Inactive Waste Management Facility.

For Site Description, location, and description of threat please refer to previous POLREPs.

For detailed information on the Preliminary Removal Assessment and Site Inspection please refer to the Removal Site Evaluation POLREP (POLREP #2) and the the RSE Site Evaluation Report (2007).

As stated earlier, the Site had a previous Removal Site Evaluation conducted by EPA in June, July, and August of 2007.  Detailed information on that RSE can be found in POLREP #1 and in the Final RSE Report submitted 11/21/2007.  However, a review of that data concludes that the threats posed still remain. After a review of the data generated from the previous site evaluation and the current site condition, ERRB concluded that the site met the criteria as set forth in 40 CFR 300.415 (b)(2) for a time critical removal action.  An Action Memorandum was signed on September 10, 2010 to initiate a time-critical removal action at the Site.

The following actions took place during this reporting period:

During this reporting period START continued to hazcat unknown materials and conducted a thorough inventory of the materials in the chemical storage closet and began hazcatting the chemicals in the lab. ERRS continued to overpack 55-gallon drums and continued to consolidate the materials in each waste stream.  ERRS also finished repackaging several damaged bags of diatomite located in a storage building along the back of the property.

Items Hazcatted to date:

55-Gallon Drums -                   302

Small Containers -                    448

ASTs -                                     30 (Includes one previously undiscovered)

Chemical Storage Closet -        509 (Not Hazcatted due to NFPA Label)

Lab Cabinet Storage -              565

Wastes are divided into the following waste streams: chlorides, bases, acids, flammables, and non-haz.

Also during this reporting period the removal of materials from ASTs 1, 2, and 3 began.  These are the three largest ASTs on site, each with a total capacity of 30,000 gallons.

Totals to date from each tank (in gallons):

Tank 1 -           29,410

Tank 2 -           24,075

Tank 3 -           18,750

Tank 1 was the only tank that was emptied during the pumping process.  Tanks 2, 3 have approximately 4,000 gallons remaining.  The bottom valves on tanks 2, 3 were unable to be opened leaving some materials in the tanks; these will be addressed once demolition of the tanks takes place.

Enforcement activities are ongoing.

During the next reporting period it is anticipated that the removal of materials from the ASTs will continue.  In addition, transportation and disposal of the overpacked drums will take place.  START will begin lab-packing the chemicals found in the chemical storage closet and the lab itself as well as blend some compatible chemicals for future disposal. 

All crews will demobe on November 19, 2010 for the Thanksgiving Holiday and mobilize back to the Site on November 29, 2010.  Security will remain onsite throughout the week.

    2.2.1.2 Next Steps


2.2.2 Issues