Pollution Report Profile - EPA OSC Response

Stoney Creek Technologies
Trainer, PA - EPA Region III
POLREP #24 - Continuing Removal Action - Action Memo Approva

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On-Scene Coordinator - Mike Towle	8/11/2010
Emergency - Removal Action	Pollution Report (POLREP) #24
Start Date: 4/19/2007

Site Description
See previous POLREPs for Site description information.

Neither Stoney Creek Technologies nor any other Respondent to EPA's Orders or Potentially Responsible Party is conducting response actions due to bankruptcy, financial inability, or other reasons; therefore, EPA continues to use its own contractor resources to conduct response actions at the Site.

The OSC continues to estimate that the remaining chemical inventory within the tanks at the Site is approximately 200,000 gallons and consists primarily of lower viscosity materials and tank heels in about 80 tanks. The START contractor is currently completing a final characterization of remaining tank residuals.

An Action Memo which increased the funding to $11,281,585 and modified the scope to include final cleanup activities was approved by EPA on August 3, 2010.

Current Activities
The START contractor completed an evaluation of all tanks at the Site to determine material volume, consistency, and vapor issues in order to allow the OSC to scope and prioritize remaining response actions.

EPA contractors have continued and still continue to break and drain lines and equipment and process vessels containing chemical inventory.  Additional leaks were discovered at the Site including a leaking flange at the D-104 sulfonator.  About 30 gallons of acid was drained from this system.  Excessive heat is expected to blame for the increased number of leaks discovered in July and August.  Operations have included steaming of limited pipe segments, the OSC has directed that decontamination waters generated by the operation are stored in Tank 460.

The ERRS contractor is preparing to remove and neutralize remaining oleum sludge located in T-105.

The OSC has noticed an increased amount of oily material migrating into the Site drainage system from the railroad tracks.  On 07/09/2010 and 7/12/2010, black oily material migrated into the trench system.  The OSC instructed ERRS to remove the oil.

Significant rain events occurred on 7/13/10 and 7/14/10. No off-Site releases occurred from the on-Site waste water treatment plant during these events (despite the overflow of the system on 7/14). However, a minor amount of oil was observed in the street discharging from the sidewalk after the 7/14 rain event.

After the 7/13 rain event, the rain water leaking from the oleum dike was found to have a pH of 1.

The OSC directed ERRS to drain the material from T-229; a thick resin material (Beckosol).  To date 38 drums have been generated.

Approximately 2,540 gallons of material was removed and disposed from Tank 672.

ERRS began to remove chemical materials from the trench system alongside the alkylate storage tanks.

On August 3. 2010, Region III received approval to raise the removal project ceiling to $11,281,585 and to modify the scope of the removal action.  The new scope will include activities intended to remove all residuals from the Site and allow for cessation of the need for treatment of the water migrating through the Site.  The OSC is now evaluating and prioritizing new scope implementation.

The OSC is coordinating with EPA Pre-Remedial personnel presently evaluating the Site for possible NPL listing.

Planned Removal Actions
Treat (neutralize) oleum sludge and complete off-Site disposal of drummed wastes.

Evaluate next steps for wastes within roll off boxes and within the trenches and drains leading to the waste water treatment plant. Additionally, evaluate priorities for response actions to address the remaining wastes within tanks (e.g., low viscosity materials and tank heels).

Continue to clear pipelines of remaining chemical inventory, consolidate and prepare materials for disposal.

Continue to monitor, treat, and discharge excess waters from the Site into Stoney Creek and prevent oily material from migrating from the Site into Stoney Creek via discharges onto the adjacent public roadway.

Next Steps
Prioritize remaining removal actions and coordinate with Pre-Remedial regarding possible NPL listing.

Disposition Of Wastes
Disposal activities include disposal from individual tanks, tank consolidations, and a variety of drums. Single manifests may include wastes from multiple sources. Wastes are primarily disposed as corrosive (acids and caustics), flammable (items containing solvents), and non hazardous (primarily oil-based materials).

