The Schulte Metals Site is located at 4909 Charlemar Drive in Cincinnati, Hamilton County, Ohio. The three-acre Site is located in a mixed residential, commercial, and light industrial area, and is less than 200 feet from residential areas. The Site is bordered to the north and west by residential properties, and to the east and south by commercial and light industries. The Site includes one large building that contains plating lines, a hand-line plating area, a laboratory, a waste treatment area, offices, a machine shop area, and numerous drum storage areas. U.S. EPA and WESTON START observed approximately three hundred 55-gallon drums containing various chemicals, 144 plating tanks, and several hundred smaller containers with varying chemical waste capacities.
The Schulte Corporation, the business’s operating name from 1958 to 1992, later known as the Schulte Metals Finishing Company (SMFC), conducted copper cyanide, chrome, and nickel plating at the Site. The facility conducted plating operations for plumbing fixtures and specialty automotive parts from 1958 until December 2006.
According to Cincinnati Police Department (CPD) records, the Site has a history of vandalism and trespassing between 2002-2006.
SMFC ceased operations in December 2006 without notifying the Cincinnati Municipal Sewer District (CMSD). On March 8, 2007, CMSD and the Ohio Environmental Protection Agency (Ohio EPA) inspected the Site and observed that most of the plating tanks were empty, and there were numerous drums containing hazardous waste.
On March 30, 2007, CMSD, Ohio EPA, and the CFD inspected the Site in response to a complaint that plating tanks were being emptied during the auction. The CFD vacated the premises and secured the building. All utilities were discontinued, and CMSD, with SMFC’s permission, placed a sewer plug into the Site outflow sewer line.
In a letter dated April 5, 2007, Ohio EPA requested assistance from the U.S. EPA Region V Superfund Division in conducting a potential time-critical removal action involving several hundred 55-gallon drums and numerous tanks containing plating waste.
On April 16, 2007, U.S. EPA, Ohio EPA and CFD conducted a site reconnaissance inside the facility.
U.S. EPA observed a Laboratory inside the facility, which contained numerous laboratory chemicals such as hexane, various poisons, benzyl chloride, ammonium chloride, nitric acid, acetic acid, sulfuric acid, and various containers labeled as ‘containing cyanide’.
The Hazardous Waste Storage Area is located northwest of the Laboratory. In this area of the Site, U.S. EPA observed approximately 200 chemical-containing 55-gallon drums and containers labeled as: hydrochloric acid, sulfuric acid, sodium hypochlorite, copper solutions, nickel sulfide/brightener, cyanide copper, and chrome strip. The drums were staged in rows. Ohio EPA stated that some of the drums were filled with spent plating solutions that the Site owner emptied from the process plating tanks.
South of Dry Chemical Location A is Liquid Chemical Location B. This area contained approximately 70 containers with volumes of 55-gallons or less labeled as petroleum/lubricants, chrome, and liquid copper sulfate.
East of the Liquid Chemical Storage Room are the Plating Tank Process Lines. Approximately 100 plating tanks in various levels of deterioration were present. Some of the plating tanks were full of plating solutions. U.S. EPA observed a ceiling vent fan, directly above the plating line, which was open to the outside elements and would allow rainwater to enter the building.
U.S. EPA observed a 1,000-gallon plating tank that was approximately 50 percent full with a cyanide label and white crystals. The plating tank had plastic wrap over the top, either in an attempt to prevent vapors from leaving the tank or rainwater from entering the tank. U.S. EPA also observed a plating tank with a nitric acid label, approximately 25 feet from the plating tank, containing cyanide. The plating tank containing the green-colored, nitric acid liquid had a volume of approximately 500 gallons and was completely full.
Southwest of the Plating Tank Process Lines is the Waste Treatment Area. This area contained approximately 15 tanks and twelve 55-gallon drums and labeled as sulfuric acid, nickel, magnesium bisulfite solution, sodium hypochlorite, and nitric acid.
In the far southeastern corner of the building is the Cyanide Storage Area. This area contained 10 drums and containers with volumes of 40 gallons or less and labeled as sodium cyanide, zinc cyanide, copper cyanide, and potassium cyanide.
U.S. EPA observed standing water in many areas throughout the facility. The structural integrity of the building roof is questionable due to the evidence of numerous leaks. The potential is high for rain to enter the building through the roof leaks and cause the plating tanks to fill and possibly overflow.
