1. Introduction
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1.1 Background
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Site Number: |
A7K9 |
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Contract Number: |
N/A |
D.O. Number: |
N/A |
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Action Memo Date: |
12/30/2008 |
Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
Response Lead: |
PRP |
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Incident Category: |
Removal Action |
NPL Status: |
Non NPL |
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Operable Unit: |
00 |
Mobilization Date: |
6/22/2009 |
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Start Date: |
6/22/2009 |
Demob Date: |
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Completion Date: |
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CERCLIS ID: |
IAN000705908 |
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RCRIS ID: |
N/A |
ERNS No.: |
N/A |
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State Notification: |
N/A |
FPN#: |
N/A |
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Reimbursable Account #: |
N/A |
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
Weather during the reporting period was hot and sunny with temperatures reaching mid to upper 90s. Greenleaf Environmental Services LLC (Greenleaf), the potentially responsible party's (PRP's) contractor, performed mobilization activities the week of June 22. These activities included constructing a gravel access road and parking lot, equipment delivery, decontamination tent construction, office trailer set up, and utility hookup. Beam segregation to separate beams with PCB-containing residual insulation or adhesive was initiated toward the end of the week of the June 22 and is on-going. Per the approved workplan, beams from the site's stockpiles were visually inspected for residual insulation or adhesive. As of July 2, 2009, 346 steel beams were separated from the most northern stockpile and visually inspected. A visual inspection revealed that 61 of the metal beams appeared to contain no residual insulation or adhesives. The remaining 285 metal beams contained visible residual insulation or adhesive and were relocated to the decontamination staging area for subsequent removal of the material. Actual decontamination procedures have not been initiated.
2.1.2 Response Actions to Date
The only previous action taken at the SIM site with respect to the beams is the installation of a temporary fence to restrict access to the beams. The fence was installed by the property owner at EPA's request in July 2008. The Iowa Department of Natural Resources (IDNR) provided a list of Applicable or Relevant and Appropriate Requirements (ARARs) for consideration for the response action. No other state activities have occurred.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The PRP has been identified as Dico, Inc. and its parent company Titan Tire Corp. The PRPs were issued an Administrative Settlement Agreement and Order on Consent to perform the response action. The opportunity to negotiate was waived. PRPs are currently under a Unilateral Administrative Order (UAO) to perform response activities proposed in the Action Memorandum.
2.1.4 Progress Metrics
Wastestream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
PCBs |
Steel Beams |
285 |
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0 |
0 |
PCBs |
Soil |
? |
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0 |
0 |
PCBs |
Bulk Insulation |
? |
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2.2 Planning Section
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2.2.1 Anticipated Activities
2.2.1.1 Planned Response Activities
An action memorandum was prepared and issued December 30, 2008. The proposed action consists of decontaminating the beams by removing the PCB residues by scarification. The beams would be decontaminated to meet the Visual Standard No. 2, Near-White Blast Cleaned Surface Finish, of the National Association of Corrosion Engineers (NACE), as called for by 40 CFR 761.79(b)(3)(B). This standard applies to "non-porous surfaces in contact with nonliquid PCBs (including non-porous surfaces covered with a porous surface, such as paint or coating on metal)." The beams are a nonporous surface in contact with nonliquid PCBs (insulation and adhesive residue) and the beams are coated with paint. Following scarification, the cleaned beams would then be available for reuse. Decontamination waste including the scarifying agent would be containerized and transported off-site for disposal in accordance with applicable TSCA regulations. Soil beneath the area where the beams have been stored would be sampled using a statistical sampling scheme to verify that appropriate cleanup levels are achieved. Any areas exceeding cleanup levels would be excavated and transported off-site for disposal in accordance with 40 CFR 761.61.
2.2.1.2 Next Steps
Beam segregation to separate beams with PCB-containing residual insulation or adhesive is expected to continue. Scarification procedures are also expected to be initiated. A sampling event is scheduled for July 20 and 21 to provide confirmation for beams that have been visually inspected and appear to contain no residual insulation or adhesive.
2.2.2 Issues
Greenleaf's supply trailer was discovered stolen on June 30, 2009. They have procured personnel to secure the site when response personnel are not present.
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2.3 Logistics Section
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There are currently no logistical concerns.
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer On May 27, 2009, the site health and safety plan was finalized by Greenleaf Environmental.
2.6 Liaison Officer No activities.
2.7 Information Officer
2.7.1 Public Information Officer
The Administrative Record was fedexed to the Ottumwa Public Library for public availability on June 30, 2009.
2.7.2 Community Involvement Coordinator
No activities.
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3. Participating Entities
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3.1 Unified Command Titan Tire Corp. Dico Inc. US EPA
3.2 Cooperating Agencies None
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4. Personnel On Site
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1 EPA RPM 4 Greenleaf Environmental Contractors 1 Titan Tire/DICO Consultant
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5. Definition of Terms
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PCBs - polychlorinated biphenyls
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6. Additional sources of information
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6.1 Internet location of additional information/report For additional information please refer to http://epaosc.net/SouthernIowaMechanical.
6.2 Reporting Schedule The next polrep will be reported on July 20, 2009.
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7. Situational Reference Materials
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No information available at this time.
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