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Refer to previous Polreps.
OSC Kelly tasked START to subcontract to have a property survey conducted to determine the property boundaries. The survey was completed in October 2008.
On December 1, 2008, an Action Memo was approved by EPA Region III to conduct a removal action at the site to remove and dispose of lead-contaminated soil. Subsequently, an Administrative Settlement and Order on Consent for Removal Response Action (Consent Order) between Norfolk Southern Railway Company (NSRC) and EPA Region III was signed on June 26, 2009. Under the consent order, NSRC agreed to conduct remediation of the site to include excavation of contaminated soil and off-site disposal. The clean up level for lead-contaminated soil was established as 400 parts per million (ppm).
NSRC submitted a draft Remedial Action Plan (RAP) to EPA in June, 2009. EPA reviewed the RAP and provided comments/concerns to NSRC. A revised RAP submitted to EPA on July 16, 2009, was subsequently approved.
OSC Kelly and the Office of Regional Counsel (ORC) obtained court-ordered access to the Old Athens Turnpike Site, because a portion of the site was not a part of NSRC property.
Contractors for NSRC commenced site preparatory operations on August 5, 2009. NSRC conducted sampling to delineate the horizontal and vertical limits of lead-contaminated soil to be excavated. Waste disposal profile samples were also collected. Analytical results indicated that fourteen of twenty six 625 sq. ft. grids will have to be excavated to depths ranging from 0.5 ft. to 3 ft. depths. Analytical results for the disposal profile samples indicated that the samples will have to be disposed of as hazardous waste.
Excavation of contaminated soil and transportation/disposal operations are scheduled to commence on September 24, 2009.
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