The Interim Removal Measure is to remove tarry waste materials from Lagoons 1 and 2 at the site. After removing much of the waste from Lagoon 2, it has become apparent that the pressure of ponded rainwater in Lagoon 3 has caused the berm between Lagoon 2 and 3 to become saturated and therefore unstable. If the berm fails, unknown amounts of hazardous material from Lagoon 3 could flow into Lagoon 2. Therefore, unless action is taken promptly, before the next significant rain event, this berm could fail catastrophically and threaten the physical integrity of the approved removal action in Lagoon 2, potentially endangering workers at the site and ultimately compromising the existing remediation effort.
Placing and mixing LKM into Lagoon 3 would reduce the moisture from the southern portion of Lagoon 3. Following placement of the LKM, the reduction of seepage forces could be achieved by construction of a temporary sump within Lagoon 3. The placement and mixing of LKM with Lagoon 3 materials should allow for the construction of a storm water sump within Lagoon 3. As a result, the ponded water could be removed and not allowed to remain in the southern portion of Lagoon 3 where it is causing instability of the berm. Additionally, this emergency action would minimize the seepage forces in the berm. Therefore, it is urgent that LKM be placed into Lagoon 3 prior to the next significant rain event.