On-site response actions from September 1 through September 14 consisted of treating excavated soil using a stabilizing amendment and transporting the treated waste to the designated disposal facility.  In accordance with the approved Work Plan, soil was consolidated for waste characterization in 250 cubic yard batches.  One four-point composite sample was collected from each stockpile for analysis by EPA SW-846 Method 1311, Toxicity Characteristic Leachate Procedure (TCLP).  Analytical results were received for all stockpiles during this reporting period, with TCLP results ranging from 6.8 mg/L to 130 mg/L.  Based on these results, all excavated soil on-site was determined to be characteristically hazardous waste as defined by 40 CFR 261.24, requiring treatment prior to land disposal.  Waste treatment operations were conducted September 7 through September 11 by physically mixing EnviroBlend® stabilizing agent in accordance with the process outlined in the approved Removal Work Plan at a 4% ratio as determined through the site specific bench-scale testing.  Following treatment of each 250 cubic yard batch, a post-treatment composite sample was collected for TCLP analysis with a 24-hour laboratory turnaround.  Post-treatment sample results were received for all but one treated stockpile during this reporting period, with results for all samples showing non-detectable levels of lead in leachate following treatment. 

On September 12, 2012, waste hauling began to the Butler County Landfill in David City, Nebraska.  A total of 12 trucks were running and operated under subcontract with the landfill.  The landfill is running 12 or 13 double trucks consisting of 15-cubic-yard tandem-axle dumps pulling a 10-cubic-yard trailer.  Due a nearly 4-hour round trip to the disposal facility, only two runs were completed on September 12.  Loading and hauling continued in similar fashion for the remainder of this reporting period, although on September 13 and 14 an earlier start allowed for three runs each day.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

An Administrative Settlement Agreement and Order on Consent, CERCLA-07-2012-0053, was established between NL, the EPA and Moweco, Inc., effective August 7, 2012.  ODM is a property owner and has provided access to complete the removal action as well an Environmental Covenant for implementation of Post-Removal Site Controls.  Moweco filed a similar environmental covenant for the parcels under their ownership.

2.1.4 Progress Metrics

The following waste quantities are volume estimates based on treated stockpile dimensions.  After weight tickets are received and reviewed from the disposal facility, this information will be revised to reflect an accurate waste quantity in tonnage.

Belinda Young is the EPA Public Information Officer (PIO) assigned to this project.  Refer to POLREP #1 for a detailed description of the public involvement activities conducted by the PIO.