U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Metropolitan Metals Finishing Site - Removal Polrep

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region I
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Subject:
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POLREP #3
Continuation of Action
Metropolitan Metals Finishing Site
014L
Hamden, CT
Latitude: 41.3357326 Longitude: -72.9344964
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To:
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From:
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Michael Barry, OSC
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Date:
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3/26/2010
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Reporting Period:
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2/27/2010 to 3/26/2010
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1. Introduction
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1.1 Background
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Site Number: |
014L |
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Contract Number: |
EP-W-08-061 |
D.O. Number: |
0016 |
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Action Memo Date: |
1/20/2010 |
Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
Response Lead: |
EPA |
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Incident Category: |
Removal Action |
NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
2/10/2010 |
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Start Date: |
2/10/2010 |
Demob Date: |
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Completion Date: |
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CERCLIS ID: |
CTD001183052 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
2/10/2010 |
FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Time Critical Removal Action.
1.1.2 Site Description
The Site is an abandoned, privately operated metal finishing business that went out of business in 1996, and has been abandoned since. The building has deteriorated in the intervening years; there is a hole in the roof which has allowed the basement to be filled with precipitation. Evidence of use as living quarters by local indigents was observed despite repeated efforts by local authorities to secure it by boarding up windows, installing locks, and adding police patrols. Residual plating shop contaminants and sludge in vats, tanks, and throughout the building present a hazard to the indigent residents.
The building is a one-story structure of approximately 18,000 square feet with a 1000 square foot basement on approximately 0.5 acres. In addition to metal plating process residues, It contains general debris, solid waste, and biological waste composed of food scraps and human waste from indigents’ use of the facility as living quarters. The basement is flooded with about six feet of water, obstructing assessment of hazardous materials that may be in it.
1.1.2.1 Location
The Site is located in a mixed residential and commercial area adjacent to residential properties and a new greenway/recreational path on a former rail right-of-way. The address is 400 Goodrich St, Hamden, CT 06517 or 75 Daisy St, New Haven, CT 06511; the geographic position is 41 20.08’ N, 072 56.04’ W.
1.1.2.2 Description of Threat
Residual metal plating chemicals, sludge and residues present a contact hazard to local indigents using the Site as living quarters. Concentrations of metal contaminants on Site are above the CTDEP direct contact criteria for residential and commercial exposure scenarios. Due to the use of the site building, residential exposure scenario is appropriate. Mercury and PCB containing switches and fixtures are throughout the site building. Due to their degraded condition release of their contents to the building and environment is likely; thus exposing the building squatter residents and community.
The Site building has become a haven for local indigents' use as a living quarters and drug usage despite repeated attempts to secure it by town authorities. The activities result in a threat to public health and sanitation directly to those engaging in these activities and to the neighborhood and community as a whole. Indigents' attempts to heat and cook with fires and heaters and the large amount of solid debris and waste on site pose a threat of fire which could mobilize the contaminants on site and release them to the environment.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
The Site contains approximately 85 metal plating vats with residual contaminants, several tanks, process piping, and fixtures containing hazardous contaminants that are in poor condition. Not including the basement, which couldn’t be inventoried; the following additional hazardous wastes and materials were identified; PCB and mercury containing light fixtures and switches and biological waste.
A total of 44 solid samples were collected inside the building from metal plating vats, tanks, the floor, walls and other components. The samples were analyzed for Resource Conservation and Recovery Act (RCRA) 8 metals, poly chlorinated biphenyls (PCB’s), asbestos, hexavalent chromium, cyanide and Toxicity Characteristic Leaching Procedure (TCLP) metals analysis. The contaminants present a risk to indigent and homeless resident trespassers because they exceed CTDEP Residential and/or Commercial/Industrial Standards; analytical results for the highest result are shown below. CTDEP Residential Remediation Standard Regulation (RSR) and CTDEP Commercial/Industrial Direct Exposure Criteria (DEC) are provided for comparison:
Contaminant
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Result, parts per million (ppm)
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CTDEP RSR, Residential,
ppm
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CTDEP DEC, Commercial/Industrial, ppm
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Antimony
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170
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27
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8200
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Cadmium
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660
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34
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1000
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Chromium (Total)
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12,000
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3900
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51,000
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Copper
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180,000
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2500
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76,000
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Lead
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980
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500
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1000
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Nickel
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540,000
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1400
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7500
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Zinc
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190,000
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20,000
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610,000
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Cyanide
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40,000
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1400
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41,000
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
Personnel conducted a site walk with 2 EPA OSC and the ERRS RM on 2/4/2010 to verify site conditions and then commenced lining up resources. On 2/10/2010 2 EPA OSC, 4 ERRS and 1 START personnel mobilized to the site and commenced set-up operations; clean up operations started on 2/11/2010 and continue.
2.1.2 Response Actions to Date
2/04/2010 - 2/26/2010 - See POLREPS 1 and 2.
2/27/2010 - 3/26/2010
-Approximately 95,000 gallons of basement water and 1500 gallons of vat water was thawed and sampled. Meeting CTDEP discharge requirements, it was pumped to the sanitary sewer.
-All approximate 85 vats on the main floor have been decontaminated and cut up for recyling disposal; seven 20 cuyd containers have been filled and shipped to date.
-Non-hazardous and hazardous debris/waste seperation is complete on approximately 75% of the site, seven 30 cuyd containers of non-hazardous debris have been filled and six shipped off site to date.
