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 (stored in Area H)  that contain the source material from the incident that occurred on 9/14.  Additional monitoring equipment for possible degradation products remains on site.  The equipment includes SO2 sensors, and Drager CMS Chips (H2S, SO2, and HCN).  No heat or evidence of reaction were present.    Analytical results of the September 26 sampling event of source material have been received.  ERRS initiated the bid process for off-site disposal of the waste.    

- Cleanup in Area A continued.  The sludge in the secondary containment pits was solidified with corn cob & portland cement. The solidified sludge was excavated for disposal.  During the reporting period, 18 cubic yards (one steel roll off container) of Hazardous Waste Solids was removed from the secondary containment pits and sent for off-site disposal; see table below for details.  The pits were washed and cleaned with caustic water and that rinse water was pumped out and stored for disposal.  The pits have been emptied, cleaned and backfilled / partially backfilled. An additional load of recycled concrete has been delivered to continue backfill operations.     

- Cleanup in Area Z continued.  Process piping and tank supports were demolished and placed into the appropriate roll off. Vats Z9, Z10, Z15, Z16, and Z17 were cleaned and rendered unusable.  A large opening was cut into Vat Z6.  ERRS accessed the Vat and began to remove debris and baskets containing zinc ball anodes.  The Vat is approximately 70 feet long and 7 feet wide and contains substantial amount of material.  ERRS accessed a hatch to Z25, which appears to be a dryer for the plating process.  Mechanical equipment was observed inside.   

- Cleanup in Area E continued. Hazard Categorization, using improved procedure developed by ERRS were used with START oversight to determine the chemical characteristics of several unknown wastes in small containers.  
EPA is supporting the haz cat work with additional air monitoring instruments.  ERRS loaded solidified non-hazardous waste sludges from containers / vats located in Area E and placed into a roll-off for off-site disposal.   

-  Cleanup in Area J continued.  ERRS removed liquid / sludge from Vat J12. 

- EPA and START continued to develop a Quality Assurance Project Plan for START sampling associated with the removal.  The sampling includes the sample collected from J12 to determine the threat posed by wastes associated with Area W.      

-  A representative from Keller Engineering, Inc. conducted a site visit on October 4 to conduct a structural integrity assessment of the Site.  A report is expect during the week of October 8.  EPA requested a determination on structural soundness of the building, methods to access / remove waste from Area W and methods to remove air handling systems.

- EPA OSC and START completed their sweep of the site and found no signs of combustion, heat, or reactions.

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

The following waste has been staged for disposal as of October 5, 2012:

20 55-gallon drums of Haz basic vat bottom sludge

15 55-gallon drums of Haz acid vat bottom sludge

6 330-gallon totes of Haz cyanide containing liquid

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

1 Cubic-yard boxes of Haz cyanide solids

0  95-gallon overpacks of Haz cyanide solids

16 Cubic-yard boxes of Haz solids

2 330-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)

77 330-gallon tote metal frames (poly portion has been cut apart and placed in roll-offs)

10  330 gallon tote Haz base liquid

17 330 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 Oct. 8, 2012, the following activities are anticipated:

- Monitor the eight containers of the source material from the Sept. 14 incident.  Continue to explore off-site disposal options for the waste. 
-  Continue hazcat of miscellaneous small containers using improved hazard categorization procedures.
- Continue cleanup work in Areas E and Z. 
- Evaluate the engineering report to determine cleanup options in Area W.   
- Ship out hazardous waste for transportation off-site to a disposal facility as necessary.  
- Assess options to access & manage 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 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.

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.