The Electro Tech facility, located at 13511 NE Kerr Road in Vancouver, Washington, is a small electro-polishing business located in a small industrial park east of downtown Vancouver. The business park is comprised of 13 rental units of which Electro Tech operates out of 4 units: Units 4, 5, 6 and 7. Brad Reiner, the owner of Electro Tech, also rents Unit 10 for personal storage. The entire business park is owned by Ms. Sally Biffle, who also owns J&S Steel, a company operating out of the same business park. The business park is surrounded by light industrial and commercial businesses. Residential neighborhoods are located within 500 feet of Electro Tech on the north, south, and west sides.
Since at least 2001, the Washington State Department of Ecology has documented recurring Resource Conservation and Recovery Act (RCRA) compliance violations. In July 2007, a release occurred at the facility that resulted in electro-polishing solutions (listed hazardous waste F006 and characteristic waste because of chromium toxicity) leaving the building and entering the two storm drains in the parking lot. Arsenic, cadmium, chromium, and lead have been found in samples collected by Ecology in Site groundwater and soil and the facility septic system above their respective Washington State Model Toxics Control Act Method A Cleanup Levels (unrestricted land use cleanup levels). Electro Tech operates on property located inside the City’s ten-year zone of contribution for a municipal well head, meaning groundwater and groundwater contaminants at the property would be expected to migrate to the municipal well head within ten years.
On March 11, 2009, EPA and Ecology visited the Site and conducted an inspection and an inventory of hazardous substances on Site. Inside the Electro Tech shop were seven vats of various dimensions and eight 55-gallon drums. Five of the seven vats contained metal polishing solutions and two of the 55-gallon drums contained liquid contents. Based on generator knowledge, the owner of the business claimed these substances to be RCRA-listed hazardous wastes and stated his intent to arrange for disposal of the wastes at an approved facility. In addition to the wastes, contaminated containers, and other debris, the floors, walls, ceiling, and other hard surfaces of the building itself are suspected to be contaminated based on staining, pitting, and other signs of chemical corrosion.
On March 17, 2009, Washington State Department of Ecology formally requested EPA assistance in addressing contamination at the property where Electro Tech operates. Ecology specifically cited concerns about metals contamination in soil and groundwater caused from discharges into the septic systems serving the entire business park, historically large quantities of waste generated at Electro Tech, and their failure to comply with state dangerous waste regulations. Ecology referred to Electro Tech’s failure to comply with Ecology’s 2007 Administrative Order and Penalty. Ecology has sought to compel Electro Tech’s compliance with the Ecology Order through the courts. Electro Tech has yet to fully comply despite a court order issued in February 20, 2009. The City of Vancouver also has encouraged EPA involvement due to their concern for their domestic water supply.
In January 2010, EPA finalized an Administrative Order on Consent issued to Mrs. Biffle to conduct a removal at the Electro Tech business. The scope of the removal project includes removal and disposal of electro polishing wastes found in the tanks and containers, removal and disposal of contaminated equipment and debris, and decontamination of building surfaces (floor, walls, and ceiling). The removal project began on March 4, 2010 and is expected to conclude by March 15, 2010.
