Pollution Report Profile - EPA OSC Response

DLH Plating Site
Cleveland, OH - EPA Region V
POLREP #8 - Removal Action

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On-Scene Coordinator - James Augustyn	3/16/2009
Time-Critical - Removal Action	Pollution Report (POLREP) #8
Start Date: 11/11/2008

Site Description
See POLREP #1 for Site Description.

Current Activities
On February 20, 2009, ERRS completed the gross removal of sludge from wastewater treatment holding tank 128 and began sludge removal from tank 127. ERRS continued solidification and consolidation of cyanide sludge in Room M. Twenty (20) cubic yards of hazardous waste solids [Hazardous Waste Solid, D006, D007, F006, F007] were removed from the Site in roll-off boxes and transported to Envirite of Ohio, Inc. for disposal.

On February 23, 2009, ERRS completed gross removal of sludge from Tank 127 and began removal of sludge from tank 130 at the wastewater treatment facility. Forty (40) cubic yards of RCRA empty containers and debris was transported off site to American Landfill for disposal.

On February 24, 2009, ERRS completed gross removal of sludge from Tank 130 at the wastewater treatment facility. Additional solidification was required for the wastewater treatment sludge that was placed in roll-off boxes. Fiberglass Tanks 116, 117 and 118 were moved to the northeast portion of the Site and cut in half. The bottom half of the three tanks were used for consolidation and solidification of sludge from other tanks on the Site.

On February 25, 2009, ERRS began removal of sludge from Tank 113 in Room B. ERRS also began cutting, decanting, and removal of process piping in Room A. Thirty-three (33) cubic yards of hazardous waste solids [Hazardous Waste Solid, D006, D007, F006, F007] were removed from the Site in roll-off boxes and transported to Envirite of Ohio, Inc. for disposal.

On February 26, 2009, ERRS completed removal of sludge and decontamination of Tank 113 and removed the tank from the building. ERRS completed the removal of process piping in Room A. A hydrochloric acid pipe was accidentally hit with the excavator while removing Tank 113 from the building. Some acid within the pipe spilled on the floor of Room B and created acid vapors. Sorbents and neutralizing agents were placed on the spill. The acid vapors dissipated within 2 hours, and air monitoring levels were at background levels. ERRS began evacuation of water from the Pump House in preparation for removal of tanks 122, 123, 124 and 125.

On February 27, 2008, ERRS continued removal of water from the Pump House. ERRS began cutting, decontaminating and removing sections of four tanks from the Pump House. ERRS cut the steel fasteners to all of the tanks in Room A in preparation for removal of tanks from the building. Solidified and consolidated acid sludge was placed into hazardous waste roll-off boxes.

On March 2, 2009, ERRS continued cutting, decontaminating, and removing piping and tanks from the Pump House. ERRS began removal of fiberglass tanks inside Room A. ERRS removed the tanks, solidified the sludge and placed the sludge into a roll-off box. Asbestos consultants on Site for site walk and submittal of an asbestos survey bid in preparation for demolition activities. A large hole was cut in the side of Tank 121 to render it non-reusable. Forty (40) cubic yards of RCRA empty containers and debris was transported off site to American Landfill for disposal.

On March 3, 2009, ERRS continued removal and solidification of sludge, piping, and tanks from the Pump House. ERRS continued removal and solidification of sludge and tanks from Room A. Sixteen (16) cubic yards of hazardous waste solids [Hazardous Waste Solid, D006, D007, F006, F007] were removed from the Site in a roll-off box and transported to Envirite of Ohio, Inc. for disposal.

On March 4, 2009, ERRS completed solidification and removal of sludge and all tanks from the Pump House. ERRS continued the solidification and removal of sludge from tanks in the Acid house (Room A). Tanks 1 through 5 were rendered non-reusable. Additional solidification was required for sludge already placed in roll-off boxes on Site. Sixteen (16) cubic yards of hazardous waste solids [Hazardous Waste Solid, D006, D007, F006, F007] were removed from the Site in a roll-off box and transported to Envirite of Ohio, Inc. for disposal.

On March 5, 2009, ERRS completed removal of sludge and the last tank (Tank #6) from Room A. ERRS continued a general debris clean-up of Room A. Crew began assembling cubic yard Gaylord boxes in preparation for transferring high cyanide sludge. Additional solidification was required for sludge already in roll-off boxes on Site. ERRS continued categorization and bulking of laboratory chemicals, and general debris clean-up in the laboratory and chemical storage rooms.

Activities performed by START from February 20, 2009 to March 5, 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 within the tanks and totes; categorizing and consolidating small containers from throughout the facility; decontaminating tanks, removing them from the building, and rendering them as 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. Asbestos survey and preparation for partial or complete demolition of the building.

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

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

Key Issues
None.

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.
270 cubic yards of Hazardous Waste Solid D006, D007, F006, F007 (Chromium, Cadmium) have been transported to Envirite of Ohio, Inc. for disposal.

240 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 20, 2009.

Waste Stream	Quantity	Manifest #	Disposal Facility
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, D007, F006, F007	20 cubic yards	001594110	Envirite of Ohio, Inc., Canton, Ohio
RCRA empty containers and debris, Profile 104621OH	40 cubic yards	375258	American Landfill, Waynesburg, Ohio
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, D007, F006, F007	17 cubic yards	001594100	Envirite of Ohio, Inc., Canton, Ohio
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, D007, F006, F007	16 cubic yards	001594101	Envirite of Ohio, Inc., Canton, Ohio
RCRA empty containers and debris, Profile 104621OH	40 cubic yards	375259	American Landfill, Waynesburg, Ohio
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, D007, F006, F007	16 cubic yards	001594101	Envirite of Ohio, Inc., Canton, Ohio
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, D007, F006, F007	16 cubic yards	001594101	Envirite of Ohio, Inc., Canton, Ohio