Waste Stream	Quantity	Manifest #	Disposal Facility
T-132	22,200 gal.	various (D002)	Vickery Env. Inc., Vickery, OH
T-134	7,900 gal.	various (D002)	Vickery Env. Inc., Vickery, OH
T-171	22,363 gal.	various (D001)	Clean Harbors, Baltimore, MD
T-172	13,816 gal.	various (D001)	Clean Harbors, Baltimore, MD
T-174	3,8000 gal.	various (D001, D002)	Clean Harbors, Baltimore, MD
T-174	42,464 gal.	various (D001)	Clean Harbors, Baltimore, MD
T-176	35,621 gal.	various (D001)	Clean Harbors, Baltimore, MD
T-198	3,960 gal.	various (Non-Haz)	FCC Environmental, Wilmington, DE
T-201	10,742 gal.	various (D001)	Clean Harbors, Baltimore, MD
T-337	11,190 gal.	various (Non-Haz)	Env. Recycling Corp., Lancaster, PA
T-340	19,967 gal.	various (Non-Haz)	FCC Environmental, Wilmington, DE
T-401	5,000 gal.	various (D001, D002, D003)	Clean Harbors, El Dorado, AR
T-406	24,375 gal.	various (D001)	Heritage WTI, East Liverpool, OH
T-407	14,892 gal.	various (D001, D002)	Clean Harbors, Baltimore, MD
T-411	12,776 gal.	various (D001)	Clean Harbors, Baltimore, MD
T-420	10,004 gal.	various (D001)	Casie Protank, Vineland, NJ
T-421	9,010 gal.	various (D001)	Casie Protank, Vineland, NJ
T-422	7,661 gal.	various (D001)	Clean Harbors, Baltimore, MD
T-424	8,638 gal.	various (Non-Haz.)	FCC Environmental, Wilmington, DE
T-425	8,450 gal.	various (D001)	Clean Harbors, Baltimore, MD
T-431A	32,631 gal.	various (D001, D002, D003)	Clean Harbors, El Dorado, AR
T-437	23,470 gal.	various (D001, D002)	Clean Harbors, Baltimore, MD
T-495	3,701 gal.	various (D001)	Clean Harbors, Baltimore, MD
T-521	16,667 gal.	various (Non-Haz.)	Env. Recycling Corp., Lancaster, PA
T-525 (Mar. 09)	69,561 gal.	various (Non-Haz.)	FCC Environmental, Wilmington, DE
T-525 (Jan. 10)	45,050 gal.	various (sludge)	Republic, Hatfield, PA and Veolia ES Greentree, Kersey, PA
T-526 (Mar. 09)	46,592 gal.	various (Non-Haz.)	FCC Environmental, Wilmington, DE
T-526 (Jan. 10)	30,340 gal.	various (sludge)	Republic, Hatfield, PA
T-527 (tank bottom)	7,775 gal.	various (D001)	Clean Harbors, Baltimore, MD
T-527 (tank top)	10,287 gal.	various (Non-Haz.)	FCC Environmental, WIlmington, DE
T-539 (Feb. 09)	19,354 gal.	various (Non-Haz.)	Env. Recycling Corp., Lancaster, PA
T-539 (Oct. 09)	22,625 gal.	various (D001)	Clean Harbors, Baltimore, MD
T-640	34,208 gal.	various (Non-Haz.)	FCC Environmental, Wilmington, DE
T-641	30,609 gal.	various (Non-Haz.)	FCC Environmental, Wilmington, DE
T-660	30,750 gal.	various (D001)	Clean Harbors, Baltimore, MD
T-661	21,264 gal.	various (Non-Haz.)	Env. Recycling Corp., Lancaster, PA
T-663	41,010 gal.	various (Non-Haz.)	FCC Environmental, Wilmington, DE
T-680	17,013 gal.	various (Non-Haz.)	FCC Environmental, Wilmington, DE
T-681	20,339 gal.	various (Non-Haz.)	FCC Environmental, Wilmington, DE
T-105	12,608 gal.	various (D002)	Vickery Environmental, Vickery, OH