Contamination in the creek remains in Sections A, D and E of the creek. The ponds remain to be cleaned out.
On March 23, 2008, On-Scene Coordinator (OSC) Robert Wise reviewed the Health and Safety Plan (HASP) provided by Greka's new contractor, Filter Recycling Services (FRS). The HASP did not meet the requirements pursuant to 29 CFR 1910.120(b)(4): Site Specific Safety Plan under HAZWOPER. OSC Wise provided comments to FRS. FRS had also been directed to provide the Health and Safety Program Plan pursuant to 29 CFR 1910.120(b)(1), but failed to provide it with the HASP. With the comments, OSC Wise directed again to provide the Program Plan as well as the Respiratory Protection Program plan pursuant to 29 CFR 1910.134.
On March 26, 2008, OSC Wise directed Greka to have their contractor's revised plan to EPA by March 27, 2008. FRS provided the plan, but again it did not meet the minimum regulatory requirements pursuant to 29 CFR 1910.120(b)(4). FRS also failed to provide the other requested documents. On March 31, 2008, EPA notified Greka that FRS was unacceptable to conduct the cleanup.
On March 28, 2008, Greka notified EPA that they would be unable to meet the April 1, 2008 deadline for the Upper Bell Pond excavation. On March 26, 2008, OSC Wise reminded Greka that the plan was due and that their would be no further extentions.
Greka was also in violation of the Bell Lease 311(c) Clean Water Act Order for failure to provide Workplan 1 as described in the Order and the post-removal sampling plan.
Based on the above facts, plus the continued presence of oil in the creek, EPA took control of the Bell Lease 3 Spill on March 31, 2008. Greka was verbally notified on March 31, 2008 and in writting on April 1, 2008.
OSC Wise deployed the ERRS contractor to the site on March 31, 2008, to begin planning for the cleanup. On April 1, 2008, ERRS repaired the underflow dams in the creek and prepared the creek for the pending rain event forcasted for April 2, 2008.
ERRS is also setting up the command post and conducting other logistical tasks in preparation for the start of cleanup operations. Cleanup operations are expected to begin on April 3, 2008.
1. Remove oil from creek on in Section A. Oil is being released from historical asphaltic formations. After consulting with other agency stakeholders, it is believed that the fresh oil from the spills is liberating oil from this area. The fresh oil will be removed via mechanical excavation. The excavations will initally not exceed a depth of 3' bgs.
2. Removal of oil in Section D and E. Free standing water containing oil will be removed. The oil containing sediment will then be removed using mechanical methods.
3. Removal of sediment from the Upper Bell Pond. The sediment removed will be disposed of off-site along with all material removed from the creek.
4. The creek will be restored to prevent downstream sediment loading and erosion. The restoration will be conducted in cooperation with the California Department of Fish and Game (CADFG). A PRFA will be issued to CADFG to provide technical assistance to EPA during the cleanup.
1. Setting up a command post. The command post will be located at 6840 Palmer Road, Santa Maria, CA.
2. Excavation of Section A.
1. The excavation of Section A will be initially conducted in several test areas to determine the implications of excavating the asphaltic formations in the creek seeping the crude oil.
2. On April 2, 2008, EPA will be meeting with the CADFG biologist and stream alteration specialists to discuss restoration and excavation issues.
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