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2.1.1 Narrative
During this time period, the ERRS contractor continued work on the interceptor trench on the CPA property and encountered a number of historic buildings/structures in the subsurface which impeded response action efforts. The START contractor collected samples of excavated soils. Contaminated soils were packed up for transport and transported off site.
2.1.2 Response Actions to Date
MONDAY
July 7, 2014: Personnel on-site: EPA – 1, USCG – 1, START –
1, ERRS – 7, APEC - 1, SEARCH - 1. ERRS completed excavation of interceptor
trench segment 13/14. There wasn’t enough space to install a full segment 14 due to the presence of a historic foundation which was discovered. The structure was substantial and believed to be part of the Japanese Sugar Factory which is listed on the National Registry of Historic Places. Documentation was conducted by the on site archeologist and discussions occurred between the archeologists, ERRS, ERT and OSC Rogow. Therefore segment 13 was over-excavated for 10 ft or so. The coral encountered was soft and it
fractured easily into coarse sand, gravel and cobbles and appeared quite
permeable. A distinct diesel
odor was observed and an oil sheen also formed on the water table. While
breaking the coral, a pungent, sulfur-like odor was first observed, indicating
that the diesel is probably undergoing anaerobic degradation. ERRS also began
mixing and pouring concrete to form the pads around the installed sumps.
In addition, a subcontractor
delivered one load of washed coral to the site for trench pack. The START collected five stockpile samples
and also a composite sample of a black tar-like material that was found in
buried containers in the Recovery Trench segment 3 area.
TUESDAY
July 8, 2014: Personnel on-site: EPA – 1, USCG – 1, START –
1, ERRS – 7, APEC - 1, SEARCH - 1. ERRS investigated the area just east
and south of the interceptor trench to determine if an interceptor trench could
be installed there to trap diesel south of where the interceptor trench
terminated. A building floor and foundation pillars were found in the shallow subsurface
of this area. ERRS then excavated a test pit due south of the interceptor
trench in the southwestern corner of the Site. No structural remnants were encountered during the
excavation. A distinct diesel odor was observed and an oil sheen also formed on
the water table of the test pit. While breaking the coral, a pungent, sulfur-like
odor first observed, indicating that the diesel is probably undergoing
anaerobic degradation. Incidentally, the odor and the coral encountered was
soft and it fractured easily into coarse sand, gravel and cobbles and appeared
quite permeable, was similar to what was observed during the over-excavation of
interceptor trench segment 13. The
test pit was backfilled after about an hour of observation. ERRS backfilled interceptor
trench segments 13/14 with crushed wash coral to above the water table; filter
fabric was placed on top of the coral, and sump installed. ERRS also replaced
the oil boom that was washed ashore, and continued mixing and pouring concrete
to form the pads around the sumps. START shipped samples collected yesterday.
WEDNESDAY July 9, 2014:
Personnel on-site: EPA – 1, USCG – 1, START – 1, ERRS – 7, APEC - 1, SEARCH - 1. START received analytical results for
eleven stockpile samples. Saturated zone stockpile samples from recovery trench
segments 1 and 2 had TPH concentrations that were above the Site action level.
Overburden stockpile samples from interceptor trench segments 10/11, 11, 12,
and 13/14 had TPH concentrations that were all below the Site action level.
Saturated zone stockpile sample
TPH concentrations from interceptor trench segments 10, 11 and 12 were all
below the Site action level. The overburden stockpiles sampled for PCBs all
came back below the method reporting limit. ERRS initiated backfilling of recovery
trench segments 3 and 4 and interceptor trench segment 13/14 with stockpile soil,
and started packing stockpiles from recovery trench segments 1 and 2 into cubic
yard boxes for shipment. ERRS also repaired the section of the transformer
secondary containment wall that was previously damaged by the excavator, and removed
forms from previously-poured sump concrete pads.
