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Heller Heat Treating

All POLREP's for this site Heller Heat Treating
Clifton, NJ - EPA Region II
POLREP #6
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On-Scene Coordinator - Cris Donofrio, OSC 9/30/2009
Emergency - Removal Action Pollution Report (POLREP) #6
Start Date: 4/24/2009
Pollution Report (POLREP) #6
Site Description
See POLREPs 1 and 2.

Current Activities
EPA continued Site cleanup activities for this period as follows:
• Waste removal from the plating line vats and secondary containment has been completed.  The waste was removed from the secondary containment using a mini-excavator.  The waste material was then bulked into three (3) separate 20 cubic yard roll-off containers for transportation and disposal (T&D).  
• Laboratory analytical results from waste stream samples have been received and are currently being evaluated for waste profiling and solicitation of transportation and disposal services.    To date, approximately 40 potential waste streams have been identified.  
• The methanol from the above ground methanol tank was removed on 9/14/09.  A total of 728 gallons were recovered and for recycling by the original vendor, Houghton Chemical Corporation of Allston, MA.  
• A total of four (4) 30 cubic yard roll-off containers of non-hazardous debris were shipped off-site during the period 9/9/09 through 9/17/09.  The waste was shipped to Keystone Sanitary Landfill in Dunmore, PA.  The wastes were generated from the decommissioning of the plating lines and included non-metallic plating line debris (piping/equipment), spent PPE and decontaminated/demolished drums from waste consolidation operations.
• EPA/ERRS completed the waste removal, dismantling and removal of three air scrubber units located on-site.  The wastes from the scrubbers were bulked into a 20 cubic yard roll-off container for T&D pending sample analysis and waste profiling.    
• EPA/ERRS pumped residual oil out of the UST located at the northwest end of Building 5.  Approximately 60 gallons of oil were recovered.  There is a sludge layer of undetermined thickness at the bottom of the tank; however, it appears that water intrusion into the tank has not occurred, suggesting that the tank shell is intact.
• Three sections of the concrete supports associated with the decommissioned plating lines appear to be heavily contaminated based on the color and/or poor integrity of the concrete.  Two of these are suspicious for hexavelant chromium and/or hydrochloric acid based on the color of the concrete, the location within the plating line and its deteriorated condition.  The third area may be contaminated with dyes associated with the plating/coating process.   Samples were collected from all three suspect sections of the concrete supports.  The samples were submitted to a laboratory for Target Analyte List (TAL) metals, hexavelant chromium and disposal parameters.
• The two sections of plating line supports suspected for chromium contamination were demolished and removed using a backhoe-ram.  The contaminated concrete has been staged for disposal pending analytical results.  The third section suspected of dye contamination was power washed.  Final disposition of this area will be determined pending receipt of analytical results.
• Sodium nitrate salt residues from one of the austemper furnace lines were removed using a backhoe ram.  An approximate two-foot thick section of the salt has been removed and staged for disposal pending receipt of the appropriate roll-off container.  A residual layer of the material at the bottom of the austemper line, approximately 2-6 inches thick, could not be removed because it is tied up in the metal conveyor belt.  Attempts at /removing the conveyor belt have been unsuccessful.  It currently appears that the only way to access the residual material would be to remove the tank from its below-grade location and cut the tanks into sections to allow better access to the salts.  This would require a heavy crane and possibly roof removal to perform; EPA will investigate other potential options before determining the final fate of this material.  
• Drum over-packing and empty drum disposal operations continue as necessary.  The empty drums generated from waste consolidation efforts are being cut up to minimize volume and are being placed into roll-off containers for T&D.
• Debris removal continues as necessary to allow access for removal of potentially contaminated dust, oil and grime from the facility floors.    
• A draft Request for Proposal (RFP) for T&D was prepared based on analytical results from the various waste streams.  The RFP is expected to be finalized and issued by the end of the week of 9/28/09.
• The USCG AST continues to support EPA for on-site safety compliance.  The AST performs daily Area-Rae monitoring in the work zones and monitors site activities to ensure H&S compliance.

A metal recycler that entered into a contractual agreement with the Trustee/auctioneer is still in the process of disassembling and removing plant equipment for scrap value.  EPA/ERRS continues to coordinate with the recycler as needed to decontaminate equipment and ensure appropriate management of wastes associated with equipment liquidation.  Additionally, EPA is confining intrusive work to well-defined areas that are remote from the equipment removal activities to avoid conflicts in health and safety requirements and to avoid interfering with auction-related activities.  


Planned Removal Actions
Currently EPA plans to remove all chemical waste drums, containers and laboratory chemicals.  Additionally, EPA will remove and dispose of wastes from all vats, tanks, sumps and equipment reservoirs and will conduct surface decontamination of the plating line sumps, troughs and other areas as necessary.  EPA will continue to work closely with the Bankrutpcy Trustee to identify chemicals that may have value and can be sold or reclaimed.


Next Steps
The Next Steps Planned for removal acitivities include the following:

• Continue decontamination of the plating line sumps/troughs, dismantle remaining austemper equipment and decontamination of the associated below-grade sumps;
• Sample waste streams generated during decontamination as necessary; and
• Continue evaluation of analytical results, establishing waste profiles and soliciting subcontracts for transportation and disposal.


Key Issues
The ERRS project cieling was increased from $750K to $950K and the contract period of performance was extended  from 9/27/2009 to 12/26/2009.  

The USCG Atlantic Strike Team project ceiling was also increased from $6.5K to $22K.