2.1.1 Narrative
See POLREP 1

2.1.2 Response Actions to Date

On May 2, 2011, AVS loaded and hauled out 10 loads (55,000 gallons) of oily stormwater from the site, 9 loads (49,500 gallons) from the northeast area for treatment at United Water’s facility in Cincinnati, OH and 1 load (5,500 gallons) from the primary separator pit, for treatment at Clean Water Limited’s Cherokee Drive facility in Dayton, OH.
- AVS began pressure washing the concrete/asphalt in the northeast area, south of the DAF tanks.
- A fourth 21,000 gallon frac tank was mobilized to the Site to provide additional stormwater storage capacity. All four new frac tanks on site are being staged north of the Solids Building.

On May 3, 2011, 0.5” of rain fell during overnight hours, resulting in pooled stormwater above the manholes in the southwest and northeast areas.
- AVS loaded and hauled out 10 loads (54,500 gallons) of oily stormwater from the site, 9 loads (49,500 gallons) from the northeast area for treatment at United Water’s facility in Cincinnati, OH and 1 load (5,000 gallons) from the primary separator pit, for treatment at Clean Water Limited’s Cherokee Drive facility in Dayton, OH.
- AVS continued pressure washing the concrete/asphalt in the northeast area by the concrete access pit.
- PTFD Marshall Steve Jones was on site for a site visit and to review current fire suppression. 

On May 4, 2011, 0.1” of rain fell during overnight hours, with continued pooled stormwater above the manholes in the southwest and northeast areas.
- AVS loaded and hauled out 15 loads (81,500 gallons) of oily stormwater from the site, with 13 loads (71,500 gallons) from the northeast area for treatment at United Water’s facility in Cincinnati, OH and 2 loads (10,000 gallons) from the Tank 43/44 secondary containment for treatment at Clean Water Limited’s Cherokee Drive facility in Dayton, OH.
- AVS continued pressure washing and scraping oil from the concrete/asphalt in the northeast area, north of the API tanks.
- A subcontractor was on site to check future sampling locations at Tank #51 without checking in/out or notifying site personnel (WSP’s subcontractor PSI). As a result, at the request of OSC Simon the gate will continuously be “dummy locked” and Trihydro put a sign up instructing all personnel entering the site to check in at the office.
- There was a report by a local citizen to IDEM about oil sheen in Crooked Creek, downstream of Oil Creek. After both Marion County Health Dept and START Shauna Ross investigated Oil Creek, it was determined that the oil sheen was not a result of site activities at ESI.

On May 5, 2011, AVS loaded and hauled out 10 loads (54,100 gallons) of oily stormwater from the northeast area, with 9 loads (49,600 gallons) for treatment at United Water’s facility in Cincinnati, OH and 1 load (4,500 gallons) for treatment at Clean Water Limited’s Cherokee Drive facility in Dayton, OH.

 - AVS continued pressure washing the concrete/asphalt in the northeast area, south and east of the Solids Building. AVS began pumping oil sludge/oily water from the bottom of the northeast area manways and storing it in the east solidification pit.

 - Trihydro completed an inventory of known totes/drums on site: 56 totes (including 29 presumed empty) and 56 drums (including 16 presumed empty).
- WSP submitted their Storm Water Management and Tank 51 PCB Decontamination and Disposal Work Plan for review by the PRP Group and USEPA.

On May 6, 2011, 0.2” of rain fell during overnight hours.

The PRP Group, IDEM, and City of Indianapolis had a meeting to discuss potential future discharge of site stormwater to Oil Creek. USEPA did not participate.
- AVS loaded and hauled out 10 loads (53,100 gallons) of oily stormwater from the site, 8 loads (43,600 gallons) from the northeast area for treatment at United Water’s facility in Cincinnati, OH and 2 loads (9,500 gallons) from the primary separator pit, for treatment at Clean Water Limited’s Cherokee Drive facility in Dayton, OH.- AVS continued pressure washing the concrete/asphalt in the northeast area, south and east of the Solids Building—including the trench between the Solids Building and Dehydration Building. AVS continued pumping oil sludge/oily water from the bottom of the northeast area manways and storing it in the east solidification pit.
- Trihydro discharged 74,298 gallons of stormwater from the southwest area to the City of Indianapolis sanitary system under the SDA issued on April 12, 2011. The discharge event information was reported to the City of Indianapolis.

- OSC Verneta Simon, START Shauna Ross, Steve Flemming (Safety-Kleen), and Dave McLay (WSP) agreed to the following changes to WSP’s Storm Water Management and Tank 51 PCB Decontamination and Disposal Work Plan:

WSP will not have a subcontractor sampling the Tank 51 wall for asbestos until the secondary containment stormwater has been pumped down.

WSP will not discharge stormwater to the southeast area stormwater system prior to discharge to the City sanitary sewer—they will run aboveground piping/hose from the Tank 51 secondary containment directly to the City sanitary sewer for discharge, if the City of Indianapolis also agrees.

Per D. McLay, WSP and their subcontractor Focus Contracting will be on site on Tuesday, May 10, 2011, to begin discharging Tank 51 stormwater to the City sanitary sewer pursuant to the SDA issued on April 19, 2011.

- OSC Simon, START Ross, and Marion County Health Dept (MCHD) personnel met AT&T and their subcontractor Underground Contractors, Inc (UCI) at the spill site from May 4, 2011, located at 8465 Guion Rd Indianapolis, IN.

- According to AT&T, UCI was installing a utility pole when a hydraulic line on their truck spilled approximately 10 gallons of hydraulic fluid on the asphalt/concrete parking lot and ground adjacent to the utility pole. Hydraulic fluid migrated to the nearby stormsewer, which discharges into the Payne Branch, leading to Crooked Creek. Hydraulic oil was still visible in the spill area and sheen was visible in the stormsewer outfall and in Payne Branch.

OSC Simon instructed AT&T/UCI to take the following actions:

- Notify the National Response Center of the incident (NRC Case #975355).

- Place absorbent boom at the stormwater outfall to Payne Branch and downstream in Crooked Creek at 79^th St & Michigan Ave.

- Clean the asphalt/concrete parking lot of oil.

- Remove impacted soil & take confirmation samples for TPH.

- Submit a report to U.S. EPA/IDEM/MCHD in 7 days describing the incident, policies in place to handle these incidents, and corrective actions taken.

- UCI had placed boom in the two areas described above & had contracted SET Environmental to clean up the spill area (cleanup was underway).

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Four additional PRPs were added on May 2, 2011 to the executed ASAOC. A copy of the ASAOC amendment is available on this website under "Documents".

2.1.4 Progress Metrics