OSC, Region 4 
To:
Regional Response Center, 4WD-ERRBShane Hitchcock, Chief, ERRBDon Rigger, Chief, Emergency Response SectionLisa Boynton, EPA-HQ Regional CoordinatorChris Staton, DHEC
Site No:
A4GF
Delivery Order No:
__-__-__ Not Yet Assigned
DO Amount:
$ 5,000.00
Contractor:
Kemron
CERCLIS No:
__________
ERNS NO:
______________________
Response Authority:
CERCLA
NPL Status:
Non-NPL
State Notification:
21OCT04
Start Date:
21OCT04
Demobilization Date:
21OCT04
Completion Date:
21OCT04
I. INTRODUCTION
A removal site evaluation performed on 21OCT04 by the On-Scene Coordinator (OSC) andrepresentatives from South Carolina Department of Health and Environmental Control (DHEC),in accordance with the National Oil and Hazardous Substances Pollution Contingency Plan(NCP), 40 CFR Part 300.410,
 
has determined that there is a potential threat to public health orwelfare or the environment
 
posed by the presence of paint related wastes, vehicle antifreeze,used oil, and unknown materials affecting a heavily populated and active area in Greenville, SC.These substances are believed to include ignitable substances, ethylene glycol, and metals whichare CERCLA Hazardous Substances.Based on a review of the removal site
 
evaluation
 
the OSC has determined that the Site meets thecriteria for initiating a Removal Action under Section 300.415 of the NCP. As a result of Siteconditions, immediate action pursuant to Section 104 of the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA), is needed at the Site.Pursuant to Delegation 14-1-A, authority to obligate emergency CERCLA funding in the amountof $250,000 to initiate removal/stabilization actions has been delegated to the OSC.
 
The OSChas approved the use of CERCLA funding to mitigate the threat to public health, welfare and theenvironment at the Altamount Road Drums Site.
 
II. BACKGROUND
On 20 October 2004 DHEC identified seven 55-gallon drums on an undeveloped lot in a heavilyused area of Greenville, SC. The adjacent commercial property owner/operator stated that hehad righted the drums which had been overturned by unknown persons. Some of the drums wereonly partially full, at least one was leaking at the time of the DHEC inspection. The remainingdrums were full.DHEC researched the property ownership and contacted the primary owner who claimed that thedrums were not hers. She stated the drums were her brother’s property. DHEC attempted tocontact the brother to no avail. The brother is also filed as secondary owner to the property.
III.
 
THREAT
Section 300.415 of the NCP lists the factors to be considered in determining the appropriatenessof a Removal Action. The selected criteria from paragraphs (b)(2) (i), (iii), (iv), (v), (vi), (vii)and (viii) directly apply as follows to the conditions at the Site:X 300.415 (b)(2)(i) "Actual or potential exposure to nearby human populations,animals or the food chain from hazardous substances or pollutantsor contaminants"The drums were found on their sides leaking in a heavily used section of Greenville, SC. Thematerials appeared to be waste paint related materials, used oil, and antifreeze. Some materialshad spilled to the earths surface.X 300.415 (b)(2)(iii)"Hazardous substances or pollutants or contaminants indrums, barrels, tanks, or other bulk storage containers, thatmay pose a threat of release"The materials were found in 55-gallon drums that were leaking. Several of the drums were onlypartially full and had likely lost the majority of their contents to the ground surface.X 300.415 (b)(2)(iv)High levels of hazardous substances or pollutants orcontaminants in soils largely at or near the surface that maymigrate”Staining and saturation of surface soils were observed by reconnaissance teams.X 300.415 (b)(2)(v)"Weather conditions that may cause hazardous substancesor pollutants or contaminants to migrate or be released"The drums are located out doors in Greenville, SC, an area that is prone to seasonal rains and
 
periodic hurricanes. X 300.415 (b)(2)(vi)Threat of Fire or explosionSome of the materials are believed to be paint-related spent solvent which may have flashpotential.X 300.415 (b)(2)(vii)"The availability of other appropriate Federal or Stateresponse mechanisms to respond to the release"DHEC requested EPA assist in mitigation of the fugitive drums due to insufficient fundingavailable.
IV. SCOPE OF WORK
With the $200,000 emergency funding, the OSC proposes to remove the threat of explosion, fire,or poisoning to nearby population. The removal action consists of the following activities:- conduct air monitoring to dteremine immediate local hazards;- over-pack the containers into sound DOT-approved containers;- sample the materials to determine contents;- excavate contaminated soil;- provide for appropriate transportation and disposal;- backfill and re-establish vegetative cover.The authorized budget for this $ 200K removal is:EPA (Direct)$ 10,000START$ 10,000ERRS$ 20,000Subtotal$ 40,000Contingency$160,000TOTAL$200,000
V. OSC ACTION
On 21OCT04, the OSC determined that a hazardous substance threat exists at the Site. The OSCactivated $250,000 to initiate a Removal Action to mitigate the threat to human health and theenvironment. The OSC issued a Delivery Order to ERRS Contractor KEMRON to initiate aRemoval Action to mitigate the threat to human health and the environment. Additionally theOSC has enlisted the assistance of the START Contractor TTEMI
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