2.1 Operations Section

2.1.1 Narrative

EPA is coordinating with TEMA, FEMA, and TDEC to assess impacted areas for oil and hazardous material releases.  Currently, EPA Operations are divided into Western and Central Tennessee Operations. OSCs Garrard and Dixon are conducting assessments in Central Tennessee out of the Nashville ICP and OSCs Gaughan and Byrd are conducting assessments in Western Tennessee based from Memphis and Jackson.  EPA currently has two missions, (1) to assess designated counties for oil and hazardous material releases due the flooding and (2) to remove and dispose of oil and hazardous materials discovered in these impacted areas.

2.1.2 Response Actions to Date

During this operational period, the Central Tennessee Operations remained divided in two teams lead by OSCs Dixon and Garrard. The Assessment Team lead by OSC Dixon began reconnaissance activities at TrussCraft. LLC, which was reported to EPA by Cheatham County Fire Department. The team also conducted assessment at State Industries. The Assessment Team lead by OSC Garrard began reassessment activities at Nashville Electric Service (NES), Bonnell Aluminum, which was reported to EPA by TDEC, January Environmental and reassessment of drums and tanks along Nestor Road.

The Western Tennessee Operations remained divided into two teams lead by OSCs Gaughan and Byrd. The Assessment Team lead by OSC Gaughan began reassessment activities in Dyersburg in Dyer County, specifically on the south side of town where the majority of flooding was observed, as well as some smaller communities in the area.  The team’s goal was to identify what ERRS activities needed to take place in the area. The Assessment Team lead by OSC Byrd began reassessment activities in Shelby County, participating in a fly over conducted by the Shelby County Sheriff Department to better assess facilities with potential release of hazardous materials, and assessed FRP and chemical facilities by drive through of the county.

Central Tennessee Operations-Assessment Team 1, Lead by OSC Dixon

Cheatham County

·         The Assessment Team met with Kevin Harrell, the Environmental Engineer for A.O. Smith (aka State Industries) located at 500 Tennessee Waltz Parkway in Ashland City

o       Company manufactures water heaters, boilers and other various items, and the facility covers approximately forty acres.

o       The coordinates for the facility are 36.270033 N and -87.067278 W.

o       Three large propane tanks were observed. One was floating off its footing by a roll off box during the flood, but since water has receded, it has set back down on its footing. Due to concerns for the integrity of the tank, the crews emptied the liquid from the tank and are currently burning off residual liquid propane from the tanks using a flare tower.

o        The facility maintains a Spill Prevention Control and Countermeasure plan, and likely lost some oil during the flood. ASTs in the containment area were floating.

o       Several drums were observed outside the facility fence line. Clean up is ongoing and crews are in the process of recovering containers.

o        EPA will follow up with this facility to ensure clean up measures are completed.

·        The Assessment Team conducted reconnaissance at TrussCraft, located at 1035 Graham Road in Ashland City. The team met with Billy Nettles, the Plant Supervisor.

o       The facility manufactures wood and steel trusses.

o        The coordinates for the facility are 36.215822 N and -86.999714 W.

o        The facility lost ten to twelve drums of oil / hydraulic fluid during the flood. The crews at the facility are currently cleaning up and preparing to commence operations.

o       The facility will not require further follow up by EPA.

Wayne County Assessment

• The Assessment Team contacted EMA director for Wayne County, Mr. Robert Farris. The director reported the county did not need assistance with hazardous materials and /or spills.
• The county will not require further follow up by EPA.

Lewis County Assessment

• The Assessment Team contacted a staff member at the EMA office for Lewis County. There was no EMA director listed for the county. The staff member reported the county did not need assistance with hazardous materials and /or spills.
• The county will not require further follow up by EPA.

DeKalb County Assessment

• The Assessment Team attempted to contact the EMA director for DeKalb County, Mr. Charlie Parker; however, contact was not made. The team left a message for the EMA director in regards to locating facilities of concern for hazardous materials release and left contact information. No return phone call was received.
• EPA will follow up with the county to contact the EMA Director.

