United States Environmental Protection Agency
Region IV
POLLUTION REPORT

Subject: 

See POLREP #1 for details.

1)  Approximately 2,500 gallons of CCA impacted water from the containment pit at Treatment Building B was pumped out, transported, and disposed of by Heritage.  Residual CCA-solution from the concrete sump area was removed using a high-pressure washer.  The Sump Area was excavated and backfilled with clean clay material.
2) Conducted air monitoring for particulates during demolition activities using Personal Data Rams (PDRs).
3) The concrete drip pad at Treatment Building B area was demolished and the subgrade materials were excavated from the former drip pad area.  A concrete crushing machine was mobilized to crush the concrete excavated from former drip pad area. Scrap metal rebar was removed from demolished concrete. Scrap metal rebar was screened for arsenic using an XRF instrument. A shearer was used to cut steel rebar for metals recycling. A berm was constructed around the perimeter of the drip pad and concrete sump areas.
4) The sloped area on the southeast side of the site (southeast bank) was excavated and backfilled with clean clay material. Approximate area of excavation was 100 feet long and 6 feet wide.
5) The drainage ditch along the railroad right-of-way located behind the former shop building was filled with additional rock to control erosion.
6) The excavation along the Holly Avenue right-of-way area was completed. Residential clean-up goal of 40 ppm arsenic at the surface was met for this right-of-way area. A building sewer from the former treatment plant was located about 2 feet below the ground surface in the right-of-way. An action level of 1,500 ppm arsenic at depth was calculated based on ingestion exposure pathway for an adult utility worker. Post excavation XRF screenings at the bottom of the excavation inside the drainage ditch showed an average arsenic level of 93 ppm.
7) The asphalt surfaces adjacent to Treatment Building B were found to exceed the industrial action level of 160 ppm for arsenic.  In these areas, the asphalt was removed; the subgrade was screened using an XRF and excavated, as necessary, to meet the industrial action level for arsenic.
8) Transportation and disposal of nonlisted soils was completed during the week of September 26, 2008.

1) Dispose of listed hazardous waste soils and debris.
2) Re-grade Treatment Plant B area, and establish ground cover via hydroseeding.
3) Place erosion control fabric over areas onsite exceeding 160 ppm As and cover with dense grade aggregate.

EPA's fund-lead removal activities are anticipated to be completed by 10/31/08.

The scope of EPA's removal action included excavation of soils both at the KY Wood Site, and at two off-site locations.  EPA considers that these removal activities have effectively mitigated immediate threats associated with potential exposures to arsenic-contaminated soil.

KDEP considers arsenic-containing soils at concentrations above a regional average background level of 13.12 ppm to be a threat to human health.  Several properties adjacent to the site exhibit arsenic at concentrations exceeding 13.12 ppm.   KDEP sent letters to neighborhood residents in September 2008, requesting permission to sample for arsenic in off-site areas.  KDEP is currently in the process of evaluating XRF data collected in residential areas within close proximity to the KY Wood Site.