2.2.1 Anticipated Activities
2.2.1.1 Planned Response Activities
The OSCs propose to undertake the following response actions to mitigate threats posed by the presence of hazardous substances at the Site:
1. Develop and implement a Site-specific Health and Safety Plan, including an Air Monitoring Plan, and a Site Emergency Contingency Plan;
2. Conduct characterization sampling to determine if wastes can be segregated to minimize the volume of mixed waste transported off-site for disposal at a hazardous waste landfill. The OSCs and Emergency and Rapid Response Services (ERRS) contractor will dig test trenches across the Site and collect samples from various depths within each test trench;
3. Conduct a treatability study to determine if leachable metals can be treated prior to off-site disposal;
4. Inventory and perform hazard characterization on substances contained in cylinders and drums;
5. Consolidate and package hazardous substances, pollutants and contaminants contained in cylinders and drums for transportation and off-site disposal to a RCRA/CERCLA-approved disposal facility in accordance with U.S. EPA’s Off-Site Rule (40 CFR § 300.440);
6. Transport and dispose off-site any hazardous substances, pollutants and contaminants at a RCRA/CERCLA-approved disposal facility in accordance with U.S. EPA’s Off-Site Rule (40 CFR § 300.440);
7. Take any other response actions to address any release or threatened release of a hazardous substance, pollutant or contaminant that the EPA OSC determines may pose an imminent and substantial endangerment to the public health or the environment.
2.2.1.2 Next Steps
If the Action Memorandum is approved and written access to the Site is obtained, EPA will mobilize to the Site and begin removal activities as described in Section 2.2.1.1.
2.2.2 Issues
During the week of January 18, 2010, a Site owner verbally granted access to the Site for the Site Assessment. However, EPA has not been able to obtain a written access agreement, despite repeated attempts. The enforcement team is planning to pursue a court-issued warrant or order for access for removal actions.
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