Pollution Report Profile - EPA OSC Response

Economy Plating Inc. (Chicago)
Chicago, IL - EPA Region V
POLREP #5 - Cleanup Continues

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On-Scene Coordinator - Ramon Mendoza, On-Scene Coordinator	10/23/2009
Time-Critical - Removal Action	Pollution Report (POLREP) #5
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 10/3 to 10/22/2009:
- 2464 pounds of scrap lead recovered (vat liners), decontaminated, and recycled.
-  95 drums of hazardous waste were packed, staged and shipped offsite this period.The drums contained chromic acid solution, chromic acid solid flakes, Waste codes include D007, D010,D008, D004, D002, D006.
-  Cleanup in the roof area completed. Contaminated air pollution control units and gravel/soil removed.
-  Cleanup in the areas of the old plating shop, basement, and second floor is 95% complete, all drums and contaminated soil/sudge removed.
-  Cleanup in the main vat area initiated and ongoing.  Work involves removal and cleaning of metal vats, and removal of debris and sludge in the pits.
-  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.  The seal is indicating visible signs of failure.
-  Miscellaneous containers of acid, caustic, and other hazardous materials have been staged for hazard categorization, packing, and disposal. Volume is estimated to be 12 drums.
-  EPA management conducted a site visit/audit on 10/16/2009.  All comments were addressed and implemented.
-  Samples were taken from the outside walls averaged 1,067.5 ppm of hex chromium.  Soils from the parking area contain 422 ppm hex chromium. A phase I risk assessment was completed and exposure to the hex chromium from these two sources combined equates to a Hazard Index of 1.1 for children and 2.8x10-1 for adults. Exposure to these sources also equates to a total lifetime cancer risk of 5.7x10-4. US EPA recommends that Hazard Index values do not exceed 1 from exposure to contaminated sites and lifetime cancer not to exceed 1x10-4.  Even with the removal of all hazardous substances and materials inside the building, the building itself still presents a health threat to the surrounding community due to long term exposure.

Planned Removal Actions
-  Continue evaluation of effectiveness of epoxy seal on outside walls and reapply as necessary.
-  Complete removal of all hazardous substances/materials not attached or part of the building structure to the extent practical.
-  Determine feasibility of building demolition as a response action. Response action with demolition will include, partial removal of contaminated foundation and soil, fencing, vegetated soil cover and institutional controls.

Next Steps
-  Complete hazcat categorization, consolidation, packing, and disposal of remaining miscellaneous  hazardous materials staged.
-  Complete removal of vats/piping and contaminated sludge, solids, and liquids from the main vat pit area.
-  Continue housekeeping work to keep down dust during operations.
-  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.
-  Contact owners of building to get permission to demolish the building unconditionally.
-  Contact City and other entities to determine and meet demolition requirements.
-  Plan for next public meeting by mid November.

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.

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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
Chromic acid solution, D002,D004, D006, D007, D008, D010	21 Drums	002500727FLE	Envirite of Illinois Harvey, IL
Chromium Waste Solids, D007	3 Drums	002500727FLE	Envirite of Illinois Harvey, IL
Chromic acid Solution,D002, D004, D006, D007, D008, D010	18 Drums	002500728FLE	Envirite of Illinois Harvey, IL
Chromium Waste Solids, D007	12 Drums	002500728FLE	Envirite of Illinois Harvey, IL
Chromic acid Solution,D002, D004, D006, D007, D008, D010	27 Drums	002500729FLE	Envirite of Illinois Harvey, IL
Chromium Waste Solids, D007	14	002500729FLE	Envirite of Illinois Harvey, IL