1) accomplishments of Lance Oil regarding project over previous 18 months (e.g. total recovery/reduction of oil, construction accomplished, oil observations via well or surface water, plume delineation, estimated time to project completion); 2) provisions of the Order and proposed way forward (proposed change in Project Manger credentials and Site history of Steve Smith; also proposed work force); 3) history and cause of recurrent oil sheening - and proposed remedy. At the meeting were representatives from EPA, Lance Oil, GA EPD, and Atlanta Watershed Management.
During the meeting, Lance Oil identified a reduction in plume free product from a depth of 6 feet to less than one foot. Lance Oil identified Steve Smith as the new proposed Project manager to replace Mark Faas who withdrew from the project. EPA accepted the suitability of Mr Smith. Other discussion during the meeting included Lance Oil not following EPA operational procedures in well or stream monitoring. One example being Mr Brooks (owner of Lance Oil), an untrained technician, who failed to recognize crude oil discharges during his monitoring, plus EPA observations of Mr Brooks introducing chemical agents to the monitoring wells. Further discussion included the failure of Lance Oil to determine the extent of the subsurface oil plume. Lance offered that the plume, although not delineated, had shrunk in size due to the vapor phase destruction of the past 12 months. EPA agreed to allow for another monitoring episode or two prior to enforcing the provisions of the Order regarding plume delineation.
Since that time, additional stream sampling indicate exceedance of in-stream water quality standards (observed release) for which Lance Oil has conducted appropriate reporting.
2.1.2 Response Actions to Date - During this reporting period, Lance Oil has maintained absorbent materials to intermittent discharges to Clear Creek, conducted notifications to the NRC for respective discharges, monitored six monitor wells and the intercept trench.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs) - EPA will evaluate the performance of Lance Oil with respect to implementing measures identified in the Amended Administrative Order. Additionally, EPA RCRA Enforcement will evaluate discharge events.
2.1.4 Progress Metrics
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