THURSDAY July 10, 2014:
Personnel on-site: EPA – 1, USCG – 1, START – 1, ERRS – 7, APEC - 1, SEARCH - 1. OSC Rogow returned to site. ERRS
continued packing stockpiled materials that were above the action limit into
shipping containers; completed backfill and compacting of interceptor trench
segment 13/14 to grade; and redeployed boom. ISLA trucking, a subcontractor,
picked up two sealed containers of contaminated soils for shipping and
delivered two empty ones. START collected confirmation samples from three areas
below former soil stockpiles.
FRIDAY July 11, 2014:
Personnel on-site: EPA – 1, USCG – 1, START – 1, ERRS – 7, APEC - 1, SEARCH - 1. ERRS continued packing stockpiled materials
that were above the action limit into shipping containers. At the direction of
the OSC, ERRS excavated two additional test pits directly south of the
interceptor trench: the second pit was approximately 100-ft south of the gate
at the southwestern corner of the CUC fence; and the third pit was midway
between the first and the second pit. Soft coral (a
gravelly-cobbly-coarse-sandy matrix) was encountered in the second pit at
greater than a 10-ft depth. A faint, diesel, sulfurous odor was detected at
maximum depth of 12 ft, however after being left open for two hours, no diesel accumulated.
The EPA determined that this location was not impacted by diesel product and
the pit was backfilled. Pit 2 was excavated to about a 12-ft depth. Soft coral
was encountered at shallow depth, approximately 4 ft below ground. At greater
than 10 ft, coarse loose sand was encountered, similar to segment 3 of the
recovery trench. Once the saturated zone was encountered, brown-colored diesel
flowed immediately into the excavation, and a strong sulfurous-diesel odor was observed.
ERRS subsequently backfilled the pit. Based on the results of the test pitting,
the EPA decided to install interceptor trench 2 south of interceptor 1.
Interceptor trench 2 will extend from halfway between test pit 2 and 3 to the
north for approximately 80 ft, terminating on the remnants of the of building
foundation unearthed previously. ERRS exposed the southern portion of the
building remnant found earlier. SEARCH archeologist initiated worked to define
the footprint and determine the details of the structure for documentation
purposes. START shipped samples
collected yesterday.
SATURDAY July 12, 2014:
Personnel on-site: EPA – 1, USCG – 1, START – 1, ERRS – 7, APEC - 1, SEARCH - 1. SEARCH archeologist was on site until
11:00 AM. Start received analytical for four stockpiles. Saturated zone stockpiles samples from
recovery trench segments 3 and 4 had TPH concentrations that were above the
Site action level; and saturated zone stockpile samples from interceptor trench
segment 13/14 were below the Site action level. ERRS continued packing
stockpiled materials that were above the action limit into shipping containers.
SEARCH archeologist defined and
documented the southwestern footprint of the underground structure. ERRS
removed the entire overburden for interceptor trench 2 while the SEARCH archeologist was on site. Coral
limestone was encountered at a shallow depth along the entire trench, at
approximately 4 to 5-ft in depth. ERRS initiated rock breaking and excavation
at the southernmost end of the trench. The coral was hard and competent for the
entire depth (14 ft) for the southernmost 10 ft of the trench and then it
transitioned into a soft coral with a coarse sand in the saturated zone. Once
the saturated zone was encountered, brown-colored diesel with a strong
sulfurous-diesel odor flowed immediately into the excavation. Approximately 30 ft of trench
was excavated.
SUNDAY July 13, 2014:
DAY OFF; ERT Johnson and USCG demobed.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Responsible party (CNMI CUC) has been providing assistance, logistical support and supplies, including diesel fuel for heavy equipment.
2.1.4 Progress Metrics
Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
petroleum contaminated |
soil |
80 cuyds |
012380932,012380926, 012380925, 012380924,
012380913 |
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petroleum contaminated |
soil |
64 cuyds |
012380937, 012380931,012380930, 01238916 |
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