• Biological Treatment Basin (approx 3 million gallon)
  • FID - sustained reading at surface of approximately 60 ppm and background in the breathing zone.
  • H2S - sustained reading of 10 - 20 ppm at the surface and 10 ppm in the breathing zone.
• Pump Station (approx 1000 gallons)
  • FID - sustained readings of 60 ppm total volatile organics at the surface with max of 2000 ppm and approx 50 ppm in the breathing zone.
  • Hydrogen sulfide (H2S) - sustained readings of 20 ppm with max of 125 ppm at the surface and 10 ppm in the breathing zone.
• No other parameters were detected.
• Air monitoring results outside the immediate area of the basins and within the property boundaries were at background.
• Air monitoring results outside the fenceline and at the closest residence were at background.

Additional actions:

• OSCs conducted an additional entry to collect samples for hazardous categorization as well as waste profiling.
• Liquid and sludge samples will be sent for 24 hours  turn around analysis.

• Setup of water suppression system to act as a protective tactic during gas treatment.  The water suppression system has access to a sequestering agent to mitigate any unintentional releases of hydrogen sulfide.  The delivery system was tested and also acted to reduce the growing pressure and size of the bulge by cooling the tarp.  Elevated atmospheric temperatures had increased the rate of the exothermic reaction.
• Preparation and execution of methods to safely access the gases either thru the existing pipeworks of the scrubber which is in disrepair or thru a PVC 'under the tarp/liner' access system.
• Soft boom was placed in the creek at effective locations to minimize the effect of the ongoing oily discharge.
• Staging and setup area for arrival of the mobile scrubber which was temporarily delayed in transport.
• Upon arrival late in the afternoon, the mobile scrubber was staged and hooked up to necessary power sources.

• Remaining bulges in tarp/liners for both the equalization basin and the biological treatment basin were processed via fire suppression rain curtain with sequestering agent to minimize hydrogen sulfide migration. This operation was assisted via long reach excavator tarp/liner manipulation.
• Tarps/liners in both basins were gathered via long reach to appropriate locations along the inner edge of the ponds for removal in later stages.  The tarp were left in the ponds to prevent liner contamination and allows residual contaminant drainage.
• Hydrated lime stabilization and mixing was initiated in both ponds on the evening of the 6th.  The intent of this operation was to increase the pH in both ponds to short circuit the hydrogen sulfide gaseous releases.  
• Hydrated lime stabilization continued throughout the day on the 7th.  The equalization basin received approximately 75 tons.  The biological basin received approximately 50 tons.
• Overflow containment measures were constructed in the low spot of the adjacent road to the basins to mitigate and capture potential oil releases from the basins thus preventing discharge to the storm sewer.

10/08/2012 thru 10/09/2012

1. VIPER perimeter monitoring was discontinued after completion of basin stabilization by early afternoon of the 8th.
2. Operations for the 8th were as follows:

• Final application and mixing of approximately 25 tons of lime was completed by early on the afternoon of the 8th.
• Both basins were stabilized at an approximate ph of 10.
• Power panel shutdown was completed at all relevant buildings including aeration, discharge stations, sludge press and laboratory.
• Decontamination and demobilization of equipment and contractor personnel began during the afternoon of the 8th.

3. OSCs Neal, Francendese and Ball demobed during the afternoon of the 8th and facility gate was secured.
4. Remaining equipment was demobilized on the morning of the 9th.

10/15/2012

1. Site operations continues as an emergency action pending a ceiling increase in funding under a time-critical action memorandum.  A verbal increase for an additional $200,000 was approved by the Superfund Division Director to support operations at the Site.
2. Periodic air monitoring continues in the neighboring community.

10/17/2012

• ERRS and START conducted a joint sampling event to collect waste water to support future treatment and disposal operations from Equalization Basin No. 2 (3-million gal capacity)  and the Aeration Basin (7-million gal capacity).
• EPA OSC collected documents from the Laboratory building to support enforcement and cost recovery.
• Periodic air monitoring continues in the neighboring community.

