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2.1.1 Narrative
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.
2.1.2 Response Actions to Date
Following all final approvals of the CD, the Estate of
Chemetco and Paradigm Minerals mobilized a contractor (All Purpose Steel, formerly
know as Precision Crushing) to the site at the end of September 2013. In working with the OSC, the contractor began
some minor site clean-up (house keeping); scrap metal recycling, skull removals
and sales and mobilizing heavy equipment.
On November 14, 2013, U.S. EPA mobilized START contractors
to perform oversight of approved site activities previously initiated by the Estate
of Chemetco that include renting and leasing of dozers, tracked excavators,
cranes, articulated dump trucks and magnetized metal handling equipment used
for:
-
On-going demolition work of facility
plant production equipment and buildings previously used for copper smelting
and product processing have been temporarily suspended due to the low value of
scrap metal pricing.
-
The location, excavation, loading
and recovery of “skulls” and “reverts” containing higher copper or other metal
content henceforth will be called unprocessed metal bearing material (UMBM). This recovery is another important step to
aid in the financing for future work performed by the Estate. Please note that a hand-held X-ray
fluorescence (XRF) instrument has been used to determine the copper, bronze,
tin and zinc percentages or other heavy metal concentrations.
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Loading the UMBM into containers for
shipment to over-seas businesses that will recover and refine the copper, tin,
bronze and zinc.
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Relocating slag materials to create
a work area to be used for future work.
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Relocating slag materials to
construct a haul road from the slag pile to the work area.
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On December 6, 2013, the Estate
contractors initiated the construction of a loading dock adjacent to the Tank
House that will be used as part of a UMBM container loading operation. It was completed on December 13, 2013.
-
On December 9, 2013, the Estate
contractors assembled a series of material conveyor circuits in the Tank House to
be used as a part of a material bagging (Super-sack) operations.
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On December 14, 2013, the Estate
submitted to the agency the following documents:
CHEMETCO
Health and Safety Form;
Site
Safety Briefing Form;
Estate
Safety Briefing – Winter;
CHEMETCO
Site Emergency Evacuation Plan;
IEPA
Seal Order Handout;
MSDS
– Copper Slag and copper products.
From
December 2014 through December 2015 the following activities occurred:
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The Estate
took delivery of five particulate monitoring instruments that are used for the
perimeter air monitoring activities. A
metrological station was also delivered.
The estate will electronically store the air monitoring data results.
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The
loading-dock next to the “Tank” building construction was completed.
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Precision
Crushing, Inc., completed a “bump” test of the crushing circuit as a
preliminary step to access the crushing output goal to meet the 1-inch minus
product requirement set forth by the buyer at that time.
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The Estate
of Chemetco purchased two additional cameras to supplement the eight existing
plant security cameras.
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On January
15, 2015, the DJL Mining/PMES/Estate contractor, All Purpose Steel Construction
Company, initiated the construction assembly of a wet processing system that
will be used for the separation of recoverable metallic materials and further concentrate
several metals to enhance the commodity value of recoverable metals.
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On April
23, 2015, DJL Mining employees and PMES/Estate contractors initiated
calibration of a particle separation component to the wet processing
system.
-
In May
2015, the Estate submitted a revised perimeter air monitoring program plan and
QAAP.
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PMES no
longer maintains a proprietary technology but will continue to engineer the wet
processing system in conjunction with DJL Mining LLC. In the fall of 2015, All Purpose Steel
Construction in concert with DJL Mining completed a significant upgrade to the
water jig density separator including new hammer mills and conveyors.
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On
September 17, 2015, the Estate contractors acquired a water truck to be used
for the control of fugitive dusts that emanate from traffic lanes of heavy
equipment used to load or process the MBM.
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To date, a
total of 1013 ocean-tight containers of crushed and separated “Mixed Copper Tin
Material” was loaded and trans-shipped to a refinery at the Northeast Yejin
Co., Ltd. Facility in Chenzhou City, Hunan Province, China along with a
second facility, Trung Nhat Bao Thang Viet Nam Co., LTD, located in Lau Thuon
Village, Vietnam. Due to lower than expected copper
concentrations, these refineries suspended delivery of this product
stream. PMES has set about finding new
buyers for this product stream.
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On October
20, 2015, PMES shipped 38,000 metric tons of processed materials to a new buyer
refinery in China
On May 8, 2015, PMES initiated shipments of Processed
Metal Bearing Material arranged by the brokerage arm, DJL
Mining LLC, of South El Monte, CA, with delivery to the refinery, Trung Nhat
Bao Thang Viet Nam Co., LTD, Lau Thuon Village, in Vietnam with a total of 15,307.36 metric tons to date.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
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.
2.1.4 Progress Metrics
Product Stream
Recyclable Metal Bearing Material
(RMBM)
|
Medium
|
Quantity
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No. of Containers or Loads
|
Treatment
|
Reclamation
Destination
|
Cupro, Reverts and Higher Grades
of Copper, and other Metals Bearing Materials (UMBM)
|
Recyclable Copper, Tin and Bronze UMBM
|
29,188.97
Metric Tons
|
1490
|
Recycle
|
DJL Mining
Brea, CA
Hong Kong, Kaohsiung, Gaolan,
China
Interco Trading Co.
