NL Industries, Inc. (NL), selected ENTACT Environmental Services, LLC (ENTACT), as the principal contractor to conduct the removal action. The EPA completed a pre-mobilization walkthrough with the property owners and their legal representatives, NL and ENTACT personnel, on August 21, 2012. During the walkthrough, the scope and logistics of the removal action were discussed in detail. Parties playing a major role during the implementation of the time‐critical removal action were introduced. The following were present:
• Greg Dambold, ENTACT Project Coordinator
• Josh Carroll, ENTACT Field Project Manager
• Jenny Self, ENTACT Regulatory/Technical Specialist
• Kevin Lombardozzi, NL Industries Project Coordinator
• Richard DenHerder, Open Door Mission (ODM)
• Brad Stenslokken, ODM Maintenance Supervisor
• Morgan Holmes, Moweco, Inc.

On August 23, 2012, ENTACT mobilized equipment to the Site. Pre-construction video and photographs were taken to document pre-existing Site conditions. The haul route was established to the designated off-site disposal facility. Air monitoring locations were selected and approved by the EPA for time-integrated and real-time air monitoring stations.  Personnel, equipment and temporary facilities were mobilized to the Site.  Erosion, sedimentation and stormwater control measures were installed.  Work zones, equipment decontamination areas, material staging areas, and Site haul roads were delineated.  Utility locates were completed for identification of utility lines, including gas, electric, telephone fiber and wire, storm and sanitary sewers, water, and cable.  

Prior to the start of Removal activities, the limits of the Site were verified and established by a licensed
professional land surveyor. Specifically, the limits of the Site were based on the extent of impacted soil
identified during previous Site investigations to the nearest intact capped area such as a street, curb,
parking lot, asphalt, building foundation, or similar condition.

A coordinate grid system was established at the Site for excavation purposes. The Site was staked with
baselines and grids were established using a 50-foot by 50-foot or 25-foot by 25-foot grid length and
width. The elevation of the center of each grid was determined prior to the start of any soil excavation to
serve as the basis for the depth of soil excavation and backfill work. A map depicting the grid line
locations, elevation data and pre-excavation topography of the Site is presented in the final Removal Report.

Excavation was initiated at the Site on August 27, 2012. The major components of the Removal included the following:
• Excavation of exposed surface soils to a depth of 1 foot bgs in all areas that were not capped by
intact asphalt or concrete or covered by a current or historic building foundation or pad;
• Excavation of exposed surface soils to a depth of 2 feet bgs in a designated area of 14,000 square feet to facilitate future use for gardening by the property owners;
• Stabilization of excavated soils to render the soil non-hazardous and meet the required land
disposal restriction (LDR) treatment standards;
• Off-site transportation and disposal of stabilized soils in a permitted Subtitle D landfill; and
• Restoration of the excavated areas with either rock base, topsoil and/or asphalt.

Lead-impacted surface soils were excavated from the Site using a hydraulic excavator to a depth of 1 foot bgs in unpaved areas and a depth of 2 feet bgs from a 14,000 square foot area located in the center of the vacant lot. The location of this 14,000 square foot area was adjusted in the field based on requests from ODM and Moweco and was subsequently approved by the EPA. Excavated soil was gathered into 13 approximately 250 cubic yard stockpiles within the area of contamination (AOC) for treatment pending the results of characterization sampling. 

A survey of the post-excavation surface of the Site was completed by Olsson Associates to ensure the  maximum depth of excavation was reached in all areas during the TCRA. The presence or absence of fill
material at the bottom of each grid excavation was observed and noted by ENTACT. A copy of the post-excavation survey is included in the final Removal Report.

Excavated soil stockpiles were sampled for characterization purposes prior to treatment, with the exception of Stockpiles 12 and 13. Based on the characterization results for Stockpiles 1 through 11, Stockpiles 12 and 13 were assumed to require treatment and no characterization samples were collected. Characterization sampling consisted of the collection of one composite sample from each stockpile. The samples were submitted to TestAmerica Laboratories in Houston, Texas, for laboratory analysis of RCRA 8 metals using the toxicity characteristic leaching procedure (TCLP) instead of only TCLP lead. The results of characterization sampling indicated that lead was the only metal requiring treatment in order to render the soil non-hazardous and achieve the alternative LDR treatment standards for soil.

