2.1.1  Narrative

On July 21, 2011, U.S. EPA approved an action memorandum for a time-critical removal at the Site.

U.S. EPA OSC Simon, WESTON START and the ERRS contractor mobilized to the Site on July 27, 2011 to conduct disposal activities.

U.S. EPA OSC Simon, WESTON START and the ERRS contractor mobilized to the Site on August 23, 2011 to clean out the building and decontamination the concrete floor.

2.1.2 Response Actions to Date

August 23, 2011

U.S. EPA, START and ERRS mobilized to the site.  Work began by un-securing the entryways in order to regain access to the buildings.  Afterwards approximately 50 abandoned tires that remained on site were collected by the Marion County Health Department.

Two 30-yd³ rolloff boxes were delivered to the site.  ERRS began cleaning out the nonhazardous debris from the facility.  The nonhazardous debris was placed into the 30-yd³ rolloff boxes.  U.S. EPA directed “Household Hazardous Waste (HHW)” materials located throughout the site to be gathered and placed in a central location.

WESTON START used an X-ray Fluorescence (XRF) instrument to check the total lead and total chromium concentrations on the facility floor.  The XRF screening results indicated that some areas on the floor contained high levels of lead as high as 4,368 ppm, and chromium as high as 45,800 ppm.  U.S. EPA made the decision that the floor should be sealed and the surficial heavy metal contamination be encapsulated to prevent future migration of the heavy metals.  The “hot spots” on the floor were a result of the former chrome plating operations at the site. 

By the end of the day, one 30-yd³ rolloff box was filled with nonhazardous debris and was shipped to Twin Bridges RDF, located in Danville, Indiana, for disposal.

August 24, 2011

Work continued with sweeping the floor debris (sand, oil dry, dust, and other material) that remained within the building.  The floor sweeping material was placed into two-55-gallon drums for future off-site disposal.  ERRS completed cleaning out the facility and filled a second 30-yd³ rolloff box with nonhazardous debris.

ERRS began power-washing facility concrete flooring and containerizing the decontamination water. 

U.S. EPA and START inspected the basement located in the Main Garage and observed a boiler with suspect asbestos-containing material (ACM) on the boiler wrapping.  A sample was collected and submitted to a local laboratory for PLM analysis.  Results confirmed that the boiler wrap was positive for ACM. 

U.S. EPA and START also observed liquid, sludge and solids in the basement.  START collected a sample of the water and sludge that was present.  The two samples were submitted to a local laboratory to determine if asbestos fibers were present.

The current owner of the property arrived on site with potential buyers and conducted a site walkthrough with U.S. EPA and START.

ERRS pumped out the water in the basement and cleaned out the sludge and solids on the floor.  The water, solids and sludge were containerized into 9 drums.

ERRS delivered the following HHW to the Marion County’s Tox-Drop facility.  HHW consisted of the following:

• Three 1-gallon of Antifreeze
• Gallon latex paint
• 32 oz. brake fluid
• 14 oz. propane tank
• 32 oz. de-icing fluid
• Four 32 oz. cans of tire Fix-A-Flat
• 32oz. WD-40
• Two 12 oz. bottles of power steering fluid
• Five gallon bucket of gear oil
• Five gallon bucket of primer seal
• 32 oz. can of tire cleaner
• Six fire extinguishers
• Two 14 oz. cans of insecticide
• Three computer screens
• Five florescent bulbs
• Five gallons of used motor oil
• Five gallons of latex paint
• 5 gallons of joint compound
• Five gallons of vinyl composition tile adhesive
• Four oz. purple primer and PVC Cement
• 30 gallon propane cylinder

August 25, 2011

ERRS continued to power-wash the floors and adding Simple Green^®, a biodegradable water based surface washing agent, to free the floor of oil residue.

August 26, 2011

U.S. EPA received laboratory results confirming that there were not asbestos fibers in the water or the sludge that was located in the basement.

ERRS hired Star Environmental and completed removing the asbestos located on the boiler in the basement.

A total of 2 drums of used PPE and 2 drums of chromium-contaminated floor sweepings were transported for off-site disposal to PSC, Detroit, MI.

One 30-yd³ rolloff box containing nonhazardous debris was shipped for off-site disposal to Twin Bridges RDF, Danville, Indiana.

August 30 and 31, 2011

U.S. EPA, START and ERRS remobilized back to the site.  ERRS applied two coats of an epoxy sealant (V-Seal Industra-Coat #3707) to the facility floor to seal and encapsulate the heavy metal contamination on the surface of the concrete floor.  Additionally, the walls in the west back portion of the basement were screened by Weston START using an XRF and were found to contain elevated levels of lead and chromium.  The areas were marked and ERRS applied epoxy sealant to the walls.

September 1, 2011

At 0830 hours, ERRS completed boarding up the facility building for security.

At 1000 hours, 3 drums of chromium-contaminated water, 3 drums of chromium-contaminated sludge, 3 drums of chromium-contaminated solids and 2 drums of PPE were shipped to PSC, Detroit, MI for off-site disposal.

Weston START re-screened concrete floor areas utilizing the XRF to determine if the epoxy sealer effectively sealed in the surficial chromium contamination.  In the area where U.S. EPA observed total chromium concentrations as high as 45,800 ppm, an XRF reading showed a reduction to 200 ppm.  U.S. EPA determined that the sealer effectively encapsulated the surficial heavy metal contamination on the concrete flooring.

At 1200 hours, U.S. EPA conducted a final site walkthrough with the current site owner.  U.S. EPA explained that all nonhazardous and hazardous materials were removed from the site, the HHW materials were removed, the ACM in the basement had been removed and that the floor had been sealed with an epoxy sealer.