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2.1.1 Narrative
The
removal action involves the removal of contaminated soils up to two feet below
ground surface found on site. Hazardous substances will be profiled, packaged,
and transported to off-site disposal facilities that are in compliance with the
EPA Offsite Rule. All waste streams will be profiled and disposed of
appropriately. Contaminated soil will be excavated and backfilled.
The property will be graded and stabilized.
2.1.2 Response Actions to Date
During the period of 25 January – 30 January 2016, 6 grid
excavations were completed to a depth of 6 – 12 inches below ground surface;
excavated grids are located on the center portion of the site. Nine
confirmation samples from current and previously excavated grids were collected
and shipped to ALS Environmental Labs, located in Houston, Tx for analysis of
Lead contamination. One of the twelve confirmation sample results were above
the Lead action level of 800 mg/kg, the associated grid will be excavated an
additional 6 inches and re-sampled for Lead contamination. No
transportation and disposal activities occurred during this period. Air
monitoring instruments were deployed daily to monitor for particulates in the
air during excavation activities.
On 01/26/16, geophysical survey sub-contractor arrived on site
to perform surveys on specific grids throughout the site. The northern portion
of grid B07 was identified to have potential drums below ground surface and
several spots surrounding the perimeter of B07 were identified. A total of 53
empty and collapsed drums were discovered at a depth between 2ft to 3ft, and 4
miscellaneous objects were also discovered around the perimeter.
During the period of 1 February – 6 February 2016, 6 grid
excavations were completed to a depth of 6 – 24 inches below ground surface;
excavated grids are located towards the south of the site. Seven confirmation
samples from current and previously excavated grids were collected and shipped
to ALS Environmental Labs for analysis of Lead contamination. All sample
results were below the Lead action level of 800 mg/kg. An estimated 800
tons of excavated soil was transported to Maloy Landfill during this period.
Air monitoring instruments were deployed daily to monitor for particulates in
the air during excavation activities. Back
fill activities commence as soil from Vrzalik Pit in Terrell, Texas arrive via
transportation trucks. A total of 15 back fill transportation trucks each with an estimated 20 tons of soil arrived
on site and a total of 23 out of 32 girds have been back filled to date.
During the period of 8 February – 10 February 2016, no excavation
activities or sampling activities were completed. An estimated 1,000 tons of
excavated soil was transported to Maloy Landfill during this period. A total of 8 back fill transportation trucks
each with an estimated 20 tons of soil arrived on site and a total of 29 out of
32 grids have been back filled to date.
On 02/09/2016, monitoring well removing sub-contractor
arrived on site to perform plug and abandon activities of 14 monitoring wells
spread throughout the site. 1 of 14 monitoring wells were removed completely
and the remaining 13 monitoring wells were plugged in place. Sub-contractors
plugged all monitoring wells with bentonite and removed concrete pads. No
visible monitoring wells above ground are visible on site.
On 02/10/2016, START and ERRS contractors demobilize from
site for a scheduled site break. Operations will resume 21 February.
During the period of 21 February – 29 February, START and
ERRS mobilized to site to begin excavation and sampling activities; 3 grid
excavations were completed to a depth 6 -12 inches below ground surface located
towards the south of the site. Three confirmation samples were collected and
shipped to ALS Environmental Lab for analysis of Lead contamination. All
samples results were below the Lead action level of 800 mg/kg. An estimated 550
tons of excavated soil was transported to Maloy Landfill during this period. A
total of 10 back fill transportation trucks arrived on site and all 32 grids
have been back filled and graded to date.
To date, an estimated 4,200 tons of excavated soil has been
transported from the site to Maloy Landfill.
On 02/29/2016, START and ERRS contractors demobilize from
site; all activities on site have been completed.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The Site PRPs formed a steering committee, the Chemical Recycling Incorporated Steering Committee and has elected not to perform the Removal Action.
2.1.4 Progress Metrics
Disposal
metrics for the reporting period are below.
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| Non- Haz Lead |
Soil |
~800 tons |
2945040 - 2945079 |
None |
Maloy Landfill |
| Non-Haz Lead |
Soil |
~1000 tons |
2945080 - 2947935 |
None |
Maloy Landfill |
| Non-Haz Lead |
Soil |
~550 tons |
2947936 - 2947960 |
None |
Maloy Landfill |
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