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Valley Post and Sawmill. Craig Myers, OSC. Site History. Primarily a sawmill Began treating posts in the early 1980’s Operated until approximately 1996 EPA and WYDEQ joint inspection in 1987. 1987 Inspection. 1987 Inspection. 1987 Inspection. F032 not promulgated until 1988
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Valley Post and Sawmill Craig Myers, OSC
Site History • Primarily a sawmill • Began treating posts in the early 1980’s • Operated until approximately 1996 • EPA and WYDEQ joint inspection in 1987
1987 Inspection • F032 not promulgated until 1988 • Inspection identified numerous imminent violations when F032 is promulgated • No drip pads • Improper storage • Dumping of spent solution • Lack of follow-up by both EPA and WY DEQ RCRA for unknown reasons.
DEQ requests assistance • DEQ “learns” of property - Oct 2008 • Locate retort and solution tanks in Guernsey • Request EPA assistance to assess tanks - May 2009 • Follow-on request to assess former facility
PO sends several loads of scrap steel to recylcer • PO claims that the tanks were cleaned prior to transport • Tanks are refused until they are “processed” • Scrapper can’t locate a large metal shear before WYDEQ finds the tanks.
Guernsey Assessment • Both tanks still contain/are waste • PCP/wood treatment process equipment exempt from “RCRA Empty” • 40 CFR 261.35 • Deletion of waste code • Retort tank - 8,000+ ppm PCP • Retort tank still contains last load of posts • Both tanks have 3/8” holes. • CID contacted • Potentially criminal RCRA/DOT violations
VP&S Assessment • June 2009 • Confirming presence of PCP • Attempt to delineate • Use of GeoProbe • Field screen based upon color, odor, PID/FID • Lab Samples indicated larger source area • Color and PID/FID not reliable as a screen
VP&S Assessment • Returned September 2009 • Mobilized EPA mobile lab w/ SVOA GC/MS • 80+ soil samples analyzed in 2 days • Full characterization, no data gaps at demobilization.
Tank cleaning • Tanks contain flammable residue • Cannot be legally offered for transport. • Waste code can be deleted, steel recycled. • Stringent process required by 40 CFR 261.35 • Dioxins ND below 10-50 parts per quadrillion in the final rinse.
Removal at VP&S • Tasks • Construct treatment cell • Grub/clear debris • Grade • Excavate source area • Finish cleaning tanks • Solvent rinses • Thermal destruction
September 2009 - Removal Site Evaluation June 2010 - Removal Action - treatment area 90% complete
Final Stats • Approximately 800 cubic yards of soil excavated • Approximately 4 tons of steel sent off-site as F032 waste to be smelted • Approximately 2 tons of steel recycled. • Treatment is in process • Completion is forecast for 4th quarter FY10 or 1st quarter FY11.