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Metropolitan Metals Finishing Site

All POL/SITREP's for this site Metropolitan Metals Finishing Site
Hamden, CT - EPA Region I
POLREP #4
Continuation of Action, Demobilization
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Metropolitan Metals Finishing Site - Removal Polrep
Final Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region I

Subject: POLREP #4
Continuation of Action, Demobilization
Metropolitan Metals Finishing Site
014L
Hamden, CT
Latitude: 41.3357326 Longitude: -72.9344964


To:
From: Michael Barry, OSC
Date: 4/16/2010
Reporting Period: 3/27/2010 - 4/16/2010

1. Introduction
  1.1 Background
   
Site Number: 014L    Contract Number: EP-W-08-061
D.O. Number: 0016    Action Memo Date: 1/20/2010
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 2/10/2010    Start Date: 2/10/2010
Demob Date: 4/16/2010    Completion Date:  
CERCLIS ID: CTD001183052    RCRIS ID:
ERNS No.:    State Notification: 2/10/2010
FPN#:    Reimbursable Account #:

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

Result, parts per million (ppm)

CTDEP RSR, Residential,
ppm

CTDEP DEC, Commercial/Industrial, ppm

Antimony

170

27

8200

Cadmium

660

34

1000

Chromium (Total)

12,000

3900

51,000

Copper

180,000

2500

76,000

Lead

980

500

1000

Nickel

540,000

1400

7500

Zinc

190,000

20,000

610,000

Cyanide

40,000

1400

41,000

 

 

 



2. Current Activities
  2.1 Operations Section
    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 the site was demobilized on 4/16/2010.

2.1.2 Response Actions to Date

2/04/2010 - 3/26/2010 - See POLREPS 1, 2 and 3.

3/27/2010 - 4/16/2010

-All approximate 85 vats on the main floor have been decontaminated and cut up for scrap metal recyling disposal. Other metal components of opportunity have been decontaminated and cut/deconstructed for volume minimization. A total of nine 20-cuyd containers were filled and shipped. 
-Non-hazardous and hazardous debris/waste seperation is complete in the basement and main floor. A total of nine 30 cuyd containers of non-hazardous debris were filled and shipped.
-Eight drums of potentially hazardous vat scrapings/floor sweepings & decontamination debris were collected and shipped off site on 4/9/2010. 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 were collected and disposed of. 
-One drum of PCB-containing light ballasts were collected and shipped off-site on 4/9/2010.
-One pail of mercury containing items was collected and shipped off-site on 4/9/2010.
-One drum of non-PCB-containing light ballasts were collected and shipped off-site on 4/9/2010.
-One drum of high intensity discharge lamps was collected and shipped off-site on 4/9/2010.
-Eight boxes of 8' fluorescent light tubes were collected and shipped off-site on 4/9/2010. 
-Plasma torch cutter was demobilized on 3/29/2010.
-Floor drain waterflow pathways to the basement were plugged.
-Two poly vats in the basement were cut up and removed. Metal vats in the basement were holed to their bottoms so that rainwater will not collect in them.  
-The 120 kw generator, forklift, porta-johns and other misc supplies and equipment were demobilized on 4/14/2010. The office trailer was demobilized on 4/16/2010. 

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; 9 total  Solid  100,000 Lbs. (estimate)   N/A   None Pine Ave Landfill
Niagra Falls, NY 
Scrap Metal, 20 cuyd containers; 9 total  Solid  67,000 Lbs. (estimate)   N/A  None Sims Metal Management, North Haven, CT
Basement and Vat Water Liquid        100,000 + 2000 Gallons N/A None Sanitary Sewer, Greater New Haven Water Pollution Control Authority
Vat Scrapings/Floor Sweepings,  8 Drums    Solid 2400 Lbs. (estimate)      006756710 JJK     None Vexor Technology, Inc., Medina, OH 44256
 Universal Waste; PCB Ballast, Mercury Lamps, HID Lamps, Misc Wastes; 3 Drums, 1 Pail, 8 Boxes Solid  2905 Lbs. (estimate) 006756711 JJK, none  None Complete Recycling Solutions, Fall River, MA 02720


  2.2 Planning Section
    2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities

On-site actions are complete.

2.2.1.2 Next Steps

-Receive last weight slips and manifest copies.
-Tally final costs.
-Draft Removal Action Completion Report and forward copies to partnering state and local agencies.

2.2.2 Issues

-Line electric power was never obtained in a timely manner, used a 120 kw generator the whole time.


  2.3 Logistics Section
    No Issues


  2.4 Finance Section
    No information available at this time.

  2.5 Other Command Staff
    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.

Four CTDEP Brownfields Program personnel toured the site on 4/7/2010.

A variety of CTDEP, Hamden Community and Economic Board (HCED) members and follow-on Brownfields Program Project personnel toured the site on 4/9/2010. 

HCED Board members and potential future purchasers for the Brownfields Program Project toured the site on 4/12/2010.



2.7 Information Officer
2.7.1 Public Information Officer
An article about the site from the tour on 3/19/2010, and follow-on questions with EPA PIO and OSC support was in the New Haven Register on Sunday, 4/4/2010. 

2.7.2 Community Involvement Coordinator
Outreach has continually been performed with three residents immediately abutting the site.

3. Participating Entities
  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


4. Personnel On Site
  EPA OSC - 1 (per coverage schedule)
START - 1
ERRS, ER, LLC - 3
ERRS, Moran, LLC (Team sub) - 3


5. Definition of Terms
  N/A

6. Additional sources of information
  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

7. Situational Reference Materials
  N/A


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