Time-Critical Removal Action:  Manufacturing/Processing/Maintenance – Electroplating, Metal Finishing

See Initial Polrep.

1.1.2.1 Location

The Baycote Metal Finishing Site is located at 1302 Industrial Drive in Mishawaka, St. Joseph County, Indiana 46544.  The geographical coordinates for the Site are 41°39’0.03” North latitude and 86°09’57.11” West longitude.  The Site is bordered by industrial properties to the north, east, and south and Industrial Drive and industrial properties to the west.  Residential properties are located approximately 700 feet to the west.  Seven churches and two schools are located within 1 mile of the Site. The St. Joseph River, a major surface water body that terminates in Lake Michigan, is located 0.85 mile northwest of the Site. 

1.1.2.2 Description of Threat

See Initial Polrep.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results  
See Initial Polrep.

In a letter dated November 11, 2011, the St. Joseph County Health Department (SJCHD) requested assistance from the U.S. EPA to secure hazardous wastes left on-site.  SJCHD was concerned that the Site posed a significant threat to the health and safety of companies within the industrial park as well as the residential area located less than a 1,000 feet from the facility.  On February 23, 2012, the Director of U.S. EPA's Superfund Division approved an Action Memorandum for a time-critical removal action at the Baycote Metal Finishing Site.

On April 6, 2012, U.S. EPA issued a Unilateral Administrative Order to the potentially responsible parties to conduct a removal action at the Site.  The potentially responsible parties presented and inability to pay argument and indicated that they did not intend to conduct a removal action at the Site.  EPA began time-critical removal actions at the Baycote Site on May 29, 2012. 

This is a large Site, with 11 plating lines in 6 areas and several waste water treatment systems.  The OSC and its contractors have adopted a work plan to prioritize the high hazard areas / plating lines.

2.1.2 Response Actions

- EPA and START continued to conduct site perimeter and work area air monitoring to ensure worker and community protection.  

- EPA, START, and ERRS continued to monitor the eight 55-gallon drums that contain the source material from the incident that occurred on September 14.  No heat or evidence of reaction were present.  EPA consulted members of the Environmental Response Team (ERT), and START Health and Safety to determine sampling strategy.  Sampling is necessary to determine any transportation / disposal / treatment options.  Additional air monitoring equipment for byproducts of degradation of the source material is being explored.  

- On 9/20, EPA and START participated in a debrief with state, local, and hospital officials.  The Mayor of Mishawaka, Fire Department, Police Department, EMA, St Joseph Hospital Staff, Mishawaka Utilities / Building / Wastewater Departments, and IDEM were present.  Mishawaka Fire Department Area 6 Chief Cocquyt discussed the response, who was contacted – hospitals, the school, nursing home, Red Cross, and how the response was conducted.  OSC Atkociunas discussed the removal project, management of wastes, the incident, response actions, and work remaining at the site.  OSC Atkociunas provided local authorities with four large laminated copies of the site map.   

- An EPA Management Official and IDEM Represenative conducted a site visit.  The OSC provided an overview of the site, health and safety concerns, site operations, the incident, the response to the incident and follow-up.  EPA and IDEM reviewed notification procedures. 

- An ERRS Health and Safety representative and a Federal Occupational Health representative conducted investigations of the incident.  Reviews of standard operating procedures were conducted.  Any changes / modifications will be implemented.  In the interim, additional reviews / precautions (additional HazCat, bucket tests, etc.) are being conducted.       

- EPA, START and ERRS conducted a site organization review and implemented changes.  The waste staging area was reorganized.   

- Cleanup in Area A continued.  The sludge in the secondary containment pits is being solidified with corn cob / portland cement.  Sludge in pit A89 was solidified and removed; the walls and floor were scraped and powerwashed.  Rinsewaters were collected for off-site disposal.  Pit A89 was backfilled with recycled concrete.  A 15 CY roll off of Hazardous Waste Solids from the secondary containement pits was sent for off-site disposal; see table below for details.   

- Cleanup in Area Z continued.  Process piping was demolished and placed into the appropriate roll off.  Nonhazardous liquids were pumped into the on site 4,900 gallon poly tank.  Liquids from the tank were subsequently sent for off-site disposal; see table below for details.   

- Cleanup in Area E continued.  Additional process piping was demolished and placed into the appropriate roll off for disposal.  General housekeeping / cleaning was conducted.     

