U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Advance Plating Works - Removal Polrep
Final Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
Subject: POLREP #10
Final PolRep
Advance Plating Works
C589
Indianapolis, IN
Latitude: 39.7152000 Longitude: -86.1417000

To:
From: Shelly Lam, On-Scene Coordinator
Date: 3/19/2012
Reporting Period: February 27 - March 12, 2012

1. Introduction
  1.1 Background
   
Site Number: C589    Contract Number: EP-S5-09-05
D.O. Number: 0082    Action Memo Date: 12/5/2011
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 9/20/2011    Start Date: 9/20/2011
Demob Date: 3/12/2012    Completion Date: 3/12/2012
CERCLIS ID: INN000510649    RCRIS ID: IND985059898
ERNS No.:    State Notification:
FPN#:    Reimbursable Account #:


1.1.1 Incident Category
Time-Critical Removal - Former plating shop

1.1.2 Site Description
The Site is the former Advance Plating Works.  It was a family-owned business that operated on the south side of Indianapolis.  Former operations at the facility included nickel, chrome, zinc, cadmium, and copper plating.  During an interview with the current owner's stepson on December 22, 2011, the U.S. Environmental Protection Agency (EPA) learned that Advance Plating Works had been in business in 1912 but had only been at the current location since the 1970's.  Prior to ownership by Advance Plating Works, the Site was previously a slaughterhouse, cannery, and wax factory.

The Site is 3 acres in size and includes two buildings, one of which was formerly used for plating operations and office space and a second building, which was used as a warehouse.

1.1.2.1 Location
The Site is located at 1005 E. Sumner Avenue in Indianapolis, Marion County, Indiana.  Site coordinates are latitude 39.7152000 degrees north and longitude 86.1417000 degrees west.  The facility is in an area of the south side of Indianapolis that is primarily industrial and commercial.  However, there is a residential facility adjacent to the Site to the east and additional residential properties within a few hundred feet to the northeast.

1.1.2.2 Description of Threat
On September 20, 2011, the Marion County Public Health Department (MCPHD) responded to the Site based on abandoned building and trespassing complaints from the Indianapolis Metropolitan Police Department (IMPD).  Upon arriving at the Site, MCPHD personnel observed 25-30 drums stored in poor condition outside the buildings.  Additionally, MCPHD noticed that building doors were open and a section of fence had been removed to allow access for trespassing.  MCPHD immediately requested assistance from the Indiana Department of Environmental Management (IDEM) and EPA.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
EPA On-Scene Coordinator (OSC) Shelly Lam responded to the Site on the afternoon of September 20th, where she met with representatives from MCPHD and the property owners.  After obtaining access, OSC Lam conducted a reconnaissance and documented 75-100 drums, totes, plating vats and other containers inside and outside the facility buildings.  Many drums were unlabeled.  However, labeled drums included toxic, corrosive, oxidizing, and flammable materials.  OSC Lam also documented that trespassing had been occurring and that trespassers had been cutting metal process piping above the plating vats.

EPA completed an inventory of drums and containers on September 22, 2011.  EPA documented 164 drums, ten 275-gallon totes, hundreds of small containers, 6 plating vats, and 5 pits/sumps.  Identified materials included sodium hydroxide, hydrogen peroxide, potassium cyanide, sodium cyanide, sulfuric acid, hydrocyanic acid, nitric acid, and paint thinner.  Based on this information, OSC Lam determined that there was a threat to human health and the environment from abandoned drums, many of which were in poor condition and leaking.  There was also a threat of fire or explosion from improperly stored flammable materials in a building where trespassing was occurring.

