U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Custom Chrome Plating Site - Removal Polrep
Final Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
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Subject:
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POLREP #2
POLREP #2 - FINAL
Custom Chrome Plating Site
B5VU
Dayton, OH
Latitude: 39.7837180 Longitude: -84.1856619
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To:
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From:
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Steven Renninger, On-Scene Coordinator
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Date:
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6/29/2010
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Reporting Period:
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May 7 through June 29, 2010
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1. Introduction
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1.1 Background
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Site Number: |
B5VU |
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Contract Number: |
EP-S5-08-02 |
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D.O. Number: |
0050 |
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Action Memo Date: |
4/12/2010 |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
5/3/2010 |
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Start Date: |
5/3/2010 |
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Demob Date: |
6/29/2010 |
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Completion Date: |
6/29/2010 |
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CERCLIS ID: |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
Ohio EPA |
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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 Custom Chrome Plating (CCP) Site is located in a mixed commercial and light industrial area of Dayton, Ohio. The Site is located within 25 feet of another commercial business. The Site is bordered to the north by 836 Hall Avenue (a commercial business – Merrick Manufacturing); to the south by a vacant lot and a commercial business (McIntosh Safe Corporation); to the east by Interstate 75; and to the west by Hall Avenue. The Site contains a 5,373-square-foot building and a parking lot on 0.26 acre of land and is located approximately ½-mile east of the Great Miami River.
1.1.2.1 Location
The CCP Site is located at 828 Hall Avenue in Dayton, Montgomery County, Ohio. The geographical coordinates for the Site are 39° 47’ 0.2034” North latitude and 84° 11’ 9.06” West longitude.
1.1.2.2 Description of Threat
The CCP facility conducted chrome plating at the Site from 1985 until Fall 2009. The various on-site plating lines contain approximately 25 chrome plating vats and tanks. In addition to the plating lines, the Site contains approximately 100 55-gallon drums and other waste containers. The facility terminated operations at the Site on August 19, 2009.
On March 2, 2010, U.S. EPA obtained a signed access agreement from the former operator/owner of the CCP facility allowing U.S. EPA access to conduct sampling activities.
On March 4, 2010, Ohio EPA submitted a letter to U.S. EPA requesting assistance from the U.S. EPA Region V Superfund Division in conducting a potential time-critical removal action involving uncontrolled drums, vats and tanks containing chrome plating waste at the Site. Ohio EPA estimated that approximately 2,200 gallons of waste plating materials were present at the Site.
Ohio EPA also noted that the CCP facility was no longer in operation and that the City of Dayton turned off water and electrical services to the facility in 2009. The facility remains idle, and it is unclear if and when CCP will begin operations again. After CCP ceased operations in Fall 2009, hazardous wastes and other materials have accumulated at the facility. Ohio EPA stated that CCP is unclear about when it expects that all hazardous waste will be removed from the facility and properly disposed of at a permitted hazardous waste facility. To date, hazardous waste remains at the facility and the potential for a release to the environment and public health endangerment is possible.
On March 10, 2010, U.S. EPA conducted a site assessment at the CCP Site.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
On March 10, 2010, U.S. EPA conducted a site assessment at the CCP Site and observed approximately 25 chrome plating vats and tanks and 100 55-gallon drums and other waste containers within the facility. During the site assessment, U.S. EPA collected 9 liquid waste samples and 2 solid waste samples from drums, plating vats and containers. Analytical results indicated seven liquid waste samples having a pH value of less than 2.0 standard units and therefore meet the criterion for hazardous waste by virtue of corrosivity as defined in 40 CFR 261.22. Analytical results indicated that five investigative samples have TCLP chromium concentrations greater than 5.0 mg/L, with a maximum TCLP chromium concentration of 11,900 mg/L, and therefore meet the criterion for hazardous waste by virtue of toxicity as defined in 40 CFR 261.24. Analytical results indicated that two investigative liquid waste samples have flash points of less than 140 ºF and therefore meet the criterion for hazardous waste by virtue of the characteristic of ignitability as defined in 40 CFR 261.21.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
On April 12, 2010, the Action Memorandum was signed by the Director of the U.S. EPA Region V Superfund Division approving the removal action at the CCP Site.
On April 22, 2010, U.S. EPA obtained a signed access agreement from the former operator/owner of the CCP facility allowing U.S. EPA access to clean up the site.
On April 23, 2010, a delivery order was issued to the ERRS contractor (EQM) to conduct removal activities at the site.
On May 3, 2010, ERRS mobilized office trailers and set up the command post at the site.
