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.  

- The Mayor of Mishawaka discussed site activities / site progress with OSC Atkociunas.   

- High School Students from Penn High School interviewed OSC Atkociunas regarding site activities for an Environmental Science Class.

- EPA, START, and ERRS continued to monitor the source material from the September 14 incident.  Analytical data from the September 26 sampling event was reviewed.  Based upon analytical data / physical characteristics of the drums, the contents of six containers were consolidated into one 55-gallon drum and two containers were consolidated into another 55-gallon drum.  Prior to consolidation, ERRS conducted a 'bucket test' to determine if any reactions, heat, and/or byproducts of consolidation would be generated.  No anomolies were detected.  The empty containers were washed and rinsed; rinsewaters were collected for off-site disposal.  EPA, ERRS and START monitored the two drums for reactions, heat, and/or byproducts of consolidation; no anomolies were detected.  ERRS procured disposal services for the source material from the incident and scheduled shipment for the week of October 14.        

- Backfill operations in Area A continued.  ERRS placed recycled concrete in the cleaned secondary containment pits to bring the area closer to grade.      

- Cleanup in Area Z continued.  ERRS completed clean-up of Vat Z6 (the vat is approximately 70 feet in length and 7 feet wide.  Debris in the tank was cleaned and placed into the appropriate container.  ERRS accessed / cleaned Vats Z66, Z58, Z59, Z26 and Z27.   Sludges were collected for off-site disposal. ERRS cleaned / powerwashed structures and collectd rinsewater for characterization and off-site disposal.  ERRS demolished piping and a portion of the cat walk to access the Vats in the northeast section of the room. 

- The 4,900 gallon Rain for Rent poly tank (which was cleaned / decontaminated during the week of September 24) was demobilized from site.   

- A tanker load of non-RCRA material (cyanide wastewater) was shipped for off-site disposal.  The wastewater was generated from clean-up operations in Area A.  See Table below for details.  

- Cleanup in Area E continued.  ERRS pumped liquids from tank E, which is located below grade in the Northwest corner of the room.  Hazard Categorization, using improved procedure developed by ERRS were used with START oversight to determine the chemical characteristics of several unknown wastes in containers.  
EPA is supporting the haz cat work with additional air monitoring instruments.  Non-hazardous waste sludges generated from clean-up in Area E were shipped off-site for disposal; see Table below for details.    

- Cleanup in the Haz Cat area (Southwest corner of Area R) 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.  

- EPA and START continued to develop a Quality Assurance Project Plan (QAPP) 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.  Soil sampling to characterize site soils will also be included in the QAPP.      

- The Engineering Structural Condition Report was received and is in the process of being reviewed.  Recommendations will be implemented, as necessary.   

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

The following waste has been staged for disposal as of October 12, 2012:

20 55-gallon drums of Haz basic vat bottom sludge

15 55-gallon drums of Haz acid vat bottom sludge

2 330-gallon totes of Haz cyanide containing liquid

3 55-gallon drums of Haz cyanide containing vat bottom sludge

3 Cubic-yard boxes of Haz cyanide solids

0  95-gallon overpacks of Haz cyanide solids

17 Cubic-yard boxes of Haz solids

2 330-gallon totes of Haz acid liquid

3 55-gallon drums Decon water

2 55 gallons drums of cyanide waste from incident

0 55-gallon drums of Haz neutral liquid

29 RCRA-empty vats (various sizes)

79 330-gallon tote metal frames (poly portion has been cut apart and placed in roll-offs)

1  330 gallon tote Haz base liquid

33 330 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 October 15, 2012, the following activities are anticipated:

- Transport the source material from the September 14 incident for off-site disposal. 
- 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.
- Support US EPA Fields Team in a geophysical survey of site soils.   
- 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.