-Six drums of potentially hazardous vat scrapings/floor sweepings & decontamination debris have been collected to date. Though these contain heavy metals per prior sampling, the sample for disposal passed Toxicity Characteristic Leaching Procedure (TCLP) testing for disposal.
-Miscellanious small container hazardous materials have been collected and Requests For Quotes for disposal have been sent to vendors.
-The heater has been demobilized, no longer needed due to warmer temperatures and basement and vat water has been thawed and pumped out.
-Plasma torch cutter mobilized on site 3/8/2010 to speed and optimize vat cutting operations; cutting 4-6 vats per day when operating all day. Vat cutting operations with the plasma torch completed today.
-Emergency patched/plugged water inflow pathways to the basement, will monitor performance during upcoming rain.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The PRP's estate has been identified and provided access consent.
2.1.4 Progress Metrics. Amounts below are approximate, preliminary figures as of POLREP date:
Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
Non-Haz, 30 cuyd containers; 7 filled to date |
Solid |
62,000 Lbs. shipped to date |
N/A |
None |
Pine Ave Landfill
Niagra Falls, NY |
Scrap Metal, 20 cuyd containers; 7 filled to date |
Solid |
33,040 Lbs. shipped to date |
N/A |
None |
Sims Metal Management, North Haven, CT |
Basement and Vat Water |
Liquid |
95,000 + 1500 Gallons to date |
N/A |
None |
Sanitary Sewer, Greater New Haven Water Pollution Control Authority |
Vat Scrapings/Floor Sweepings, Drums |
Solid |
6-drums filled to date |
TBD |
TBD |
TBD |
Universal Waste; PCB Ballast, Mercury Lamps, Misc Wastes
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Solid |
TBD |
TBD |
TBD |
TBD |
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2.2 Planning Section
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2.2.1 Anticipated Activities
2.2.1.1 Planned Response Activities
Remove hazardous material debris and other superficial contamination from building.
Remove visible chemical residues present on vats and other process equipment and remove all vats and tanks.
Thaw, pump out and remove potentially comtaminated liquids.
Segregate and remove, recycle or stage solid waste obstructions, debris, scrap and tumbler components.
Perform air monitoring to ensure worker and public safety.
Continue to coordinate with cooperating agencies and provide updates on project progress.
2.2.1.2 Next Steps
-Obtain electric line power then demobilize 120kw generator.
-Continue segregating and removing hazardous & non-hazardous wastes in remaining areas including; basement, tool room, tumble room.
-Finalize T&D needs.
-Continue monitoring site for safety hazards.
-Continue cutting remaining vats and other metal items on the main floor as space permits in the metal roll-on/roll-off.
-Cut poly vats in the basement for disposal.
-Dry decontaminate site floor, walls and equipment that will remain on site.
Plug rainwater infiltration pathways through the floor drain system into the basement with a more robust temporary repair. Pump basement as necessary to the sanitary sewer via the basement connection.
2.2.2 Issues
Large amount of interferring solid waste and debris.
Line electric power.
Rainwater infiltration into the basement via floor drain system.
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2.3 Logistics Section
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No Issues
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer The site contains many physical hazards including slips, trips and falls (SLT). The SLT hazards are also present outside of the building due to recent winter weather. These hazards are being mitigated with engineering controls, including clearing of walkways & work areas of equipment & debris and marking, idenitifying or barricading other obstructions. Cold stress is also a potential hazard. Monitoring will be conducted for cold stress and proper work/rest schedules will be maintained. In addition, site security is being addressed by controlling unauthorized access to the site and work zones using fencing, caution tape and overnight site security. Interior and exterior air monitoring is being performed during site activities.
HASP amendment #1 was issued on 3/5/2010 to address plasma torch cutting operations. On 3/24/2010 full face shield APRs were specified for cutting operations with the Sawzall power saw.
2.6 Liaison Officer Liaison with the Hamden Director of Economic and Community Development Director, CTDEP and CTDPH has been undertaken and is ongoing.
Two CTDEP representatives toured the site on 3/10/2010.
Four Hamden Board of Economic and Community Development members, including the director toured the site on 3/19/2010.
2.7 Information Officer 2.7.1 Public Information Officer
A reporter and photographer from the New Haven Register newspaper accompanied the Hamden Economic and Community Development Board tour on 3/19/2010. .
2.7.2 Community Involvement Coordinator
Outreach was performed with three residents immediately abutting the site.
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3. Participating Entities
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3.1 Unified Command Unified command isn't being used for this site, but there is a high degree of liaison with cooperating agencies.
3.2 Cooperating Agencies CTDEP
CTDPH
Hamden City Economic and Community Development Department
Quinnipiack Valley Health District
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4. Personnel On Site
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EPA OSC - 1 (per coverage schedule)
START - 1
ERRS, ER, LLC - 3
ERRS, Moran, LLC (Team sub) - 3
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5. Definition of Terms
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N/A
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6. Additional sources of information
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6.1 Internet location of additional information/report Public Administrative Record Repositories are located at the New Haven Public Library (133 Elm St, New Haven, CT, 06510) and the Miller Memorial Library (2901 Dixwell Ave., Hamden, CT 06518).
The website for additional information is: http://www.epaosc.org/MetMetalsHamdenCT
6.2 Reporting Schedule N/A
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7. Situational Reference Materials
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N/A
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