On May 4, 2010, U.S. EPA met with the Dayton Fire Department (DFD) to discuss emergency contingency planning and emergency contact numbers. The information will be used to complete the Emergency Contingency Plan which, when finalized, can be found in the Documents section of this website.
On May 6, 2010 the Health & Safety Plan was approved by U.S. EPA, START and ERRS.
2.1.2 Response Actions to Date
On May 7, 2010, the Emergency Contingency Plan was finalized and sent to the DFD for distribution.
Week of May 10 through 14, 2010
ERRS personnel mobilized to the site on May 10, 2010 and signed the H&S Plan and set up the Contamination Reduction Zone (Decon area). HEPA fans were set up in the hot zone and water was misted onto work surfaces to minimize hexavalent chromium dust exposure. ERRS laborers began work in Level B personal protective equipment (PPE).
ERRS collected personal air samples from the three ERRS laborers and one perimeter air sample for the first three days of work. The air samples were analyzed for hexavalent chromium. Analytical data from the personal air sampling indicated that hexavalent chromium levels within the facility were less than the site action level (125 ug/m^3) in the H&S Plan, therefore, ERRS wrote an amendment to downgrade from Level B to Level C PPE with air purifying respirator.
ERRS began cleaning out the facility by placing non-hazardous debris (such as desks, chairs, and tables) in a rolloff box, hazardous debris (crushed empty drums, cut up vats, etc) into a rolloff box and non-hazardous metal into a scrap box.
ERRS completed sampling approximately 100 drums, vats and containers in Level B PPE. START completed hazard categorizing all samples and inputed the information into DrumTrak, version 2.0.0.
Week of May 17 through 21, 2010
ERRS personnel continued to clean out the facility by placing non-hazardous debris, hazardous debris and scrap metal into its appropriate rolloff boxes. ERRS continued to dismantle the plating process lines and cutting up empty plating vats and chromium-contaminated debris.
START conducted bench tests on the wastestreams developed from hazard categorization testing. Disposal samples for 1) the chromic acid liquid wastestream and 2) the floor sweepings wastestream were composited and submitted to a commercial laboratory for disposal analysis and future waste profiling.
ERRS began cutting up vats and removing contaminated ceiling tiles, ceiling tile metal brackets, ductwork and other chromium-contaminated plating items in the facility. The items were placed into the hazardous debris rolloff box.
On May 19, 2010, ERRS collected one personal air sample and one perimeter air sample for hexavalent chromium analysis to ensure action levels are not being exceeded. One rolloff box containing hazardous debris was shipped for off-site disposal to Environmental Quality (EQ), located in Belleville, Michigan.
Week of May 24 through 27, 2010
ERRS personnel continued to clean out the facility by placing non-hazardous debris, hazardous debris and scrap metal into its appropriate rolloff boxes. ERRS continued to dismantle the plating process lines and cutting up empty plating vats and chromium-contaminated debris.
On May 24, 2010, ERRS collected one personal air sample and one perimeter air sample for hexavalent chromium analysis to ensure action levels are not being exceeded.
On May 24 and 27, 2010, one rolloff box containing hazardous debris was shipped for off-site disposal to EQ, located in Belleville, Michigan.
Week of June 1 through 4, 2010
ERRS personnel continued to clean out the facility by placing non-hazardous debris, hazardous debris and scrap metal into its appropriate rolloff boxes. ERRS continued to dismantle the plating process lines and cutting up empty plating vats/drums and chromium-contaminated debris.
On June 1, 2010, approximately 2,900 gallons of chromic acid liquid was pumped into a tanker truck from on-site drums and plating vats and was transported for off-site disposal to Heritage Environmental Services, locoated in Indianapolis, Indiana.
On June 2 and 4, 2010, one rolloff box containing hazardous debris was shipped for off-site disposal to EQ, located in Belleville, Michigan.
On June 2, 2010, ERRS collected one personal air sample and one perimeter air sample for hexavalent chromium analysis to ensure action levels are not being exceeded.
Week of June 14 through 17, 2010
ERRS personnel continued to clean out the facility by placing non-hazardous debris, hazardous debris and scrap metal into its appropriate rolloff boxes. ERRS continued to dismantle the plating process lines and cutting up empty plating vats/drums and chromium-contaminated debris. ERRS mobilized a scissors-lift to access and remove contaminated piping and ductwork from the rafters of the facility.
On June 15 and 17, 2010, one rolloff box containing hazardous debris was shipped for off-site disposal to EQ, located in Belleville, Michigan.
On June 15, 2010, five drums containing hydrochloric acid were shipped for off-site disposal to Heritage Environmental Services, locoated in Indianapolis, Indiana.
