U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Paw Paw Plating - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V

Subject: POLREP #4
Continuation of Removal Action
Paw Paw Plating
B5WV
Paw Paw, MI
Latitude: 42.2113869 Longitude: -85.8949757


To: Jason El-Zein, U.S. EPA
Sam Borries, U.S. EPA
Mindy Clements, U.S. EPA
Thomas Marks, U.S. EPA
Mike Ribordy, U.S. EPA
Charlie Gebien, U.S. EPA
John Glover, U.S. EPA
Jerry Kujawa, U.S. EPA
Debbie Keating, U.S. EPA
Krause Patti, U.S. EPA
Yolanda Bouchee-Cureton, U.S. EPA
Sherry Fielding, US EPA
David Chung, U.S. EPA
David Harn, MDEQ
David Heywood, MDNRE
Mark Ducharme, MDNRE
Larry Nielsen, Village of Paw Paw
Bruce VanOtteren, MDEQ
Dan Wyant, MDEQ
Bill Schuette, Michigan Department of Attorney General
Joe Walczak, MDEQ
Rodney Stokes, Michigan DNR
Wayne Babcock, U.S. Department of Interior
Robert Burr, U.S. Department of Interior
Lindy Nelson, U.S. DOI
NPFC USCG, USCG
USCG PolRep Distribution, USCG
FEMA Polrep, FEMA

From: Tricia A. Edwards, OSC
Date: 4/1/2011
Reporting Period: 3/12/11 - 4/1/11

1. Introduction
  1.1 Background
   
Site Number: B5WV    Contract Number:  
D.O. Number:      Action Memo Date:  
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 2/7/2011    Start Date: 2/7/2011
Demob Date:      Completion Date:  
CERCLIS ID:    RCRIS ID:
ERNS No.:    State Notification:
FPN#:    Reimbursable Account #:


1.1.1 Incident Category

1.1.2 Site Description

Paw Paw Plating started primarily as a  custom electroplating operation in the 1950’s and stopped operations in December 2009.  The site is about 1.8 acres, is not fenced and contains an abandoned building with chemicals and other hazardous materials.  The site is located at 139 Commercial Ave., Paw Paw, Michigan.  Cadmium, chromium, silver, gold, nickel, copper and cyanide were used in the electroplating process.  The company also performed metal processing such  as machining, polishing and painting which included the use of Trichlorethylene (TCE).

There are a variety of abandoned hazardous materials in the building including plating baths containing heavy metals, drums of plating feed stocks, drums of hazardous waste, and a number of different size containers with a wide variety of chemical compounds. Plating solutions include but are not limited to cyanide and chromium. The presence of containers, drums and vats without secondary containment could result in contaminating soil and ground water, and pose a threat to nearby residents and businesses if a fire was to occur.

Past investigation activities by the Michigan Department of Natural Resources and Environment  indicated that contaminants  were  released into the storm sewer that discharges directly in to the Paw Paw River and also were discovered in a municipal water well that served the village of Paw Paw . Halogenated volatile organic compound (HVOCs) contamination, including TCE was identified in ground water.


1.1.2.1 Location
Paw Paw Plating located at 139 Commercial Avenue in Paw Paw, Van Buren County, Michigan 49079.

1.1.2.2 Description of Threat
Cyanides, Acids, Bases, Oxidizers, Toxics, Heavy Metals

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results


2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative

2.1.2 Response Actions to Date
Refer to earlier POLREPS for past response activities.

Air monitioring is conducted daily on site.  START maintains 4 AreaRAEs and 1 Multi-RAE while work is being conducted.

During this reporting period, ERRS removed additional piping and ancillary equipment in the plating room and water treatment room so that once all of the vats have been cleaned, they can be removed.

As of Friday, April 1 ERRS completed the removal of the the solids in the cyanide bats.  ERRS continued to clean the remaining vats to remove the solids remaining at the bottom.  The use of a high-pressure, hot water unit was utilized to break up the material.  The solids were containerized for disposal.

ERRS is developing the necessary paperwork (ie profiles) to prepare requests for quote for disposal for EPA approved CERCLA facilities for disposal.

START prepared a statement of work (SOW) for the subsurface investigation for the Membrane Interface Probe and the GeoProbe work to be conducted.  The SOW was shared with ERRS, who will three-bid the work.  The forecasted start date is the week of April 18.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Paw Paw Plating went out of the business when the owner died in December 2009.  The estate for the deceased owner does not have the funds to conduct the clean up. 

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
           
           
           



  2.2 Planning Section
   

2.2.1 Anticipated Activities
 - Removal of solids from vats
 - Removal of vats from the plating room
 - Removal of solids below the vats
 - Containerization of vats for metal recycling
 - Preparation of waste profiles for disposal
 - Coordination of transportation of waste
 - Solicit bids for sub-surface investigation


2.2.1.1 Planned Response Activities

The focus over the next few weeks will be to coordinate disposal. 

ERRS will begin the process of removing the vats from inside of the plating and water treatment rooms.  Due to the construction and layout of the plating room, it is difficult to determine the amount of contamination below the vats, although it is evident that there is contamination and build up of solids.  Once the vats have been removed, a subsurface investigation will be conducted.  In addition, a plan will be developed and implemented to manage the solid waste. 
 

2.2.1.2 Next Steps

2.2.2 Issues


  2.3 Logistics Section
    No information available at this time.

  2.4 Finance Section
   
   
Estimated Costs *
  Budgeted Total To Date Remaining % Remaining
Extramural Costs
ERRS - Cleanup Contractor $500,000.00 $247,396.18 $252,603.82 50.52%
TAT/START $90,916.00 $52,731.65 $38,184.35 42.00%
Intramural Costs
USEPA - Direct $0.00 $17,077.50 ($17,077.50) 0.00%
USEPA - InDirect $0.00 $34,155.00 ($34,155.00) 0.00%
 
Total Site Costs $590,916.00 $351,360.33 $239,555.67 40.54%

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.


  2.5 Other Command Staff
    No information available at this time.

3. Participating Entities
  3.1 Unified Command


3.2 Cooperating Agencies
Michigan Department of Natural Resources & Environment (MDNRE)

4. Personnel On Site
  U.S. EPA
START - Weston Solutions
ERRS - Environomental Restoration (ER)

5. Definition of Terms
  No information available at this time.

6. Additional sources of information
  No information available at this time.

7. Situational Reference Materials
  No information available at this time.

POLREP #4 Last Updated 5/3/2011