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LWD, Inc.

All POLREP's for this site LWD, Inc.
Calvert City, KY - EPA Region IV
POLREP #16 - Clean-up Ongoing
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On-Scene Coordinator - Steve Spurlin 6/22/2007
Time-Critical - Removal Action Pollution Report (POLREP) #16
Start Date: 3/2/2006
Pollution Report (POLREP) #16
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 114,000 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 68,000 gallons of water have been land applied.  The on-site tanker trailer T-14 has been emptied and cleaned making all on-site tanks and trailers empty and clean.  Twelve tankers totaling 57,147.5 gallons of material that had been placed in frac tanks was removed for off-site disposal.  During this period of performance, four frac tanks were emptied.  Three vacuum boxes of caustic waste and rinse water was removed for off-site disposal.  The last load of solidified hazardous waste liquids (approximately 13.3 tons) from the former AST area was transported to an off-site incinerator for disposal during this period of time.  The last load of spent sand/carbon waste from the water treatment system (approximately 20.7 tons) was transported off-site to be stabilized and landfilled.  One roll-off box containing 2.1 tons of non-contaminated baghouse filters, six roll-off boxes containing a total of 46.5 tons of ash waste, five roll-off boxes containing a total of 73.1 tons of flammable solid waste, and five vac boxes containing approximately 71.4 tons of sludge were removed for off-site disposal.  A total of 14 lab pack containers were transported to treatment drum storage facility (TDSF) facilities for disposal.


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.

EnSafe plans to conduct subsurface investigation of the soils beneath the AST secondary containment area.  These activities are planned for June 26 and June 27, 2007.

Planned completion of Phase II activities is anticipated to occur on June 29, 2007.  Planned initiation of Phase III activities is anticipated around the middle of August 2007.


Next Steps
The following items remain to be addressed:

- Continue operation of water treatment system for treatment of on-site water;
- Removal/disposal of non-hazardous materials left on-site, which includes: one roll-off box of floc material from water treatment activities, one roll-off box of slag material, one roll-off of cut up plastic totes, one roll-off of crushed drums, one roll-off of plastic overpack drums, seven pallets and on fiber drum of unused products, and one roll-off of stabilized sludge;
- Characterization and removal/disposal of the following potentially hazardous wastestreams: two roll-offs of stabilized sludge, two roll-offs of floc material from water treatment activities, and one vac truck load of frac tank sludge;
- Clean and decon empty frac tanks for removal from site; and,
- Removal/disposal of spent carbon/sand that will be generated during the dismantling of the water treatment system.


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.

Heavy metal content in water treated on-site has required additional treatment methods including increased retention times in settling pools and the addition of ferrous sulfide to help precipitate heavy metals prior to entering the sand and carbon units.  These treatment methods have helped to reduce heavy metal content in the treated water.


 
Disposition Of Wastes
A total of 2 waste Shipments of Class 9, NA3077 waste to Michigan Disposal Waste Treatment in Belleville, Michigan from 5/15/07 to 6/11/07 totaled 45,580 pounds/22.8 tons of hazardous material.  Certificates of disposal have not been received for these shipments.

A total of 16 waste shipments and 2 overpack waste shipments with a total of 14 drums of Class 9 NA3077 waste to Veolia ES Technical Solutions in Sauget, Illinois from 5/9/07 to 6/14/07 totaled 412,340 pounds/206.2 tons of hazardous material.  Certificates of disposal have not been received for these shipments.

A total of 15 waste shipments and 1 overpack waste shipment with 1 lab pack container totaling 453,160 pounds/226.6 tons 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.