Cleanup Enforcement

General
Railroad Spill of Grain

1. State whether or not any fumigant or pesticide was ever released, and if so, the dates this occurred. For each release, please include the chemical or trade name of such fumigant or pesticide, the quantity which was released, and steps taken to recover or cleanup the chemicals. Were these releases ever reported to any local, state, or federal official? If so, state the name and address of the official or agency, the date of the report, and any action taken by the official. For purposes of this question, "release" means any spilling, leaking, dumping, pouring, pumping, discharge, emitting emptying, discharging, escape, or disposal.
2. Provide the names, addresses, and telephone numbers of all individuals and/or companies contracted to provide grain fumigation services at any time at Company A.
3. State the trade or chemical name of each fumigant, pesticide, herbicide or fungicide stored, or held by Company A, for resale. Include the amount of each such chemical purchased or acquired during each year fumigants or pesticides were stored or held for resale. Also, describe the Facility or Facilities in which fumigants or pesticides were stored or held.
4. Identify by chemical or trade name and the fumigants and pesticides applied to grain stored at Company A, during each time period. For each period, state the quantity of fumigant or pesticide applied to stored grain.
5. Was carbon tetrachloride ever used to treat grain stored at Company A?
6. State the trade or chemical name of each fumigant, pesticide, herbicide or fungicide stored, or held by the Company for resale; the amount of each such fumigant or pesticide purchased or acquired during each year such fumigants or pesticides were stored, or held for resale; and describe the Facility or Facilities in which such fumigants or pesticides were stored or held.
7. Identify by chemical or trade name the fumigants and pesticides applied to stored grain by the Company during each period mentioned in your answer to the previous question and for each such period state the quantity of each fumigant or pesticide applied to stored grain.
8. Provide information on the methods (past or present) utilized by the Company (or commercial applicator) for the treatment of stored grain.
9. What is the frequency (per year) that fumigants/pesticides are applied to the stored grain?
10. Clarify if Grain Company A has receipts (for the purchase of chemicals) that would be available for review by the EPA.
11. Provide a detailed explanation of the method used for the treatment of these small loads, what chemicals were utilized, and define "small load". Also, provide the name, address, and telephone number of the individual(s) who hauled the trash/waste form the Company Facility.
12. State the trade or chemical name of each fumigant, pesticide, herbicide or fungicide stored, or held by the Company for resale; the amount of each such fumigant or pesticide purchased or acquired during each year such fumigants or pesticides were store, or held for resale; and describe the Facility or Facilities in which such fumigants or pesticides were stored or held.
13. Identify by chemical or trade name the fumigants and pesticides applied to stored grain by the Company during each period mentioned in your answer to the previous question and for each such period state the quantity of each fumigant or pesticide applied to stored grain.
14. Provide information on the methods (past or present) utilized by the Company (or commercial applicator) for the treatment of stored grain.
15. What is the frequency (per year) that fumigants/pesticides are applied to the stored grain?
16. Clarify if Grain Company A has receipts (for the purchase of chemicals) that would be available for review by the EPA.
17. Provide a detailed explanation of the method used for the treatment of these small loads, what chemicals were utilized, and define "small load". Also, provide the name, address, and telephone number of the individual(s)who hauled the trash/waste from the Company Facility.
18. Did you ever oversee or participate in the handling, formulating, packaging, storage, and/or disposal of industrial grade pesticides, products in process or finished pesticide products at the Site? Explain the extent and nature of your participation in such activities.
19. Provide information on the construction details of the facility. State when each structure was built, number of grain bins, the capacity of each bin, the type of flooring material(s) used for each structure (if concrete was used, is it sealed or unsealed).
20. Provide information on the storage of grain. Was grain ever stored on uncovered ground (outside the elevator)? If grain was stored on an outside area, state whether or not it was treated. If the grain was treated, what method(s) and fumigants were utilized.
21. State whether any of the following chemicals was ever used by the Cooperative and if so what each chemical was used for:
    1. carbon tetrachloride
    2. benzene
    3. 1,2-dichloroethane (also known as ethylene dichloride).
22. Provide the names addresses and telephone numbers of all individuals and/or companies who contracted to provide grain fumigation services at any time at the Cooperative.
23. State whether any fumigant, pesticide, or other chemical referred to in your answers, was ever released to the environment, including but not limited to the area beneath and around the grain storage building(s); and, if known, the dates such release occurred. For each such release, include the chemical and trade names of the fumigant and pesticide, the quantity of each that was released, and any steps taken to recover or clean up the chemicals. Were these releases ever reported to any local, state or federal official? If so, state the name and address of the official or agency, the date of the report.
24. Describe the nature of any business relationship(s) between the Cooperative and the U.S. Department of the Agriculture (USDA) and/or USDA's Commodity Credit Corporation (CCC). For example, has the ever rented storage space to the USDA or CCC or had any other agreement or arrangement with either agency to store grain on their behalf? If so, please list the dates of such storage, the product(s) which were stored and any pesticide or fumigant or other chemical treatment methods which were used on the grain prior to or during storage.
25. Provide a description of waste treatment and disposal methods generally at Cooperative Association, Inc., including how empty pesticide, fumigant and other chemical solvent containers were disposed of.
26. Describe the procedures for cleaning application equipment and where this was done.
27. How long has the property where your cooperative is presently located been used for storage of grain by the Company or any other entity operating at this location? Is grain stored at this location each year? What is the length of the storage period?
28. State the periods during which grain was stored by the Company.
29. Describe the treatment of stored grain by the Company during each period mentioned in your answer.
30. Provide a description of waste treatment and disposal methods during any work at Grain Company X. Please include a description of how empty pesticide and solvent containers were disposed of.

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    Railroad Spill of Grain

31. Describe in detail the Railroad's use, during its ownership, of parcels ___ and ___ which are also identified as tax lots ___ and ___ respectively.
32. State all dates when the Railroad utilized the above-referenced properties for storage, handling or loading of grain products. Provide documents to substantiate the usage of the property for grain storage or handling.
33. State all inclusive dates when the Railroad leased the above-referenced properties for storage, handling or loading of grain products. Provide documents to substantiate the usage of the property for grain storage or handling.
34. Provide information including documents which indicates that the Railroad used or arranged for the use of liquid grain fumigants, including, but not limited to, carbon tetrachloride.
35. Provide documents indicating the Railroad's relationship with Grain Storage, Inc.
36. Provide information including documents that identify other parties who leased properties before or after occupancy by Grain Storage, Inc.
37. Identify others who may be able to provide information to EPA regarding the above-referenced properties. These include, but are not limited to, railroad employees and inspectors, either private or governmental (at city, county, state, and federal levels).
38. State whether or not the Railroad obtained a license from the state or federal grain inspection authorities in connection with your activities at the above-referenced site. Provide copies of licenses if your answer is affirmative.
39. Describe any spills or accidents involving liquid fumigants at the properties identified in Attachments 2 and 3 during the period of your ownership. Specify what fumigant was involved, in what quantity, and the response to the accident or spill.

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