U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Hoosier Wood Preservers ER - Removal Polrep
Final Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
Subject: POLREP #8
Final Emergency Response Report
Hoosier Wood Preservers ER

Indianapolis, IN
Latitude: 39.7224100 Longitude: -86.2212300

To:
From: Shelly Lam, On-Scene Coordinator
Date: 9/9/2015
Reporting Period: September 9 - 10, 2015

1. Introduction
  1.1 Background
   
Site Number: C57K    Contract Number: EP-S5-09-05
D.O. Number: 168    Action Memo Date: 7/7/2015
Response Authority: CERCLA    Response Type: Emergency
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 5/26/2015    Start Date: 5/26/2015
Demob Date: 9/10/2015    Completion Date: 9/10/2015
CERCLIS ID: INN000505835    RCRIS ID: IND075982975
ERNS No.:    State Notification:
FPN#:    Reimbursable Account #:

1.1.1 Incident Category
Emergency Response at Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Incident Category:  Manufacturing/Processing/Maintenance - Lumber and wood products/wood preserving/treatment

1.1.2 Site Description
The site is the former Hoosier Wood Preservers.  The facility operated from 1969 to 2013 as a wood treating business that used chromated copper arsenate (CCA) and borate in pressurized wood treatment cylinders.   Historically, the facility also used creosote and pentachlorophenol to treat wood.  The facility has been abandoned since 2013. 

The site is 7.75 acres in size and has ten buildings, including process buildings, storage buildings, a garage, and office.  A site map is posted to the Documents section of www.epaosc.org/hoosierwoodpreservers.

1.1.2.1 Location
Hoosier Wood Preservers is located at 3605 Farnsworth Street in Indianapolis, Marion County, Indiana.  Site coordinates are 39.7224100 degrees north latitude and 86.2212300 degrees west longitude.  The site is located approximately 3.5 miles southwest of downtown Indianapolis.

The surrounding area is primarily industrial, although commercial properties are located to the south.  Residential properties are within 200 feet to the east and northeast.

1.1.2.2 Description of Threat
See Pollution Report (PolRep) #1.
    1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
    See PolReps #1 and #3.
    2. Current Activities
      2.1 Operations Section
        2.1.1 Narrative
    The U.S. Environmental Protection Agency (EPA) approved action memorandum on July 7, 2015 to conduct emergency response actions consisting of:
    • Preparing a health and safety plan;
    • Stabilizing, repackaging, and securing waste in tanks, totes, drums, and other containers;
    • Inventorying and performing hazard characterization on waste;
    • Performing sampling and analysis to determine disposal options; and
    • Consolidating and packaging hazardous substances, pollutants and contaminants for transportation and off-site disposal in accordance with the EPA Off-Site Rule, 40 Code of Federal Regulations (CFR) § 300.440.

    2.1.2 Response Actions to Date
    On September 9, 2015, EPA shipped drums, totes, and cubic yard boxes to AES Environmental in Calvert City, Kentucky for disposal. 

    On September 10, 2015, EPA shipped a 20 cubic yard roll-off to Twin Bridges Landfill in Danville, Indiana; transported mercury switches and PCB ballasts to Environmental Enterprises in Cincinnati, Ohio; and demobilized from the site.

    2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
    See previous PolReps.

    2.1.4 Progress Metrics
    Waste Stream Quantity Units Manifest Facility
    NA3082, Hazardous Waste Liquid (As, Cr) 2 cubic yards 014068424JJK AES Environmental, LLC
    NA3077, Hazardous Waste Solid (As) 10 cubic yards 014068424JJK AES Environmental, LLC
    Non-hazardous, non-regulated waste 2 cubic yards 014068424JJK AES Environmental, LLC
    NA3077, Hazardous Waste Solid (As, Cr) 17 drums 014068422JJK AES Environmental, LLC
    NA3077, Hazardous Waste Liquid (As, Cr) 1 drums 014068422JJK AES Environmental, LLC
    UN1760, Waste Corrosive Liquid (As, Cr, Cd) 4 drums 014068422JJK AES Environmental, LLC
    UN2014, Hydrogen peroxide waste 2 drums 014068422JJK AES Environmental, LLC
    Non-hazardous, non-regulated solids 17 drums 014068422JJK AES Environmental, LLC
    Non-hazardous, non-regulated liquids 8 drums 014068422JJK AES Environmental, LLC
    Non-hazardous, non-regulated liquids, oils 4 drums 014068422JJK AES Environmental, LLC
    Non-hazardous, non-regulated liquids 7 drums 014068422JJK AES Environmental, LLC
    Non-hazardous, non-regulated solids 1 drums 014068422JJK AES Environmental, LLC
    Non-hazardous, non-regulated liquids 3 drums 014068422JJK AES Environmental, LLC
    Non-hazardous, non-regulated solids 20 cubic yards NA Twin Bridges Landfill
    Mercury switches  5 each Pending Environmental Enterprises, Inc.
    PCB Ballasts 6 each Pending Environmental Enterprises, Inc.

