See POLREP 1 for details.
Container over pack operations have been completed. All chemical products have been containerized for transportation and disposal. A total of fifty-one (51) 55 gallon drums of product, ninety-five (95) product containers less than 55 gallon in size, and 23 bags of dry chemical have been over packed or re-containerized.
Clean-out of the underground settling tank was completed as of 12/7/06. A total of 2,849 gallons of liquid was removed via vacuum truck and shipped for disposal to Vickery Environmental, Inc. in Vickery, Ohio. The liquid was shipped as an F006 waste and was hazardous for lead and cadmium.
Sludge was removed from the tank during the week of 12/4/06. The tank interior was then pressure washed with hot water. All inlet/outlet piping was flushed as feasible. All sludges and rinse water were placed into 55 gallon drums. A total of 30 drums of sludge and 9 drums of rinse water were generated from this operation and have been transferred to the off-site staging area. Solids removal from the plating vats has been completed as of December 21, 2006. A total of fifteen (15) 55 gallon drums of chemical residues were generated from the vat cleaning operation.
Empty product containers are being cut up as needed and staged until disposal can be effected. All empty containers 55 gallon and less have been processed. Cutting up of the empty vats was initiated on 12/18/06 and will be performed as feasible pending other work. A total of 3 polypropylene vats have been cut-up to date.
The wood plank flooring has been removed from the plating shop floor and staged on-site for disposal. Chemical residues found beneath the planking have been removed from the floor as feasible and containerized per hazard categorization. Debris that has been encountered underneath the flooring is also being cleaned up and staged on-site. Wood plank flooring, the plating vats and other debris will be direct-loaded into a roll-off container as soon as the T&D plans have been finalized.
A total of 157 over pack drums and 2 five gallon lab packs have been generated during clean-up operations and transported to the temporary off-site staging area. Some of these include waste water generated during cleaning and equipment decontamination operations. All over pack/lab pack containers are being stored in Con-Ex boxes at the off-site location until T&D can be affected. Emergency contact information and Con-Ex inventories have been provided to township officials and emergency services personnel as a precautionary measure. Site security personnel conduct regular visits to the temporary storage area to guard against vandalism.
Sampling for disposal analysis has been completed for all chemical products, chemical residues, rinse water and contaminated debris. A total of 21 waste samples have been submitted for analysis to date. A portion of the analytical results have been received; the remaining data is anticipated to be received during the week of December 26, 2006.
The first phase of environmental sampling was initiated on 12/7/06. A jack hammer was used to open two locations in the concrete floor of the outdoor settling tank to allow sampling of the subsoil beneath. A third soil sample was collected from the tank overflow discharge point where stressed vegetation had been observed. Two additional soil samples were collected at the base of heavily stained concrete along the plating shop foundation walls. Soil samples are being analyzed for priority pollutant metals, cyanide, hexa-valent chromium and TCL organics.
Concrete core samples were collected from the concrete settling tank and two heavily stained sections of the plating shop foundation walls on 12/14/06. A total of 5 concrete samples were collected from the settling tank walls and floors. Two samples were collected from the plating shop foundation wall. Samples are being analyzed for Priority Pollutant (PP) metals and hexa-valent chromium. Analytical results will be used to evaluate the nature and extent of contamination in these areas and determine the need for further remediation.
The currently planned removal actions include the following:
• Transportation and disposal of all chemical wastes on-site; • Removal and disposal of all tanks and vats; • Disposal of contaminated wood plank flooring and debris; • Pressure washing of the concrete slab floors and walls inside the plating shop; • Collection of investigatory samples from the plating shop walls, floors and the subsurface soils beneath; • Site restoration activities as required.
The site is being temporarily de-mobed on 12/22/06 for the holidays. Security services will be retained for the period. Site activities will resume on 1/8/06. The anticipated next steps include:
• Initiate waste shipments during the week of 12/8/06. • Complete the removal of the plating vats and prepare for disposal. • Prepare the interior of the plating shop for decontamination operations. • Develop a comprehensive site sampling plan to evaluate the effectiveness of the building floor decontamination and determine the nature and extent of contamination in site soils.
The Town of Mentz has provided EPA with a temporary storage area since there is limited room on the site that would be adequate for drum storage. All liquid drums are being over-packed and stored in Con-Ex boxes at the temporary storage site until transportation and disposal of the materials can be executed. The appropriate NYSDEC and EPA RCRA Division personnel have been notified of the temporary storage plans and are in concurrence with the plan.
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