2.1.1 Narrative
See POLREP 1

2.1.2 Response Actions to Date

On May 16, 2011, AVS loaded and hauled out 9 loads (50,000 gallons) of oily water from the site, 6 loads (33,000 gallons) from the northeast area for treatment at United Water’s facility in Cincinnati, OH and 3 loads (17,000 gallons) from the primary separator pit for treatment at Clean Water Limited’s Cherokee Drive facility in Dayton, OH.
- 0.2" of rainfall was observed over the weekend.
- AVS worked to clear out the manway and sanitary line between SS-27 and SS-28 with a larger power washer attachment. Blockages which had previously hindered this line clearing and the clearing between SS-24 and SS-25 were removed. 

- AVS conducted a "confined space entry" on manway SS-27 to retrieve a piece of attachment which had fallen off the pressure washer. All necessary precautions were taken and all appropriate permits were acquired for this activity.

- AVS also continued pumping oily sludge/ oily water from the bottom of the northeast area  manways and storing it in the east solidification pit.
- Trihydro conducted a stormwater discharge to the City sanitary sewer under the SDA permit issued on 4/12/2011. A total volume of 41,117 gallons of water were discharged at a maximum flow rate of 325 gallons per minute.

- US EPA conducted a conference call with START, the PRP group Project Coordinator, the Heritage Group, and Asphalt Materials regarding stormwater  run-on and run-off between ESI and Asphalt Materials. Also, property belonging to Asphalt Materials was fenced in by ESI. An e-mail will be sent to all on the conference call by Monday, May 23, 2011 describing a conceptual solution.

On May 17, 2011, AVS loaded and hauled out 3 loads (15,250 gallons) of oily water from the site. All 3 loads (15,250 gallons) were hauled from the northeast area for treatment at United Water’s facility in Cincinnati, OH. 
- No rainfall was observed overnight.
- AVS conducted continued sanitary sewer cleaning between SS-19 and SS-23. This stretch of line was cleared of all blockages and then rinsed clean with hot water. 

- AVS also began clearing out the large vault adjacent to the air stripper on the northeast portion of the site. This vault was the meeting point of the 36" line and the 60" line. Vacuuming and pressure washing activities revealed approximately 4' of sludge waste at the bottom of the vault.

- Stephen J. Christensen & Associates (subcontractor for Asphalt Materials) arrived on site to shoot elevations on the Asphalt Materials parcel and the paved areas of the ESI property. 

On May 18, 2011, AVS loaded and hauled out 6 loads (23,750 gallons) of oily water from the site. All 6 loads (23,750 gallons) were taken from the northeast area for treatment at United Water’s facility in Cincinnati, OH.  
- Approximately 0.1 inch of rain was observed yesterday; showers are expected throughout the evening.
- AVS began clearing out the 36" line which meet in the large vault adjacent to the air stripper on the northeast portion of the Site.

- AVS cleared out the 36" line which runs from the vault, in a northly direction, towards SS-23. All sludge blockage was cleared from the line and it was rinsed with hot water. 
- AVS also began clearing out the 60" line which tuns southwest from the vault towards the southwest portion of the site. The length of this line is currently not known.
 

On May 19, 2011, AVS loaded and hauled out 1 load (4,250 gallons) of oily water from the site. The 1 load (4,250 gallons) was taken from the northeast area for treatment at United Water’s facility in Cincinnati, OH. 
- Approximately 0.1 inch of rain was observed yesterday; showers are expected throughout the evening.

- AVS cleared out and plugged the 16" sump in the Control Building. A "confined space entry" was staged, the pump and sample system removed, and the line was plugged. 

- AVS power washed the vault where the 36" line and the 60" line meet. 

- AVS also continued power washing the pavement near the frac tank storage area and the area near the solidification pits. 

- AVS completed the work on the site and demobed from this task. 

- Trihydro conducted a site walkthrough with contractors who are bidding on the removal activities still on site. Bids are expected back by 5/25 and the work will be awarded by 5/26.

On May 20, 2011, AVS loaded and hauled 2 loads (8,500 gallons) of oily water from the site. Both loads (8,500 gallons) were taken from the northeast area for treatment at United Water's facility in Cincinnati, OH.

- No rain was observed overnight, although showers are forecasted over the weekend.

- AVS contractors were not on site today.

- Focus Contracting arrived on site and conducted LEL monitoring inside Tank 51 and took a sample of the material still in the tank. VOC readings were found to be approximately 75 ppm inside the tank, although O2 readings were at 20.9, and LEL readings were 0%.

- A sludge sample was taken from Tank 51 and submitted for disposal analysis to Pace Analytical.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
It appears a small portion of property that belongs to Asphalt Materials has been fenced in by ESI. US EPA conducted a conference call with all parties involved and a conceptual solution was requested by US EPA for submission by Monday, May 23, 2011.

2.1.4 Progress Metrics

• Review Draft Work Plan submitted by PRP Group on May 19, 2011
• Possible work on Tank 51

ERRS – Emergency and Rapid Response Services

IDEM – Indiana Department of Environmental Management

OSC – On-Scene Coordinator

RCRA – Resource Conservation and Recovery Act

START – Superfund Technical Assessment and Response Team

U.S. EPA – United States Environmental Protection Agency
POLREP – Pollution Report
ASAOC - Administrative Settlement Agreement on Consent
PRP - Potentially Responsible Party