- EPA, ERRS and START continued to assess options for accessing, removing wastes in Area W.  A structural engineer was contacted.  There is an opening in the building between Areas W and J.  ERRS removed a wall air conditioning unit between the areas to obtain a visual into the open area.     

- EPA’s supplied air trailer is onsite to support Level B work.   

19 55-gallon drums of Haz basic vat bottom sludge

14 55-gallon drums of Haz acid vat bottom sludge

2 330-gallon totes of Haz cyanide containing liquid

0 55-gallon drums of Haz cyanide containing vat bottom sludge

0 Cubic-yard boxes of Haz cyanide solids

3  95-gallon overpacks of Haz cyanide solids

13 Cubic-yard boxes of Haz solids

0 330-gallon totes of Haz acid liquid

3 55-gallon drums Decon water

8 55 gallons drums of cyanide waste from incident

0 55-gallon drums of Haz neutral liquid

26 RCRA-empty vats (various sizes)

74 330-gallon tote metal frames (poly portion has been cut apart and placed in roll-offs)

9  330 gallon tote Haz base liquid

11 330 gallon tote Haz neutral liquid

Planned removal activities on Site include:

1. Inventory and perform hazard categorization on substances contained in vats, pits, drums, and other containers; 
2. Perform sampling and analysis to determine disposal options.
3. Continue to consolidate and package hazardous substances, pollutants, and contaminants for  
   transportation and off-site disposal;  
4. Dismantle and decontaminate process equipment and building components associated with 
   the plating areas, as necessary;
5. Transport and dispose of all characterized or identified hazardous substances, pollutants, or 
   contaminants to a RCRA/CERCLA-approved disposal facility in accordance with U.S. EPA 
   Off-Site Rule (40 CFR § 300.440) . 
6. Take any other response actions to address any release or threatened release of a hazardous substance, pollutant and contaminant that the U.S. EPA OSC determines may pose an imminent and substantial endangerment to the public health or the environment. 

2.2.1.2 Next Steps

During the week of September 24, 2012, the following activities are anticipated:

- Monitor the eight containers of the source material.
- Determine sampling strategy, procure lab services, procure additional air monitoring equipment for the source material.
- Continue to investigate the cause of the incident and implement corrective measures.
- Continue cleanup work in Areas A, E and Z. 
- A shipment of waste containers is scheduled for transportation off-site to a disposal facility.
- A shipment of a roll off containing hazardous waste solids is scheduled for transportation off-site to a disposal facility.   
- Assess options to access / managage wastes located in Area W.     
- Consolidate / repackage waste into containers as needed into D.O.T. shippable containers.  
- Demolish RCRA empty containers.
- Conduct hazcat testing / waste sampling to determine waste characteristics and disposal options.
- Continue air monitoring in the work zone and the perimeter of the Site to protect workers and residents.
- Evaluate the bids for the disposal of hazardous waste and chose facility as needed.
- Continue to submit waste profiles to selected disposal facilities as needed.
- Recycle scrap metal generated from clean-up operations. 

2.2.2 Issues
NA

The Health and Safety Plan was approved and signed by all site personnel. 
Health and Safety meetings are held daily. 

2.5.2 Liaison Officer
NA

2.5.3 Information Officer:
Community Involvement Coordinator: Ginny Narsete

IDEM

City of Mishawaka

St. Joseph County Health Department

Mishawaka Fire Department
ATSDR
Federal Occupational Health
South Bend HazMat

The following numbers of personnel were On-Site during the reporting period:

Baycote            Baycote Metal Finishing Site

CERCLA           Comprehensive Environmental Response, Compensation, and Liability Act
CRZ                  Contamination Reduction Zone

EPA                 Environmental Protection Agency
ERT                  Environmental Response Team

ERRS               Emergency and Rapid Response Services

FCA                 Field Cost Accountant

FOH                 Federal Occupational Health
HASP               Health and Safety Plan

HAZCAT            Hazardous Categorization 
IDEM                Indiana Department of Environmental Management

NA                    Not Applicable

OSC                 On-Scene Coordinator

PolRep              Pollution Report

RCRA                Resource Conservation and Recovery Act

PRP                  Potentially Responsible Party

RM                    Response Manager

POLREPS will be issued on a weekly or bi-weekly basis.