PRP Group Activities Clause Samples

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...