The LWD facility is a former hazardous waste incinerator that began operation in the early 1970's and received it's last shipment of hazwaste in early 2003. The site was referred to ERRB via the State of Kentucky for possible removal action in February 2006. Upon review of the facility, the OSC noticed that the containment area surrounding a tank farm on the north end of the facility was becoming full of collecting rainwater. The rainwater was mixing with oils and other chemicals in the containment area to produce a hazardous waste. At the time of inspection, the waste was approximately 4' deep and only 3' from overtopping the containment area walls. An emergency response was initiated to address the tank farm. The emergency response soon turned into a time critical removal action due to the wastewater and hazardous waste that was found on the site. While the site stabalization was proceding, EPA would seek to negotiate with potentially responsible parties (PRPs) to take over the removal actions at the site.
The following activities took place during the Fund-lead Performance Period:
Water/sludge was removed from the secondary containment of the tank farm located north of the incinerator building as part of the emergency response activities. Water/sludge was placed into frac tanks to be held until disposal/treatment.
A wastewater treatment system was constructed on-site to treat the accumulated rainwater (frac tanks and roll-off boxes). The system utilized sand units, a 1.5 micron sock filter unit, and carbon cells. Operation of the wastewater treatment system (WWT) treated approximately 950,000 gallons of contaminated water. The treated water was sampled and lab analyzed every 100,000 gallons. Treated water was used for decontamination operations and/or was land applied. Five roll-off boxes of spent carbon/sand generated by the water treatment system are located on-site awaiting characterization/disposal.
The 15 above-ground storage tanks (ASTs) located north of the incinerator building were emptied and removed. Material removed from the ASTs was placed into frac tanks (liquids) and roll-off boxes (sludge) for storage until disposal. During the Fund-lead performance period, over 135,000 gallons of hazardous waste removed from these ASTs was transported off-site to approved waste disposal facilities. Scrap metal from the tanks was deconned on-site and taken away for recycling.
A total of 221 drums/totes were identified on-site that required hazard categorization prior to removal from the site. These drums/totes were staged in the drum storage warehouse, HazCat samples were collected/analyzed for compatibility, and drums were placed into compatible wastestreams. After HazCat activities were performed, 108 drums were blended/bulked into roll-off boxes on-site. Once the material was thoroughly blended, this material in the roll-off boxes was placed into a frac tank to be held until disposal. A total of 113 drums remain on-site to be blended/disposed by the potentially responsible party (PRP) group.
On March 24, 2007, EPA's ERRS contractor demobed from the site turning over all removal activities to the PRP Group's contractors. EPA and START remain on site to provide over-sight of the PRP lead removal actions.
The PRP group's contractors took control of site activities on March 25. At this time, wastewater treatment will continue under the PRP's contractor control. Collected wastewater will continue to be treated and activities aimed at removing the remaining hazardous waste from the site will continue.
Upon PRP Group site takeover, the following carryover items will remain to be addressed:
- Characterization and removal/disposal of two caustic tanks;
- Characterization and blending/disposal of 113 drums of waste;
- Lab packing of miscellaneous wastes located throughout the site;
- Cleanup/disposal of materials still contained in the on-site vac trucks and tanker trailers;
- Continued operation of water treatment system for treatment of on-site water;
- Characterization and removal/disposal of two roll-off boxes of floc material from water treatment activities;
- Characterization and removal/disposal of five roll-off boxes containing spent carbon/sand from the water treatment system;
- Characterization and removal/disposal of three roll-off boxes and the barge tank containing sludge material from the ASTs; and,
- Characterization and removal/disposal of numerous roll-off boxes containing miscellaneous debris and ash located throughout the site.
- Demolition of incinerators and building with disposal of all associated waste and debris.
Unilateral Administrative Orders (UAOs) to cleanup the Site were sent to BIS, Robert Kattula, K&B, and Glen O'Connell. None of the parties complied with the UAO.
On February 28, 2007, 58 Potentially Responsible Parties (PRPs) entered into an Administrative Settlement Agreement and Order on Consent (AOC) with EPA to perform a time-critical removal action at the Site and to pay EPA's Future Response Costs.
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A total of 24 waste Shipments of Class 9, NA3082 (D018,P022,F002,D001,D021,P056,U037,U019,U165) waste to Veolia ES Technical Solutions in Port Aurther, Texas from 7/31/06 to 12/14/06 totaled 112,441 gallons/468.3 tons of hazardous material. Certificates of disposal were received for each shipment.
A total of 5 waste shipments of Class 9 NA3082 (D008,P020,D021) waste to Ross Incineration Services, Inc. in Grafton, Ohio from 10/4/06 to 10/17/06 totaled 22,740 gallons/100.0 tons of hazardous material. Certificates of disposal have not been received for these shipments.
A total of 17 scrap metal shipments from 9/18/06 to 12/5/06 totaled 207.81 tons.
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