U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Accurate Plating Company - Removal Polrep
Initial Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
Subject: POLREP #1
Time Critical Removal Action
Accurate Plating Company
C540
Cleveland, OH
Latitude: 41.5010300 Longitude: -81.6453580

To: Mike Dziak, Cleveland Division of Fire
NRC Duty Officer, National Response Center
Kevin Clouse, OEPA
Michael Chezik, US DOI
Mila Bensing, USEPA
Mark Durno, USEPA
Jason El-Zein, USEPA
Mark Johnson, USEPA
Jeff Kelley, USEPA
Linda Nachowicz, USEPA
Carol Ropski, USEPA
Jerome Kujawa, USEPA
Sherry Fielding, USEPA
Suzanne Prusnek, OEPA
From: James Augustyn, OSC
Date: 7/7/2011
Reporting Period: 06/22/2011 through 07/08/2011

1. Introduction
  1.1 Background
   
Site Number: C540    Contract Number:  
D.O. Number: 71    Action Memo Date: 6/2/2011
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 6/22/2011    Start Date: 6/22/2011
Demob Date:      Completion Date:  
CERCLIS ID: OHN000510578    RCRIS ID:
ERNS No.:    State Notification:
FPN#:    Reimbursable Account #:


1.1.1 Incident Category

Time Critical Removal Action

1.1.2 Site Description

Accurate Plating Company (Accurate) began electroplating at the Site in 1965.  Electroplating operations included grinding, polishing, detergent cleaning and rinsing, metal plating (cadmium, cyanide zinc, caustic zinc, acid zinc, nickel, and brass) and final rinsing.  Accurate ceased plating operations in 2009.

The Ohio EPA and the Cleveland Fire Prevention Bureau inspected the facility on November 29, 2010.  During the inspection, Ohio EPA inventoried fifty six (56) 55-gallon drums and (1) 250-gallon tote labeled by the owner as hazardous waste.  In addition, there were forty eight (48) 55-gallon drums labeled with non-hazardous waste labels.

In mid-2010, Accurate closed the facility and abandoned the electroplating waste at the Site.  The owner attempted to drum and label waste to aid in disposal but had insufficient funds to proceed with disposal of waste off-Site.

1.1.2.1 Location

The Accurate Site is located at 6512 Carnegie Avenue, Cleveland, Ohio 44103

1.1.2.2 Description of Threat

In addition to the drummed waste, there are multiple in-ground storage pits which contain cyanide ladened rinse waters.  Two plating lines containing sludge are present at the Site.  All tanks associated with the facility’s wastewater treatment unit are assumed to contain untreated wastewater.

Vandals have stolen all of the copper plumbing and electrical wiring and continue to break into the facility to steal scrap metal.  On November 5, 2010, the fire department responded to a fire at the facility.  The fire investigation suspects arson to be the cause of the fire.  Frequent break-ins continue at the facility.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

On April 29, 2011, U.S. EPA OSC James Augustyn conducted a Site visit with the owner and representatives of the Cleveland Fire Prevention Bureau.  Conditions at the Site remain as stated in the Ohio EPA referral package.
2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative

2.1.2 Response Actions to Date

On Wednesday, June 22, 2011, ERRS and START contractors mobilized personnel and equipment to the Site.  Three (3) Waste Management 30-cubic yard (c.y.) roll-off boxes were delivered to the Site.  ERRS filled one box with non-hazardous debris and the box was transported to Waste Management's American Landfill at Waynesburg, Ohio.

On Thursday, June 23rd, ERRS began cleaning debris from floor trenches and cutting/removing PVC pipe-runs from the trenches.  Continued placing non-hazardous debris into roll-off boxes.  Scrap steel was segregated for recycling.  Three (3) debris boxes was transported off Site to American Landfill.

On Friday, June 24th, ERRS activities same as previous day.  ERRS began collecting and staging miscellaneous drums and containers for sampling and disposal.  One (1) debris box was transported off Site to American Landfill.

On Monday, June 27th, ERRS activities same as previous day. ERRS completed removing PVC piping from trenches in the south wing of the facility.  Residual liquids were pumped to the central trench leading to the waste water treatment unit.  Crew began hand-shoveling sludge from trenches into drums.

