Pollution Report Profile - EPA OSC Response

Economy Plating Inc. (Chicago)
Chicago, IL - EPA Region V
POLREP #4 - Cleanup Continues

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On-Scene Coordinator - Ramon Mendoza, On-Scene Coordinator	10/5/2009
Time-Critical - Removal Action	Pollution Report (POLREP) #4
Start Date: 8/31/2009

Site Description
Economy Plating Inc. is an former plating shop which operated for approximately 70 years.  The site was discovered vacant and abandoned by the Chicago Department of the Environment (DOE) in January 2009. DOE's inspection indicated the presence of numerous drums and containers which were filled with unknown liquids and solids. Markings on the drums/containers include chromic acid, hyrdrochloric acid, methyl acetate, and oxidizer. DOE ordered the owner/operator to clean up the site. However, the owner/operator was unable to pay for the cleanup. The site was referred to USEPA for cleanup in May 2009.
USEPA conducted a site assessment on June 5, 2009 and found evidence of breakins & trespassers plus holes in the building where weather can enter the facility. Approximately 195 containers(open & closed, 5 gallons and greater)plus 12 vats were found containing old chromic acid solutions, other acids, and unknown solids. Several containers were found to be leaking in the basement. Results received on June 12, 2009 indicated open containers of solids contained up to 350,000 mg/kg of total cyanide. An emergency removal action was conducted from June 13-17, 2009 which collected, packaged, and properly disposed two drums of the high level cyanide materials.  In addition, 18 leaking containers were repacked and a drum of nitric acid was repacked.  The building was resecured and signage put up to discourage trespassing.

An Action Memorandum to fund and authorize a time critical removal action was approved and signed on August 4, 2009.  A site walk through was conducted on August 18, 2009 with EPA contractors and the Chicago Fire Department (CFD) . ERRS contractor acquired unpaid permit from the City to close sidewalk and street portion. OSC Mendoza notified the Chicago FD, Chicago DOE, and Alderman's office of upcoming work.  A health and safety plan (HASP) was drafted for review, by EPA ERRS contractor on August 28, 2009

Current Activities
On-site time critical removal work is on going.  The following activities were completed during this period 9/14 to 10/2/2009:
-  Additional sampling indicated hex chromium to be primary contaminant of concern. HASP amended and implemented to address risk to workers.
-  EPA risk assessment initiated to determine appropriate response action
-  North wall in alley between apartment and site was sealed with epoxy paint as temporary response to hex chromium coming out of the outside walls.
-  Solid waste debris, including all RCRA D empty drums cleared from building to be able to safely work with. three steel containers filled and disposed off-site.
-  Two rooftop air pollution control units demolished, deconned, and disposed off-site.
- Hazard categorization and staging of 74 drums completed.
-  All Chromic acid flake solids in small containers present inside building consolidated and repacked.
-  All small containers of miscellaneous hazard substances identified and segregated.
-  One 20 cubic yard box of scrap metal collected and shipped off site.
-  One 30 cubic yard box of hazardous debris collected and shipped off-site.
-  Four steel containers  (110 cubic yards) of solid waste/empty containers collected and shipped off-site.

Planned Removal Actions
-  Complete sample and analyze contents of all containers at the site, including drums, vats, tanks, piping, etc., to identify hazardous substances.
-  Consolidate and package all hazardous substances and contaminants for proper transportation and disposal.
-  Dismantle and decontaminate equipment containing hazardous substances as necessary. Uncontaminated ferrous materials will be recycled.
-  Evaluated effectiveness of epoxy seal on outside wall and reapply as necessary.

Next Steps
-  Complete initial risk assessment and study final response alternatives.
-  Continue work to keep down dust during operations.
-  Continue staging of containers to facilitate hazardous substance identification.
-  Continue work to identify and categorize hazardous substances for the purpose of consolidation, packaging, transport, and disposal.
- Collect and recycle non-hazardous ferrous material for recycling. Money generated will be used to help pay for the cleanup.
-  Conduct air monitoring to ensure safety of on-site workers and surrounding residents during daily operations.

Key Issues
Site is closely surrounded by residents and businesses. Close coordinated is needed with local authorities and community to ensure success with the removal action. Safety for onsite personnel and surrounding residents is number one priority.

Hexavelant chromium and chromic acids in solids and liquids are the main contaminant of concern.

Disposition Of Wastes
Waste Stream: RQ, Waste Cyanides, Inorganic, Solid, n.o.s. (Sodium Cyanide), 6.1,UN1588, PGII, (F008)
Quantity: Two Drums
Manifest #: 001344657 FLE
Disposal Facility: Envirite of IL. Harvey IL.

Waste Stream	Quantity	Manifest #	Disposal Facility
Class A non-hazardous waste Empty containers	20 cubic yards	006038438JJK	Countryside Landfill Grayslake, IL
Class A non-hazardous waste Empty containers	30 cubic yards	006038462JJK	Countryside Landfill Grayslake, IL
Class A non-hazardous waste Empty containers	30 cubic yards	006038461JJK	Countryside Landfill Grayslake, IL
Class A non-hazardous waste Empty containers	30 Cubic yards	006038460JJK	Countryside Landfill Grayslake, IL
RQ, Hazardous Waste Solid n.o.s. (Chromium). 9, NA3077, D007	30 cubic yards	002500713FLE	Envirite of Illinois Harvey, IL