Analytical results from the Site Assessment verified that hazardous substances were present on-Site.  EPA collected six samples from drums and a small container during the Site Assessment.  Four samples exhibited a pH less than 2 standard units (SU) and one sample had a pH of 13.5 SU, meeting the characteristic of corrosivity per 40 Code of Federal Regulations (CFR) 260.22(a)(1).  One sample had a flashpoint of 110 degrees Fahrenheit, which is below 140 degrees Fahrenheit, meeting the characteristic for ignitability, per 40 CFR 261.21(a)(1).  Total and reactive cyanide were detected in one sample at concentrations of 15,000 milligrams per kilogram (mg/kg) and 1,300 mg/kg, respectively.
2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative
On September 20, 2011, EPA responded to a request for assistance from MCPHD regarding abandoned drums at a former plating facility.  EPA conducted emergency response operations from September 20 - 22, 2011, including segregating, staging, and securing drums.  EPA signed an Action Memorandum on December 5, 2011 to complete time-critical removal activities including developing site plans such as a site-specific Health and Safety Plan (HASP), Emergency Contingency Plan, and work plan; inventorying and performing hazard categorization on substances contained in vats, pits, drums, and other containers; performing sampling and analysis to determine disposal options; dismantling and decontaminating process equipment and building components associated with plating operations; and consolidating and packaging hazardous substances, pollutants, and contaminants for transportation and off-Site disposal in accordance EPA's Off-Site Rule.  EPA finalized time-critical removal actions on March 12, 2012, and completed the scope of work outlined in the Action Memorandum.

2.1.2 Response Actions to Date

During the period from February 27 - March 12, 2012, EPA conducted the following activities:

  • Decommissioned plating and wastewater vats;
  • Swept and pressure-washed wastewater treatment room;
  • Disposed of remaining waste;
  • Conducted air monitoring; and
  • Maintained Site security.

EPA demobilized from the Site on March 12, 2012.

EPA conducted Green Initiatives during the removal action including recycling of paper, plastic, glass, aluminum, ink cartridges, and scrap metal.  EPA recycled 15 pounds of plastic and 64 pounds of paper.  EPA and its contractors used 100% post consumer recycled paper in copiers and printers.  EPA also used alternative fuel in government vehicles and recycled paper products.  Personnel adhered to a Site policy for equipment and vehicle idling set at no more than 3 minutes for when the equipment is not in use.  EPA used the general grid for the electric power instead of generators, thereby reducing on-Site carbon emissions.  Additionally, all heaters were electric to cut back on fuel consumption.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Information on the PRP is in the Site file.

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
Hazardous waste solids (F008, D006, D007, D008) Solid 20 yards 008223069JJK NA Michigan Disposal Waste Treatment Plant
Hazardous waste solids (F008, D006, D007, D008) Solid 20 yards 008223070JJK NA Michigan Disposal Waste Treatment Plant
Hazardous waste solids (F008, D006, D007, D008) Solid 20 yards 008223071JJK NA Michigan Disposal Waste Treatment Plant
Hazardous waste liquids (D007) Liquid 29,600 pounds 009122990JJK NA EQ Detroit
Non-hazardous debris Solid 1.93 tons 1212326 NA  Twin Bridges Landfill
Hazardous Waste Liquids (D007) Liquid 53,600 pounds  009122854JJK NA EQ Detroit
Hazardous Waste Solids (D006) Solid 9,000 pounds 009122860JJK NA Michigan Disposal Waste Treatment Plant
Hazardous Waste Solids (D006) Solid 33,000 pounds 009122856JJK NA Michigan Disposal Waste Treatment Plant
Hazardous Waste Solids (F008, D006, D007, D008) Solid 20 yards 009122855JJK NA Michigan Disposal Waste Treatment Plant
Waste Corrrosive Liquid, Acidic, Inorganic (D002, D006, D007) Liquid 4500 pounds 009122858JJK NA EQ Detroit
Waste Corrosive Liquid, Basic, Inorganic (D002, D007, D010) Liquid 1800 pounds 009122854JJK NA EQ Detroit
Waste Corrosive Liquid, Basic, Inorganic (D002) Liquid 1500 pounds 009122854JJK NA EQ Detroit
Waste Corrosive Liquid, Basic, Inorganic (D002, D007, D010) Liquid 2000 pounds 009122854JJK NA EQ Detroit
Waste Corrosive Liquid, Basic, Inorganic (D001, D002) Liquid 1500 pounds 009122863JJK NA EQ Detroit
Waste Corrosive Liquid, Basic, Inorganic (D002, D007, D010) Liquid 1800 pounds 009122862JJK NA EQ Detroit
Waste Corrosive Liquid, Basic, Inorganic (D002, D007, D010) Liquid 2000 pounds 009122862JJK NA EQ Detroit
Waste Cyanide Solutions (D003, D006, D007, D008) Liquid 5500 pounds 009122854JJK NA EQ Detroit
Waste Cyanides, Inorganic, Solid (D003, D007) Solid 4500 pounds 009122854JJK  NA EQ Detroit 
Waste Flammable Liquids (D001, D005) Liquid 2250 pounds 009122858JJK NA EQ Detroit
Waste Hydrogen Peroxide, aqueous (D001)  Liquid 250 pounds 009122858JJK NA EQ Detroit
Waste Nitric Acid (D001, D002) Liquid 5 pounds 009122862JJK NA EQ Detroit
Waste Oxidizing Liquid, Corrosive (D001, D002, D005, D007, D008, D010) Liquid 3500 pounds 009122858JJK NA EQ Detroit
 Waste Oxidizing Liquid, Corrosive (D001, D002, D005, D006, D007) Liquid 1500 pounds 009122858JJK NA EQ Detroit
Waste Oxidizing Solid, Corrosive (D001, D002, D007) Solid 800 pounds  009122858JJK NA EQ Detroit
Waste Oxidizing Solid, Corrosive (D001) Solid 800 pounds 009122858JJK NA EQ Detroit