10/23/2012

• ERRS remobilizes to prepare for extended operations and to set up field offices.
• Periodic air monitoring continues in the neighboring community.
• EPA conducts public meeting in Sylacauga, Alabama at the Cromer Recreation Center.  EPA, ATSDR, ADEM & Talledega EMA fielded questions from an estimated 200 attendees.  EPA OSCs David Andrews and Timothy Neal discussed EPA's response efforts and future goals regarding the ongoing removal operations.  ATSDR addressed questions concerning health concerns pertaining to the persistent odor from the site.  ADEM outlined Reef's regulatory history. 

10/24/2012 thru 10/26/2012

• ERRS utilized a 100-ft extended man-lift to inventory 8 above ground bulk storage tanks located in the loading bay where inbound tanker truck deliveries were off loaded.
• Periodic air monitoring continues in the neighboring community.
• ERRS begins grubbing the site.
• Office trailers to accommodate EPA, ERRS & START were delivered.  Utility installation is being coordinated.
• Subcontractor for odor control/elimination conducted initial site-walk to discuss with EPA chlorine dioxide treatment for the site's waste water basins.
• ERRS continues to monitor seepage and maintains soft boom in Shirtee Creek.

• EPA's Environmental Response Team (ERT) mobilized to the site to conduct air sampling to assess low level concentration of sulfur compounds that may compose the nuisance odor emitting from the site waste water basins.  This sampling event supplements the ongoing air monitoring by START.  ERT will collect grab samples over the next 4 to 6 weeks at established sampling locations during the early morning (pre-sunrise) hours that has been identified as the peak time when odor complaints have taken place. 
• Periodic air monitoring continues in the neighboring community.

• ERRS identifies "lime" (from Equalization Basin No. 2) at the seepage point on the bank of Shirtee Creek and excavates a portion of the bank to better reflect the seepage and control the discharge. 
• Periodic air monitoring continues in the neighboring community.

11/5/2012 thru 11/9/2012

• As an ongoing and weekly event, EPA's Environmental Response Team (ERT) mobilized to the site to collect air samples to assess low level concentration of sulfur compounds that may compose the nuisance odor emitting from the site waste water basins.  ERT collected air samples, in canisters, at five locations off site within the neighboring community to the southeast of the site and three on site next to the basins which are the source of the odors. Samples are collected at daybreak which has been the highest period of reported odor complaints.  
• Periodic air monitoring continues in the community by the Superfund Technical Assessment and Response Team (START) contractor in the early morning and late afternoon hours.
• The Emergency and Rapid Response Services (ERRS) contractor has completed installation of site office trailers and utilities connection to the trailers.  ERRS also completed detailed grubbing the site to permit safe access to major site features or structures and identify areas of concern.   ERRS continues maintenance of the seepage from Basin 2 that impacted the bank of Shirtee Creek.
• START mobilized a waste water treatment (WWT) engineer to consult with the OSC and ERT Technical Support and ERRS over treatment issues for the odor and treatment and discharge options of the 13-million gallons of waste water.  At this time, the OSC has reconsidered the use of chlorine dioxide (ClO2) gas as an oxidative treatment for the odor and is considering the use of hydrogen peroxide (H2O2) which may be an equally effective, cheaper and safer oxidative treatment option for this project. 
• The OSC is drafting a scope of work and Action Memorandum and will brief the Superfund Division Director on the first week of December to address the health threat, odor control, treatment and disposal for the 13+ million gallons of waste water. 

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

        The Office of Environmental Accountability (OEA) is  pursuing enforcement.

2.1.4 Progress Metrics

• After two meeting with EPA, discharge to the Sylacauga Utilities Board (SUB) municipal waste water treatment has not been approved.  Acceptable treatability standards will have to be accomplished prior to discharge approval by SUB. 
• ERRS continues control measures to control and contain the seep from Equalization Basin No. 2. 
• The OSC is coordinating efforts by ERT and waste water engineers with ERRS and START to evaluate treatment options for the three basins of waste water. H2O2 shows promise as the oxidation treatment solution for the odor and will not compromise future treatment steps.

• EPA (OSC) - 1

• START (Tetra Tech) - 1

• ERRS (WRS Compass)- 6

• ADEM - 1