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2.1.1 Narrative
An Action Memo for a removal action was signed on February 15, 2011, effectively transitioning the site from an emergency response action to a removal action. The scope of the removal action incudes but may not be limited to the excavation and removal of CCA sludge within the secondary containment system, storage tanks, and associated piping, removal of the storage tanks and piping, treatment of the remaining CCA contaminated water, excavation and disposal of CCA contaminated soils and sediment on the Wood Treaters property and the Susie Tolbert Elementary School which exceed EPA Removal Action Levels for industrial and residential exposure scenarios.
2.1.2 Response Actions to Date
Titanium dioxide was continually used as a treatment media for processing the existing CCA contaminated waste water in frac tanks. Due to time constraints and budget, 80,294 gallons of waste water were transported off site to a regulated facility for disposal. Approximately 68,000 gallons of the CCA waste water were treated on site and discharged into the municipal sewer system. To reduce cost, approximately 17,072 gallons of the CCA waste water were shipped off site for reuse at another wood treater site.
Additional equipment was brought to the site for the purpose of excavating CCA contaminated soil on the Wood Treater property, Susie Tolbert Elementary Schoo and three nearby homes. This same equipment was also used to excavate CCA contaminated sediments from the detention ponds on the Wood Treater property and the Susie Tolbert Elementary School property. The soils at the Wood Treater property contained a high percentage of crushed rock therefore a vibratory screen was utilized to seperate the rock from the CCA contaminated soils. This process reduced the final waste stream by approximately 60%. Approximately 4,097 tons of CCA contamnated soil and sediment from the facility, school and homes were excavated and shipped off site to a regulated facility for disposal.
CCA contaminated sludges from the product tanks and frac tanks were stored and decanted in 55 gallon drums and roll-offs. Approximately 100 drums and 9 tons of bulk contaminated sludges were transported off site for disposal at a regulated facility.
The sump floor of the former tank area was pressure washed and treated with a waterproof epoxy paint to prevent short term leaching of collected rainwater. For safety issues, the doors to the steel pressure cylinder were welded shut.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
2.1.4 Progress Metrics
Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
CCA |
soil |
4,097 tons |
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off site |
CCA |
water |
80,294 gallons |
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off site |
CCA |
sludges |
9 tons |
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off site
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