Chromium(VI) and chromium(III) are used for chrome plating.  Chromium is known to be a human carcinogen.  According to ATSDR, Breathing high levels of chromium(VI) can cause irritation to the lining of the nose, nose ulcers, runny nose, and breathing problems, such as asthma, cough, shortness of breath, or wheezing. The concentrations of chromium in air that can cause these effects may be different for different types of chromium compounds, with effects occurring at much lower concentrations for chromium(VI) compared to chromium(III).

The plating building structure is currently red tagged (condemned) by the Los Angeles City Building Department as unsafe.  There are several plating lines buried under debris from the collapsed roof throughout the plating lines whose condition and stability are unknown.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

On the morning of July 13, 2014 (Sunday), a fire began a at the Highland Plating.  The fire was contained to the plating building bordering Orange Drive.  Over 130 LA firefighters defended the fire and it was ultimately extinguished sometime in the morning of July 14.   A huge smoke plume lasted all morning and recurred briefly in the evening.  Over 1 million gallons of water was used to fight the fire.  Significant amounts of runoff water containing plating solutions were released from the building.  Aggressive containment efforts were implemented in the streets bordering the northwest and east sides of the building although some material did enter the storm drain. 

The Los Angeles County Health Hazardous Materials Division (Health Hazmat) requested EPA assistance in overseeing cleanup efforts.  OSC Robert Wise arrived at the site at approximately 2030 hours on July 13, 2014 to assess the scene.  After participating in the Unified Command Briefing, OSC Wise demobilized to the EPA office to collected equipment and remobilized arriving at approximately 0100 hours of July 14, 2014.   OSC Wise integrated into the Unified Command which was being lead by the City of Los Angeles Fire Department (LAFD).  EPA   joined with Health Hazmat, California Department of Fish & Wildlife (DFW) , and City  of Los Angeles Watershed Protection (LAWSP) in to assess the reach of contaminated water runoff.  Some impacted storm drains flow to the Ballona Creek wetlands.  This area was assessed by biologists from DFW and determined to not be impacted.  Sampling by LAWSP has documented that metals concentrations in Ballona Creek were at background levels. 

EPA also initiated an air surveillance program which consisted of air monitoring for total volatile organic compounds (VOCS), carbon monoxide and total hydrogen cyanide (HCN) and air sampling for acid gases, HCN and total metals.  The air monitoring did not detect any significant concentrations of any of the compounds of concern.  The air sampling data is pending.    The START is preparing an after action Quality Assurance Sampling Plan (QASP), Emergency Data Quality Objectives Plan (DQO) and a Data Management Plan (DMP).  The South Coast Air Quality Management District also collected three SUMA canisters with the data pending.

The City of Los Angeles Industrial Waste (LAIW) initiated sampling of the sewer on 07/14/2014 with a grab sample and the installation of an ISCO samplers to collect daily samples for metals.  With the exceptions of the day of the fire, no elevated contaminants have been found. 

July 13 - 14, 2014; Monday

OSC Robert Wise mobilized with START to the Highland Plating Facility in Los Angeles, CA.  The facility has been on fire since Sunday morning.   The local lead agencies are LAFD, LAWSP and Health Hazmat.  Upon arrival OSC Wise noted water and plating solutions (primarily chromic acid) leaking from the building doors located on the west side of the property (N. Sycamore Drive) and south side of the property (Romaine Street).  A large quantity of this runoff ran directly into the storm drain.  Chromic Acid was confirmed in the storm drain system, but the direction of flow in the underground system had not been determined.   EPA initiated an air surveillance program that included the collection of air samples for HCN, acid gases and metals.  Real time air monitoring for HCN was conducted with the Area Raes and Pac-3.

The property/building owners, (PRP), hired  environmental contractors (Enviroserv and Patriot) to begin clean up activities. The contractors also worked with LASWP to assess the impact to the storm drain.  The environmental contractor began collecting  runoff behind temporary earthen dikes and pumping the runoff from the gutters into temporary storage tanks.  Once the fire was out, the contractor also transferred cyanide liquids from open vats along the north interior wall of the plating facility into temporary storage totes.  Bags of cyanide solids were left in place due to the lack of stability/integrity of the burned structure.  The bags of cyanide were stabilized in-place and the enclosure they were in was temporarily fortified in case of worst-case scenario event (rain, earthquake, etc.).

