2.1.1 Narrative
See POLREP 1

2.1.2 Response Actions to Date  

On September 12, 2011, Midwest hauled off (1) 20 cyd roll-off box of solidified sludge to Southside Landfill in Indianapolis, IN.

• 0.10” of rain over the weekend, and TriHydro reported that the rain did not overtop the storm sewers or escape the Site.
• Midwest continued solidifying material in the solidification pits with wood pulp.
  
• Midwest began pressure washing and cleaning the east containment.
• Midwest had (2) 50,000 pound loads of wood pulp solidification agent delivered.

 

On September 13, 2011, Midwest hauled off (7) 20 cyd roll-off boxes of solidified sludge to Southside Landfill in Indianapolis, IN.

• Midwest continued solidifying material in the solidification pits with wood pulp. 
• Midwest had (2) 50,000 pound loads of wood pulp solidification agent delivered.
• Midwest continued pressure washing and cleaning the east containment.
• Steve Flemming (Safety Kleen), Dave Mamrose (Trihydro), Frank Vest (Midwest), Rick Mehl (START), and Shauna Ross (START) participated in a site walk and meetings at the Site.  Topics included:
  • Per Mr. Vest, there is approximately 600,000-700,000 gal of sludge (both pumpable and non-pumpable) remaining in each bunker tank & the plan for removing sludge removal/cleanup has not been finalized. The sludge also cannot be sold for btu value due to solids content.
  • Midwest will replace all DAF/API tank lids to their original locations after some were removed during cleanup activities.
  • During a conference call with OSC Simon, Mr. Flemming agreed to conduct a pilot test for process pipe cleaning.
    • Trihydro will compare sampling/screening results following flushing an oil- impacted process pipe with water & flushing one with degreaser.
    • Sampling will include flashpoint & pH (conducted on site).
    • Screening will be performed with a PID.

On September 14, 2011, Midwest hauled off (10) 20 cyd roll-off boxes of solidified sludge to Southside Landfill in Indianapolis, IN.

• Midwest continued solidifying material in the solidification pits with wood pulp.
• Midwest continued pressure washing and cleaning the east containment.
• Midwest had (2) 50,000 pound loads of wood pulp solidification agent delivered
• Dave Mamrose (Trihydro) met with the City of Indianapolis and the PRP Group's two potential stormwater contractors at City Hall to discuss post removal action stormwater management
  

On September 15, 2011, Midwest hauled off (4) 20 cyd roll-off boxes of solidified sludge to Southside Landfill in Indianapolis, IN.

• Approximately 0.25” of rain fell.  No water overtopped the manholes or escaped the Site.  TriHydro pumped the storm water from the storm sewer into a frac tank.
• Midwest continued solidifying material in the solidification pits with wood pulp.
• Midwest completed final cleaning of the East Containment.
• Midwest started cleaning the caustic tanks (Tanks 2, 3, and 3a).
• TriHydro treated raw stormwater.
• TriHydro and Midwest collected a sludge and a solidified sludge sample from Tank 51 since previous sampling was not deemed representative of the full sludge profile:
  • TANK51DSL-20110915 – composite of the north and west holes from the bottom of the tank to the top of the sludge (~15).
  • TANK51DSOLID-20110915 - composite of the north and west holes from the bottom of the tank to the top of the sludge (~15) treated with wood pulp solidification agent.
  • Both samples analyzed for TCLP metals, TCLP SVOCs, TCLP VOCs, TCLP PCBs, paint filter, and flashpoint.
  • The samples were collected to provide further information for treatment and disposal of the sludge as directed by the insurance company Chartis.
  • Summary of PRP Group Tank 51 sampling:
    • August 10, 2011 - Two samples for total analyses.
      
    • September 6, 2011 - One composite of solidified sludge for TCLP analyses.
      
    • September 15, 2011 - One composite of solidified sludge and one composite of unsolidified sludge for TCLP analyses.
      

On September 16, 2011, Midwest hauled off (3) 20 cyd roll-off boxes of solidified sludge to Southside Landfill in Indianapolis, IN.

• Midwest decontaminated their vac truck so that it could handle waste caustics.

• Midwest continued cleaning the caustic tanks (Tanks 2, 3, and 3a).  The caustic waste is collected by the vac truck and staged in totes.
• TriHydro treated raw stormwater.
• TriHydro had their two potential storm water management contractors (Roger Ward Engineering and American Structurepoint) on site for site walks.  Their storm water management proposals are due to TriHydro on Thursday, September 22. 
  
• TriHydro requested visual inspection of the East Containment and the API sump pit.  No visible product was noted in either structure.  The condition was documented with two photos each.   

The wood pulp solidification material is a reclaimed/recycled product.  As of September 20, 2011, approximately 1,400,000 pounds had been used to solidify waste sludge.

 

2.1.3 Enforcement Activities, Identity of Potentially

 

 

 

 

Responsible Parties (PRPs)
N/A

2.2.1.2 Next Steps
US EPA will provide oversight of PRP Group removal activities.

Begin cleaning the primary separator pit.
Sample the oxidation pit. 

2.2.2 Issues


Starting in Mid-July, the weather became very hot and humid, and special care was taken to make sure that people working outside are well hydrated and taking adequate breaks. 

Groundwater infiltration is suspected in the sanitary sewer system on Site. TriHydro is investigating potential options for mitigating infiltration. 

Standing water has been observed in several locations around the site. Warmer weather can lead to mosquito breeding in standing water. EPA has requested that Trihydro address all standing water on site as soon as possible.

Ongoing management of wildlife at the site due to nearby ecosystems.

In previous POLREPs an incorrect name was used when referring to the oily water disposal facility. The correct name should be United Waste Water, Inc. not United Water.

"Control structure" refers to the pit or sump attached to and immediately south of the million gallon bunker tanks.  It has been referred to as "access pit" and "access pit/control structure" in the past.

START Contractor