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LWD, Inc.

All POLREP's for this site LWD, Inc.
Calvert City, KY - EPA Region IV
POLREP #15
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On-Scene Coordinator - Steve Spurlin 5/7/2007
Time-Critical - Removal Action Pollution Report (POLREP) #15
Start Date: 3/2/2006
Pollution Report (POLREP) #15
Site Description
Please refer to previous POLREPs for site description and previous actions taken.

Current Activities
The following activities took place during the PRP-lead Performance Period:

Operation of the wastewater treatment system (WWT) was performed throughout this period.  Approximately 170,000 gallons have been treated by the WWT system during this performance period.  Treated water is being used for decontamination operations and/or being land applied.  During this performance period approximately 119,000 gallons of water have been land applied.  The on-site vac trucks and tanker trailers (with the exception of tanker T-14) have been emptied and cleaned.  Material from the vac truck and tanker cleaning activities have been placed in a frac tank and profiled for off-site disposal.  The material in tanker T-14 is scheduled for off-site disposal.  Characterization of the two caustic tanks was conducted and the contents have been placed into three vacuum boxes.  This material is awaiting laboratory analysis and off-site disposal.  There was approximately 71.4 tons of solidified hazardous waste liquids from the former AST area transported to an off-site incinerator for disposal during this period of time.  Approximately 162.1 tons of spent sand/carbon waste from the water treatment system was transported to an off-site incinerator for disposal.  A total of 27 lab pack containers totaling 19,760 pounds was transported to a treatment drum storage facility (TDSF) facility.  Samples from frac tanks, ASTs, roll-off boxes, and drums continue to be taken as needed for characterization purposes.


Planned Removal Actions
The PRP Group's contractor will continue to collect wastewater to be treated through the wastewater treatment system and activities aimed at removing the remaining hazardous waste from the site will continue.

Next Steps
The following items remain to be addressed:

- Removal/disposal of material from the two caustic tanks now located in three vac boxes;
- Disposal of materials still contained in the on-site tanker trailer;
- Continue 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;
- Removal/disposal of spent carbon/sand from the water treatment system;
- Complete removal/disposal of barge tank sludge material from the ASTs; and,
- Characterization and removal/disposal of numerous roll-off boxes containing miscellaneous debris and ash located throughout the site.


Key Issues
Weather continues to pose problems at the Site.  Afternoon thunder storms causes delays or suspension of work.  The arrival of warmer weather requires more time to complete tasks and poses a potential safety issue with workers.

 
Disposition Of Wastes
A total of 7 waste Shipments of Class 9, NA3077 (D006, D008) waste to Michigan Disposal Waste Treatment in Belleville, Michigan from 4/24/07 to 5/7/07 totaled 322,420 pounds/161.2 tons of hazardous material.  Certificates of disposal have not been received for these shipments.

A total of 3 waste shipments of Class 9 NA3077 (D006, D008,D009, D013, D018,D021) waste to Veolia ES Technical Solutions in Sauget, Illinois from 4/27/07 to 5/4/07 totaled 142,740 pounds/71.4 tons of hazardous material.  Certificates of disposal have not been received for these shipments.

A total of 1 overpack waste shipment with 27 lab pack containers totaling 19,760 pounds was transported to Veolia Technical Solutions, a treatment drum storage facility (TDSF),  in West Carrollton, Ohio.  Certificates of disposal have not been received for this shipment.