United States Environmental Protection Agency
Region V
POLLUTION REPORT

Subject: 

Economy Plating Inc. is a former plating shop which operated for approximately 70 years.  The site was discovered vacant and abandoned by the Chicago Department of the Environment (DOE) in January 2009. Markings on the drums/containers include chromic acid, hydrochloric acid, methyl acetate, and oxidizer. DOE ordered the owner/operator to clean up the site. However, the owner/operator was unable to pay for the cleanup. The site was referred to USEPA for cleanup in May 2009.

USEPA conducted a site assessment on June 5, 2009 and found evidence of break-ins and trespassers, as well as holes in the building where weather can enter the facility. Approximately 195 containers (open and closed, 5 gallons and greater), as well as 12 vats were found containing old chromic acid solutions, other acids, and unknown solids. Several containers were found to be leaking in the basement. Results received on June 12, 2009 indicated open containers of solids contained up to 350,000 mg/kg of total cyanide. An emergency removal action was conducted from June 13-17, 2009 which collected, packaged, and properly disposed two drums of the high level cyanide materials.  In addition, 18 leaking containers were repacked and a drum of nitric acid was repacked.  The building was re-secured and signs put up to discourage trespassing.  

An action memorandum for Time Critical Removal Action was signed on Aug. 4, 2009.  Field activities were initiated on Aug. 31, 2009, and were completed to the extent practicable on November 19, 2009.  The removal work completed during that time in the main plating shop and old plating shop areas included removal and cleaning of metal vats and the removal of solid and hazardous debris and sludge. Accessible windows and doors were boarded up and locked, and the parking lot was fenced to deter trespassers. During this period, the cleanup team made significant progress towards mitigating the threat to human health and the environment presented by the facility, including: 1) recovering, decontaminating, and recycling an additional 16.455 tons of scrap metal; 2) collecting and disposing of 25 cubic yards of hazardous waste; 3) shipping 128 drums of chromium contaminated hazardous waste offsite; 4) disposing of 26 drums of additional hazardous substances, which included cyanide, nitric acid, hydrochloric acid, sodium hydroxide, mercury, PCB light ballast, fluorescent lamps, and flammables; 5) removing 160 cubic yards of solid waste; and 6) sampling the site for additional environmental factors.  As a result of additional environmental sampling, the response team confirmed the presence of chromium contaminated soil beneath the main plating shop pit.  In addition, hexavalent chromium has seeped through the building and is now located on the building’s exterior walls.  Controls to block exposure pathways to surrounding residents have been installed including epoxy sealant, plywood boards, and metal fencing.  Signs have been posted to deter people from touching contaminated walls and to deter trespassers.  However, to eliminate the potential threat to human health and the environment presented by the building itself, removal of this contamination through demolition of the building and disposal of the material is necessary.

A second action memorandum was signed on June 18, 2010 requesting a ceiling increase and exemption from the 1 year statutory limit from the removal action.

In order to gain legal access to demolish the Site’s building and complete the removal action, USEPA worked several months to obtain an Federal Administrative Warrant which was signed on September 28, 2010.  

After acquiring asbestos abatement and demolition subcontractors (Robinette), EPA re-mobilized to the site on November 8, 2010.  Asbestos contractors removed asbestos containing material (window and door seals) from the building.  In addition, ERRS removed universal waste left in building, including mercury thermostats and freon from remaining white goods.

The building was demolished.  During demolition, contaminated surface water runoff was controlled using a vac truck.  Dust was controlled primarily using water from a nearby fire hydrant in coordination with the Chicago Fire Department.  During the Demolition period, the following hazardous substances were removed and properly disposed from the site: 250 tons hazardous soil, 462 tons hazardous debris, 150 cubic yards hazardous debris, 330 kg of PCBs, 45 cubic yards of asbestos containing material, and 1,955 gallons of hazardous liquid.  In addition, about 600 cubic yards of solid debris was removed and disposed from the Site.

Contaminated soil underlying the pit in the main plating shop and the basement below the old plating shop area was excavated to approximately 8 feet below the sidewalk level. Soil samples were field screened using the XRF instrument and submitted for laboratory analysis to confirm that the soil was non-hazardous and below the TACO tier 1 remediation objectives for commercial properties.  Clean demolition debris was used to backfill the excavation.  Clean backfill materials were also used to fill in the excavation.  

During demolition activities, ambient air monitoring was conducted daily for particulates.  In addition, air samples for asbestos and total metals including chromium, lead, and arsenic analyses were collected for 4 days in the work zone, upwind, and downwind when hazardous substances were most likely be released.  Results of the air monitoring and sampling indicated that all contaminants of concern were below NIOSH and OSHA criteria.  

Freezing temperatures onsite prevents the use of asphalt and concrete to replace about 20 feet of contaminated wall on the north side of the Site, small portion of the sidewalk and alley. OSC has decided to return to the Site in the Spring 2011 to complete the cleanup.

On February 4, 2011, U.S EPA and ERRS mobilized to the Site to repair the temporary fence which had been destroyed by the Blizzard and to clear out the sidewalks around the site.

• On April 25, 2011, U.S. EPA, WESTON START, and ERRS re-mobilized to the Site to remove the remaining contaminated wall, repair the concrete sidewalk along Winchester Street, and install permanent fencing around the perimeter of the Site.  The removal activities summarized below were conducted from April 25 through May 5, 2011.

• The remaining portion of the contaminated brick wall on the west side of the site and fill material along the wall was removed.  Approximately 15 yd3 of chromium solids (hazardous soil) were removed from the Site (Manifest No. 008261352JJK) and transported to Envirite, Inc. of Harvey, Illinois for stabilization and disposal.

• On April 26, 2011, U.S. EPA and WESTON START collected one confirmatory soil sample under the sidewalk of the gangway on the west side of the Site.  The soil sample was submitted for laboratory analysis of total metals and TCLP metals.  Analytical results indicated total metals concentrations below the TACO values.  The TCLP metals results were below the TCLP regulatory criteria.  

• A new concrete wall was installed along the gangway on the west side of the Site.

• The damaged concrete sidewalk along Winchester Avenue was removed and a new sidewalk was installed.

• Permanent security fencing was installed along the perimeter of the Site to restrict access to the Site.  The fencing was equipped with a gate along the alley (southwest) side of the Site that has been secured with a padlock.  

•  Fresh gravel was brought on to the Site to fill in any exposed soil and regrade the ground to ensure proper drainage.

On May 9, 2011, the U.S. EPA OSC conducted a final walk through of the Site to ensure completion of field work.

None.  Site work is complete.

None.