Pollution Report Profile - EPA OSC Response

Miller Plating Site
Evansville, IN - EPA Region V
POLREP #7 - Final POLREP

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On-Scene Coordinator - Kevin Turner	10/15/2009
Time-Critical - Removal Action	Pollution Report (POLREP) #7
Start Date: 1/19/2009	Completion Date: 10/5/2009

Site Description
The former facility sets on seven acres, of which approximately three acres are under roof and holds four parcels in Center Township of Evansville.  The site is bordered by Allen Lane and a residential neighborhood to the south; a residential neighborhood to the north; Sixth Avenue and a residential neighborhood to the west; Railroad tracks to the east.  In February of 2004, Don Stocks purchased the business from the Miller family and changed the name to Miller Plating & Metal Finish Incorporated.

The former facility conducted electrolysis nickel plating using eight plating lines primarily on aluminum, as well as conducting steel copper, chrome, and brass electroplating processes.  Precious metal finishing and plating had also been performed
at the facility. The Site processed a variety of parts and offered the following finishes:
Electrode less Nickel, Bright Acid Tin, Black Chrome, Sulfamate Nickel, Bright Nickel,
Copper, Gold Silver, and Anodizing.  A variety of RCRA hazardous wastes which are associated with electroplating, cleaning processes, maintenance activities, and the
waste water treatment process was generated at the facility.  These included cyanide plating solutions and other RCRA waste with codes listed as F002, F003, F006, F007, F008, and F009.  On December 31, 2007, the facility ceased its plating operation due to bankruptcy.

After filing bankruptcy, the Indiana Department of Environmental Management (IDEM) was concerned the electricity was going to be cut off increasing the likelihood that chemicals in product lines would freeze and that the piping conveyances might also burst causing a release/spill of chemicals at the facility and potentially causing harm to the environment.  Additionally, the Pretreatment Coordinator for the Evansville Wastewater Treatment Plant reported that Evansville would be pulling the water meter and plugging the sewer.  The facility has, historically, been a large quantity hazardous waste generator with on going regulatory environmental compliance issues.  IDEM asked for US EPA’s assistance with an emergency stabilization within the facility.  Using the On-scene Coordinators (OSC) authority to initiate emergency response activities under the NCP section 300.415 (b) (2) OSC Kevin Turner was provided $25,000 ceiling to perform an emergency stabilization.

Following the emergency stabilization efforts in January 2008, both IDEM and US EPA worked with the PRP and various banks in attempts to remove all liquids and clean-up the facility.  After an auction in August 2008, a fire started as contractors were attempting to remove vats from the east building.  The fire resulted in nickel plating solution being released to the environment.  The former facility has been broken into several times and is in unstable condition.  On October 24, 2008, IDEM formally asked US EPA to abate the risks associated with uncontained hazardous materials at the Site.

Current Activities
• START had conducted air monitoring during all site activities.
• On July 21st, a mini-excavator was used on site for mixing sludge’s and soil excavation.
• Soil excavation is from a past spill of liquid “silver strip” which occurred on site in August 2002.  The spill location is on the east side of the property, adjacent to the bulk waste water treatment storage building.  The release was partially excavated in 2002 and the excavated soils were containerized in a roll-off box which remained on-site.  The cleanup was never completed by the Miller Plating company.
• On July 22, 2009, at the direction of OSC Turner, ERRs excavated an additional four inches of soil located in the “silver strip” liquid spill area.  On July 24th the excavation was completed and a total of 30 cubic yards of non-hazardous soil was stockpiled on poly sheeting and covered.  Once the area was excavated it was checked and backfilled with clean soil.
• On September 1, 2009 the fence in the soil spill area that separated Miller Plating from the back neighbor was replaced.  This fence had been removed in 2002 when the “silver strip” was released.
• ERRs requested approval from Laubscher Meadows Landfill (LML) to dispose the site’s excavated non-hazardous soil to their facility.  At the request of LML, the excavated soil was to first be analyzed for TCLP RCRA eight metals, TCLP Volatile Organic Compounds (VOCs) and TCLP Semi-volatile Organic Compounds (SVOCs). Based on the sample results LML approved the soil to be disposed at their landfill in Evansville. Sixty cubic yards of soil were sent off for disposal.
• On July 24, ERRs continued the removal activities in the waste water liquid chemical storage (WLCS) building.  The building held five 5,000-gallon tanks.  The tanks were emptied, an access hole was cut into them, cleaned out and decommissioned.  The WLC had containment of a cement floor and four foot wall and with one sump located on the floor. The rest of the WLCS wall was made of metal along with a metal roof. The floor and walls were gross decontaminated using a power washer. The sump was vacuumed out.  On July 27, ERRs completed the removal activities in the WLCS.
• Starting on August 4, the bulk of the work focused on the completion of the waste water treatment building (WWTB).  The WWTB floor design is open and lies in two levels, upper and lower level, and joins the main building.  The WWTB had all its container’s removed and tanks emptied.  ERRs began cutting an access hole in the bottom of sand filters in order to remove the sand that remained within.  The lower level also included a wall barrier which held two 3,500 gallon chemical feed tanks.  Once the tanks were emptied, they had to be cut up and removed in order to thoroughly clean the floors inside the containment from past chemical spills.  The upper and lower floors were gross decontaminated using a power washer and the sumps were vacuumed out. On August 14, ERRs completed the removal activities in the WWTB.
• Removal activities in the wheel line room continued by removing all liquids and sludges and placing them into bulk tanks.  All the vats and were decontaminated and cut up for disposal. ERRs removed all the piping located in the wheel line and pit.  The sump located in the pit was cleaned out.  On August 19, ERRS had completed all activities within the wheel line room.  Four 1,000 gallon tanks were decontaminated but were not totally decommissioned.  The tanks were deemed in excellent condition and the idea, for leaving them, was for the possibility of being reused by another entity.
• On August 11, ERRs worked on completing the removal activities in Building #2, Chemical Storage Manufacturing Storage Building (Bldg#2), located on the northeast corner of the property.  The building container’s had been emptied, tanks removed, and the floors were decontaminated using a power washer.  The building also included a pit that held water.  The water was pumped from the pit and the sumps were vacuumed out.  On August 12, ERRs completed the removal activities in Bldg#2.
• August 18, after all the vats and piping were cut up, cleaned and disposed, ERRS began the gross decontamination of the floors, walls and pits located where the former main plating lines existed.  Once the area was deconned, ERRs used cement mix to fill damaged areas of the cement floor caused by past chemical spills.   The gross decon and repair of the main plating line was accomplished by August 21st.
• Solidification of all sludge’s was completed on August 24th.
• On August 26th, the lab packing of small containers was completed.
• ERRs had continued to remove piping (plastic and metal) from and above former plating lines.  A total of 28,920 linear feet of piping was removed.  Once removed, the pipes were decontaminated and placed into a roll-off box for off-site disposal.  In addition, empty drums are decontaminated and placed into the roll-off.  Approximately 189.03 tons of non-hazardous debris has been disposed of thus far. The non-hazardous debris is disposed at the Laubscher Meadows Landfill in Evansville, IN.
• Approximately 89,668 gallons of non-hazardous liquid waste has been taken off site by Waste Management.  The non-hazardous waste liquid was taken to the Outerloop Landfill located in Louisville, KY, for solidification.
• Approximately 23.47 tons of scrap metal has been taken off site by a local recycler, Fligeltaub of Evansville, IN.
• ERRs completed the process of decommissioning all but four tanks located on site.  The tanks are decommissioned by cutting large holes toward the bottom or cutting then in half.  On August 21st, 79 tanks have been decommissioned of which 58 tanks were eventually completely cut up, cleaned and disposed of as nonhazardous debris.  There are 21 decommissioned tanks left on site.
• On August 27th, the last of the off-site disposal activities were completed.
• In order to alert visitors at the site, OSC Turner requested that safety and caution signs be posted at various potential hazardous areas.  There were “caution signs stating unsafe structure” posted on the platform located in the waste water treatment building.  Do “not enter” signs were posted on doors into the building and to where the pits are located.