Patriot composed and maintained the IAP for the environmental cleanup operations during the fire.

 July 15, 2014; Tuesday

OSC Duncan arrived on site and met with  Health Hazmat, LAWSP, Enviroserv and Patriot.  The primary activity for the morning was to transfer all liquids that had been contained in street  into temporary storage containers. Most of these liquids have a low pH and contain various metals including chrome, nickel and copper.  Material was collected into 7 x 4300 gallon Baker tanks and stored on the street near the corner of N. Orange Drive and Romaine Street to await disposal.  Once the liquids had been transferred,  Enviroserv began loading contaminated sands (used for containment dikes) into 20-yard roll-off  bins.  A total of seven roll-off bins were filled with sand.  Samples were collected from the roll-off  bins and each Baker tank stored on the street and were sent to a laboratory for analysis.  The analytical data and will be used to profile the wastes and transport them off-site to an appropriate disposal facility.   The 7 totes of cyanide solutions, roughly 260gals each (approximately 1820 gallons total) were moved from the street into a stable portion of the building.

In addition to cleaning streets, Enviroserv also worked on preventing the on-going overflow of secondary containment inside the burned building.  Enviroserv worked with facility employees to identify drain lines that could be plugged to prevent secondary containment draining into trenches and channels that were overflowing and draining to the outside of the building.  All the water, which overflowed and spread out in the building, was collected and transferred into an 8^th Baker tank.  Although they were successful in stopping the continuous discharge from the building,  the plugs and containment will be evaluated over the next several days to make sure the threat was successfully resolved.  

Impact to Ballona Creek/wetlands was not determined because data from CUPA/Watershed protection of stormwater runoff from the site is not yet available.  Down-gradient of site (Firmosa and Willoughby) there is a large construction project with a NPDES permit, dewatering site, buffers out any acidic conditions that may have been present from the Highland Plating Facility runoff. Volume of water from highland plating is diluted by the NPDES-permit facility, however metals contamination is still unclear.

Street cleaning activities are planned to continue through the night.  Enviroserv will pressure wash the impacted sections of Romaine Street and N. Sycamore Drive as well as three parking spaces in the northwest section of the parking lot that borders the facility and may have been impacted by run-off.   Following the street washing, Health Hazmat agreed to conduct XRF in situ metals analysis using the Niton XRF to verify, that the streets were cleaned to an acceptable level. 

Finally, the Stormdrains between Romaine/Sycamore (on-site) and Willoughby/LaBrea(Firmosa) will be flushed out during night operations.

July 16, 2014; Wednesday

Last night Enviroserve finished cleaning the street (Romaine and Sycamore) and used approximately 2500 gallons of water to flush stormdrains. Watershed protection deemed the flushing activities to be sufficient and called for no further action concerning the cleaning of the stormdrains.

During the night the secondary containment inside the facility began to overflow again.  Fortunately the material was captured prior to releasing into the street.  The secondary containment overflow issue will be monitored on a daily basis going forward during this phase of the stabilization and until removal activities are conducted.

Health Hazmat used in-situ XRF to measure effectiveness of power washing activities in the street and on site walks. Additionally XRF was used to measure the concentration in right-of-way between the facility and Romaine St.  Elevated concentrations of Cr, and Ni were observed.  Enviroserv will remove six inches of soil from those areas.  Health Hazmat conducted XRF analysis on soil located on the northeast side of the building and found no elevated metal levels.

The treatment system inside of the facility is still connected to the municipal/sanitary sewer system.  A method to plug/cut off this system needs to be implemented in order to rule out any further release to that system.

A contractor (HarBro) arrived on site to begin boarding up entrances and windows in order to secure the property from the casual trespasser.  LAFD Arson Investigator isn’t able to make entry into the facility because of hazardous waste/and unstable structural conditions.

July 17, 2014; Thursday

The insurance adjustor for the building inspected the facility today.  The Attorney for the PRPs was also on site and was provided a Notice of Federal Response Action (NFRA). 

Enviroserv completed the following actions prior to leaving the site for the day:

1)    They sealed/permanently obstructed the lateral line from the clarifier/treatment system to the municipal sanitary sewer

2)   They cleaned out water valve/utility vaults located in the street where runoff from fire fighting activities took place. 

OSC Duncan requested the PRP to provide 24-hour security until the waste that is currently stored in the street is removed.

OSC Wise meet with DTSC representative on site and discussed potential support that the State could provide.