The soil stockpiles were treated with approximately 3% by weight of EnviroBlend 90/10, based on the
results of the treatability study discussed in the Laboratory Scale Treatability Study Report dated August
13, 2012, in order to achieve a concentration of less than 5 ppm TCLP lead. Each soil stockpile was mixed for a period of approximately 2.5 hours using a hydraulic excavator. At the conclusion of mixing, 2 post-treatment verification samples, i.e., 1 grab and 1 composite, were collected from each treated soil stockpile for laboratory analysis of TCLP RCRA 8 metals. Based on discussions with the EPA, mercury was dropped from the analyte list for Stockpiles 12 and 13. Upon the receipt of laboratory results which indicated that post-treatment verification TCLP lead concentrations were below 5 ppm, the soil was prepared for transport and off-site disposal at an approved Subtitle D disposal facility. Approximately 5,556 tons of soil from the Site were disposed as non-hazardous waste at the Butler County Landfill. A summary of the waste disposal information and copies of the completed waste manifests are included in the final Removal Report.

Characterization and post-treatment verification sampling was conducted in accordance with the
approved Workplan. The results of the characterization and post-treatment verification sampling are presented in the final Removal Report. No materials staged for off-site disposal were kept on-site for longer than 90 days.

At the completion of excavation, a demarcation layer, e.g., orange woven fabric, was placed at the base of the excavation to denote the presence of potential contamination at depths greater than that excavated. The excavation was then backfilled under dry conditions with 3/8 inch limestone screenings. The area west of the ODM fenceline in the vegetated swale was backfilled with topsoil. The 14,000 square foot area in the center of the vacant lot was backfilled from 1 to 2 feet bgs with 3/8 inch limestone screenings and from 0 to 1 foot bgs with topsoil, at the request of the property owners.

Approximately 25,966 square feet of asphalt was installed on ODM property, including 6 inches of new asphalt on previous gravel surfaces and 3 inches of asphalt cap on previous asphalt surfaces.  In November, 2012 ODM resurfaced an additional 20,000 square feet of low integrity asphalt in accordance with terms of the environmental covenant for the property.

A final topographic survey was performed to produce as-built drawings of the Site. The final as-built survey is included in the final Removal Report.

A post-removal inspection of the Site was completed with representatives from NL, the EPA, ENTACT, ODM, and Moweco. The purpose of the final inspection was to document completion of the Removal activities. All parties in attendance at the final inspection confirmed the completion of the Removal.

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

An Administrative Settlement Agreement and Order on Consent, CERCLA-07-2012-0053, was established between NL, the EPA and Moweco, Inc., effective August 7, 2012.  ODM is a property owner and provided access to complete the removal action as well as an Environmental Covenant for implementation of Post-Removal Site Controls.  Moweco filed a similar environmental covenant for the parcels under its ownership. 

2.1.4 Progress Metrics

The following waste quantities are accurate as of September 28, 2012, based on weigh tickets from the Butler County MSWLF disposal facility.  To date, 184 loads of waste soil have been transported for disposal.  A spreadsheet summarizing the disposal quantities is available for review in the supporting documents section of the project website: http://www.epaosc.org/formercarterwhite.

Belinda Young was the EPA Public Information Officer (PIO) assigned to this project. A public information fact sheet was developed by the PIO and distributed as follows:

(1) E-mailed to federal and state elected officials on July 26, 2012
(a) Senators Nelson and Johanns
(b) Congressman Terry
(c) State Senators Ashford, Cook, Council, Haar, Howard, Krist, Lathrop, Lautenbaugh, McCoy, Mello, Nelson, Nordquist, and Pirsch.

(2) E-mailed to local elected officials on July 26, 2012
Omaha Mayor and City Council

(3) Mailed to nearby businesses and residents on July 27, 2012

(4) Posted on the EPA R7 website on July 27, 2012

The Administrative Record was made available for public review after it was compiled and finalized by the EPA R7 Records Center staff at the following locations:

Omaha Public Libraries
Charles B. Washington Branch
2868 Ames Avenue
Omaha, Nebraska 68111
Phone: 402-444-4849

EPA Region 7 Records Center
10221 Renner Boulevard
Lenexa, Kansas 66219
Toll Free: 1-800-223-0425