2.1.1 Narrative

An Action Memo for a removal action was signed on February 15, 2011, effectively transitioning the site from an emergency response action to a removal action. The scope of the removal action incudes but may not be limited to the excavation and removal of CCA sludge within the secondary containment system, storage tanks, and associated piping, removal of the storage tanks and piping, treatment of the remaining CCA contaminated water, excavation and disposal of CCA contaminated soils and sediment on the Wood Treaters property and the Susie Tolbert Elementary School which exceed EPA Removal Action Levels for industrial and residential exposure scenarios.


2.1.2 Response Actions to Date

To minimize cost the same contractor responding to the emergency response was utilized to perform the removal action. The inital activities for the removal action began by preventing run-off the drip pad from entering into the secondary drainage system which had historically increased the volume of CCA contaminated water within the secondary containment area. Additional titanium dioxide was purchased for use as a treatment media for processing the existing CCA contaminated waste water.

Additional equipment was brought to the site for the purpose of excavating CCA contaminated soil on the Wood Treater property and the Susie Tolbert Elementary School property. This same equipment was also used to excavate CCA contaminated sediments from the detention ponds on the Wood Treater property and the Susie Tolbert Elementary School property. The soils at the Wood Treater property contained a high percentage of crushed rock therefore a vibratory screen was utilized to seperate the rock from the CCA contaminated soils. This process reduced the final waste stream by approximately 60%. Approximately 3,200 yards of CCA contamnated soil and sediment have been stockpiled and samples collected for the disposal profile. Approximately 58,000 gallons of CCA contaminated water have been processed through the on-site treatment system and discharged to the sewer system. And additional 20,000 gallons of CCA contaminated water were shipped off site for recycling at another wood treater site.


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

During the process of dismantling the above ground tanks to remove sludge inside and beneath the tanks, the property owner observed the action and threatened to revoke access. The removal action has been temporarily suspended since June 10, 2011.  Meanwhile EPA has been working with the property owner to address his concerns and establish a new access agreement . The property owner has verbally agreed to grant EPA access for completing the remainder of the removal action. EPA will resume the removal action following receipt of the signed access agreement from the property owner.  

2.1.4 Progress Metrics