Planned Removal Actions
None

Next Steps
None

Key Issues
None

Disposition Of Wastes

Waste Stream	Quantity	Manifest #	Disposal Facility
RQ, Waste Corrosive Liquid Acidic, Inorganic, n.o.s. (sulfuric Acid, Chromic Acid), 8, UN3264, PGII (D002, D007)	5,720 gallons	002501960FLE/001650053FLE	Envirite of Illinois 16435 Center AV, Harvey, IL 64026
RQ, Waste Corrosive Liquid Acidic, Inorganic, n.o.s. (Soium Hydroxide), 8, UN3264, PGIII (D002, D007, D008,D010, D011)	2,600 gallons	002009343FLE	Envirite of Illinois 16435 Center AV, Harvey, IL 64026
RQ, Hazardous Waste Solid, N.O.S (Chromium), 9, NA3077, PGIII (RQ-10lbs) (D007, F008)	4.45 tons	002689632FLE/002689633FLE	Michigan Disposal Waste Treatment Plant, 49350 N. I-94 Service DR. Bellevill, MI 48111
RQ, UN3414, Waste Sodium Cyanide Solution, 6.1, PGII, (Sodium Cyanide/Potassium Cyanide) (D009,D011), ERG#154	4,000 gallons	000270035WAS	Michigan Disposal Waste Treatment Plant, 49350 N. I-94 Service DR. Bellevill, MI 48111
RQ, UN3414, Waste Corrosive Solids, Toxic, n.o.s. 6.1, PGII, (Sodium Cyanide/Potassium Cyanide) (D009,D011), UN2923, ERG#154	20.14 tons	006328141JJK	Envirite of Ohio, Inc. 2050 Central AV S.E., Canton, OH 44707
RQ, Waste Corrosive Liquids, Acidic, Inorganic, n.o.s. (Sulfuric Acid), 8, UN3264, PGII, ERG#154	550 gallons	006328133JJK	Environmental Enterprises Inc., 4650 Spring Grove AV, Cincinnati, OH 45232
Stannous, , Non Hazardous/non Regulated	5 gallons	006328133JJK	Environmental Enterprises Inc., 4650 Spring Grove AV, Cincinnati, OH 45232
RQ, Sodium Dithionite, 4,2, UN 304, PGII, ERG#135	55 gallons	006328127JJK	Environmental Enterprises Inc., 4650 Spring Grove AV, Cincinnati, OH 45232
RQ, Waste Potassium Persulfate, 5.1, UN1492, PGIII, ERG#140	55 gallons	006328127JJK	Environmental Enterprises Inc., 4650 Spring Grove AV, Cincinnati, OH 45232
Sodium Hydrosulfide, non hazardous/non regulated	55 gallons	006328127JJK	Environmental Enterprises Inc., 4650 Spring Grove AV, Cincinnati, OH 45232
RQ, Hazardous Waste Liquid, n.o.s., (Trichloroethylene), 9, NA3062, PGIII, ERG#171	165 gallons	006328138JJK	Environmental Enterprises Inc., 4650 Spring Grove AV, Cincinnati, OH 45232
RQ, Waste Corrosive Liquid, Acidic Inorganic, n.o.s. (Chromic Acid), 8, UN3264, PGII, ERG#154	495 gallons	006328138JJK	Environmental Enterprises Inc., 4650 Spring Grove AV, Cincinnati, OH 45232