• On April 6, 2011, U.S. EPA met with personnel from Safety-Kleen (Project Coordinator) and TriHydro (Contractor), both from the PRP Group. The PRP Group personnel began waste characterization sampling and waste volume assessment activities.
• On April 7, 2011, OSC Boseman, PRP Group personnel, and the City of Indianapolis personnel met at the site for a transitional site meeting.
• On April 8, 2011, OSC Boseman and TriHydro were on site.  TriHydro continued site characterization in preparation for removal activities. U.S. EPA will oversee the PRP Group's removal activities.
• On April 8, 2011, U.S. EPA agreed to continue the discharge events as outlined in the modified SDA until the City of Indianapolis has issued a SDA to the PRP Group.  TriHydro loaded and hauled off 5,000 gallons of oily water from the northeast area storm sewer.  The water was disposed of at Clean Water Limited’s Cherokee Drive facility in Dayton, Ohio.  The PRP Group has contracted site security, and utilities will be transferred to PRP Group on April 11, 2011.
• On April, 11, 2011, START member Jay Rauh mobilized to the Site to begin oversight of the PRP removal activities.  Tim Gunn of TriHydro is the on-site PRP Group representative. Mr.Gunn requested that US EPA discharge water from the southwest area storm sewer since the PRP group had not received their SDA from the City of Indianapolis. 

  TriHydro loaded and hauled off 24,000 gallons of oily water from the northeast area storm sewer.  The water was disposed of at Clean Water Limited’s Cherokee Drive facility in Dayton, Ohio.  The water level in the northeast area storm sewer dropped by 1.5 feet after removing 24,000 gallons of oily water from it. 

  US EPA OSC Verneta Simon, US EPA Community Involvement Coordinator (CIC) Janet Pope, PRP Group Project Coordinator Steve Fleming, TriHydro Project Manager Gary Risse, Pike Township Fire Department (PTFD) Fire Marshal Stephen Jones, and the City of Indianapolis participated in a community meeting held at 1200 Madison, Indianapolis, Indiana.

• On April 12, 2011, Rauh, Gunn, and Risse were present at the Site.  

  Stephen Jones, PTFD Fire Marshal, was on site to relay his concerns about fire hazards and building occupancy.  Since the fire suppression systems were inoperable in the unloading building and solid storage building, he requested that all materials be removed those buildings.  He also requested that all vehicles park further than 20 feet from either building to prevent any potential fire from spreading from one source to the other.  Since the unloading building has usable offices attached, he would allow those offices to be occupied if those conditions were met.  He will return to the Site to decide if the materials have been removed to his satisfaction before major work begins. 

  Sam Coffman and Michael Gordon of Commercial Sewer Cleaning (CSC) were on site to attempt videotaping portions of the northeast storm sewer system.  They were not able to use their camera due to water and sludge buildup in the sewer. 

  Richie Byrd of Environmental Restoration, a US EPA ERRS contractor, was on site to discharge storm water from the southwest area to the City of Indianapolis sanitary sewer system under the US EPA SDA.  33,132 gallons of water was discharged. A total of 584,118.8 gallons of the allotted 1 million gallons in the modified SDA issued on February 15, 2011 has been discharged to the City of Indianapolis sanitary sewer system. Late in the day, Stephen Fleming received his SDA. A copy of the PRP Group's SDA is contained in the section called  "Documents".  Mr. Byrd also trained both START and TriHydro on how to use the computer in the Control Building, in the event it was necessary to pump the primary separator, since ESI did not leave an operations manual. 

  Gunn collected water sample SWArea-SS17,041211 from the effluent of the southwest area discharge system.  The sampling results will be submitted to the City of Indianapolis for consideration of a discharge permit for the PRP Group.  Gunn also collected water sample NEArea-SSVault,041211 from the northeast area storm sewer system.  The sampling results will be used to explore alternate disposal options for the oily water.

  TriHydro loaded and hauled off 19,400 gallons of oily water from the northeast area storm sewer.  The water was disposed of at Clean Water Limited’s Cherokee Drive facility in Dayton, Ohio. 

• On April, 13, 2011, TriHydro subcontractor, EQIS, began removing materials from the unloading building.  All oily waste was placed in a roll-off box to be disposed of as Subtitle D oily waste, and the other material was placed in a standard roll-off box to be landfilled.

• On April, 14, 2011, TriHydro subcontractor, EQIS, continued removing materials from the unloading building.  All oily waste was placed in a roll-off box to be disposed of as Subtitle D oily waste, and the other material was placed in a standard roll-off box to be landfilled.  EQIS also collected unusable oily hoses and placed them in the Subtitle D roll-off box.

  Tom White and Mark Richards of the City of Indianapolis Water Department were on site to collect a water sample from the Tank 51 containment area.  Sample ESI-51-041411 was collected from the northeast corner of the Tank 51 containment.  The sampling results will be used for consideration of a discharge permit to the City of Indianapolis storm sewer system.

