U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Lyndon Street Drums - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
Subject: POLREP #7
Time-Critical Removal Continues
Lyndon Street Drums
Pending
Detroit, MI
Latitude: 42.3955500 Longitude: -83.1502640

To: Jason El-Zein, U.S. EPA
Beverly Kush, U.S. EPA
Osric Wilson, DFD
Harold Watkins, DFD
Robin Eagan, DFD
Bruce VanOtteren, MDEQ
Jennifer Wolf, MDEQ
Joe DeGrazia, MDEQ
Ray Scott, Detroit Environmental Affairs
John Maritote, U.S. EPA
Carol Ropski, U.S. EPA
Michael Chezik, U.S. DOI
Sherry Fielding, U.S. EPA
Duty Officer, USCG
Joe Walczak, MDEQ
Shawn Battle, DFD
Patricia Lawton, MDEQ
Charles Gebien, U.S. EPA
Thomas Marks, U.S. EPA
Jeffery Trevino, ORC
John Glover, U.S. EPA
Mark Johnson, ATSDR
Linda Dykema, MDCH
Christina Bush, MDCH
Lisa Quiggle, MDCH
Edward Primeau, USCG
Joel Ferguson, USCG
Jon Gulch, U.S. EPA
David Szymanski, Wayne County
From: Jeffrey Lippert, On-Scene Coordinator
Date: 12/10/2011
Reporting Period: 12/5/2011 - 12/10/2011

1. Introduction
  1.1 Background
   
Site Number: C566    Contract Number: EP-S5-08-04
D.O. Number: 0039    Action Memo Date: 9/14/2011
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 8/18/2011    Start Date: 8/18/2011
Demob Date:      Completion Date:  
CERCLIS ID: MIN000510622    RCRIS ID:
ERNS No.:    State Notification: 08/18/2011
FPN#:    Reimbursable Account #:

1.1.1 Incident Category
The Lyndon Street Drums Site began as an emergency response on August 18, 2011.  The site was secured and U.S. EPA began a time-critical removal on October 24, 2011.

1.1.2 Site Description
The site is the abandoned laboratory of Riverside Organics, Inc.  The site is bordered by Lyndon Street and commercial and industrial properties to the south, a vacant lot and commercial and industrial properties to the west, residential homes to the north, and industrial and commercial properties to the east.

1.1.2.1 Location
It is located at 8100 Lyndon Street, Detroit, Wayne County, Michigan 48238.

1.1.2.2 Description of Threat
U.S. EPA was contacted by the Detroit Fire Department (DFD) on August 18, 2011 regarding hundreds of drums and miscellaneous containers, many leaking, in an abandoned building at 8100 Lyndon Street, Detroit, Wayne County, Michigan 48238 (site). DFD requested assistance with securing the site and removal and disposal of the drums and containers.

U.S. EPA secured the building and leaking drums, collected samples and conducted air monitoring during emergency response activities on August 18, 2011.  Over 500 drums and containers existed inside the building in very poor condition.  U.S. EPA collected five waste liquid samples during emergency response activities.  All five samples were characteristically hazardous for either ignitability, corrosivity, or toxicity as defined by 40 C.F.R § 261.21, §261.22, or §261.24, respectively.   All samples collected by U.S. EPA also contained various levels of cyanide, a CERCLA hazardous substance.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
U.S. EPA responded to the site on Thursday, August 18, 2011 at approximately 1400 hours. U.S. EPA confirmed the presence of hundreds of drums and containers at the site. Many were marked "Toxic", "Flammable", "Corrosive", "Poison", "Reactive", and "Dangerous When Wet", many were leaking and in poor condition.

Many containers were stacked on top of each other and incompatiple wastes (containers labeled "oxidizer" and "corrosive") were stored in close proximity of one another.  VOC readings were over 500 ppm on two drums that were opened during sampling activities.

The building is in a state of disrepair. Holes in the roof are allowing rain and snow to infiltrate the building.  Precipitation was contributing to the already unstable condition of the drums and containers. There was no perimeter fencing and the building was open and unlocked.
2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative
U.S. EPA was contacted by DFD on August 18, 2011 regarding hundreds of drums and miscellaneous containers, many leaking, in an abandoned building at 8100 Lyndon Street, Detroit, Wayne County, Michigan 48238. DFD requested assistance with securing the site and removal of the drums and containers. 

U.S. EPA responded to the site on Thursday, August 18, 2011 at approximately 1400 hours. U.S. EPA confirmed the presence of hundreds of drums and containers at the Site. Many were marked "Toxic", "Flammable", "Corrosive", "Poison", "Reactive", and "Dangerous When Wet", many were leaking and in poor condition.

The building is in a state of disrepair. Holes in the roof are allowing precipitation to infiltrate the building.  The precipitation was contributing to the already unstable condition of the drums and containers. There was no perimeter fencing and the building was open and unlocked.

U.S. EPA secured the wastes and the building and conducted air monitoring and drum sampling on August 18, 2011.

U.S. EPA remobilized to the site on October 24, 2011 and began the time-critical removal action.