 Maury County Assessment

• The Assessment Team attempted to contact the EMA director for Maury County, Mr. Mark Blackwood; however, contact was not made. The team left a message for the EMA director in regards to locating facilities of concern for hazardous materials release and left contact information. No return phone call was received.
• EPA will follow up with the county to contact the EMA Director.

Clay County Assessment

• The Assessment Team contacted EMA director for Clay County, Ms. Natalie Boone. The director reported the county did not need assistance with hazardous materials and /or spills.
• The county will not require further follow up by EPA.

Macon County Assessment

• The Assessment Team contacted EMA director for Macon County, Mr. Keith Scruggs. The director reported the county did not need assistance with hazardous materials and /or spills.
• The county will not require further follow up by EPA.

Lawrence County Assessment

• The Assessment Team contacted EMA director for Lawrence County, Mr. Joe Baxter. The director reported the county did not need assistance with hazardous materials and /or spills.
• The county will not require further follow up by EPA.

Central Tennessee Operations-Assessment Team Two Lead by OSC Garrard

Smith County

• The Assessment Team conducted reassessment at the Bonnell Aluminum facility in Gordonsville, TN. The crew is actively cleaning up the facility and is currently in operation.
• The facility will not require further follow up by EPA.

Wilson County

• The EMA director for the county contacted OSC Garrard and asked him to contact Environmental Science Corporation (ESC) about possible flooding at the facility. ESC was contacted and although they had approximately six inches of water in the facility, no chemical containers were compromised.
• Follow up in the county will not be required by EPA.

Davidson County

• The Assessment Team conducted reconnaissance of locations along Nestor Road Nashville, TN. Oil and drums located in a ditch were inspected and all but two drums were empty.  Oil staining and debris was present. The water level in the creek located along Nestor Road has dropped and drums and debris remain on the banks and throughout the wooded areas. Sheen on the creek needs to be addressed.
• The Assessment Team deployed sixty feet of absorbent boom at the creek along Visco Drive at the intersection of Nestor Road.
• EPA will follow up on these locations along Nestor Road. 

• The Assessment Team inspected drums across Briley Parkway near Nashville Electric Service (NES). The drums assessed were either empty or other debris.  There is no further action required from EPA for the field down gradient from NES. No activities were ongoing at the NES facility or along Briley Parkway.
• EPA will follow up with NES to ensure clean up measures are completed.

• The Assessment Team stopped by Quality Plating to conduct assessment of the facility. The team was informed that the staff reported a 1,000 gallon 14% zinc solution spill to Metro Water.
• EPA will follow up with this location to make sure the spill has been cleaned up.

Western Tennessee Operations-Assessment Team One Lead by OSC Gaughan

Gibson County

·         The Assessment Team contacted a local Fire Department Chief in Gibson County. The chief reported localized minor flooding in the areas; however, no oil or hazardous material releases were reported.

·         Follow up in the county will not be required by EPA.

Weakley County

·         The Assessment Team contacted Jason Smith, the Deputy Director for the EMA in Weakley County. The director reported no significant flooding in the areas and no oil or hazardous material releases were reported.

·         Follow up in the county will not be required by EPA.

Carroll County

·         The Assessment Team contacted Amanda Sneed, the Deputy Director for the Carroll County EMA. The director reported no significant flooding in the areas and no oil or hazardous material releases were reported.

·         Follow up in the county will not be required by EPA.

Benton County

·         The Assessment Team contacted John Smoot, the Director of the Benton County EMA. The director reported a gasoline odor in the Birdsong Marina Area along route 191.

·         EPA will further investigate the area and follow up with the EMA director.

Western Tennessee Operations-Assessment Team Two Lead by OSC Byrd

Shelby County

·         The Assessment Team assessed Ergon Terminaling, Inc., BKEP Materials LLC, Owens Corning Trumbull Asphalt, W.M. Barr & Company, Archer Daniels Midland Company, and Cargill Foods, Inc. on Channel Avenue.