  TriHydro loaded and hauled off 5,000 gallons of oily water from the oil/water separator west of the unloading building.  After pumping 5,000 gallons of water from the oil/water separator, the water level in the oil/water separator dropped by 0.73 feet.  The water was disposed of at Clean Water Limited’s Cherokee Drive facility in Dayton, Ohio.
• On April 15, 2011, TriHydro subcontracted an electrician to identify any potential electrical hazards at the Site.  TriHydro loaded and hauled off 15,000 gallons of oily water from the northeast area storm sewer.  The water was disposed of at Clean Water Limited’s Cherokee Drive facility in Dayton, Ohio.
• On April 18, 2011, OSC Simon, Ken Gollon of TriHydro, and Rauh were on site.  Gollon spent time working on a website that could disseminate information about removal activities at the Site to US EPA and the public.  The information, presented in a daily log format, includes personnel on site, amount of materials loaded and hauled off, and any other pertinent information.  
• On April 19, 2011, Gunn, Gollon, and Rauh were on site.  1.5" of rain fell during a heavy thunderstorm in the morning.  To prevent the oil/water separator from overflowing, TriHydro moved 5,000 gallons of oily water from the oil/water separator to the west million gallon tank, using the computer inside the Control Building.  The liquid level in the oil/water separator dropped by 1 foot after the 5,000 gallons were moved.   No stormwater was noticed escaping the Site.  TriHydro loaded and hauled off 30,000 gallons of oily water from the northeast area storm sewer.  The water was disposed of at Clean Water Limited’s Cherokee Drive facility in Dayton, Ohio.  The water in the northeast area storm sewers was notably rising during the heavy rains. 
  

Carol Staniac of US EPA Water and Megan Nagle of IDEM Water were on site for a site walk.  

• On April 20, 2011, Gunn, Gollon, and Rauh were on site.  1" of rain fell during the overnight hours, and elevated water levels were noted in the northeast part of the Site.  Water backed up in the northeast area storm sewer had entered into and equalized with the Off Spec Oil Containment (East Containment).  The liquid level in the oil/water separator had also risen.  TriHydro loaded and hauled off 40,000 gallons of oily water from the northeast area storm sewer.  The water was disposed of at Clean Water Limited’s Cherokee Drive facility in Dayton, Ohio.  

OSC Simon and Carol Staniac of US EPA Water were on site for a site walk.

• On April 21, 2011, Rauh, Gunn, and Gollon were on site. 

Heritage Environmental was on site with a vac truck to determine whether the sludge in the million gallon tanks was pumpable. 

A conference call regarding plans to seal the million gallon tanks from the stormsewer system took place with OSC Simon, Weston START members Rick Mehl, Jay Rauh, and Brian Coninx, and PRP Group representatives Steve Fleming (Safety Kleen), Gary Risse (TriHydro), and Tim Gunn (TriHydro).  The PRP Group proposed using cement to make the seal.  Weston START Rick Mehl suggested alternately using expanding cellular concrete as a non-permanent solution.  OSC Simon discussed using a bladder pig. The PRP Group agreed to take the suggestions under consideration.  In another conference call with the same parties later in the day, OSC Simon gave approval to use the cement method after the PRP Group reported difficulty finding a local supplier for the cellular concrete. The PRP Group will begin the sealing the million gallon tanks at 0800 EST on April 22, 2011.

TriHydro loaded and hauled off a total of 42,080 gallons of storm water from the northeast area storm sewer and East Containment.  The water was taken to Clean Water Limited’s Cherokee Road facility in Dayton, OH for disposal.

• On April 22, 2011, Rauh, Gunn, and Gollon were on site along with their various cement and other subcontractors.
  

TriHydro constructed a temporary containment on the curbing just south of the East Containment with sand bags and poly sheeting. 

The cement work took place at the vault structure of the million gallon tanks.  There were 4 total “pours,” two into each million gallon tank vault.  As the initial pour took place, aeration was obvious in the back of the vaults.  The second pours did not cause aeration which was viewed as a positive sign.  The volume estimates appeared to be good, and TriHydro and their subcontractors reported that everything went as planned.  The seal will be tested further next week, but initial indications are that the million gallon tanks are now separate from the stormsewer system.

TriHydro mobilized two frac tanks with  42,0000 gallons of capacity

TriHydro used left over cement to patch a curb in the southwest area which appeared to be a potential low point.  They also made ramps on the south berm so that the frac tanks could be moved into the northeast area

TriHydro loaded and hauled off 29,000 gallons of water from the northeast area stormsewer and East Containment.

• Hydraulically disconnect the million gallon bunker tanks from the storm sewer system
• Clean storm sewer system
• Remove wastes

ERRS – Emergency and Rapid Response Services

IDEM – Indiana Department of Environmental Management

OSC – On-Scene Coordinator

RCRA – Resource Conservation and Recovery Act

START – Superfund Technical Assessment and Response Team

U.S. EPA – United States Environmental Protection Agency
POLREP – Pollution Report
ASAOC - Administrative Settlement Agreement on Consent
PRP - Potentially Responsible Party