2.1.2 Response Actions to Date

For the week of 12/05/11 - 12/10/11, U.S. EPA completed hazcat activities and began bulking compatible liquid wastes.  A total of 329 samples were hazcatted and the contents of 149 containers were verified with the First Defender RMX.  Thirteen waste streams have been identified and sampled for disposal.  Disposal samples were shipped to the laboratory for disposal analysis.  Four BASF cylinders were shipped to BASF for recycling.  U.S. EPA continued staging containers for lab pack activities.  U.S. EPA collected soil samples in an area of stressed vegetation behind the building.  USCG - AST completed their tour on Saturday, 12/10/11.

During all response activities, U.S. EPA conducted air monitoring for contaminants.  No readings above action levels were recorded.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The enforcement process is on-going.

2.1.4 Progress Metrics
Waste Stream Medium Quantity Manifest # Treatment Disposal
 Hazardous liquid
(Hydrazine Hydrate)		  gallons  55 g  008968929  H141 Dynecol, Inc
Detroit, MI
 Hazardous liquid
(Thionyl Liquid)		  gallons  55g  008968929  H141 Dynecol, Inc
Detroit, MI
 Hazardous liquid
(Allyl Chloride)		  pounds  40  009226931  H141 Petro-Chem Processing Group Detroit, MI
 Hazardous liquid
(Allyl Bromide)		  pounds  60  009226931  H141 Petro-Chem Processing Group Detroit, MI
 Hazardous liquid
(Toulene, Sodium Dihydrobis (2-methoxyethoxy)Aluminate)		  pounds  120  009226931  H141 Petro-Chem Processing Group
Detroit, MI
Hazardous liquid
(Hydrogen Peroxide)		  pounds  30  009226931  H141 Petro-Chem
Processing Group
Detroit, MI
Hazardous liquid
(Benzyl Chloride)		  pounds  100  009226932  H141 Petro-Chem
Processing Group
Detroit, MI
Hazardous Liquid
(Methylmagnesium Chloride, Tetrahydrofuran)		  pounds  60  009226932  H141  Petro-Chem
Processing Group
Detroit, MI
Hazardous Liquid
(Styrene Monomer)		  pounds  50  009226932  H141 Petro-Chem
Processing Group
Detroit, MI
Hazardous Liquid
(Trimethylacetyl Chloride)
  pounds  50  009226932  H141 Petro-Chem Processing Group
Detroit, MI
Hazardous Solid
(Sodium Borohydride)		  pounds  30  009226932  H141 Petro-Chem
Processing Group
Detroit, MI
Hazardous Solid
(Waste Magnesium Metal Chip)		  pounds  140  009226932  H141 Petro-Chem
Processing Group
Detroit, MI
Hazardous Liquid
(Lithium Borohydride)		  pounds  50  009226932  H141 Petro-Chem
Processing Group
Detroit, MI
Hazardous Liquid
(Sodium Hydride)		  pounds  80  009226932  H141 Petro-Chem
Processing Group
Detroit, MI
Hazardous Solid
(Benzoyl Peroxide)		  pounds  30  009226932  H141 Petro-Chem
Processing Group
Detroit, MI
 Hazardous Solid
 (Waste Sodium)		  pounds  06  009226932  H141 Petro-Chem
Processing Group
Detroit, MI
 Waste Sulfuryl Chloride gallons 20 009653648  H141  Dynecol, Detroit, MI


  2.2 Planning Section
   

2.2.1 Anticipated Activities

Continue to transfer drums and containers from building to conex boxes prior to lab-pack activities;

Enter all hazard categorization data into U.S. EPA's ERT DrumTrak database program;

Continue general cleanup activities; and

Continue air monitoring during removal activities.

2.2.1.1 Planned Response Activities

Secure the building and leaking containers;

Develop and implement a site-specific Health and Safety Plan;

Develop and implement a site Work Plan;

Inventory, hazcat, and sample for off-site disposal hazardous substances in drums and containers;

Conduct off-site disposal of drums and containers and their contents;

Excavate and dispose of contaminated soil; and

Backfill excavation areas with clean soils and restore the site as needed.

2.2.2 Issues
None.
  2.3 Logistics Section
    Not Applicable.
  2.4 Finance Section
    No information available at this time.
  2.5 Other Command Staff
    2.5.1 Safety Officer
Stan Williams - ERRS

2.6 Liaison Officer
Not Applicable.

2.7 Information Officer
None.

2.7.1 Public Information Officer
None.

2.7.2 Community Involvement Coordinator
None.
3. Participating Entities
  3.1 Unified Command
Unified Command is not utilized.

3.2 Cooperating Agencies
Detroit Fire Department
Michigan Department of Environmental Quality
Detroit Environmental Affairs
United State Coast Guard - Atlantic Strike Team
4. Personnel On Site
  U.S. EPA - 1
START - 1
ERRS - 7
USCG - 2
5. Definition of Terms
  U.S. EPA - United States Environmental Protection Agency
ERRS - Emergency and Rapid Response Service
START - Superfund Technical Assessment and Response Team
DFD - Detroit Fire Department
C.F.R - Code of Federal Regulations
USCG - United States Coast Guard
ppm - Parts Per Million
ppb - Parts Per Billion
VOC - Volitile Organic Compound
HASP - Health and Safety Plan
6. Additional sources of information
  6.1 Internet location of additional information/report
www.epaosc.org/lyndonstreetdrums

6.2 Reporting Schedule
POLREPS will be issued weekly or as necessary.
7. Situational Reference Materials
  Material Safety Data sheets
Emergency Response Guidebook