On June 16, 2010, lab packing of flammable liquids, waste oils and compressed gas cylinders was conducted. All lab packs were shipped for off-site disposal to EQ Detroit, located in Detroit, Michigan.
Week of June 21 through 25, 2010
ERRS personnel continued to clean out the facility by placing non-hazardous debris, hazardous debris and scrap metal into its appropriate rolloff boxes. ERRS continued to dismantle the plating process lines and cutting up empty plating vats/drums and chromium-contaminated debris. ERRS utilized a scissors-lift to access and remove contaminated piping and ductwork from the rafters of the facility. ERRS power-washed the floor inside the building and pumped all floor decon water into a poly tank for disposal on Monday, June 28, 2010.
On June 24, 2010, two drums containing chromic acid were shipped for off-site disposal to Heritage Environmental Services, located in Indianapolis, Indiana.
On June 25, 2010, one rolloff box containing hazardous debris was shipped for off-site disposal to Environmental Quality (EQ), located in Belleville, Michigan.
On June 25, 2010, ERRS personnel completed cleaning out the facility.
Week of June 28 through July 1, 2010
On June 28, 2010, approximately 990 gallons of floor decon water (containing chromium and lead) was shipped for off-site disposal to Petro-Chem Processing Group.
On June 29, 2010, U.S. EPA conducted a final walkthrough of the facility with the the Ohio EPA to show that the time-critical removal action was completed.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
U.S. EPA has identified two PRPs, but they did not respond to General Notice Letters from US EPA.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| Hazardous Debris |
Solids |
8 rolloff boxes
(120 tons) |
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Environmental Quality
Belleville, MI |
| Nonhaz Debris |
Solids |
6 rolloff boxes
(90 tons) |
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Stony Hollow Landfill
Dayton, OH |
| Chromic Acid |
Liquid |
3,500 gallons |
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Heritage Environmental
Indianapolis, IN |
| Hydrochloric Acid |
Liquid |
5 drums |
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Heritage Environmental
Indianapolis, IN |
| Cylinders |
Gas |
10 each |
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AirGas
Dayton, OH |
| Lab Pack |
Liquids and Gas |
10 lab packs |
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EQ Detroit
Detroit, MI |
Decon Water
(Chromium & Lead) |
Liquid |
990 gallons |
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Petro-Chem Processing Group
Detroit, MI |
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2.2 Planning Section
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2.2.1 Anticipated Activities
Per the approved Action Memorandum, U.S. EPA completed the following activities:
1. Developed and implemented a site-specific Health and Safety Plan, including an Air Monitoring Plan, and a Site Emergency Contingency Plan;
2. Developed and implemented a Site Security Plan;
3. Inventoried and performed hazard characterization on all substances contained in containers, drums, vats, and tanks;
4. Consolidated and packaged all hazardous substances, pollutants and contaminants for transportation and off-site disposal;
5. Dismantled and decontaminated process equipment, tanks and building components associated with the plating area, as necessary;
6. Transported and disposed of all characterized or identified hazardous substances, pollutants, wastes, or contaminants to a RCRA/CERCLA-approved disposal facility in accordance with U.S. EPA’s Off-Site Rule (40 CFR § 300.440).
2.2.1.1 Planned Response Activities
See Section 2.2.1.2
2.2.1.2 Next Steps
None.
Time-critical removal action is completed.
2.2.2 Issues
None.
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2.3 Logistics Section
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No information available at this time.
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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
On May 5, 2010, the Site H&S Plan was finalized.
On May 10, 2010, all site personnel read and signed the approved H&S Plan.
On May 17, 2010, a H&S amendment was signed to downgrade from Level B PPE to Level C PPE.
Hexavalent Chromium analytical results from the personal air sampling conducted throughout the project showed that Level C PPE with APRs was the appropriate level of protection for the work activities stated in the H&S amendment.
2.6 Liaison Officer
2.7 Information Officer
2.7.1 Public Information Officer
2.7.2 Community Involvement Coordinator
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3. Participating Entities
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3.1 Unified Command
3.2 Cooperating Agencies
Ohio EPA DERR
Dayton Fire Department
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4. Personnel On Site
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1 EPA OSC
6 ERRS (EQM and Inland Waters of Ohio)
1 START (WESTON Solutions)
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5. Definition of Terms
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No information available at this time.
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6. Additional sources of information
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6.1 Internet location of additional information/report
For additional information, please refer to the "Documents" Section of the project website http.//www.epaosc.org/.
6.2 Reporting Schedule
This is the FINAL POLREP. No additional reports will be posted on this website.
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7. Situational Reference Materials
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No information available at this time.
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