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2.1.1 Narrative - (See previous POLREPS for detailed operational information)
This emergency removal action continues as EPA evaluates whether further removal action is appropriate. Simultaneously, the facility assets are being claimed separately by entities under negotiation with the secured creditor.
2.1.2 Response Actions to Date - During this reporting period, EPA has implemented a strategy to minimize storm water flow through the tank farm containment. The tactics include rewashing the drip pad, installing a concrete curb, and installing a relief trough from the pad to the site lay down area. The curb was installed to block off flow from the pad to the pressure vessel containment sump. The relief trough allows runoff to exit the drip pad towards the west. Without the trough, storm water would accumulate on the drip pad and potentially overtop the curbing. Rinse samples collected from the cleaned drip pad indicate water concentrations of the metals to be less than one part per million for each constituent.
Beginning December 13th, EPA flowed several test runs of treated water to the sanitary sewer system to determine whether the metals-contaminated water would cause a system upset. This was a necessary test as the third party respirometer analyses were inconclusive. On the 22nd, JEA granted a conditional permit to discharge treated site water to the POTW. Initially the weekly allowable volume will be 20,000 gallons released in maximum 10,000 gallons events. Other conditions include discreet testing and communications regarding each batch of treated water.
EPA delivered prospective process water (batch water from tanks #1and #2 as well as effluent collected from the containment structure) to the Savannah Wood Preserving Company. Savannah Wood has approved the waters for receiving. With some process alteration, Savannah Wood has indicated it can bring the waters up to specification that meets the quality required for beneficial use. EPA inquiry to GA EPD indicates that Savannah Wood maintains environmental compliance.
EPA continues to process contaminated storm water. The process, which is an adapted absorption polishing to remove metals, requires several passes through the titanium dioxide media to remove the concentrations that we have on site. The arsenic and copper tend to have a high afinity for the reaction and are removed quickly, however the chromium requires repeated processing to meet the JEA discharge requirement. As of this report, one frac tank has been successfully treated and discharged. Two others are believed to be ready, pending chemical analyses. Two more have been processed multiple times and are close to the final polish. The final polish requires a fresh media loading into the treatment process vessel.
Several set backs have occurred over this reporting period. Abnormally low temperatures have caused water to freeze making treatment start-up difficult each morning. WRS has had to drain and winterize the flow lines each night to minimize the delays. Also several sight glasses have broken on the vertical facility tanks. In one case the tank released much of it's contents to the containment structure. WRS sealed the sight glass valve and pumped the material back into the tank. Several tanks have begun to weep leakage to the containment. Additionally one brittle PVC line connecting a submersible pump to a holding tank failed releasing its contents to the containment structure. WRS replaced that line with new piping and pumped the material back into its tank.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs) - Regional Superfund Enforcement personnel are engaged in this project.
2.1.4 Progress Metrics
TABLE 1 - Media and Wastes Collected
Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal/
Discharge |
captured lagoon water |
water |
40,000 gals |
|
Absorption |
20,000 to JEA |
contaminated facility storm water |
water |
250,000 gals |
|
Absorption |
|
process batch water |
water |
100,000 gals |
|
beneficial use
off-site |
|
CCA sludge |
solid |
14 drums |
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TABLE 2 - Batch Summary (the status of the waste stream is ongoing, the tank disposition is a snapshot in time)
Batch |
Source |
Current
Storage
Unit |
Status |
Alpha |
Pond Water |
F-13 |
3rd Treatment, awaiting analytical results |
Beta
|
Pond Water |
None |
Discharged from Dec 13th throough 21st |
Gamma |
Tank Sump |
F-3 |
Petroleum contaminated |
Delta |
Tank Sump |
F-4 |
Untreated - likely to Savannah Wood |
Epsilon |
Tank Containment |
F-2 |
Treated once, combined w/ former w/s Iota which was only half full |
Zeta |
Tank Sump |
F-6 |
Untreated - likely to Savannah Wood |
Eta |
Tank Containment |
F-10 to F-1 |
1st Treatment pass underway |
Theta |
Tank Containment |
F-14 |
Treated once, combined w/ former w/s Iota which was only half full |
Iota |
Tank Containment |
|
Combined into Theta and Epsilon |
Kappa |
Tank Containment |
F-5 |
twice treated (As, Cu good, Cr at 300 ppm) |
Lambda |
Tank Containment |
F-7 |
twice treated, awaiting analysis |
Mu |
Tank Containment |
F-12 |
Untreated - likely to Savannah Wood |
Nu |
Tank Containment |
F-11 |
several treatment passes, awaiting analytical |
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