Pollution Report Profile - EPA OSC Response

DLH Plating Site
Cleveland, OH - EPA Region V
POLREP #6 - Removal Action

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On-Scene Coordinator - James Augustyn	2/6/2009
Time-Critical - Removal Action	Pollution Report (POLREP) #6
Start Date: 11/11/2008

Site Description
See POLREP #1 for Site Description.

Current Activities
On January 23, ERRS continued the decontamination of the cyanide totes and tanks. ERRS also continued categorizing and consolidating the non-RCRA, non-hazardous small containers within the building. Six (6) steel tanks were decontaminated and removed from the building.

On January 26, ERRS began the removal of tanks from the auto cadmium plating line in Room L. Twenty six (26) tanks were removed from the plating line in Room L, segregated, and temporarily staged in Room M for consolidation and decontamination.

On January 27, ERRS completed the removal of the solidified sludge from the tank 86 from the auto cadmium plating line in Room L. Tank 86 is a large tank which contains high concentrations of cyanide sludge. A local scrap contractor arrived on Site to render the empty and decontaminated tanks to a non-reusable condition by crushing them with a larger excavator. 40 cubic yards of RCRA empty containers and debris was transported off site to American Landfill for disposal.

On January 28, ERRS completed the removal of the solidified acid sludge from the tanks removed from the auto cadmium plating line from Room L. Work activities were terminated at noon today because of heavy snow conditions.

On January 29, ERRS began the cutting of tank 86 into smaller, more manageable sections. This tank needed to be cut into 3 sections in order to remove it from the auto cadmium plating line in Room L. ERRS also began loading roll-off boxes with floor debris from Rooms B, G and M. Thirty-five (35) cubic yards of hazardous waste solids from the solidified acid sludge [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. Representatives from the Ohio EPA were on Site to conduct a site-walk and to monitor the progress of the removal activities.

On January 30, ERRS continued cutting tank 86 into smaller, manageable pieces in order to remove it from the building. ERRS also continued loading roll-off boxes with hazardous waste solids from floor debris from Rooms B and G. Forty (45) 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 2, ERRS decontaminated twenty-three (23) tanks and removed them from the building for decommissioning. ERRS completed the decontamination of tank 86 and removed it from the building for decommissioning. Solidified cyanide waste from Room M was removed and placed into roll-off boxes for off site disposal.

On February 3, ERRS began cutting the tanks which were removed from the building. Tanks which cannot be properly decontaminated will be cut into 3’ by 3’ sections and placed into roll off boxes for hazardous waste disposal. ERRS also began the clean-up of floor debris from the plating line in Room L. Consolidated floor debris from Room G and Room M was placed into a roll-off box for hazardous waste disposal.

On February 4, ERRS continued with the clean-up of floor debris from the auto cadmium plating line in Room L. Heavy snow fall prohibited the tank cutting operations of the decontaminated tanks which were staged outside. Fifty (50) 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. ERRS began loading roll-off boxes with “cut-up” tanks which could not be decontaminated. Steel tanks which cannot be decontaminated will be placed into a roll-off box for hazardous waste disposal.

On February 5, ERRS continued with the clean-up of floor debris from the auto cadmium plating line in Room L. Floor debris containing high concentrations of cyanide were segregated from the other waste streams and temporarily staged in Room F. Scrap steel was transported off site for recycling. Forty (40) 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.

Activities performed by START from January 23, to February 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; sampling, 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.

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 system, dismantling and decontamination of the wastewater treatment system, decontaminating the walls and floor once the 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:

75,240 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.
195 cubic yards of Hazardous Waste Solid D006, D007, F006, F007 (Chromium, Cadmium) have been transported to Envirite of Ohio, Inc. for disposal.

160 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 January 23, 2008.

Waste Stream	Quantity	Manifest #	Disposal Facility
RCRA empty containers and debris, Profile 104621OH	40 Cubic Yards	375257	American Landfill, Waynesburg, Ohio
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, D007, F006, F007	15 Cubic Yards	001594056	Envirite of Ohio, Inc., Canton, Ohio
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, D007, F006, F007	20 Cubic Yards	001594057	Envirite of Ohio, Inc., Canton, Ohio
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, D007, F006, F007	20 Cubic Yards	001594065	Envirite of Ohio, Inc., Canton, Ohio
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, D007, F006, F007	25 Cubic Yards	001594066	Envirite of Ohio, Inc., Canton, Ohio
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, D007, F006, F007	25 Cubic Yards	001594082	Envirite of Ohio, Inc., Canton, Ohio
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, F006, F007	25 Cubic Yards	001594083	Envirite of Ohio, Inc., Canton, Ohio
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, D007, F006, F007	20 Cubic Yards	001594097	Envirite of Ohio, Inc., Canton, Ohio
RQ, NA3077, Hazardous Waste Solid, N.O.S. (Chromium, Cadmium), 9, PG, D006, D007, F006, F007	20 Cubic Yards	001594096	Envirite of Ohio, Inc., Canton, Ohio