Pollution Report Profile - EPA OSC Response

Norwood Industries
Toledo, OH - EPA Region V
POLREP #3 - Continuation of Removal Activities

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On-Scene Coordinator - Jon Gulch	11/21/2008
Time-Critical - Removal Action	Pollution Report (POLREP) #3
Start Date: 10/21/2008

Site Description
See POLREP #1 for a full Site Description

Current Activities
From November 8-21, 2008, EPA has completed the process of clearing the interior of the eastern and central portion of the warehouse facility by disposing of miscellaneous non-hazardous bulk debris. This is required to safely identify the presence of waste drums and containers that are intermingled with the general debris. EPA has utilized this space to stage drums and containers for Level B sampling activities. Currently, approximately 50% of the main building and all of the western portion of the warehouse is still inaccessible due to the haphazard accumulation of general debris.

To date, a total of 134 55-gallon drums and 253 5-gallon containers have been staged and sampled for Hazard Categorization (HazCAT) identification. Twenty-six (26) pallets containing various solids (silica sands, finely milled sands, dyes, and powders) have been inventoried and disposed of in two (2) 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. Thirteen (13) 20-cubic yard roll-off boxes of miscellaneous non-hazardous bulk debris have been removed from the Site, in addition to one (1) 20-cubic yard yard roll-off of RCRA empty drums.

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
-  Continue non-hazardous general debris removal and disposal;
-  Continue segregation of materials;
-  Continue sampling of all materials;
-  Continue 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.

Key Issues
On November 18, 2008, an entry was made into the basement of the building, which was previously inaccessible due to the haphazard placement of general debris. During the investigation, an additional several hundred drums and small containers were discovered. In addition, at least three-quarters of the basement floor (which is the entire footprint of the main floor) is covered with an unknown liquid and sludge-like material. The source of the material on the floor is unknown and there are several floor drains. A pathway of cardboard boxes and burlap bags had been spread to provide access to all areas of the basement. At the back corner of the basement, there are burlap bags several feet thick laying on the floor and intermingled with the unknown sludge material. In addition, there is an elevator shaft that is approximately 4 feet deep with an oily liquid and the unknown sludge material from the floor. Samples have been collected for on-site HazCAT. An extensive inventory of the drums and small containers in the basement will be conducted to determine if additional funding will be required to complete the Removal Action.

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. Thirteen (13) 20-cubic yard roll-off boxes of non-hazardous debris have been removed from the Site. In addition, two (2) non-hazardous inert solids roll-offs and one (1) 20-cubic yard roll-off of RCRA empty drums.

Waste Stream	Quantity	Manifest #	Disposal Facility
Construction/Demolition Debris	Estimated Weight 14 tons	11-05-08 Bill of Lading	Vienna Junction 6233 Hagman Road, Erie, MI 48133
Construction/Demolition Debris	Estimated Weight 14 tons	11-12-08 Bill of Lading	Vienna Junction 6233 Hagman Road, Erie, MI 48133
RCRA Empty Drums	Estimated Weight 20 cubic yards	0167917	Vienna Junction 6233 Hagman Road, Erie, MI 48133
Construction/Demolition Debris	Estimated Weight 14 tons	11-19-08 Bill of Lading	Vienna Junction 6233 Hagman Road, Erie, MI 48133
Non-Hazardous Inert Solids	Estimated Weight 20 Cubic Yards	0167913	Vienna Junction 6233 Hagman Road, Erie, MI 48133
Non-Hazardous Inert Solids	Estimated Weight 20 Cubic Yards	0167916	Vienna Junction 6233 Hagman Road, Erie, MI 48133
Construction/Demolition Debris	Estimated Weight 14 tons	11-21-08 Bill of Lading	Vienna Junction 6233 Hagman Road, Erie, MI 48133