Common use of PRP Group Activities Clause in Contracts

PRP Group Activities. In April 1991, the Interchem PRP Group performed an initial inspiection and inventory of the deteriorating wooden sheds located adjacent to the railroad tracks. The inspection revealed that the sheds housed containers with pesticides and other unidentified materials. The PRP Group transported 277 readily accessible empty drums from the sheds to Loveland Industries in Greeley, Colorado for triple rinsing and storage. The sheds were secured to restrict access. On June 13, 1991, an Administrative Order on Consent (AOC) was signed between EPA and the Interchem PRP Group. Pursuant to the June 1991 AOC, the PRP Group conducted the following site characterization activities in September/October 1991: • Exterior soil sampling; • Toxaphene Pad concrete sampling; • Monitoring well installation; • Groundwater sampling; • Conducting inventory of the Main Building; • Sampling of Tank contents. The site characterization study indicated that soil samples collected from areas on the north and east sides of the main building, as well as the toxaphene pad area, exceeded pesticide action levels established in the AOC. The study also indicated that five of the tanks contained fluids characterized as oil/water mixtures. The fire and explosive hazards associated with the tanks were considered minimal based upon the percent oxygen and low Lower Explosive Limit (LEL) values obtained using a Combustible Gas Indicator (CGI) during tank sampling in October 1991. The results of these investigations are discussed in the Site Characterization Report (WCC, 1992) with the exception of the inventory of the Main Building which is discussed in the Hazardous Materials Inventory Report (HMIR) (WCC, 1991a). The Phase I Interim Drum Removal was conducted by the PRPs pursuant to the 1991 AOC during October 1991 and consisted of the following: • All of the drums from the South Shed were removed and transferred to the North Shed. Two piles of unknown materials were removed from the South Shed and transferred to 55-gallon steel-drums, which were then moved to the North Shed. • The remaining empty containers (269) were removed from the Sheds by Heritage Remediation/Engineering, Inc. and transported to the Heritage facility in Lemont, Illinois. These drums were crushed and shipped to the U.S. Steel Works, where they were resmelted with other scrap metal. The walls, floors, and the interior roof of the sheds were vacuumed. • An inventory of the remaining drums was conducted. • Samples of the materials inside the drums were collected for screening tests to evaluate treatment/disposal options. • The sheds were secured to restrict access. During the April/May 1992 Phase I cleanup activities the drums from the sheds were transferred to an area adjacent to the main building prior to the dismantling and disposal of the sheds. The drums from the sheds were eventually transported off­ site for incineration on September 15, 1992. The contaminated exterior soils/concrete and free liquids in the above-ground storage tanks were also addressed during the April/May 1992 Phase I cleanup activities in accordance with the Removal Work Plan (WCC, April 1992). The liquids in the tanks were removed, the tanks rinsed, and all liquids properly disposed. After the tanks were drained two sets of CGI readings again indicated acceptable values for percent oxygen and LELs. The exterior soils/concrete that exceeded the pesticide action levels established in the AOC were excavated for offsite disposal. Excavated areas were backfilled and seeded. The Main Building has been secured, locked-up, warning signs posted, and the access controlled. The door locks were changed. All of the windows that were formerly broken have been boarded over, and all of the garage doors have been locked and padlocked from the inside. Entry is currently restricted to PRP individuals with keys. In accordance with the AOC, leaking and unstable containers were overpacked in 85-gallon drums. A total of twelve 55-galIon containers were overpacked into twelve 85-gallon drums. An inventory of all the containers and equipment inside the Main Building was documented in the HMIR. In September 1993 all containers and product listed on the HMIR were reevaluated resulting in profiling, consolidation, and staging of drummed material. As of August 1994, the drums await shipment for offsite disposal.

PRP Group Activities. In April 1991, the Interchem PRP Group performed an initial inspiection inspection and inventory of the deteriorating wooden sheds located adjacent to the railroad tracks. The inspection revealed that the sheds housed containers with pesticides and other unidentified materials. The PRP Group transported 277 readily accessible empty drums from the sheds to Loveland Industries in Greeley, Colorado for triple rinsing and storage. The sheds were secured to restrict access. On June 1318, 1991, an Administrative Order on Consent (AOC) was signed between EPA and the Interchem PRP Group. Pursuant to the June 1991 AOC, the PRP Group conducted the following site characterization activities in September/October 1991: • Exterior soil sampling; • Toxaphene Pad concrete sampling; • Monitoring well installation; • Groundwater sampling; • Conducting inventory of the the' Main Building; • Sampling of Tank contents. The site characterization study indicated that soil samples collected from areas on the north and east sides of the main building, as well as the toxaphene pad area, exceeded pesticide action levels established in the AOC. The study also indicated that five of the tanks contained fluids characterized as oil/water mixtures. The fire and explosive hazards associated with the tanks were considered minimal based upon the percent oxygen and low Lower Explosive Limit (LEL) values obtained using a Combustible Gas Indicator (CGI) during tank sampling in October 1991. The results of these investigations are discussed in the Site Characterization Report (WCC, 1992) with the exception of the inventory of the Main Building which is discussed in the Hazardous Materials Inventory Report (HMIR) (WCC, 1991a). The Phase I Interim Drum Removal was conducted by the PRPs pursuant to the 1991 AOC during October 1991 and consisted of the following: • All of the drums from the South Shed were removed and transferred to the North Shed. • Two piles of unknown materials were removed from the South Shed and transferred to 55-gallon steel-steel drums, which were then moved to the North Shed. • The remaining empty containers (269) were removed from the Sheds by Heritage Remediation/Engineering, Inc. and transported to the Heritage facility in Lemont, Illinois. These drums were crushed and shipped to the U.S. Steel Works, where they were resmelted with other scrap metal. The walls, floors, and the interior roof of the sheds were vacuumed. • An inventory of the remaining drums was conducted. • Samples of the materials inside the drums were collected for screening tests to evaluate treatment/disposal options. • The sheds were secured to restrict access. During the April/May 1992 Phase I cleanup activities the drums from the sheds were transferred to an area adjacent to the main building prior to the dismantling and disposal of the sheds. The drums from the sheds were eventually transported off­ site for incineration on September 15, 1992. The contaminated exterior soils/concrete and free liquids in the above-ground storage tanks were also addressed during the April/May 1992 Phase I cleanup activities in accordance with the Removal Work Plan (WCC, April 1992). The liquids in the tanks were removed, the tanks rinsed, and all liquids properly disposed. After the tanks were drained two sets of CGI readings again indicated acceptable values for percent oxygen and LELs. The exterior soils/concrete that exceeded the pesticide action levels established in the AOC were excavated for offsite disposal. Excavated areas were backfilled and seeded. The Main Building has been secured, locked-up, warning signs posted, and the access controlled. The door locks were changed. All of the windows that were formerly broken have been boarded over, and all of the garage doors have been locked and padlocked from the inside. Entry is currently restricted to PRP individuals with keys. In accordance with the AOC, leaking and unstable containers were overpacked in 85-gallon drums. A total of twelve 55-galIon gallon containers were overpacked into twelve 85-gallon drums. An inventory of all the containers and equipment inside the Main Building was documented in the HMIR. In September 1993 all containers and product listed on the HMIR were reevaluated resulting in profiling, consolidation, and staging of drummed material. As of August 1994, the drums await shipment for offsite disposal.