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LWD, Inc.

All POLREP's for this site LWD, Inc.
Calvert City, KY - EPA Region IV
POLREP #10
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On-Scene Coordinator - Steve Spurlin 12/1/2006
Time-Critical - Removal Action Pollution Report (POLREP) #10
Start Date: 3/2/2006
Pollution Report (POLREP) #10
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 performed throughout this period.  Approximately 784,000 gallons have been treated by the WWT system.  Treated water is being used for decontamination operations and/or being land applied. The cutting up of roll-offs was continued using a Komatsu PC 200 LC with a shear attachment.  Completed dismantling and cutting up tanks located in the North Tank Farm (NTF).  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 48 tons of metal was recycled with approximately 207 tons having been recycled to date. Completed mechanical demolition of piping, valves, and pumps within the containment areas .  The piping was cut into manageable pieces; pumps and valves were disassembled; and all components were decontaminated prior to being placed in a trailer for recycling at a scrap facility. There was approximately 9,600 gallons of hazardous waste liquids transported to an off-site incinerator for disposal during this period of time.  To date there has been approximately 106,900 gallons of hazardous waste liquids transported to an off-site incinerator for disposal.  A Komatsu 138US LC with a rotating drum grappler was used to bulk the contents of 206 drums (various sizes) and 13 totes (various sizes) into the different waste streams.  These bulked chemicals will be sampled to establish a waste profile for disposal.  Samples from storage tanks continue to be taken as needed for characterization purposes.

ERRS contractor demobilized the site on November 18, 2006 for the Thanksgiving holiday.  Mobilization back to the site was on November 27, 2006.



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

Neutralization of the caustic tower contents in preparation for disposal.  Transportation and disposal of on-site hazardous waste will be continued.  

Containers of paint remain on site inside the drum storage warehouse.  To prevent spill migration, all containers will continue to be checked for leaks and bulges and will be over-packed as necessary.

Waste water treatment will be continued.



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

The waste in the caustic tanks will be neutralized, removed, and staged for characterization and disposal. Collected wastewater will continue to be treated. The tentative schedule is to shutdown the site before Christmas for a short winter break.  24-hour security will continue to be provided.


Key Issues
Weather continues to pose problems at the Site.  Heavy rains causes delays or suspension of work and impacts to the wastewater treatment system with an increased volume of water to be processed.  The arrival of colder weather requires more time at end of each day to winterize the pumps and hoses to prevent them from freezing up.