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2.1.2 Response Actions to Date
WGE has submitted requested change in contractor. Memo can be found here: Contractor Change Document
From 02-28-2011 through 03-01-2011, restricted areas were barricaded in the warehouse. Floors in these areas were covered with paper flooring to prevent dust migration. These restricted areas were decontaminated for lead using Trisodium phosphate (1/2 cup per 1-gallon of water). The floors were scrubbed using wire brushes. XRF screenings were conducted after each area was scrubbed.
At the north end of the warehouse, a sealent prevented decontamination on the flooring. Grinding away two layers of concrete were necessary to sufficiently decontaminate the area. Additional barricades were constructed to prevent spreading dust generated during grinding. Workers wore level C personal protective equipment and a High Efficiency Particulate Air (HEPA) vacuum was used to contain the dust from grinding.
During decontamination, ambient air monitoring was performed with GilAir sampling pumps. Filters are being analyzed for lead. In addition, waste waters generated during decontamination are stored in 55-gallon drums and labeled appropriately for future disposal.
XRF screening levels for lead below 400 ppm are considered decontaminated. Superfund Technical Assistance and Response Team (START) and PRP contractors conducted XRF screenings. After completing decontamination, cleaned areas were sealed with poly to prevent future contamination.
On 03-28-2011:
- WGE began decontamination of the area between the restroom and the shared pathway designated Area A (Warehouse Decontamination Map). Built containment to contain dust, water and conduct air monitoring activities.
- PRP's contractor started decontamination of area between bathroom and shared pathway, washed with vinegar, and scrubbed with wire brush, vacuumed all water and contained in a 55 gallon drum with lead hazard stickers. A tavasco grinder was used on the floor, all dust vacuumed and contained in a contractor bag with lead hazard stickers, and placed into a 55 gallon drum. The floor was washed with vinegar to complete decontamination procedures.
- Workers wore level C personal protective equipment and a HEPA vacuum was used to contain the dust from grinding.
On 03-31-2011 through 04-01-2011:
- WGE marked 2 ft by 2 ft grids and conducted XRF readings. START collected confirmation XRF readings. Any readings above 400 ppm were additionally decontaminated and re-screened. All areas in Area A were decontaminated to below 400 ppm (Warehouse Decontamination Map).
On 04-04-2011through 04-01-2011:
- WGE began decontamination of designated Area B (Warehouse Decontamination Map). WGE began decontamination of the walls, steel beams, insulation and ceiling. START collected confirmation XRF readings. Readings were above 400 ppm. As such START conducted wipe sampling at several locations. The locations were below 400 ppm.
On 04-12-2011 through 04-25-2011:
- WGE continued with decontamination of Area B. WGE has completed cleaning the ceiling, walls and side insulation panels (between the top of the building walls and below the roof line).
- START conducted wipe sampling at several locations along the insulation panels. The wipe samples were screened using the XRF. Readings were below 400 ppm.
On 04-26-2011 through 05-16-2011:
- WGE continued with decontamination of Area B. WGE has completed cleaning the walls and steel support beams.
- WGE also completed decontamination of the floor and will mark 2 ft by 2 ft grids and conduct XRF readings.
- WGE will also conduct wipe sampling for XRF screening along the walls and steel support beams.
- During the week of 05-16-2011 START will verify XRF readings.
On 05-17-2011 through 05-19-2011:
- WGE completed decontamination of Area B. START verified WGE XRF results on the floor, walls and support beams. All verified XRF results were below below 400 ppm. Contractor Daily Progress Reports (DPRs) can be found in the documents section.
On 05-23-2011 through 06-20-2011:
- WGE also began working on Area C of the warehouse floor, clearing equipment and miscellaneous items.
On 06-21-2011 through 07-11-2011:
- WGE continued working on Area C of the warehouse floor, clearing equipment and miscellaneous items.
On 07-11-2011 through 08-20-11:
- WGE continued working on Area C of the warehouse floor, clearing equipment and miscellaneous items.
- Items that could not be decontaminated were placed in plastic shrink wrap and containerized for future disposal.
On 08-21-11:
- WGE indicated the building warehouse is approximately 80%-90% complete. WGE is in the process of moving impacted material to the Belton facility for future disposal.
On 08-22-11 through 10-28-11:
- WGE continued working on Area C of the warehouse which included cleaning the floor, walls and ceiling. Additional man hours was needed to clear fthe floor, walls, ceiling and miscellaneous items.
- On 10-21-11, WGE received an EPA Generator Identification Number (SCR000773127).
- WGE transported lead impacted materials generated from the Palmetto site activities to the Belton facility for future disposal.
- WGE indicated that the project is approximately 95% complete. WGE has also indicated that the remaining areas will be completed by 11-04-11.
- WGE will submit the Palmetto Site Closeout Report 30 days following the completion date.
The following environmental actions have been completed:
1. START conducted daily visual inspection of the paper/plastic floor covering and barricades for integrity purposes.
2. START conducted reconnaissance of the decontamination process and conducted confirmation screening of the PRP's contractor data during the screening of the floor path area (loading docks and walk paths).
3. START conducted reconnaissance of the decontamination process and conducted confirmation screening of the PRP's contractor data in the area designated Area A (Warehouse Decontamination Map).
4. START conducted reconnaissance of the decontamination process and conducted confirmation screening of the PRP's contractor data in the area designated Area B (Warehouse Decontamination Map).
5. WGE has completed site activities and submitted the report documenting completion of field activities.
6. The conditions of the order have been completed.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
An Access Agreement has been secured and NOFI CERCLA Cost Recovery and Legal support have been initiated. PRPs have been identified. The signed AOC and Enforcement Action Memorandum was submitted as final on 05-12-2011 (Action Memo).
On 06-29-12, the completion report has been reviewed and approved by the EPA OSC (WGE Palmetto Final Report).
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