On July 9, 2012, U.S EPA, START, IDEM, and the PRP Group attorney conducted a Site walk. The following observations and recommendations were made and action items were communicated to the PRP Group:

• A 6-inch stormwater pipe was installed between manways SS9 and SS28, connecting the southwest drainage area with the northeast drainage area. A discharge pipe from manway SS29 was installed and will discharge water to the drainage ditch.  A valve was installed in the discharge pipe to allow for closure of the valve in the event of an onsite spill.
  • Access to the valve was located in an open manway and a cover should be placed atop the manway to protect the valve.
• A 6-inch drainage pipe was installed at the base of Tank 51 containment area that will drain stormwater into manway SS14. The pipe should effectively drain stormwater from the Tank 51 containment.
• A 6-inch drainage pipe was installed in near the top of the oil-water separator with the drainage directed to manway SS12. The drainage pipe will effectively keep the oil-water from overflowing, but water will remain in the tank.
• The east bunker tank has been backfilled to grade with on-site soil.
• Standing water was observed in the west bunker tank and the tank was enclosed by a 6-foot chain link fence. There was no oil sheen observed. The roof in the southeast corner of the tank was in a state of collapse.
• The northeast corner of the Site has been graded in an easterly direction towards the drainage ditch. Silt fencing was placed adjacent to the drainage ditch along the majority of the newly graded area. Hay was placed atop of the newly graded area and rip rap was placed in the corner to minimize offsite erosion.
  • A 50-foot section of silt fencing was missing along the north border and should be installed.
  • The area should be seeded and additional rip rap be placed in the graded area to further minimize erosion.
• The solidification pits have been backfilled to grade.
  • The soil should be compacted to insure that the structural integrity of the backfilled soil is adequate.
• Oil staining was observed on and around manway SS9.
  • The area should be cleaned to prevent any oil sheening.
• A large area of oil stained soil/oil dry was observed along the east side of the Solids Building.
  • The soil should be scraped and from the asphalt and appropriately disposed of.
• A large area of oil stained asphalt was observed at the northeast corner of the Solids Building.
  • The asphalt should be cleaned to prevent any oil sheening.
• The overhead doors of the Solids Building were observed in an open position.
  • The doors should be closed preventing unwanted access to the buildings. 

On July 23, 2012, Trihydro was on Site to address the observations and recommendations identified by U.S EPA and START during the Site walk on July 9, 2012. The following action items were completed:

• A removable metal grated step stool was placed atop the stormwater discharge valve to protect the valve.
• A 50-foot section of silt fencing was installed in the northeast corner of the Site and the disturbed area was reseeded.
• Rip rap-sized crushed stone and gravel was installed to prevent shifting in the graded, Site material was used to minimize erosion, and the area disturbed during these activities was reseeded.
• Further compaction of Solidification Pit backfill material was completed by utilizing a Bobcat with the bucket preloaded with sand. The compacted areas were refilled with sand and additional sand was backfilled, in the event of future settling .
• Oil staining observed on and around manway SS9 was cleaned using Simple Green and covered with oil dry.  The oil dry was worked into the asphalt and following cleaning was collected and drummed for disposal. 
• A Bobcat equipped with a flat faced bucket was used to scrape soils and oil dry from the area along the east side of the Solids Building.  The remaining oil stains were cleaned using Simple Green and covered with oil dry.  The oil dry was worked into the asphalt and following cleaning was collected and drummed for disposal. 
• The area northeast of the Solids Building was heavily scraped during the cleaning and the top 1 to 2-inches of material were removed during scraping.  The remaining oil stains were cleaned using Simple Green and covered with oil dry.  The oil dry was worked into the asphalt and following cleaning was collected and drummed for disposal. 
• All exterior doors were closed during the final mobilization.
• The life preserver in the west bunker tank area was retrieved from inside the enclosed fence and placed along the outside of the fence, in a highly visible location.
• The sandbags along the ESI/AMI berm were arranged to remove any breaches and restore the competence of the sandbag containment. 
• Approximately one 55-gallon drum of accumulated solids and cleaning residuals were generated during Site activities and were hauled to Southside Solidification landfill in Carmel, Indiana for disposal.

Upon completion of Site activities, the PRP Group submitted their Final Report and received U.S. EPA approval on October 9, 2012. START submitted the Removal Action Report for U.S. EPA review. Following the PRP Group Final Report approval, U.S. EPA issued a Notice of Completion of Letter. A copy of the Notice of Completion Letter is available in the "Documents" section.

 
2.1.3 Enforcement Activities, Identity of Potentially 

Responsible Parties (PRPs)
N/A

 
2.1.4 Progress Metrics

ASAOC – Administrative Settlement Agreement on Consent
ERRS – Emergency and Rapid Response Services

IDEM – Indiana Department of Environmental Management
OSC – On-Scene Coordinator

POLREP – Pollution Report
PRP - Potentially Responsible Party
QMP - Quality Management Plan
RCRA – Resource Conservation and Recovery Act

START – Superfund Technical Assessment and Response Team

U.S. EPA – United States Environmental Protection Agency