2.2.1 Anticipated Activities
Planned removal activities on-site include:
a) Developing and implementing a site-specific Health and Safety Plan, including an Air Monitoring Plan, and a site Emergency Contingency Plan;
b) Developing and implementing a Site Work Plan that includes a Site Security Plan;
c) Securing, characterizing, and sampling known and suspected hazardous substances, contained or uncontained, at the site;
d) Consolidating and packaging hazardous substances, pollutants and contaminants for transportation and off-site disposal;
e) Decontaminating contaminated structures as necessary;
f) Transporting and disposing of all characterized or identified hazardous substances, pollutants, wastes, or contaminants that pose a substantial threat of release (except NORM) at a Resource Conservation and Recovery Act/CERCLA-approved disposal facility in accordance with EPA’s Off-site Rule (40 C.F.R. § 300.440), as applicable;
g) Removing and reusing or disposing of NORM in accordance with CERCLA and with all applicable state regulations; and
h) Taking any other response actions to address any release or threatened release of a hazardous substance, pollutant and contaminant that the U.S. EPA OSC determines may pose an imminent and substantial endangerment to the public health or the environment.
Additional site activities may include security, perimeter air monitoring, and decontamination on the site, as needed to complete the removal action.
2.2.1.1 Planned Response Activities
Please see above.
2.2.1.2 Next Steps
Over the next few weeks, we will work offsite to coordinate disposal of staged waste. As soon as disposal has been coordinated, we will return to site, and ship the staged waste for proper disposal. We anticipate that disposal will be fully arranged in mid-February.
When
we return in February, we will also properly dispose of the metal shavings pile
that has combusted, the empty drums and small containers, the rolloff(s) – 1 or 2 pending analytical
results, the asbestos waste that is outside in the center of the site, and
other hazardous substances as necessary.
EPA’s
Health Physicist anticipates returning to the site the week of 1/20/14 to
collect and properly dispose of the radium source from the roundhouse.
First
Energy has taken 6 pole mounted transformers offsite, and anticipates returning
next week to remove and properly dispose of the ground level transformer.
While
we are off site, our technical contractor will visit the site weekly
to verify that the site and the wastes are still secure. OEPA
will also do periodic inspections over that period as well.
Keys
to the buildings and the gate have been left with the Ashtabula Fire Chief, and
OEPA in case of emergency.
2.2.2 Issues
None.
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