2.1.1 Narrative
See POLREP 1

2.1.2 Response Actions to Date

On June 27, 2011, AVS hauled off 6 loads (33,000 gal) of oily water from the northeast area and east containment to United Water’s facility in Cincinnati, OH.

On June 28, 2011, AVS hauled off 12 loads (67,400 gal) of oily water from the solidification pits and primary separator pits to United Water’s facility in Cincinnati, OH.

-AVS hard piped the frac tank/GAC system north of the solids building.

-Trihydro personnel discovered that a 55-gal poly sulfuric acid drum had fallen over east of the three solidification pits on the northeast area of the site due to the pallet it was on collapsing. 

·         Trihydro/AVS deployed socks from the adjacent spill kit to prevent the material from further migrating across the surrounding paved surface and into the nearby storm drain. 

·         The drum was placed upright and four 50-pound bags of neutralizing agent (soda ash) were placed on the spilled material to neutralize it and prevent further degradation of the surrounding asphalt. 

·         AVS brought additional soda ash onsite to replace the quantity used for the response activities. 

·         Per Trihydro, a skid steer will be brought onsite on the tomorrow, June 29, 2011, to place the drum into an overpack and prepare it for ultimate shipment and disposal.

·         An estimated 3-5 gallons of acid may have entered the northeast stormsewer system. 

·         Per Trihydro, they will inspect the remaining pallets to determine if there are any additional integrity issues.

-Trihydro ran the GAC system treating the water of 1 raw water frac tank and pumping it into 1 finish water frac tank.

-Trihydro pumped southwest area water to the City sanitary sewer.

·         Discharge event information:

-Initial Time: 1254;             Initial Reading: 1,109,560 gal

-Final Time: 1624;               Final Reading:  1,172,080 gal

-Total Volume:  62,520  gal;              Average Flowrate:  298 gpm

On June 29, 2011, AVS hauled off 4 loads (22,400 gal) of oily water from the primary separator pit and solidification pits to United Water’s facility in Cincinnati, OH and Clean Water’s facility in Dayton, OH.

-Trihydro continued running the GAC system.

·         1.75 finish water tanks are currently full of treated water.

·         A small hole was identified on one of the GAC system tanks and per Trihydro, the manufacturer will be repairing it.

-Focus discharged approximately 6,000 gal of stormwater from the Tank 51 containment into the Focus/WSP frac tank staged north of the administration building.

-Trihydro placed the damaged 55-gal poly sulfuric acid drum into an overpack and moved it into the dehydration building along with 4 other somewhat bulging 55-gal poly drums in order to remove them from the elements and onto a spill pallet.

- Safety Kleen, Trihydro (+4), and Midwest (+5) were on site for a cleanup kick-off meeting.

·         Trihydro/Safety Kleen/START personnel walked the site with Midwest personnel.

·         Per Trihydro/Midwest, they will initially be addressing the following:

-Drums/totes management and removal;

-Frac tanks 7-10 and AST 6 emptying/cleaning for potential stormwater storage;

-Hauling out solidified sludge staged north of the solidification pits.

·         Per Midwest, they intend to haul oily water to United Water in Cincinnati, OH and solidified sludge to Southside Landfill in Indianapolis, IN.

-Safety Kleen, Trihydro, START, Heritage, and Asphalt Materials (+2) met briefly to discuss the AMI-ESI parcel.

·         The PRP Group does not intend to engage in a “property swap”, so AMI/Heritage was instructed to move forward with the permanent stormwater management actions.

·         Per AMI, they will begin activities late next week or early the week following.

On June 30, 2011, Trihydro continued running the GAC system and both finish water tanks are currently full of treated water.

-Trihydro temporarily repaired the small hole on one of the GAC system tanks and per Trihydro, the manufacturer will be bringing them a replacement tank.

-OSC Verneta Simon, START, City of Indianapolis (+3), United Water, Trihydro (+2) conducted a site walk.

·         Per Kim Cussen (United Water), Trihydro can transport oily water to United Water during rain events via truck using approved haulers.

·         Per K. Cussen, United Water will have to discuss discharging northeast area water to the City sanitary sewer with other City personnel (not present).

·         Per K. Cussen, two separate Special Discharge Agreements will be required for discharge directly to the City sanitary sewer and for hauling northeast area water to the WWTP.

·         Per Tom White (City of Indianapolis), he will be on site on Tuesday, July 5, 2011, to sample the northeast area water (both treated and untreated).

·         Per T. White, due to consistently low/NA contaminant levels, the City may decrease sampling frequency requirements in the southwest area.

·         Per Mike Massonne (City of Indianapolis), he needs to discuss potential discharge rates for treated water to Oil Creek with other City personnel (not present).

·         Trihydro shows City personnel their proposed GAC system piping route and Oil Creek discharge point, located southeast of the east containment.

-Chemical, Inc. was on site to remove their 8 totes:

·         5 sulfuric acid totes;

-4 stored outside, east of the solidification pits;

-1 stored in the chemical building;

·         2 aluminum sulfate totes;

-1 stored east of the unloading building;

-1 stored in the chemical building;

·         1 ferric chloride tote stored in the chemical building

-Aaron Equipment Company was on site as a bidder for LEAF pertaining to equipment for repossession.

·         START/Aaron were able to locate 4 of the pieces of equipment (centrifuge, screener, stator pump, and submersible pump) east of the solids building. (Photos of the equipment are posted under "Images".)

·         START/Aaron could not locate the 2 Cornell pumps listed.

On July 1, 2011, Trihydro pumped southwest area water to the City sanitary sewer.

·         Discharge event information:

-Initial Time: 1020;             Initial Reading: 1,172,080 gal

-Final Time: 1350 ;               Final Reading: 1,214,050 gal

-Total Volume: 41,970  gal;              Average Flowrate: 200 gpm

-Per Kristin Heitman (Providence Wildlife), when the mallard ducklings rescued from ESI have attained release criteria, they will be released into a species-appropriate habitat.
-Trihydro continued hard/flexible piping GAC connections to the City sanitary sewer manway and to the ditch leading to Oil Creek.

-Brenntag Midsouth, Inc. was on site to remove their 4 totes:

·         4 empty hypochlorite solution (bleach) totes;

·         Due to a lack of forklift at the site when the hauler arrived, Brenntag was unable to remove the totes and will be back on site next week to do so.

-EQ was on site and collected waste characterization samples for the DAF tanks, API tanks, and Tank #6.

-Midwest (+4) was on site taking drum samples and testing drum content pH.

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

2.1.4 Progress Metrics

• Revised Work Plan

ASAOC – Administrative Settlement Agreement on Consent
ERRS – Emergency and Rapid Response Services

IDEM – Indiana Department of Environmental Management

OSC – On-Scene Coordinator

POLREP – Pollution Report
PRP - Potentially Responsible Party
RCRA – Resource Conservation and Recovery Act

START – Superfund Technical Assessment and Response Team

U.S. EPA – United States Environmental Protection Agency