On Tuesday, June 28th, ERRS activities were the same as previous day.  Completed remving PVC pipe runs in the central wing of the facility.  Two (2) debris boxes were transported off Site to American Landfill.

On Wednesday, June 29th, ERRS activities were the same as previous day.  One (1) scrap steel roll-off box was picked up by Cleveland Scrap and $479.90 was credited back to the Site.

On Thursday, June 30th,  ERRS completed collecting and staging miscellaneous drums and containers for sampling.  All drums and containers were numbered and hazard characterization samples were collected.  In addition, hazard characterization samples were collected from all tanks, vats, pits, and trenches.

On Friday, July 1st, ERRS began cutting up two (2) 3,000-gallon, fiber glass storage tanks in the waste water treatment unit.  Continued placing non-hazardous debris into roll-off boxes.  All 55-gallon drums previously staged by the property owner were placed on pallets and segregated by waste stream determined by a cleanup contractor hired by the owner.  START and OSC Lori Muller conducted Hazmat ID and Ahora waste profile identification on approximately 70+ hazard characterization samples at the Westlake office.

On Tuesday, July 5th, ERRS completed cutting storage tanks and drummed residual wastes.  Fiber glass tanks were placed in non-hazardous waste roll-off box for disposal.  One (1) scrap steel roll-off box was picked up by Cleveland Scrap and $733.92 was credited back to the Site.

On Wednesday, July 6th, ERRS completed taking down florescent light bulbs for recycling and cutting down light fixtures that contain PCB ballasts from the central wing of the facility.

On Thursday, July 7th,  ERRS completed opening and sampling all 55-gallon drums previously staged by the property owner.  Hazard characterization sampling was performed on remaining samples.

On Friday, July 8th, ERRS completed removing florescent light fixtures from south wing of the facility and placed into scrap steel box for recycling.  PCB ballasts were removed from the fixtures for disposal.

Activities performed by START from June 22, 2011, to July 8, 2011, included:  written and photographic documentation of Site activities and conditions; observing ERRS on site removal activities, and the collection air monitoring readings.  One (1) scrap steel roll-off box was picked up by Cleveland Scrap and $408.00 was credited back to the Site.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

The Accurate Plating Company is owned and operated by Mr. Charles Foley Jr.
 

On February 2, 2010, Ohio EPA received from Accurate a 30-day extension request to the 90-day hazardous waste accumulation time limit.  The request was approved by the Ohio EPA but subsequently expired on March 8, 2010.  The owner was unable to secure funding to ship the waste off Site for disposal.  Ohio EPA issued a Notice of Violation (NOV) on April 12, 2010.

 

On August 23, 2010, Ohio EPA issued “Proposed” Orders to Accurate to properly dispose of all waste off Site.  Accurate did not reply to the Proposed Orders.

 

On February 17, 2011, the Ohio EPA received notification from the owner’s personal legal counsel of his intent to file for personal bankruptcy.

On May 17, 2011, U.S. EPA issued a General Notice of Potential Liability to Mr.Foley.  Mr. Foley did not provide a written response to the Notice Letter. .

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
           
           
           



  2.2 Planning Section
    No information available at this time.
  2.3 Logistics Section
    No information available at this time.
  2.4 Finance Section
    2.4.1 Narrative

ERRS costs as of 7/6/11 (including pending costs)

Scrap steel reimbursement $1,622 

   
Estimated Costs *
  Budgeted Total To Date Remaining % Remaining
Extramural Costs
ERRS - Cleanup Contractor $150,000.00 $56,537.00 $93,463.00 62.31%
TAT/START $25,000.00 $9,644.00 $15,356.00 61.42%
Intramural Costs
USEPA - Direct $42,000.00 $5,500.00 $36,500.00 86.90%
 
Total Site Costs $217,000.00 $71,681.00 $145,319.00 66.97%

* 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
  No information available at this time.
4. Personnel On Site
  One (1) U.S. EPA OSC, one (1) START Contractor, six (6) ERRS contrator personnel (1 RM, 1 FCA, 1 T&D Coordinator, 1 Foreman, 2 Laborers).

5. Definition of Terms
  No information available at this time.
6. Additional sources of information
  6.1 Internet location of additional information/report


6.2 Reporting Schedule
Weekly

7. Situational Reference Materials
  No information available at this time.
POLREP #1 Last Updated 7/27/2011