    Regional Metrics
    This is an Integrated River Assessment. The numbers should overlap. 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 Number of contaminated residential yards cleaned up NA
    Number of workers on site 6
    Contaminant(s) of Concern Arsenic, chromium
    Oil Response Tracking
    Estimated volume Initial amount released NA
    Final amount collected NA
    CANAPS Info FPN Ceiling Amount NA
    FPN Number NA
    Body of Water affected NA
    Administrative and Logistical Factors (Place X where applicable)
      Precedent-Setting HQ Consultations (e.g., fracking, asbestos)   Community challenges or high involvement   Radiological
      More than one PRP   Endangered Species Act / Essential Fish Habitat issues   Explosives
      AOC   Historic preservation issues   Residential impacts
      UAO   NPL site   Relocation
      DOJ involved   Remote location   Drinking water impacted
    X Criminal Investigation Division involved X Extreme weather or abnormal field season X Environmental justice
      Tribal consultation or coordination or other issues   Congressional involvement   High media interest
      Statutory Exemption for $2 Million   Statutory Exemption for 1 Year   Active fire present
    X Hazmat Entry Conducted – Level A, B or C   Incident or Unified Command established   Actual air release (not threatened)
    Green Metrics
      Metric   Amount   Units
      Diesel Fuel Used   NA   gallons
      Unleaded Fuel Used   NA   gallons
      Alternative/E-85 Fuel Used   NA   gallons
      Electricity from electric company   NA   kWh
      Electric Company Name and Account #   NA    
      Electricity from sources other than the electric company   NA   kWh
      Solid waste reused   NA    
      Solid waste recycled   NA    
      Water Used   NA   gallons



      2.2 Planning Section
        2.2.1 Anticipated Activities
    The following sections detail anticipated activities.

    2.2.1.1 Planned Response Activities
    On August 5, 2015, EPA approved an action memorandum to conduct a time-critical removal action at the site.  EPA will begin the removal action in the fall of 2015.

    2.2.1.2 Next Steps
    The removal action will consist of:
    • Preparing site plans including a Work Plan, Quality Assurance Project Plan, site-specific Health and Safety Plan, and an Emergency Contingency Plan;
    • Excavating approximately 4,000 tons of soil to a depth of two feet bgs, contaminated material from the floor of the Wood Stacker Building, and ash from the former Drip Pad Building;
    • Investigating geophysical anomalies to an approximate depth of 10 feet bgs;
    • Collecting and analyzing confirmation samples from the bottom of each excavation;
    • Placing a visible barrier at the bottom of each excavation;
    • Replacing excavated soil with clean soil;
    • Treating contaminated material with Free Flow 100®, or a similar reagent, prior to disposal;
    • Consolidating and packaging hazardous substances, pollutants and contaminants for transportation and off-site disposal in accordance with the EPA Off-Site Rule, 40 C.F.R. § 300.440; and
    • Taking any other response actions to address any release or threatened release of a hazardous substance, pollutant or contaminant that the EPA OSC determines may pose an imminent and substantial endangerment to the public health or the environment. 

    2.2.2 Issues
    Although the facility was fenced and locked, vandals broke into the site.  They removed the lock from one Conex box, although nothing appeared to have been disturbed.  They also sprayed graffiti on side of a Conex box.
      2.3 Logistics Section
        The Emergency and Rapid Response Service (ERRS) contractor provided logistical support.
      2.4 Finance Section
        No information available at this time.
      2.5 Other Command Staff
        2.5.1 Safety Officer
    OSC Lam was the Safety Officer for EPA's response.  START prepared a Health and Safety Plan for the site.  Site personnel attended daily health and safety briefings.  There were no reportable incidents.

    2.5.2 Liaison Officer
    Not applicable (NA)

    2.5.3 Information Officer
    See previous PolRep.
    3. Participating Entities
      3.1 Unified Command
    EPA worked under Wayne Township Fire Department, who had control of the scene because of the fire investigation

    3.2 Cooperating Agencies
    EPA received assistance from the Indiana Department of Environmental Management (IDEM) and Marion County Public Health Department (MCPHD).
    4. Personnel On Site
      The following personnel were on-site during the reporting period.

    Agency/Company # Personnel
    EPA 1
    ERRS 3
    American Transportation Solutions 2


    5. Definition of Terms
     
    CCA Chromated copper arsenate
    CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
    CFR Code of Federal Regulations
    EPA Environmental Protection Agency
    ERRS Emergency and Rapid Response Services
    IDEM Indiana Department of Environmental Management
    MCPHD Marion County Public Health Department
    NA Not Applicable
    OSC On-Scene Coordinator
    PolRep Pollution Report
    PRP Potentially Responsible Parties
    START Superfund Technical Assessment and Response Team


    6. Additional sources of information
      6.1 Internet location of additional information/report
    For additional information, refer to www.epaosc.org/hoosierwoodpreservers 

    6.2 Reporting Schedule
    No additional PolReps for the emergency response will be submitted.
    7. Situational Reference Materials
      Refer to refer to www.epaosc.org/hoosierwoodpreservers.