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Ingersoll Removal

All POLREP's for this site Ingersoll Removal
Chicago, IL - EPA Region V
POLREP #12 - Ongoing Site Activities
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On-Scene Coordinator - Tom Cook 8/7/2006
Time-Critical - Removal Action Pollution Report (POLREP) #12
Start Date: 1/18/2006
Pollution Report (POLREP) #12
Site Description
The detailed site description can be found in POLREP #1

Current Activities
ERRS conducted ACM removal in Building 924 for this reporting period.  Approximately 2,200 linear feet of ACM were removed.  During removal activities, an exclusion zone was created around the work areas with caution tape and water suppression and glove bags were used to prevent the release of ACM fibers to the atmosphere.  Continuous personnel and work zone perimeter air monitoring was conducted by START.  ACM debris generated during the removal has been double-bagged, labeled, and consolidated into a 30 cubic yard roll-off box on site.  

ERRS continued excavating contaminated sludge and debris from the center conveyor pit in Building 912 and furnace pits 4, 5, and 6 in Building 924.  Debris removed from these areas was stockpiled in Buildings 912 and 924.  Excavation of the conveyor pit was completed during the reporting period.  Cleanup of the wastewater holding area was completed during the reporting period.
During this reporting period, approximately 18,100 gallons of non-hazardous wastewater were hauled off-site to the Clean Harbors Services, Inc. treatment facility in Chicago, IL.  Loads were transported on July 11, July 20, July 21, July 22, July 24, July 26, and July 31, 2006.    
A ramp was constructed from consolidated debris along the east side of Building 715 so that heavy equipment could be mobilized into the building in preparation for ACM removal.  
On July 25, 2006, while walking over a plywood covering on the floor of Building 924, an ERRS employee fell though the plywood covering into an eight-foot deep pit containing approximately six feet of oil and water.  Another ERRS employee was there to assist the employee who had fallen and help him climb out of the pit.  The employee who had fallen was taken to a medical clinic for a checkup, although he had only sustained minor cuts and bruises.  Following the incident, ERRS conducted an internal health and safety audit, and performed the following corrective actions:  performed an all-hands review of the site health and safety plan; backfilled the pits in Building 924 that have been cleaned out; installed plywood coverings over pits and manholes that cannot be filled in yet; ensured that a 12-inch overlap of plywood along the pit perimeters is allowed at every pit; marked pits and holes within work areas with additional caution tape and orange spray paint; and re-emphasized the use of the buddy system at all times.

Air Sampling and Monitoring:

At the request of the OSC, START continued to collect daily asbestos air samples from the breathing zone of ERRS laborers and the perimeter of the work area on the days that asbestos removal work was being performed during the reporting period.  One asbestos air sample was collected daily from one ERRS laborer and four or five samples were collected from around the perimeter of the work area.  The perimeter samples covered all four compass directions and one additional location.  The ERRS workers are encouraged to wet the ACM prior to removal to reduce the amount of airborne ACM fibers.  Analytical results have indicated that all levels of asbestos in air have been below permissible exposure levels with the exception of the personnel sample collected on July 27, 2006.  The result indicated 0.13 asbestos fibers per cubic centimeter (0.10 fibers per cubic centimeter OSHA PEL).  However, the pump malfunctioned during this sampling event after running for 85 minutes thereby drastically shortening the sampling period and not providing a sample that represented the work day.   The results have been discussed with ERRS.
Two air samples were overloaded during the reporting period; one perimeter air sample collected on July 27, 2006 and one personnel air sample collected on July 19, 2006.  The overloading was a result of the impact of dust generated during other site work performed adjacent to the exclusion zone while ACM removal was being conducted.  The results have been discussed with ERRS and, as a corrective action, ERRS has agreed to conduct any additional site construction activities during periods when ACM removal is not being conducted.  
Due to the continuous change in work activities and the number of interconnected buildings on site, the OSC has recommended that the workers continue to dress in Level C PPE (level C) while performing asbestos removal work.

START conducted air monitoring with a MultiRae® five-gas photo-ionization detector (PID) on July 11, July 12, and July 25, 2006.  Monitoring was done during the cleanup of the wastewater holding area on July, 11 and July 12, 2006 and around the ERRS employee who fell into the pit on July 25, 2006.  The VOC, CO2, H2S, LEL and oxygen level readings for the workers’ breathing zone were at or below background levels.  

Liquid Sampling:

No liquid samples were collected during this reporting period.

Wipe Samples:

No wipe samples were collected during this reporting period.  

Solid Samples:

No solid samples were collected during this reporting period.  

For additional information regarding site removal activities and sampling, see the Summary of Activity and Samples table in the documents section.


Planned Removal Actions
To mitigate the threats to human health and the environment posed by conditions at the Former Ingersoll Site, the U.S. EPA plans to:

•• Fortify and maintain site security to prohibit the public from entering the site;
•• Evaluate the nature of liquid in on-site sumps, pits, vaults, basements, and manholes, and remove and dispose of contaminated liquid and sediment from those areas;
•• Evaluate transformer pads for PCB contamination and remove those pads that are contaminated;
•• Decontaminate surfaces contaminated with PCBs; and
•• Evaluate the exposure of nearby populations to asbestos fibers that may migrate from the site property and remove the ACM from the site.


Next Steps
•• Continue with ACM removal;
•• Continue stockpiling debris and floor scrapings from within facility buildings;
•• Continue the extent of contamination survey of on-site sumps, pits, vaults, basements, and manholes containing liquid as well as potentially impacted soil;
•• Continue de-watering contaminated liquid from sumps, pits, vaults, basements, and manholes;
•• Continue power washing surfaces, excavation of pits and trenches, and backfilling open pits and trenches with clean fill;
•• Continue collecting air samples for asbestos from worker breathing zones and work zone perimeter;
•• Continue to document site activity and conditions;
•• Evaluate analytical results from samples collected on-site as they become available; and
•• Continue transportation and disposal of liquid and solid waste.


Key Issues
•• Meeting transportation and disposal analytical requirements for debris and floor scrapings that have been stockpiled;
•• Handling contents of on-site sumps, pits, vaults, basements and manholes that may contain standing or running liquid with potentially elevated levels of toxic and hazardous constituents;
•• Covering remaining manholes, pits and trenches;
•• Maintaining health and safety protocols; and
•• Taking all proper measures to keep airborne asbestos and lead contamination below OSHA and EPA standards.