Pollution Report Profile - EPA OSC Response

Norwood Industries
Toledo, OH - EPA Region V
POLREP #6 - Continuation of Removal Activities

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On-Scene Coordinator - Jon Gulch	3/3/2009
Time-Critical - Removal Action	Pollution Report (POLREP) #6
Start Date: 10/21/2008

Site Description
See POLREP#1 for a full Site Description.

Current Activities
From January 13, 2009 - March 3rd, 2009, EPA has completed the process of clearing all portions of the central (main) warehouse facility, including the upstairs and downstairs by disposing of and removing miscellaneous bulk debris.   This is required to safely identify the presence of waste drums and containers that are intermingled with the general debris.  EPA continues to utilize the cleared portions of the main warehouse to stage drums and containers during Level B sampling activities.

On February 17th, 2009 ERRS personnel identified uncontained elemental mercury in an upstairs 3-shelf laboratory cabinet.  EPA mobilized a Lumex RA-915+ mercury analyzer to the Site to confirm that the uncontained mercury was confined to the laboratory cabinet and that the surrounding area was not contaminated.  Prior to mercury removal, initial screenings with the Lumex indicated mercury vapor readings ranging from 15,000 to 50,000 micrograms per cubic meter (ug/m3) within the breathing zone level in front of the lab cabinet. Wood floor readings in front of the cabinet ranged from 12,000 to 15,000 ug/m3.

On February 24, 2009, the removal of the uncontained mercury started utilizing pipettes and a mercury vacuum.  Miscellaneous debris around the laboratory cabinet was placed into bags and sealed; glassware from inside the cabinet was also bagged and sealed for later screenings.  After the mercury was removed, HGx powder was applied within the laboratory cabinet and in surrounding floor area. Post mercury removal screenings inside the laboratory cabinet ranged from 1500 to 4,600 ug/m3.  A second round of removal activities was initiated using a mercury vacuum to remove remaining ‘micro’ mercury beads and another application of HGx powder was started. Secondary screenings ranged from 500 to 2,000 ug/m3.  With all visible mercury beads removed, the laboratory cabinet was wrapped in polyvinyl sheeting for disposal along with the small debris from within and in front of the cabinet. Post laboratory cabinet removal mercury vapor readings at floor level averaged around 500 ug/m3 for immediate area where cabinet was located.

To date, a total of 1,026 55-gallon drums and 1,281 5-gallon containers have been staged and sampled and approximately 1,000 containers (5 gallons or less) staged for future lab-pack activities.  A total of 2,742 items have been through the process of Hazard Categorization (HazCAT) identification.  Thirty-six (36) pallets containing various solids (silica sands, finely milled sands, dyes, and powders) have been inventoried and disposed of in three (3) 20-cubic yard roll-off boxes.  These powders were removed from the Site due to information gathered from Material Safety Data Sheets (MSDS) and off-site research.   Twenty five (25) 20-cubic yard roll-off boxes of miscellaneous non-hazardous bulk debris and five (5) 20-cubic yard yard roll-off of RCRA empty drums have been removed from the Site.

START continues to monitor ambient air conditions both within and around the perimeter of the site for volatile organic compounds (with the AreaRAE system) and particulates (with a DataRAM and the Rapid Assessment Tools Software).

Planned Removal Actions
-  Complete segregation of materials;
-  Complete sampling of all materials;
-  Complete field Hazard Categorization (HAZCAT);
-  Continue to develop waste streams;
-  Perform final disposal; and
-  Perform final building decontamination, if needed.

Next Steps
Continue the Time-Critical Removal Action after re-mobilization of Site personnel which will concentrate on Transport & Disposal of all waste streams.

Key Issues
Site personnel will demobilize the week of March 6th, 2009 and removal activities will temporarily cease until re-mobilization in April.

Disposition Of Wastes
To date, removal of waste from interior of warehouse facility has consisted of non-hazardous misc. bulk debris classified as construction/demolition debris and non-hazardous inert solids. Twenty five (25) 20-cubic yard roll-off boxes of non-hazardous debris have been removed from the Site. In addition, three (3) non-hazardous inert solids roll-offs and five (5) 20-cubic yard roll off of RCRA empty drums.

Waste Stream	Quantity	Manifest #	Disposal Facility
Construction/Demolition Debris	Estimated Weight 14 tons	01-14-09 Bill of Lading	Vienna Junction 6233 Hagman Road, Erie, MI 48133
Construction/Demolition Debris	Estimated Weight 14 tons	01-23-09 Bill of Lading	Vienna Junction 6233 Hagman Road, Erie, MI 48133
Construction/Demolition Debris	Estimated Weight 14 tons	02-03-09 Bill of Lading	Vienna Junction 6233 Hagman Road, Erie, MI 48133
Construction/Demolition Debris	Estimated Weight 14 tons	02-26-09 Bill of Lading	Vienna Junction 6233 Hagman Road, Erie, MI 48133
RCRA Empty Drums	Estimated Weight 20 cubic yards	008288	Vienna Junction 6233 Hagman Road, Erie, MI 48133