On April 23, 2007, U.S. EPA conducted a site assessment at the Site. During site assessment activities, U.S. EPA tasked WESTON START to collect 22 samples from drums, tanks, and containers. Analytical results indicated the following:
• Four liquid samples showed the hazardous characteristic of ignitability, with flash points between 65 ºF and 71 ºF;
• Seven liquid samples showed the hazardous characteristic of corrosivity (acid), with pH levels between 0.0 and 0.42 standard units;
• One liquid sample showed the hazardous characteristic of corrosivity (caustic), with a pH level of 14.0 standard units;
• Six samples showed the hazardous characteristic reactivity, with total cyanide concentrations of 1,080 mg/L and 37,500 to 294,000 mg/kg; and
• One sample showed the hazardous characteristic of toxicity, with a TCLP chromium concentration of 4,000 mg/L and a TCLP lead concentration of 14.0 mg/L.
Based on analytical results and Site conditions during the site assessment, the Site meets the criteria for a removal action pursuant to 40 CFR 300.415(b)(2). The chemicals detected at the Site pose an imminent health threat and present a danger to the public and environment.
June 1-6, 2007, the EPA removal action was initiated with mobilization of personnel and equipment. A Site Health & Safety Plan and Site Emergency Contingency Plan was finalized and air monitoring activities were intiated. START completed a site waste inventory. Drum staging was initiated by ERRS.
From June 6 - July 13, 2007, the EPA removal action continued with sampling of wastestreams, packaging of lab chemicals, removal of plating vats, bulking of liquid wastestreams, and air monitoring.
Week of July 16 through July 20, 2007 – The following work was completed:
• ERRS continued dismantling the existing plating line and cutting up empty tanks and drums.
• ERRS pumped all drums and tanks containing hazardous liquid (chrome) into the above-ground storage tank.
• ERRS completed decontamination of Pit #5.
• Three rolloff boxes containing hazardous debris was transported for off-site disposal at Michigan Disposal Waste Treatment Plant (EQ), Belleville, Michigan.
Week of July 23 through July 27, 2007 – The following work was completed:
• ERRS continued dismantling the existing plating line and cutting up empty tanks and drums.
• ERRS completed decontamination of Pit #2.
• ERRS completed transferring all chromic acid liquid from drums and tanks into 50 poly drums; transferring all acid liquid into 6 poly drums; and transferring all acid solids into one poly drum.
• ERRS began consolidating caustic liquid into new poly drums.
Week of July 30 through August 3, 2007 – The following work was completed:
• ERRS continued dismantling the existing plating line and cutting up empty tanks and drums.
• ERRS completed cleaning out cyanide-containing sludge in the drainage trenches surrounding the main plating line.
• Two rolloff boxes containing hazardous debris was shipping for off-site disposal at Michigan Disposal Waste Treatment Plant (EQ), Belleville, Michigan.
Week of August 6 through August 10, 2007 – The following work was completed:
• ERRS continued dismantling the existing plating line and cutting up empty tanks and drums.
• ERRS loaded 50 drums containing chromic acid liquid on a box truck for off-site disposal at Michigan Disposal Waste Treatment Plant (EQ), Belleville, Michigan.
• ERRS loaded six drums containing acid liquid and one drum containing acid solid on a box truck for off-site disposal at EQ Detroit, Inc., Detroit, Michigan.
• ERRS consolidated all caustic liquid and caustic solids into drums, in preparation for off-site disposal.
• One rolloff box containing hazardous debris was shipping for off-site disposal at Michigan Disposal Waste Treatment Plant (EQ), Belleville, Michigan.
• Remove all drums and tanks containing hazardous waste and ship for off-site disposal.
• Decontaminate pits and sumps.
• Continue off-shift security during nights and weekends.
• No on-site work scheduled for August 13 through 17, 2007.
• Arrange for the off-site disposal of the drums containing caustic liquid and caustic solids.
• Bulk cyanide and pit sludge/floor sweepings into 55-gallon, poly drums for off-site disposal.
• Continue air monitoring with AreaRAEs.
• Arrange for a tanker to pump out the drums containing cyanide liquid.
• Arrange for a tanker to pump out the drums containing basic chrome liquid.
Abandoned hazardous waste on-site currently includes cyanides and caustics.
Site emergency contingency plan was finalized and distributed to local response agencies on June 1, 2007.
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