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LWD, Inc.

All POLREP's for this site LWD, Inc.
Calvert City, KY - EPA Region IV
POLREP #6
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On-Scene Coordinator - Steve Spurlin 7/12/2006
Time-Critical - Removal Action Pollution Report (POLREP) #6
Start Date: 3/2/2006
Pollution Report (POLREP) #6
Site Description
Please refer to previous POLREPs for site description and previous actions taken.

Current Activities
The following activities took place during the reporting period:

Operation of the WWT continued during this period.  As stated in POLREP #5, all of the rolloff boxes were pumped down, except for two which will need offsite disposal.  Currently, ERRS crews have been in the process of pumping out the frac tanks that were used in the initial response to the site to pump out the containment area surrounding the north tank farm (NTF).  To date, 5 of 9 frac tanks have been pumped out, cleaned, and demobilized from the Site.  The remaining 4 will remain onsite to aid in future pumping operations at the NTF.  To date, approximately 300,000 gal of water have been treated.  The carbon in the WWT was washed.  This will extend the life of the carbon as well as make the treatment process more efficient.


Planned Removal Actions
The following activities are planned during the next reporting period:

Next week, the EPA OSC will be meeting with a representative from the Bureau of Reclamation (BOR) on site.  BOR will be assisting the OSC in providing consistent site coverage as well as act as a technical specialist on certain demolition activities that will be occurring on-site in the future.  This will utilize an Inter-Agency Agreement (IAG) with BOR.

Also next week, ERRS will begin to remove the pipe manifold from around the tanks in the NTF.  Once that is completed, the tanks themselves can be pumped out, product disposed of, cleaned, and scraped.  Of the 15 tanks in the NTF, 5 can be treated via the onsite WWT with the other 10 needing to be disposed of offsite.

The final task that will take place during the next reporting period will be the over-packing of several leaking and/or bulging drums remaining onsite.  There are approximately 50 to 75 drums remaining onsite, both inside the incinerator building and the drum storage warehouse.  To prevent spill migration, all drums that appear to be in poor condition or have already begun to leak will be over-packed.


Next Steps
The following have been identified as next steps in the stabilization phase of this removal action:

-  The south sump area in the rolloff staging area will be bermed and will become the location for cutting and cleaning of the rolloff boxes. This process will begin once the NTF is in the stage where the tanks can be removed.  This is so that the shears will only need to be mobilized to site once.
-  The carbon in the WWT will be replaced in the next month or so.
-  The two caustic towers will also be removed.


Key Issues
Weather continues to pose problems at the Site.  Rain causes additional water to get into the treatment system and it adds water on top of the water we are currently discharging on the landfill.  Also, we are entering the summer months and the higher temperatures can cause heat stress and will limit the amount of time crews can work in PPE.