United States Environmental Protection Agency
Region III
POLLUTION REPORT

Subject: 

See previous POLREP

The Trustee continued to have discussions with the new owner about entering the West Virginia Voluntary Remediation Program (VRP). The Trustee and property owner have verbally agreed to do so, and the application is being finalized.

During the May 6, 2008 site inspection, ENSR observed chipping of portions of the concrete pad that had been stained by wood treatment operations. The chipping is likely the result of weathering or operation of heavy equipment on the pad during the excavation and backfill work. ENSR is proposing a second round of decontamination of the pad surface to supplement the work that was performed by EPA in January 2007. An outline of the plan for the decontamination is provided in the following
section.

Proposed Pad Decontamination

In January 2007, the wood treatment pad was decontaminated by EPA via hand scraping and pressure washing. To address any residual staining that may remain on the surface of the pad as a result of wood treatment operations, ENSR is proposing to perform a more aggressive cleaning. Specifically, a concrete scarifier will be utilized to remove the upper layer (approximately 2-centimeters deep) of concrete followed by rinses with high pressure water and an acid etching solution (if necessary). The work will be focused on areas that are visibly stained. Prior to beginning, ENSR will mark out the areas to be addressed. Passes will be made over the stained areas with a walk-behind concrete scarifier. After each pass, ENSR will inspect the area to see if staining remains. A maximum of two
passes will be made before an acid etching solution is utilized. After ENSR determines through visible inspection that sufficient staining has been removed, the area will be swept and pressure washed.
Solids from the concrete scarifying, and solutions from the pressure washing and acid etching, will be collected and containerized in 55-gallon steel drums. Since the waste may contain constituents from
the wood treatment operations, it will be handled as Resource Conservation and Recovery Act (RCRA) F035 waste and transported off site for disposal. The additional decontamination is expected to take
two days onsite to complete and will be conducted within 30 days of approval of this strategy by EPA. Level C personal protective equipment will be worn while operating the concrete scarifier.

Anticipated Response Activities During the Upcoming Reporting Period

ENSR will conduct additional pad decontamination within 30 days of approval of the proposed strategy by EPA.

The Trustee anticipates applying to enter the Site into the West Virginia VRP.

Modifications to the RAP and Schedule

ENSR proposes that the next reporting period cover the period of September 27 through December 31, 2008.
ENSR will implement the pad decontamination plan within 30 days of its approval by EPA.
Additional site investigation, including another round of groundwater sampling, is expected to be necessary for the VRP. Assuming the site is accepted into the program, ENSR anticipates submitting an investigation work plan to the West Virginia Department of Environmental Protection (WV DEP) during the next reporting period.