See POLREP #5 for site description and background information.
Work was initially delayed beginning the week of June 8, 2009, while storm water from a large rain event was pumped into the two frac tanks. Waste removal operations continued throughout the week, and the first loads of hazardous liquids were collected from tanks SH-4 and OP-4. Samples were collected from each of 6 vacuum boxes and sent to AES laboratory for TCLP analysis due to requirements from Republic landfill. Per EPA requirements, a Winter Environmental employee or contractor remained on-site throughout the weekends of June 13 and June 20 to monitor the tanks containing wastes while a disposal decision was pending. TCLP analysis later showed that liquids in three vacuum boxes were nonhazardous and were sent off-site for disposal at Broadhurst Landfill on June 22 after approval by Republic Services; liquids in the three other boxes were found to exceed the TCLP limit for benzene so analytical information was sent to EQ for waste disposal profiling.
On June 10, drums from the containment area and warehouse were loaded onto a truck and transported off-site for disposal. On June 11, hazardous wastes from tanks T-7B, T-4, and T-5 were loaded into specialty tankers (segregated by waste streams) and transported off-site to Vickery Environmental in Ohio for disposal. A portion of the hazardous waste from tank T-6 was loaded onto a specialty tanker and transported off-site to Vickery Environmental on June 16; the remaining portion was sent off-site on June 30.
On June 22, approximately 40,000 gallons of rainwater was discharged to the Waycross WWTP from two frac tanks. Decontamination activities continued throughout the week and wash water was collected and transported off-site to the Broadhurst Landfill for solidification and disposal.
During the week of June 29, decontamination activities continued and four vacuum boxes of wash water was collected and transported off-site for solidification and disposal. A total of three vacuum boxes and one specialty tanker transported wastes that had been identified as hazardous off-site for disposal at Vickery Environmental in Ohio.
During the week of July 6, hazardous waste from tank OP-4 was placed into a series of 5 vacuum boxes and transported off-site to EQ-Michigan for treatment and disposal. Closure of tanks began per guidelines provided by 40 CFR Part 112.2 and OSC direction (see POLREP #7). Large holes were cut into fiberglass and polymer tanks to prevent rainwater accumulation or reuse. A large portion of the underside was cut out from open-top conical-bottom tanks to prevent rainwater accumulation or reuse. Sheet metal was tack welded over access ports that had been cut into closed-top vertical and horizontal tanks, and seams around the sheet metal were tarred to prevent water infiltration.
During the week of July 13, hazardous waste was removed from 3 tanks and placed into a series of 8 vacuum boxes the transported off-site to EQ-Michigan for treatment and disposal. Decontamination activities continued throughout the week, including neutralization of acidic and caustic residues from several tanks. Tank closure activities also continued throughout the week.
During the weeks of July 20 and July 27, site closeout and decontamination procedures were completed. Sheet metal covers were completed over all metal tanks (included tack welding to secure and tarring to prevent infiltration), remaining pipes were vacuumed, pipes were disconnected from tanks and flywheels were removed from valves, closed metal tanks were labeled “permanently closed container” (all other tanks were either laid on their sides or cut open to prevent accumulation), the secondary containment area and sumps were pressure washed, and grates over sumps were securely fastened. Residuals in tanks containing corrosives (T-4, T-5, T-6 and T-7B) were neutralized and decontaminated; wash water was collected in vacuum boxes and transported off-site to the Broadhurst Landfill for solidification and disposal. From July 23 to 24, approximately 40,000 gallons of rainwater was discharged to the Waycross WWTP from two frac tanks.
OSC Huyser visited the site on July 21 and 22 to oversee closeout conditions and confirmed that they met the objectives set forth in the work plan as well as objectives in documented discussions between EPA and Winter Environmental over the course of the removal action. START visited the site on July 27 and 28 to document site closeout conditions for a final report. Winter Environmental demobilized all personnel and equipment from the site on July 28.
- Implementation of the OSC-approved removal action in accordance with the schedule and requirements of a Removal Action Work Plan (COMPLETE);
- Removal of waste material from all tanks, drums, and other containers on the Site, as well as from the secondary containment area (COMPLETE);
- Decontamination and/or disposal of all tanks, drums, and other containers on the Site, as well as decontamination of the secondary containment area (COMPLETE); and
- Disposal of the waste material removed from the Site, including any sampling and analysis necessary to determine proper treatment and disposal methods (COMPLETE).
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