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USEPA negotiated a Consent Order with the PRP Group (Commonwealth Edison, AT&T Corporation, and Fermi Research Alliance LLC) to address the imminent and substantial endangerment documented by the previous site assessments. The Consent Order was signed on October 14, 2009. Prior to implementation of the removal work plan submitted under the Order, the City of Elgin agreed to voluntarily remove the drums and cylinders from the site and provide access to the PRP Group. U.S. EPA reviewed, commented and oversaw the voluntary action by the City of Elgin.
On July 14, 2009 the City of Elgin hired Terracon and SET Environmental, Inc (SET),to conduct the following activities:
A total of 130 cylinders were inventoried and staged onsite (fire extinguishers, acetylene, propane, and chlorine). SET determined that several of the cylinders will need an overpack for transportation due to condition and/or not having a DOT approved sticker on them. A total of 78 drums inventoried and staged onsite (metal shavings/slag, oily substances, magnesium powder, and misc contents). SET determined that most (if not all) of the drums will need an overpack for transportation due to condition. A sample was collected from each drum for analyses needed in determining transportation and disposal costs. At this time, the cylinders and drums will remain onsite. The cylinders are nested and chained under a portion of the building’s roof. The drums are staged on a concrete pad with poly sheeting and absorbent boom.
On August 24, 2009, US EPA, SET, Terracon, and WESTON mobilized to the Elgin Salvage site to begin removal of immediately dangerous materials. Terracon subcontracted the removal operations to SET Environmental (SET) of Wheeling, Illinois. U.S. EPA On Scene Coordinators Steve Faryan and Brian Schlieger were on site, and START contractor Weston Solutions provided oversight. An Elgin Fire Department representative was on site and volunteered support if the decision was made to “flare off” a large propane cylinder. OSC’s Faryan and Schlieger reviewed and signed the health and safety plan (HASP). SET overpacked compromised cylinders, including one chlorine gas cylinder and two liquefied petroleum gas (LPG) cylinders, into cylinder overpacks. The sturdy outer cylinders were sealed and the empty space inside the overpack was interted with nitrogen gas. While overpacking compromised cylinders, SET monitored for chlorine gas with Drager tubes. They were prepared to upgrade to level B PPE if there was a release. START monitored for VOC’s, LEL, and H2S with a MultiRAE. There were no readings above background levels. After testing the contents of the large propane cylinder, SET determined that the contents could be treated by venting the cylinder through a drum of activated carbon. After procuring the activated carbon and proper valve fittings, the propane was treated with this method. On August 25, 2009, US EPA, Terracon, SET, and WESTON returned to the Site to continue removal activities. SET continued to label cylinders and load them into a semi-trailer. Compromised drums containing hazardous levels of metals and other contaminants were overpacked into 85 gallon salvage drums. Several bags of flammable metals including magnesium turnings and aluminum powder were manually load into drums and mixed with mineral oil to render the material non-flammable. All drums were loaded into a SET semi-trailer. SET also loaded (2) 20 yd3 and (1) 30 yd3 roll-off box with scrap metal and other debris at the site. All roll-off boxes were transported to Waste Management’s Countryside Landfill in Gray’s Lake, Illinois for disposal. All hazardous materials, drummed non-hazardous material, and cylinders were loaded into a semi-trailer for transport and treatment and/or disposal at SET’s facility in Texas. The contents of the semi-trailer were: (9) 85 gallon drums of magnesium turnings in oil, (5) 85 gallon drums of aluminum powder in oil, (9) 55 gallon drums of aluminum powder in oil,(1) 85 gallon drum of metal sheets in oil,(3) 85 gallon drums of machinery oil (2) 85 gallon drums of non-hazardous liquid/sludge,(8) 85 gallon drums of hazardous metal solids,(4) chlorine gas cylinders,(23) acetylene gas cylinders,,) ammonia gas cylinder,(31) propane cylinders,(10) oxygen cylinders,(39) fire extinguishers,(5) carbon dioxide cylinders (3) compressed gas, flammable cylinders,(3) compressed gas, non-flammable cylinders,(1) nitrous oxide cylinder,(9) empty cylinders
The activities approved in the Removal Work Plan submitted by the PRP Group and approved by USEPA initiated on October 21, 2009 . US EPA and Weston met on site to discuss the upcoming soil removal and confirmation sampling over the next two to three week period. CRA is the prime contractor for the PRP Group. EQ is CRA’s subcontractor who will perform on-site removal activities and transportation and disposal of soil. According to EQ (Ron Evenson) there will be approximately 300-400 yards of material leaving the site, which includes: Non-Hazardous refuse, TSCA soil and Non-TSCA soil (treated and untreated). All Non-Hazardous material will be shipped to VEOLIA in Loves Park, IL and all Hazardous material will be shipped to Belleville, MI.
On October 21, 2009, removal of non-hazardous surface debris began by removing the material from the concrete surfaces and placed it into roll-offs for disposal by the City as general refuse.
On October 22, 2009 through October 30, 2009 the following work activities occurred on the Site:
•Excavation areas were staked. •Shoring of the lean-to roof in northeast corner. •Approval and disposal of the non-hazardous debris was completed •Approximately 90% of the debris (burned/collapsed lean-to) was manifested and transported off-site for disposal. •Stabilization of the designated TSCA soils using EnviroBlend. •Stone was brought in for site entry to lessen mud tracking to street from trucks. All soil stockpiles were covered and secured with poly while awaiting for loading and off-site disposal •Confirmatory sampling was conducted at all of the soil excavation areas •Non-hazardous refuse previously loaded into roll-off boxes were removed by the City •Removal of the non-hazardous building demolition debris was conducted •Seeping and pressure washing of the concrete surfaces was completed, •Removal and disposal of soil from 2 non-TSCA excavation areas •Several dioxin samples were collected by Terracon •All non-TSCA soil was removed from site •Deep excavations were backfilled with clean fill •All TSCA soil was transported and disposed of at Enviromental Quality's landfill in Belleville, Michigan. The crew and equipment were demobilized on October 30 The week of November 6, 2009, Decon water and debris were removed and disposed of by Environmental Quality.
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