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LWD, Inc.

All POLREP's for this site LWD, Inc.
Calvert City, KY - EPA Region IV
POLREP #8
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On-Scene Coordinator - Steve Spurlin 10/7/2006
Time-Critical - Removal Action Pollution Report (POLREP) #8
Start Date: 3/2/2006
Pollution Report (POLREP) #8
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 wastewater treatment system (WWT) was resumed September 6, 2006.  Approximately 597,000 gallons have been treated by the WWT system.  Treated water is being used for decontamination operations and/or being land applied. the cutting up roll-offs bgan on September 19, 2006 using a Komatsu PC 200 LC with a shear attachment.  Metal pieces were decontaminated and placed in a trailer for recycling at a scrap facility using a Caterpillar 320C L with a grappler attachment.  Approximately 82 tons of metal has been recycled to date. Mechanical demolition of piping, valves, and pumps within the containment areas is being continued.  Piping is being cut into manageable pieces; pumps and valves are being disassembled; and all components are being decontaminated prior to being placed in a trailer for recycling at a scrap facility. There was 26,800 gallons of hazardous waste liquids transported to an off-site incinerator for disposal.  To date there has been 50,355 gallons of hazardous waste liquids transported to an off-site incinerator for disposal.  Samples from storage tanks continue to be taken as needed for characterization purposes.



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

The mechanical demolition of piping, valves, and pumps will be continued.  The cutting up of roll-offs will be continued.  Demolition of piping and valves on the two caustic towers will be continued.  Transportation and disposal of on-site hazardous waste will be continued.  

There are approximately 300 drums and containers that remain onsite, both inside the incinerator building and the drum storage warehouse.  To prevent spill migration, all drums will continue to be checked daily for leaks and bulges and will be over-packed as necessary.  All of the drums and containers will also be staged in the drum storage building and samples will be taken to determine the hazard characterization of the waste for future bulking and disposal.


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

Preperations will continue so that the NTF can be completely dismantled along with the two caustic towers.  This process will begin as soon as the liquid hazardous waste in tanks in the NTF have been removed.  The sludges in the tanks will be removed and staged for characterization and disposal. The tanks will then be cut up, decontaminated, and the steel will be recycled  

The south sump area, in the rolloff staging area, has been bermed and will continue to be the location for cutting and cleaning of the rolloff boxes.

The approximately 300 drums and containers will be staged in the drum storage building and the waste will be characterized for future bulking and disposal.


Key Issues
Weather continues to pose problems at the Site.  Electrical storms and/or heavy rains causes delays or suspension of work.  A severe rain event occurred between 9/22-24/06 that dropped approximately 10" of water on the site.  This greatly impacted the wastewater treatment system with an increased volume of water to be processed.