Toolbox Safety Meetings are held each morning before the start of the work day. Meeting topics are related to the actual work activity scheduled for that particular day.  EPA’s Mobile Command Post is staged by a nearby truck scale each day document tare and loaded weights for all trucks entering and leaving the site. 

During this reporting period, the crew continued the demolition and sludge removal phase of the project.  Using a 55 ton hydraulic crane, the superstructure and roofs were removed off tanks 140 thru 142 (65’dia x 35’ high). This enabled the demo crews to access the sides of the tanks safely. The sides of these tanks were stainless steel and required the use of a Plasma Arc to cut the steel (see Section 5). Sheets of stainless sheets were measured and connected to the crane with “picking eyes” prior to cutting.  After the steel plate was cut and removed it was deconned and prepared for transport to the recycler.  To date, a total of 737.69 tons including 22 tons of stainless steel have been shipped off site.

While tank demolition continued, sludge removal crews continued solidification of contaminated materials found in the tank bottoms and prepared the material for transportation and disposal (T&D). Solidification of the sludge materials required an add-mix of wood flyash and sawdust to bring it to an acceptable quality for T&D. The add-mix quantity differed from tank to tank from 30% to as much as 60%.  As of this reporting period 3025 tons of non-hazardous sludge (pH <12.5) have been removed.  Corrosive liquids that were extracted from the sludge were consolidated into frac tanks, pending off-site disposal.

As demolition of tanks 140 thru 142 continued, a second demo crew prepared to pull over tanks 63 thru 66 (30dia x 40’ high). Wire rope slings (1 1/4” x 70’ long) were shackled together and connected to a 80,000 lb. excavator.  As a safety precaution and prior to pulling the tank to the ground, a Job Hazard Analysis was performed including an engineered planned layout drawing. To control the direction of the planned fall, a relief cut was made approximately 5’ up from the bottom of the tank and approximately 20’ wide. This “Controlled Method” was used to help direct and drop the tank slowly and safely to the ground. A warning signal was given by the SSO using a hand held air horn before the tank was dropped. Once the tanks were on their sides, demo crews easily removed the roof and bottom allowing the tank cylinder to be cut and laid out in one flat section.

Demolition continued on the next series of tanks 36 thru 38. The decision was made to dismantle tank 36 using the onsite 55 ton crane to handle the steel cut by oxygen & acetylene torches. Tank 36 was constructed very close to an electrical switch gear room and any steel that could fall from the demolition of the tank could damage the building. Tank 38 was constructed with a stainless steel inner liner and a mild steel outer shell. The stainless liner had leaked and made it very difficult for the torch operator to cut through the double wall tank shell. The liquor trapped in the annulus of the double wall tank caused splash back on to the torch operator and created a hazardous work environment. To alleviate this problem a 80,000 lb. excavator with large set of demo shears was mobilized to the site and dismantled the double wall tank quickly and safely.

As the sludge and mixing structures were removed from tanks 140 thru 142, it was learned that these tanks had conical bottoms and the corrosive material below the thin/eroded concrete bottom was at a higher pH than the sludge itself.  This necessitated a new profile for the waste as it would need to be disposed at a Subtitle C facility.  The TO was modified to add additional funding and ERRS prepared an RFP and disposal profile for this material.  Bids have been received and ERRS received subcontract consent from the CO.

A nominal amount of mercury-contaminated debris that was identified during the early days of this project (two 55-gallon drums) and waste sulfuric acid (two 55-gallon drums) were prepared for T&D.  Additionally, two flasks of elemental mercury were prepared for retirement.   

With the majority of pulping liquors gone and the rainy season over, frac tank temporary storage needs diminished.  A total of 11 frac tanks were on site for this project providing a total storage capacity of 231,000gal.  As frac tanks were emptied, they would be cleaned and demobbed from the site.  Prior to cleaning any of the tanks, a Confined Space Entry permit is filled out and issued by the SSO and a site specific activity meeting is held at the tank to be entered and cleaned.

2.1.2 Response Actions to Date

04-09 May 2015 - OSC Waldon

Completed removal of stainless steel sides on tank 141. Continued to remove sections of steel from tank 36.  Deconned and prepared steel for shipment to recycler.

Completed cleanout of sludge from tank 142

Continued extraction of liquids from tanks 19, 38, and 141.

Removed pipe rack from tank 19

Solidified and removed sludge from tanks 19 and 141.  Plan to use tank 19 as a solidification mixing tank

Continued removal of mixing rakes from tanks 140 and 141

Dismantled tanks 63 and 64 and began dismantling tanks 65 and 66

11-16 May 2015 - OSC Calanog

Continue solidification and removal of sludge from tank 141

Continue extraction of liquids from tanks 19, 38, and 141

Cut larger access in tank 38 and remove sludge and commence dismantling.

Completed dismantling tank 66

Remove sludge from tank 19 to make room as sludge mixing tank

Continued removal of rakes from tanks 140 and 141

Removed two tanks from the boiler building and solidified caustic material and drummed sulfuric acid for disposal

Continued solidifying sludge with sawdust and fly ash in tanks 7, 8, 19, and 42

Completed removal mercury contaminated items from warehouse.  Waiting on proper packaging material to prepare elemental mercury for retirement.

18-23 May 2015 - OSC Guria

26-28 May 2015 - OSC Heister

Sludge Trucks:                   T&D 33 loads x 21 tons = 693 tons

Liquid Tanker Trucks:      T&D 4 loads = 23,710 gallons

Tanks dismantled:           Horizontal Turpentine Tank (No Tank#) dismantled with shears

                                                Tank 38 dismantled with shears

                                                Tank 37 pulled down and dismantling ongoing

Frac Tanks:                          Emptying and decon'ing continues

Asbestos Piping:               ACM wrapped and prepped for shipment and offsite disposal

Hg, Misc. T&D Debris:     Profiling of material on going

Metal Scrapping:              Stainless and milled steel decon'ed, segregated and recycling  continues

The shears arrived Tues. PM and were used Wed AM to cut up horizontal turpentine tank and began work on Tank 37 when they broke down. 

28 May – 13 Jun 2015  OSC Weden

Complete Load and transport sludge materials to offsite disposal per task order

Completed demolition of tank 37

Continued hauling Liquor from Frac Tanks 7012  and 7252  to offsite disposal

Cleaned Frac Tanks as they are emptied and demob off site.

Demolished Tank 38 with Excavator & Shears

Continued to decon and prepare ship steel scrap for shipment to off-site recycle

Covered tanks 7, 8, 19 and 42 in case of rain event.

Received T&D bid results for additional sludge materials 6/10/15, subcontract consent received from CO by COB 6/12/15!

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