U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Rochester Silver Works LLC - Removal Polrep
Initial and Final Removal Polrep

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region II
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Subject:
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POLREP #1
Initial and Final POLREP
Rochester Silver Works LLC
A299
Rochester, NY
Latitude: 43.2023211 Longitude: -77.6444635
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To:
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Judith Enck, US EPA, Region II
Lisa Plevin, US EPA, Region II
Joe Rotola, USEPA Region 02
Eric Mosher, USEPA , Region 2, ERRD-RPB
George Zachos, USEPA Region 2 ERRD
Mary Mears, USEPA, Region 2, PAD
Mark Pane, USEPA, Region 02, ERRD-RAB
Gregory Deangelis, RPB
Beckett Grealish, ERRD-RAB
Tim Grier, USEPA Headquarters 5202G
Region 02 RRC, R2 RRC
Dennis Farrar, NYSDEC
Bob Marino, NYSDEC
Pradeep Jangbari, NY State Dept of Env. Con.
Ralph Holmes, Rochester Silver Works LLC
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From:
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Gregory DeAngelis, OSC
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Date:
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1/17/2012
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Reporting Period:
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12/29/2011 - 1/17/2012
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1. Introduction
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1.1 Background
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Site Number: |
A299 |
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Contract Number: |
None |
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D.O. Number: |
None |
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Action Memo Date: |
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Response Authority: |
CERCLA |
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Response Type: |
PRP Oversight |
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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: |
12/29/2011 |
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Start Date: |
12/29/2011 |
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Demob Date: |
1/17/2012 |
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Completion Date: |
1/17/2012 |
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CERCLIS ID: |
NYR000184986 |
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RCRIS ID: |
NYR000184986 |
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ERNS No.: |
999197 |
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State Notification: |
NYSDEC 12/29/2011 |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Active Production Facility
1.1.2 Site Description
The Rochester Silver Works refines silver, manufacturies silver nitrate and recycles photographic film base material. The facility consists of 4 main buildings on 9.98 acres and employs 55 personnel. The facility at Building 156 separates and recovers metals (sliver, cadmium, nickel, and lead) contained in ash hoppers from Building 101 Smelter Baghouse. Two hoppers of ash are added with Kodak Paper (KP) Water to Tank-1 and transferred to Tank-2. The process is repeated a second time and Tank-1 is rinsed with more KP Water to Tank-2. Additional water is added to Tank-2 and the mixture of ash hoppers and water is ready for treatment. The treatment takes place in Tank-2 where additional KP Water and Nitric Acid is added which results in a insoluble silver halide phase which is directed to Building 110 for silver recovery; and, an acidic aqueous phase that receives further treatment in Building 156 prior to external metals recovery.
1.1.2.1 Location
The incident occurred at Building 156681 West Ridge Road, Rochester, NY 14652. The building is owned by the Rochester Silver Works LLC. This is located within the Eastman Business Park.
1.1.2.2 Description of Threat
On December 29, 2012 at 0830 it was discovered that approximately 1700 gallons of 40% nitric acid spilled within Building 156; of which approximately 233 gallons leaked out of an overhead doorway onto soil adjacent to the building.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
On 12/29/2011, in response to the spill at Building 156, a preliminary investigation by the Rochester Silver Works suggested the liquid to be nitric acid. Examinations of the level loss of the nitric acid bulk storage tank found 1,718 gallons was used. Calculations based on recovered/collected liquids that drained into the floor tank identified 233 gallons of nitric acid escaped the building onto adjacent soils. Further investigation and calculations determined that due to the dilution in the process the nitric acid (raw from the tank farm) starts out as 60% nitric acid was diluted to approximately 40% nitric acid in the spill. On 1/9/2012, OSC DeAngelis reviewed the response actions and cleanup activities that were taken by Rochester Silver Works and was satisfied with the actions taken.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
See attached (Release Follow-up Reporting Form) for the Root Cause Analysis of the Spill.
