Time Critical Removal Action – Copper smelting slag and residual products remain from the former operations at the Chemetco Superfund Site.  This facility was a secondary copper smelting and recycling operation that left remnant metal bearing materials in the environment.   

1.1.2 Site Description

Please refer to Initial POLREP for details.

Please refer to Initial POLREP for details.

Please refer to Initial POLREP for details.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

Please refer to Initial POLREP for details. 

The time-critical removal response actions will be conducted by the bankruptcy Trustee and Paradigm Minerals, in accordance with Section 104(a)(1) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. § 9604(a)(1) and Section 300.415 of the National Oil and Hazardous Substance Pollution Contingency Plan (NCP, 40CFR 300.415, to abate or eliminate the immediate threat posed to public health and/or the environment by the presence of the hazardous substances on the Site.

U.S DOJ, U.S. EPA, State of Illinois, the Estate of CHEMETCO and Paradigm Minerals negotiated a Consent Decree to govern the removal activities. 

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2.    Oversee the site maintenance and enhancements to site security and access controls to the entire facility.  Security cameras and recorders will be utilized.  Additional security lights will be added and a guard service will be contracted for off-hours and weekend security needs. 

Continue to manage on-site surface waters so that no off-site releases occur.  Continue to sample for and maintain all NPDES requirements.  

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4.    Participate in monthly meetings with the Estate, Estate employees, Estate contractors and Estate Trustee.

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6.    Review the Health and Safety Plan (HASP) assembled by the Estate related to all employees and its contractors.

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8.    Plant Demolition – Conduct oversight of the ongoing demolition and resultant scrap metal recovery work as required.

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10.  Perimeter Air Monitoring Program – Review the revised air monitoring plan to be used by the Estate to monitor fugitive dusts from materials handling and crushing operations. 

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12.  Oversee the implementation and approach to process crush, screen, wet separate, dry , load, containerize, and trans-ship unprocessed metal bearing materials (UMBM and Zinc sludge’s) at the Site, which should include, at a minimum:

·     Excavate/load and delivery of UMBM bearing delivered to the crushing circuit and wet separation  processing;

·      Product crushing circuit will include a jaw crusher, magnetic conveyor separator, screening tables along with several material conveyors.  Generous water-spray and misting for dust suppression will be included in critical areas of jaw crushing UMBM size screening and wet separation processing;

·      Operation and Maintenance of the UMBM wet processing systems;

·      Freight forwarding transporting the loaded ocean-tight cargo containers to an Agency approved intermodal loading facility with ultimate destination to reclamation facility(s) in accordance with EPA's Off-Site Rule (40 CFR § 300.440) and the project Consent Decree (CD), up to and including oversea port destinations in Germany, China and Vietnam;

·     Control access to the contaminated areas to prevent further migration of contamination, by fencing, traffic restrictions or other applicable means;

·     The Estate has subcontract a street sweeping service to maintain clean roadway surfaces inside the facility and near the main gate;

·     Load product into ocean-tight containers for freight forwarding trans-shipment to nearby rail terminals with destinations to domestic loading facilities with outbound oversea destinations to China, Vietnam and Germany.

.2.1.1    Planned Response Activities

·        Take all necessary steps to implement source control of the slag and scrubber sludge.  Source control may include surface water and storm water control measures to control off-site migration of zinc oxides and other metals.

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·        Enhance the Site Security Plan elements by the purchase of addition security cameras and digital recorders. 

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·        Prepare for the forthcoming PMES process work by which metals will be separated and concentrated to enhance the metals commodity value.

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·        Backfill any subgrade excavated areas with clean fill to effectuate storm water control and grade the Site as necessary.

2.2.1.2 Next Steps

·        Prepare for forthcoming wet processing, loading and shipping ocean-tight containers of all product streams for metals recycling either domestic or abroad. 

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2.2.2 Issues

While full production to process, size, and load the “mixed copper, zinc and tin materials” into ocean-tight containers is possible.  Logistical delays in transportation of the materials has been experienced due to the extreme cold weather throughout the East and Midwest along with a strike at the West Coast ports that created a shortage of available empty shipping containers.  Additionally inbound shipments of specialized equipment that will be used to separate the UMBM has resulted delays. 

Inclement weather may create weather delays to the project schedule. 

Financing along with the engineering and construction of the forthcoming Paradigm process could delay future schedules.

U.S. EPA  – 1
START     – 1
PMES       – 7

Estate Employees - 5