2.1.1 Narrative
On September 2, 2010 the Action Memo was approved to expend up to $1,039,042 to conduct a time-critical removal action at the Pickens Plating Site. Corrosive substances in drums, containers and vats were sampled and returned with pHs as low as 0.8 standard units (su) and as high as 12.5 su. Both levels are considered characteristically hazardous. Numerous drums labeled “hydrofluoric acid” were also present in the building. These drums were not opened during the Site Assessment due to the extreme hazard they present for inhalation and skin adsorption. Fumes from stainless steel drums labeled as “nitric acid” produced a pH of 0.0 su on field equipment. The site has over 40 open vats of plating chemicals that had pHs which considered characteristically hazardous.
The floors of the building were in poor condition and showed numerous signs of chemical spills. Staining on the floor indicated years of waste accumulation from general operation and poor house keeping on-site.
The building is unwatched and fairly secluded with no perimeter fencing to keep out prospective vandals and scavengers. Leaks in the roof in many locations will lead to premature corrosion of containers within the building, increasing the chance for a release of these substances. The rain water from the leaky roof also has the potential to enter open-top acid vats and react, causing an airborne vapor release.
2.1.2 Response Actions to Date
On 10/25/2010, ERRS completed clearing space for a drum staging area by cutting RCRA empty drums and containers and placing the carcasses in a roll-off box for disposal. ERRS also removed any metal debris that was inhibiting clear access to drums, vats, and other containers. Metal debris was placed in a separate roll-off box for recycling. ERRS sampling crew continued sampling vats and drums. ERRS chemist began haz catting solids and liquids from vats and drums.
On 10/26/2010, ERRS continued cutting RCRA empty drums and other non-metal debris and placing it in a roll-off box for disposal at C&C Landfill in Marshall, Michigan. Metal debris was placed in a separate roll-off box for recycling. One load of RCRA empty drums and debris was hauled off site to be disposed of at C&C Landfill in Marshall, Michigan. ERRS sampling crew continued sampling vats, drums, and other containers of waste. ERRS chemist continued haz catting small samples collected by the sampling crew.
On 10/27/2010, ERRS sampling team continued sampling drum and vat contents. Samples were haz catted by the ERRS chemist. Drums 130 and 135 had hits for cyanide. These two drums were staged away from other drums containing corrosives. ERRS continued cutting RCRA empty drums and other non-metal debris and placing these items in a roll-off box for disposal at a C&C Landfill in Marshall, Michigan. Metal debris was placed in a separate roll-off box for recycling.
On 10/28/2010, ERRS sampling team continued container sampling. ERRS chemist continued haz catting samples collected by the sampling team. ERRS also continued disposal of RCRA empty drums and recycling of scrap metal. ERRS continued cutting RCRA empty drums and other non-metal debris and placing these items in a roll-off box for disposal at a C&C Landfill in Marshall, Michigan. Metal debris was placed in a separate roll-off box for recycling. Kevin Markovich from the Albion Department of Public Service stopped by the Site for an update on work
On 10/29/2010, ERRS sampling team completed container sampling. ERRS chemist completed haz catting samples collected by the sampling team. ERRS also continued disposal RCRA empty drums and scrap metal. ERRS continued cutting RCRA empty drums and other non-metal debris and placing these items in a roll-off box for disposal at a C&C Landfill in Marshall, Michigan. Metal debris was placed in a separate roll-off box for recycling.
Throughout the week, USCG performed health and safety oversight and conducted work zone air monitoring with a MultiRae. No readings elevated above background were reported and no safety incidents were noted.
USCG also monitored the air around the perimeter of the facility with AreaRaes. HCN sensors installed in the Area Raes were operated while ERRS was in the work zone. No readings elevated above background were recorded. U.S. EPA assumed documentation duties from START and USCG assumed file keeping duties.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The title search report and information obtained from Calhoun County indicate that the current owner of the Site is the Calhoun County Treasurer's Office. U.S. EPA will obtain an appraisal of the property to ascertain its value. Depending on the value of the property (and whether Calhoun County has Bona Fide Prospective Purchaser (BFPP) status under CERCLA), U.S. EPA may place a lien on the property, pursuant to CERCLA sections 107(1) or 107(r). A 104(e) information request may also be sent to a representative of the dissolved corporation, to discover whether assets were transferred from the corporation within the clawback period established by relevant Michigan law. If substantial assets were transferred from the corporation within the clawback period, U.S. EPA will attempt to capture those assets to offset the costs of the response action.
2.1.4 Progress Metrics
Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
RCRA Empty Containers and General Debris |
Solid |
30 CY |
0057 |
|
C&C Landfill |
RCRA Empty Containers and General Debris |
Solid |
30 CY |
0059 |
|
C&C Landfill |
RCRA Empty Containers and General Debris |
Solid |
30 CY |
0058 |
|
C&C Landfill |
RCRA Empty Containers and General Debris |
Solid |
30 CY |
0060 |
|
C&C Landfill |
Scrap Metal |
Solid |
40 CY |
N/A |
Recycled |
|
Scrap Metal |
Solid |
40 CY |
N/A |
Recycled |
|
Scrap Metal |
Solid |
40 CY |
N/A |
Recycled |
|
|