Madison, IL
Aurubis Group, Lunen, Germany
Bremerhaven
and
CMAC
Northeast Yejin Co., Ltd., Liyu
Jiang Town, Chenzhou City, China
Interco Trading Co.
Madison, IL
Aurubis Group, Lunen, Germany
|
North Polishing Pond Zinc Sludge
(Dry)
UMBM
|
Recyclable
Zinc Oxide
|
1,087.21
Metric Tons
|
55
|
Recycle
|
CMAC
Northeast Yejin Co., Ltd., Liyu
Jiang Town, Chenzhou City, China
|
Zinc Oxide Bunker Materials (Dry)
UMBM
|
Recyclable
Zinc Oxide
|
37,411.29 Metric Tons
|
1231
|
Recycle
|
DJL Mining LLC, South El Monte, CA
Kaohsiung, Gaoloan, China
Trung Nhat Bao Thang Vietnam Co.,
LTD, Lau Thuon Village, Vietnam
|
Copper Block
PMBM
|
Recyclable copper, tin and bronze
|
15,716.155 Metric Tons
|
722
|
Recycle
|
DJL Mining LLC, South El Monte,
CA,
Kaohsiung, Gaolan, China
Trung Nhat Bao Thang Vietnam Co.,
LTD, Lau Thuon Village, Vietnam
|
Scrap Steel
|
Recyclable
Steel
|
131
Tons
|
19
|
Recycle
|
Grossman Iron & Steel
St. Louis, MO
|
|
|
|
|
|
|
Waste Stream
|
Medium
|
Quantity
|
No. of Loads
|
Treatment
|
Disposition
|
Special Waste (Non-Hazardous
|
RCRA Empty Super-Sacks/55-gallon
poly-drums
|
17.24 tons
|
7
|
Land Disposal
|
Republic Waste Services. Inc.
Roxana, IL
|
General Refuse
64 cubic yards/month
|
Garbage
|
320 cubic yards
|
NA
|
Land Disposal
|
Republic Waste Services. Inc.
Roxana, IL
|
Construction/Demolition
Debris (Non-Hazardous)
|
C&D, General Refuse
|
8.43 Tons
|
NA
|
Land Disposal
|
Republic Waste Services. Inc.
Roxana, IL
|
White-goods, computers, office
equipment, etc.
|
Recyclable
Steel
|
3.32 tons
|
NA
|
Recycle
|
Component Level Recycling
Sauget, IL
|
Hydraulic oil spill materials
|
Sorbent pads / PPE
|
2 drums
|
1
|
Land Disposal
|
Heritage Enviro. Services,
Indianapolis, Indiana
|
Waste oil
|
All waste oil
|
1780 gallons
|
1
|
Recycle
|
Future Environmental, Peoria, IL
|
Refractory Brick
|
Broken refractory
|
15.24
tons
|
1
|
Land Disposal
|
Heritage Enviro. Services,
Indianapolis, Indiana
|
Contaminated Concrete
|
General
Refuse
|
tons
|
-
|
Land Disposal
|
Unknown at this time
|
Contaminated Wood
|
General
Refuse
|
tons
|
-
|
Land Disposal
|
Unknown at this time
|
Waste Tires
|
Scrap
Tires
|
|
-
|
Recycle
Thermal
|
Unknown at this time
|
Miscellaneous Debris (Hazardous)
|
General Refuse
|
8.43 Tons
|
-
|
Land Disposal
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Heritage Enviro. Services,
Indianapolis, Indiana
|
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APPA
– Asset Purchase and Processing Agreement
ATSDR
– Agency for Toxic Substances and Disease Registry
CERCLA
– Comprehensive Environmental Response, Compensation, and Liability Act
CD
– Consent Decree
CFR
– Code of Federal Regulations
Chemetco
– Chemetco Superfund Site , (“the Estate,” “Trustee for the Estate of
bankruptcy Trustee” -- --- or, “Trustee”), previously d.b.a. Chemetco
Metals Corporation
Cupro
– Copper containing (aka cupriferous, cupronickel)
CWA
– Clean Water Act, 33 U.S.C. §§ 1251-1387
HASP
– Health & Safety Plan
IDPH
- Illinois Department of Public Health
IEPA
– Illinois Environmental Protection Agency
ILCS
– Illinois Compiled Statues
MBM
– Metal Bearing Materials
NCP
– National Oil and Hazardous Substance Pollution Contingency Plan
NPL
– National Priorities List
PA/SI
– Preliminary Assessment / Site Inspection
Paradigm
– Paradigm Minerals & Environmental Services
Paradigm
Process – A propriety chemical process used to separate metallic particles and
concentrate by element
PMBM
– Processed Metal Bearing Material
PMES
– Paradigm Minerals & Environmental Services
PRP
– Private Responsible Parties
RCRA
– Resource Conservation and Recovery Act
RMBM
– Recyclable Metal Bearing Material
Skulls
– Slag with copper bearing commodity value
START
– Superfund Technical Assessment & Response Team
Super-sack
– 1 to 2-ton polypropylene woven bags used to store and handle bulk processed
materials
TCLP
– Toxicity Characteristic Leaching Procedure
UMBM
– Unprocessed Metal Bearing Materials
XRF – X-ray fluorescence
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