 R5 Priorities Summary
Integrated River Assessment Miles of river systems cleaned and/or restored  NA
Cubic yards of contaminated sediments removed and/or capped  NA
Gallons of oil/water recovered  NA
Acres of soil/sediment cleaned up in floodplains and riverbanks  NA
Stand Alone Assessment Acres Protected 3 
Number of contaminated residential yards cleaned up 0
Human Health Exposures Avoided 3800
Number of workers on site 10



  2.2 Planning Section
    2.2.1 Anticipated Activities
EPA has completed time-critical removal activities.

2.2.1.1 Planned Response Activities
None 

2.2.1.2 Next Steps
EPA will refer the Site to IDEM for any future remedial actions. 

2.2.2 Issues
None
  2.3 Logistics Section
    2.3 Logistics
The Emergency and Rapid Response Services (ERRS) contractors provided logistical support including:

  • Temporary worksite trailers;
  • Bathroom facilities;
  • Electrical contractors to restore power;
  • Water and plumbing service;
  • Trash service;
  • Drinking water;
  • Security contractors for non-operational hours overnight, weekends, and holidays;
  • Temporary lighting inside the facility; and
  • Temporary space heaters inside the facility to facilitate removal activities.


  2.4 Finance Section
    No information available at this time.
  2.5 Other Command Staff
    2.5.1 Safety Officer
OSC Lam was the overall Safety Officer for the response.  EPA's contractors prepared a site-specific HASP.  Additionally, all personnel attended daily safety briefings.

2.6 Liaison Officer
Not applicable (NA)

2.7 Information Officer

2.7.1 Public Information Officer
The Office of Public Affairs (OPA) issued a press release on March 9, 2012.  There were no media inquiries.

2.7.2 Community Involvement Coordinator
The community involvement coordinator is Susan Pastor, who established a website and coordinated a fact sheet for distribution.
3. Participating Entities
  3.1 Unified Command
NA

3.2 Cooperating Agencies
IDEM
MCPHD
4. Personnel On Site
  The following personnel were on-Site during the reporting period.

Agency Position # Personnel
EPA OSC 2
ERRS Response Manager 1
  Foreman 1
  Laborer 3
  Field Cost Accountant 1
START   1


5. Definition of Terms
 
CFR Code of Federal Regulations
EPA Environmental Protection Agency
ERRS Emergency and Rapid Response Services
HASP Health and Safety Plan
IDEM Indiana Department of Environmental Management
IMPD Indianapolis Metropolitan Police Department
MCPHD Marion County Public Health Department
mg/kg milligrams per kilogram
NA Not Applicable
OPA Office of Public Affairs
OSC On-Scene Coordinator
PolRep Pollution Report
PRP Potentially Responsible Party
START Superfund Technical Assessment and Response Team
SU Standard Units


6. Additional sources of information
  6.1 Internet location of additional information/report
Refer to www.epaosc.org/advanceplatingworks and www.epa.gov/Region5/cleanup/advanceplating/ for additional information.

6.2 Reporting Schedule
The OSC will not submit any additional Pollution Reports (PolRep).
7. Situational Reference Materials
  NA