A Jan. 13 letter from EPA to the Elkhart, Ind.-based CTS rejects the company's proposal for a series of soil tests at the site, on the basis that the plan does not include a sufficiently thorough group of sampling points and depths that were recommended in an independent sampling design developed by a third-party engineering firm.
EPA contracted with a Native-American-owned Wisconsin-based firm, Oneida Total Integrated Enterprises, to provide technical support to the EPA at the CTS site. Oneida, which provides expertise in Superfund-related cases, was asked to conduct a technical review of a plan developed by a CTS contractor for soil sampling to confirm the adequacy of volatile organic compound removal at the site by an on-site Soil Vapor Extraction system.
A soil-vapor extractor was installed at the CTS site back in 2006; the EPA says it collected some 6000 pounds of hazardous compounds before it was disabled in 2010 when vandals removed the copper pipes that serviced the device.
The primary objective of the investigation now being planned is to collect subsurface soil samples at the site to confirm the adequacy of volatile organic compound removal by the earlier system from the soil beneath the CTS facility. This soil investigation is being completed under an Administrative Order on Consent signed between EPA, CTS Corporation and current property owner Mills Gap Road Associates back in January, 2004.
EPA has given CTS seven days to respond with written notice that it intends to conduct the more thorough sampling regimen. The agency further demands that CTS implement the more stringent plan developed at Oneida within 30 days; if it does not, EPA says the agency will do so independently.