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.             

- Cleanup in Area Z continued.  ERRS accessed and cleaned Vats Z35, Z01, Z02, Z03, Z04 and Z05.  Sludges were collected for off-site disposal. ERRS cleaned / powerwashed the Vats, which were rendered unusable.  ERRS continued to demolish process piping which was decontaminated and powerwashed.  ERRS also cleaned residual material on the floor in Area Z.  Rinsewaters were collected for off-site disposal.   

- Cleanup in Areas U and C continued.  ERRS removed air pollution control systems (local exhaust hoods, associated duct work, filters) from the areas. The equipment was removed, demolished, powerwashed and placed into the appropriate roll-off.  Rinsewaters were collected for off-site disposal.   

- Cleanup in the HazCat 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 HazCat work with additional air monitoring instruments.  Lab packing of miscellaneous containers was initiated and completed.    

- Test pits were excavated in areas where EPA Fields Team detected anamolies based upon the geophysical survey.  Evidence of waste burial (ie. drums, containers, and plating waste) was not observed.  START collected several soil samples in the area of the area.  Metal debris (ie. bolts, nuts) was present at or near the surface in the area.  START also collected additional soil samples in the field east of the Site building.  The samples were sent off site for laboratory analysis.   

- EPA and START developed a Quality Assurance Project Plan (QAPP) for START sampling associated with the removal.  The sampling includes the sample collected from Vat J12, soil samples and START samples to be collected in Area W. 

- Empty containers / equipment continued to be demolished and placed into the appropriate roll-off for off-site disposal.        
      
- ERRS placed telescopic floor jacks under beams located in Area W.  EPA, START and ERRS accessed portions of Area W to determine waste management strategies. 

- EPA and its contractors are implementing Green Practices onsite (double sided printing, Culligan water servIce / dedicated water bottles, dedicated steel toed Chem boots, city electrical power, CFL bulbs, etc...).  To date approximately 101,460 pounds of scrap steel has been recycled.  Water service / reusable dedicated water bottles saved approximately 3,100 disposable water bottles.      


2.1.4 Progress Metrics

The following waste has been staged for disposal as of October 26, 2012:

24 55-gallon drums of Haz basic vat bottom sludge

16 55-gallon drums of Haz acid vat bottom sludge

19 Cubic-yard boxes of Haz solids

1  330 gallon tote Haz base liquid

32 330 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 29, 2012, the following activities are anticipated:

- Continue HazCat of miscellaneous containers using improved hazard categorization procedures. 
- Conduct an assessment / sampling of Area W to determine removal options.  
- Ship out hazardous waste for transportation off-site to a disposal facility as necessary.     
- 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. 
- Decontamination of site equipment.

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.