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Heller Heat Treating

All POLREP's for this site Heller Heat Treating
Clifton, NJ - EPA Region II
POLREP #9
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On-Scene Coordinator - Cris Donofrio, OSC 12/18/2009
Emergency - Removal Action Pollution Report (POLREP) #9
Start Date: 4/24/2009
Pollution Report (POLREP) #9
Site Description
See POLREPs 1 and 2.

Current Activities
The crew was remobilized after the Thanksgiving break and resumed site activities on 12/1/2009.  Upon return to the site it was learned that the Bankruptcy Trustee officially transferred custody of the Site property back to the President of Alfred Heller Heat Treating Company.  

Site activities for the period 12/1/2009 through 12/18/2009 continued as follows:

• Liquids generated during the decontamination of site equipment (plating lines, drums, etc.) were recovered and shipped for disposal via vacuum truck on 12/1/2009.  Approximately 2,580 gallons of liquids that were hazardous for chromium and trichloroethylene were shipped for disposal to Safety-Kleen Systems in Linden, NJ.

• Analytical results from the floor sweepings (all buildings) and contaminated concrete and brick from Building 5 areas indicated that these materials can be profiled as one waste stream.  

• The asbestos contaminated debris from the court yard area was loaded into 2x20 cubic yard (cy) roll-off containers on 12/8/09.  Dust levels were kept to a minimum using a water/detergent spray mist throughout the removal and loading operations.  The asbestos containers were shipped off-site for disposal on 12/11/2009 and 12/14/2009, respectively.  The material was shipped to Modern Landfill in York, Pennsylvania for disposal.

• Air monitoring and air sampling were conducted throughout the asbestos loading operations in order to ensure that airborne asbestos levels remained within safe limits for both workers and the public.  Monitoring and sampling locations included the perimeter of the court yard, the breathing zone inside the operations area and personnel sampling pumps on workers inside the exclusion zone.  All results indicate that asbestos fibers did not present a danger outside of the exclusion zone.  While a few asbestos fibers were indicated in some personnel samples, results were well below the OSHA 0.1 fiber/cc standard.  Workers within the exclusion zone utilized appropriate Level C personal protective ensembles.  No asbestos fibers were detected in any perimeter samples.  

• T&D activities continued during this operational period and a significant amount of site wastes were shipped for disposal.  Waste shipments were as follows:

o All loose pack and lab pack chemicals were shipped for disposal on 12/8/2009.  A total of 37 loose pack/lab pack drums were shipped off-site to the EQ-Detroit facility for treatment.  Wastes streams shipped to EQ-Detroit included acids, caustics, flammable and combustible liquids, copper chloride, ammonium hydrogen di-fluoride and hydrogen fluoride.  A total of 8 loose pack/lab pack drums were shipped to Ross Incineration in Grafton, OH.  Waste streams shipped to this facility included flammable metal powders, waste chloroform, potassium permanganate, silver nitrate and peroxides.
o One 30 cubic yard (cy) roll-off container of non-hazardous debris was shipped off- site for disposal on 12/4/09.  One 22 ton load of floor sweepings/debris was shipped for disposal on 12/10/09.  Both loads were shipped to Modern Landfill in York, PA.

• Vapor intrusion sampling activities were initiated in Building 1 on 12/7/09.  The ERRS crew assisted in the installation of the sampling ports at 4 sub-slab locations.  The RST contractor installed the sampling probes; the probes were allowed to cure and equilibrate for 24 hours prior to sampling.   Sample locations for this event were placed surrounding a pre-existing equipment area where tetrachloroethylene (PCE) is known to have been used in degreasing operations.  RST began the 24 hour sample collection using Summa canisters on 12/8/09.  Sample collection was completed and the samples sent to the laboratory for analysis on 12/9/09.  In conjunction with the sub-slab sampling, two 24 hour ambient air samples were collected from Building 1 along with a background sample from an outdoor, upwind location.

• Soil sampling activities were initiated on 12/14/09 and completed by C.O.B. on 12/17/2009.  ERRS cored holes through the concrete flooring at sample locations to assist the RST contractor in accessing soil beneath the building slabs.  A total of 28 soil locations were sampled; 24 of which were sub-slab locations.   Sampling locations were chosen based on visual observations and knowledge of past site activities.  

• ERRS initiated the clean-out of two of the floor pits in Building 4 on 12/7/2009.  Oily liquid residues and oily debris were removed from the pits that were reported to have been used to impound waste wash water from the austemper lines.  During the clean-out it was discovered that there was an approximate 18-24 inch layer of solidified sodium nitrite/nitrate austemper salts (an oxidizer) in each of the pits.  Initial attempts to remove this material with a backhoe failed due to the hardness of the material.  A 1,000 pound hydraulic hammer attachment mounted on a back-hoe was mobilized on 12/9/09 to facilitate the removal of the oxidizer salts.  Removal of the salts from the Building 4 floor pits was completed on 12/10/09.

• Removal of the sodium nitrite/nitrate austemper salts from one of the austemper furnace pits in Building 3 was resumed on 12/11/2009 and completed by 12/17/09.  Previous attempts at removal with a smaller hoe-ram had failed. The 1,000 pound hoe-ram was used successfully during this attempt to remove the hardened material from the pit.    Progress was hindered due to the presence of the conveyor system and a considerable amount of metal parts that were entombed in the salt.  The conveyor system was cut out as necessary to allow access to the solidified material.  An approximate total of 40 cubic yards of the hardened oxidizer salts were removed during this operational period and placed into roll-offs for T&D.  An approximate total of 60 cubic yards of sodium nitrite/nitrate salts have been removed from various pits on site as of 12/17/2009.

• A second austemper furnace in Building 3 currently contains salt residues that cannot be removed at this time.  This furnace is intact and was sold at auction.  Since removal of the salts would damage the conveyor system, EPA will not remove the salt residues unless otherwise notified by the purchaser.  EPA has notified the purchaser that the salt residues are being left in the furnace and will be the responsibility of the purchaser unless action to reclaim the conveyor system is completed by early January 2010.    

• Since there is no heat in any of the Site buildings, the Site owner submitted a request to the Clifton Fire Department (CFD) to drain the wet fire suppression systems that protect Buildings 3 and 4.   The CFD granted verbal conditional permission on 12/10/2009 in order to avoid freeze damage to the system.  To satisfy the CFD requirements and allow drainage of the system,  ERRS cleaned out combustible debris materials from buildings 3 and 4 and relocated 60x 55 gallon drums of recyclable, feed-stock grade austemper salts that were sold at auction.  The austemper salts are being temporarily stored in Building 5 until final disposition of the material is effected.  Building 5 is currently protected by a dry fire suppression system; the wet portions of which were protected with heat tape and insulation.  The combustible debris from buildings 3 and 4 has been staged for disposal.

• The ERRS crew was demobilized on 12/19/09 in observance of the traditional holiday season.  Site activities will be resumed on 1/4/2010.


Planned Removal Actions
• Complete clean-out of the decon pit sump.
• Continue coordination and execution of T&D activities.
• Complete removal of austemper salts from the remainder of the pits as feasible.


Next Steps
Re-mobilize the ERRS contractor on 1/4/2010 to continue planned removal actions stated above.

Key Issues
• The ERRS project ceiling was increased from $1,050,000 to $1,250,000 on 12/7/2009.  The period of performance was extended from 12/26/2009 to 2/9/2010.