Pollution Report Profile - EPA OSC Response

DLH Plating Site
Cleveland, OH - EPA Region V
POLREP #7 - Removal Action

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On-Scene Coordinator - James Augustyn	2/20/2009
Time-Critical - Removal Action	Pollution Report (POLREP) #7
Start Date: 11/11/2008

Site Description
See POLREP #1 for Site Description.

Current Activities
On February 6, 2009, ERRS continued cleaning of floor debris and floor trenches in Rooms L and M, and continued the removal of solidified cyanide sludge from tanks. The solidified cyanide sludge was placed into roll-off boxes for off-site disposal. ERRS completed the removal of ventilation ducts from auto cadmium line in Room L.

On February 9, 2009, ERRS began dismantling the filter press of the wastewater treatment facility in Room M. A power outage to the building was caused by snow melt and excessive rain events. Standing water accumulated on the floor throughout most parts of the building. ERRS crew began pumping the standing water from the floor in Rooms L, M, G and the Hallway.

On February 10, 2009, ERRS began cutting access holes in the wastewater treatment tanks and clarifier in order to remove sludge. ERRS continued segregating, consolidating and bulking small 1 and 5-gallon containers staged in the hallway. Removal of standing water on the floor throughout most parts of the building continued. Approximately 5,300 gallons of liquids [Hazardous Waste Liquid (Cadmium, Chromium) D006, D007] were transported to Vickery for disposal.

On February 11, 2009, ERRS continued the removal of the standing water on the floor throughout most of the building, and continued segregating and consolidating 1 and 5-gallon containers. ERRS began the removal of sludge from wastewater tank #129 and clarifier. Due to excessive rain, migration of petrolium-contaminated surface water was observed entering the southwest corner of the Site from the adjacent property. Earthen berms and diversion drainage ditches were created, and sorbent booms installed to prevent the migration of contaminated surface water to the Site. Representatives from the Ohio EPA arrived on site to investigate and document. Cleveland Public Power (CPP) on Site to inspection the electrical service to the building. CPP determined that it is unsafe to continue to provide electrical service to the building and de-energized power to the facility.

On February 12, 2009, ERRS activities included; changing the sorbent booms from migration of surface water, continued cutting and removing steel I-beams from the auto cadmium plating line in Room L, continued segregating and consolidating 1 and 5-gallon containers staged in the hallway, continued pumping floor water out of the building, and began cleaning out the floor trenches in Room G. Ohio EPA representatives on site to investigate the migration of petroleum-contaminated surface water from the adjacent property.

On February 13, 2009, ERRS continued cleaning the floor trenches in Room G, continued cutting and removing the steel I-beams from the auto cadmium plating line in Room L and continued removing standing water from the floor throughout the facility.

On February 16, 2009, ERRS completed cutting access ports into the sides of the wastewater treatment tanks and continued removing the sludge from the clarifier and tanks. ERRS also continued the decontamination of cyanide tanks and the disassembled ventilation system from the auto cadmium plating line in Room L. Three (3) steel tanks were decontaminated and removed from the building.

On February 17, 2009, ERRS continued removal of the sludge from the clarifier and tanks from wastewater treatment. ERRS completed the decontamination of steel acid tanks from Room M. Twelve (12) steel tanks were decontaminated and removed from the building. Solidified acid sludge from the tanks was removed and consolidated into Tank 113. Scrap steel was transported off site for recycling.

On February 18, 2009, ERRS continued removal of sludge from the tanks at wastewater treatment. ERRS continued solidification and consolidation of cyanide sludge in Room M.

On February 19, 2009, ERRS continued removal of sludge from the tanks at the wastewater treatment facility. ERRS continued solidification and consolidation of cyanide sludge in Room M. Holes were cut into the sides of Tanks 1 through 6 at the Room A Bulk Chemical Storage area in order to assess the sludge from the tanks.

Activities performed by START from February 6, 2009, to February 19, 2009, included: written and photographic documentation of Site activities and conditions; and performing air monitoring during Site activities.

Planned Removal Actions
ERRS will continue to perform the following activities: solidification/consolidation and removal of sludge from tanks and totes; categorizing and consolidating small containers from throughout the facility; decontaminating tanks, removing tanks from the building, and rendering them non-reusable; general site clean-up; performing hazard characterization testing on samples; lab packing small containers; submitting waste characterization samples to a laboratory for disposal analyses; and coordinating transportation and disposal of waste material.

START will continue to document Site activities and conditions and perform air monitoring.

Next Steps
ERRS will remove product piping within the facility, removal and disposal of the cyanide ventilation system, decontamination of the wastewater treatment system, decontaminating floor once the tanks and debris have been removed, demolition of the frontage portion of the building along Evarts Road.

Key Issues
Snow melt and excessive rain caused a power outage inside the building on February 9, 2009. These weather conditions also caused flooding inside the building which created a change in work practices and caused daily pumping of the water outside the building. Weather conditions also creating failure on some localized portions of the roof.

Disposition Of Wastes
Total to Date:

80,540 gallons of Hazardous Waste Liquids N.O.S. D006, D007 (Chromium, Cadmium) have been transported to Vickery for disposal.

23,750 gallons of Hazardous Waste Liquids D006, D007, F006 (Chromium, Cadmium, Cyanide) have been transported to Vickery for disposal.

20,850 gallons of Waste Chromic Acid Solution D002, D004, D006, D007 have been transported to Vickery for disposal.

14,001 gallons of Waste Corrosive Liquid, Basic, Inorganic N.O.S. have been transported to Vickery for disposal.
195 cubic yards of Hazardous Waste Solid D006, D007, F006, F007 (Chromium, Cadmium) have been transported to Envirite of Ohio, Inc. for disposal.

160 cubic yards of RCRA empty containers and debris have been transported to American Landfill for disposal.

See Previous POLREPs for Waste Disposition listings prior to February 6, 2009.

Waste Stream	Quantity	Manifest #	Disposal Facility
RQ, NA3082, Hazardous Waste Liquid, N.O.S., (Chromium, Cadmium), 0, NA3082, III, D006, D007	5,300 gallons	001988739	Vickery Environmental, Inc., Vickery, Ohio