2.1.2 Response Actions to Date
12/29/2011 A call was made to the Eastman Business Park 911 system and both the Rochester and Kodak Fire Departments responded to the scene. At 0900, approximately .5 hour after the discovery of the spill, the Rochester Fire Department Hazardous Response team entered Building 156 to determine that the discharge and ended and the remaining material was contained. A member of the Kodak Fire Department entered the building to activate the exhaust fan and place a hose into the floor tank to pump the nitric acid to temporary storage containers. Richmond Silver Works personnel pumped the acid from the floor and floor tank, followed by a water wash of the inside of the building (with rinse waters being transferred to the water treatment system. The soil around the spill area was excavated and placed into lined temporary containers. Soil samples were collected for disposal purposes (see attached Soil Analysis Reports) and sent to an external laboratory for both metals characterization and pH.
12/29/2011 OSC Gallo contacted NYSDEC Region 8 to obtain information regarding the spill.
1/9/2012 On 1/9/2012, OSC DeAngelis responded to Rochester to tour the facility and meet with Mr. Ralph M. Holmes Jr., Rochester Silver Works VP, Gary Winburn and Jay Hull both with Rochester Silver Works, and Mr. Pradeep K. Jangbari, P.E. of the NYSDEC. The Building 156 spill root cause analysis was discussed. OSC DeAngelis inspected the spill site and observed the staged soils awaiting disposal. At the time of the visit, the facility was awaiting the pH analysis of the soil to determine whether it would be disposed of as hazardous or non-hazardous waste.
1/17/2012 The soils were sent off site for disposal (See attached Non-Haz Manifests). EPA concluded the release at this facility had been addressed satisfactorily. No further action is necessary and the completion date for this action is January 17, 2012, the day the contaminated soil was shipped off site for disposal.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Rochester Silver Works LLC is the PRP. No enforcement actions were taken. The clean up was undertaken by the PRPs without an order and was completed on January 17, 2012.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
| UN3234 |
Soils |
8.61 Tons |
110 12 2012 -1 |
Model City Landfill (non haz) |
1-17-2011 |
| UN3234 |
Soils |
7.71 Tons |
110 12 2012-2 |
Model City Landfill (non haz) |
1-17-2011 |
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2.2 Planning Section
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2.2.1 Anticipated Activities
None
2.2.1.1 Planned Response Activities
No further response activities are anticipated.
2.2.1.2 Next Steps
None, as this completes the removal action
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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Budgeted |
Total To Date |
Remaining |
% Remaining |
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Extramural Costs
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Intramural Costs
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| USEPA - Direct |
$2,900.00 |
$0.00 |
$2,900.00 |
100.00% |
| USEPA - InDirect |
$1,100.00 |
$0.00 |
$1,100.00 |
100.00% |
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| Total Site Costs |
$4,000.00 |
$0.00 |
$4,000.00 |
100.00% |
* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.
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2.5 Other Command Staff
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No information available at this time.
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3. Participating Entities
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3.1 Cooperating Agencies
US EPA Region II
NYS DEC, Region 8
Rochester Silver Works LLC
Kodak Fire Department
Rochester Fire Department
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4. Personnel On Site
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December 29, 2011:
Rochester Silver Works LLC Personnel: approx. 10
Kodak Fire Department: 4
Rochester Fire Department: approx. 30
NYS DEC: 1
January 9, 2012:
Rochester Silver Works LLC Personnel: 3
NYS Dec: 1
US EPA: 1
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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
Release Follow-up Reporting Form: http://www.epaosc.org/sites/7543/files/Final%20Building%20156%20Release%20Report.pdf
Soil Analysis (Metals): http://www.epaosc.org/sites/7543/files/Soil%20Analysis.pdf
Soil Analysis (pH): http://www.epaosc.org/sites/7543/files/Soil%20pH%20Analysis%2001.pdf
Non-Haz Manifests: http://www.epaosc.org/sites/7543/files/B156%20Soil%20Non%20Haz%20Manifests.pdf
Site Map: http://www.epaosc.org/sites/7543/files/EBP-W%20Ground%20Lease%20Parcel%20092711.pdf
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7. Situational Reference Materials
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No information available at this time.
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POLREP #1 Last Updated 1/24/2012
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