United States Environmental Protection Agency
Region II
POLLUTION REPORT

Subject: 

See POLREPs 1 and 2.

Site work continues as follows:

• Sampling and hazard characterization activities are complete as of 8/14/09.  A total of 842 samples of waste materials have been collected from drums, tanks, vats and equipment reservoirs.  The samples were field analyzed for hazard characterization and used to develop composite sampling schemes for laboratory analysis and waste profiling.
• EPA/ERRS has completed loose packing approximately 30% of the small waste containers (5 gallons and less).  The remainders are awaiting analytical results needed for waste profiling and disposal.  
• Equipment from the zinc plating and zinc phosphate coating lines has been disassembled, decontaminated and staged for disposal.  Some of the vats will be salvaged for re-use; those with no recycle value are being demolished and placed in roll-off containers for transportation and disposal.  
• Wastes and chemical residues are currently being removed from the sumps/troughs that were located beneath the plating and coating equipment.  The waste is being transferred to roll-off containers in preparation for transportation and disposal.  
• EPA/ERRS is approximately 95% complete with sampling and laboratory analysis of wastes targeted for off-site removal.  As soon as all laboratory results are received, waste profiling and solicitation for transportation and disposal services will be initiated.  To date, approximately 40 potential waste streams have been identified.  
• EPA/ERRS is pursuing recycle alternatives for the methanol and propane from the tanks located on-site.
• Approximately 1,500 cubic yards of non-hazardous debris and approximately 12 tons of zinc-laden filter cake from the water treatment system have been shipped for disposal.  Spent drums that contained zinc wastes have been demolished and placed in roll-off containers for transportation and disposal.
• The fire suppression system at the Site is in poor condition and requires periodic maintenance and repair.  EPA/ERRS continues to make repairs to the system using a licensed local vendor to ensure that the system remains operational and in compliance with the Clifton fire code.

A metal recycler that entered into a contractual agreement with the Trustee/auctioneer is still in the process of disassembling and removing plant equipment.  EPA/ERRS continues to coordinate with the recycler as needed to ensure appropriate management of wastes associated with equipment liquidation.  Additionally, EPA is confining intrusive work to well-defined areas that are remote from the equipment removal activities to avoid conflicts in health and safety requirements and to avoid interfering with auction-related activities.

Currently EPA plans to remove all chemical waste drums, containers and laboratory chemicals.  Additionally, EPA will remove and dispose of wastes from all vats, tanks, sumps and equipment reservoirs and will conduct surface decontamination of the plating line sumps, troughs and other areas as necessary.  EPA will continue to work closely with the Bankrutpcy Trustee to identify chemicals that may have value and can be sold or reclaimed.

The Next Steps Planned for removal acitivities include the following:

• Initiate surface decontamination of the plating line sumps/troughs;
• Dismantle the remaining austemper equipment and decontaminate the associated below-grade sumps;
• Dismantle the air-scrubber systems and dispose of wastes contained therein.
• Evaluate analytical results, establish waste profiles and solicit subcontracts for transportation and disposal of on-site wastes.

The Action Memorandum was approved on July 14, 2009.  An additional $5K has been obligated to the IAG with the USCG Atlantic Strike Team to conduct H&S assistance during removal activities.