·         Ergon Terminaling, BKEP, Owens Corning Trumbull Asphalt, Cargill Foods, Inc. and Archer Daniels Midland Company accumulated rain water in their tank containment areas; however, there was no release due to flooding.  

·         W.M Barr & Company also received an accumulation of rainfall in their containment areas and roof leakage; however, there was no release due to flooding.

·         The Assessment Team assessed the Exxon Mobil Refining & Supply Company on Wisconsin Avenue. The facility accumulated rain water in their tank containment areas; however, there was no release due to flooding.  

·         The Assessment Team assessed Lion Oil Company and Petroleum Fuel & Terminal Company on Riverside Drive. Lion Oil accumulated rain water in their tank containment areas; however, there was no release due to flooding.  Petroleum Fuel & Terminal Company reported no hazardous releases.

·         The Assessment Team assessed Valero Terminaling and Distribution Company on Riverside Boulevard. The facility accumulated rain water in their containment area; however, there were no reported hazardous releases at the facility.

·         The Assessment Team assessed American Commercial Marine Service Company on West Illinois Avenue. The facility accumulated rain water in their containment area; however, there were no reported hazardous releases at the facility.

·         The Assessment Team assessed Premcor Refining Group on West Mallory Avenue. The facility reported no hazardous releases.

·         The Assessment Team assessed the Tennessee Valley Authority power facility on Plant Road. The facility reported no hazardous releases.

·         The Assessment Team assessed Chemtura Corporation on Pope Street. The facility accumulated rain water in their tank containment areas; however, there was no release due to flooding.

·         The Assessment Team assessed Tiger, Inc (Leasee) on Old Millington Road. Staff at the facility reported flood waters within three inches of the levees. The facility reported no release of hazardous materials.

·         The Assessment Team completed assessment at Cargill Foods, Inc. on Buoy Street. The facility reported no hazardous releases.

·         The Assessment Team assessed Federal Express on Spankle Road. The facility reported no hazardous releases.

·         The Assessment Team completed assessment at ConAgra on Williams Avenue. The facility reported no hazardous releases.

·         The Assessment Team completed assessment at the Tennessee Valley Authority on Elm Tree Road. The facility reported no hazardous releases.

o                    Follow up with the listed facilities above will not be required by the EPA.

·         The Assessment Team made attempts to contact the Environmental Manager at Tangent Rail Products on Channel Avenue to assess the facility; however, no contact was made.  EPA will follow up on this facility to determine if the facility poses a potential threat for hazardous release.

·         The Assessment Team made attempts to contact the Environmental Manager at Buckeye Terminals, LLC on Rental Road to assess the facility; however, no contact was made.  EPA will follow up on this facility to determine if the facility poses a potential threat for hazardous release.

·         The Assessment Team made attempts to contact the Environmental Manager at Archer Daniels Midland Company on Chelsea Avenue to assess the facility; however, no contact was made.  EPA will follow up on this facility to determine if the facility poses a potential threat for hazardous release.

·         The Assessment Team made attempts to contact the Environmental Manager at BNSF Railway Company on East Shelby Drive to assess the facility; however, no contact was made. EPA will follow up on this facility to determine if the facility poses a potential threat for hazardous release.

TDEC currently has a database established that outlines the status of wastewater facilities impacted by the flooding.  This information was collected primarily through phone calls with TDEC during the past week, but it is continually being updated.  Overall it is understood that 8 WWTPs were inundated with flood waters and 20 were in some way compromised.

TDEC Division of Water Supply has a spreadsheet identifying 5 PWSs currently on a Boil Water Notice and 9 PWSs with Diminished Capacity.
 

EPA met with USACE and TDEC drinking water reps to discuss the needs and status of water and wastewater facilities impacted by the floods.  Additional communications with Atlanta have centered around the logistics of deploying a mobile laboratory and the technical staff necessary to fill the requests of TDEC. 

A prioritized schedule for assessing wastewater treatment plants was created, focusing on facilities with the most damage and also the most rural systems.  Assessment forms were developed to also aid in the evaluation of pump stations.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

2.1.4 Progress Metrics