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Commonwealth Site

All POL/SITREP's for this site Commonwealth Site
Detroit, MI - EPA Region V
POLREP #2
Removal Continues
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U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Commonwealth Site - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V

Subject: POLREP #2
Removal Continues
Commonwealth Site
C52R
Detroit, MI
Latitude: 42.3606980 Longitude: -83.0852929


To: Jason El-Zein, U.S. EPA
Sam Borries, U.S. EPA
Mark Durno, U.S. EPA
Carolyn Bohlen, U.S. EPA
Yolanda Bouchee-Cureton, U.S. EPA
Jaime Brown, U.S. EPA
HQ EOC, U.S. EPA
Sherry Fielding, U.S. EPA
John Glover, U.S. EPA
Sharon Jaffess, U.S. EPA
John Maritote, U.S. EPA
Thomas Marks, U.S. EPA
Carol Ropski, U.S. EPA
Grace Co, U.S. EPA
Richard Murawski, U.S. EPA
Mike Rafati, U.S. EPA
Valencia Darby, U.S. DOI
Lindy Nelson, U.S. DOI
USCG PolRep Distribution, USCG
Joseph DeGrazia, MDEQ
Jennifer Wolf, MDEQ
Joe Walczak, MDEQ
Bruce VanOtteren, MDEQ
Ray Scott, Detroit Environmental Affairs
Paul Max, Detroit Environmental Affairs
Sean Kane, TetraTech
Rhonda Anderson, Sierra Club
Melissa Damaschke, Sierra Club

From: Brian Kelly, OSC
Date: 11/2/2014
Reporting Period:

1. Introduction
  1.1 Background
   
Site Number: C52R    Contract Number:  
D.O. Number:      Action Memo Date: 8/28/2014
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 10/20/2014    Start Date: 10/20/2014
Demob Date:      Completion Date:  
CERCLIS ID:    RCRIS ID:
ERNS No.:    State Notification: Yes
FPN#:    Reimbursable Account #:

Incident Category
Fund lead CERCLA time-critical removal action.

Site Description and Location

The Commonwealth Site (site) is located at 5923 Commonwealth Street, Detroit, Michigan 48208. The site is the former location of E.L.M. Industries, Inc. and Triune Iron & Metal, Inc. It is unknown when the businesses ceased operations, but the property was tax foreclosed by the City of Detroit on January 19, 2010. During an assessment of the property, several hundred drums, totes, cylinders, and small containers of waste were found.  

Description of Threat and Preliminary Removal Assessment
On May 15, 2014, EPA conducted a site assessment that documented drums, totes and small containers at the site. Some of the drums show signs of deterioration, damage and possible leaking. Drum labels include trichloroethylene, acetylene gas, hydraulic and motor oil, coating enamels, propylene glycol n-propyl ether, and hydrogen peroxide. EPA also collected samples (CW-AR-01-051514 and CW-AR-02-051514) that when tested had a flash point less than 140 degrees Fahrenheit (°F).  These wastes are considered hazardous for the characteristic of ignitability, pursuant to 40 C.F.R. § 261.21. Tetrachloroethene was detected in sample CW-DR-01-051514 at a concentration of 1.1 milligrams per liter [mg/L]). This result exceeds the toxicity criterion for tetrachloroethene of 0.7 mg/L. Therefore, the waste associated with this sample is considered hazardous according to 40 C.F.R. § 261.24.

2. Current Activities
  2.1 Operations Section
    Narrative
See initial POLREP

Response Actions to Date

Between October 20 and October 31, EPA identified, segregated, and sampled 91 drums, 11 totes and 57 small chemical containers (<5-gallons) of liquid and solid waste.  EPA also confirmed through sample analysis that two piles of dumped floor tiles contain asbestos.

On October 28, EPA mobilized a chemist to the site to conduct hazard categorization (HAZCAT) field screening on the collected samples to identify waste streams.

On October 30, EPA began the process of cutting empty drums in preparation for transportation and off site disposal.

During removal work, START has conducted perimeter and exclusion zone air monitoring for volatile organic compounds (VOCs), carbon monoxide (CO), hydrogen sulfide (H2S), lower explosive limit (LEL%) and  oxygen (O2%) utilizing an AreaRAE network and a multiRAE. There have been no exceedances of action levels.

Security is on site during nonworking hours.

Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The bankrupt E.L.M. Industries, Inc. and Triune Iron & Metal, Inc. are the only known PRPs.

2.1.4 Progress Metrics

Waste Stream Medium Quantity Manifest # Treatment Disposal
           
           
           


  2.2 Planning Section
    Next Steps
  • Complete hazard categorization 
  • Identify waste streams
  • Bulk compatible waste streams
  • Prepare composite waste stream samples for laboratory analysis 
  • Remove freestanding liquids
  • Apply absorbent materials to spilled wastes
  • Solicit bids for laboratory analysis of composite waste stream samples 
  • Solicit bids for lab-pack of small containers (if necessary) 
  • Solicit bids for transport and offsite disposal
  • Arrange for off site disposal of waste streams


  2.3 Logistics Section
   

The current resources present on site during this reporting period include:
- Air horns
- Air monitoring equipment
- ERRS equipment storage trailer
- ERRS 'break' trailer
- ERRS work crew
- ERRS work vehicles 
- ERRS removal manager
- ERRS chemist
- ERRS field cost assistant
- Federal On Scene Coordinator
- Fire extinguishers
- Office trailers
- Portable decontamination area (first aid kit, emergency shower & eyewash)
- Portable restrooms
- Portable generators 
- Security subcontractor personnel
- Skid steer with attachments
- START contractor (oversight & air monitoring) 
- Wind sock


 


  2.4 Finance Section
   
   
Estimated Costs *
  Budgeted Total To Date Remaining % Remaining
Extramural Costs
ERRS - Cleanup Contractor $200,000.00 $58,000.00 $142,000.00 71.00%
START $25,000.00 $10,000.00 $15,000.00 60.00%
Intramural Costs
 
Total Site Costs $225,000.00 $68,000.00 $157,000.00 69.78%

* 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.


  2.5 Other Command Staff
    2.5.1 Safety Officer
The site-specific HASP is reviewed and signed by site personnel.  Safety meetings are held each morning with all site workers.

2.5.2 Liaison Officer
Brian Kelly serves as liaison with local officials and interested parties.

2.5.3 Information Officer
See Section 2.5.2

3. Participating Entities
  3.1 Unified Command
N/A

3.2 Cooperating Agencies
Detroit Environmental Affairs
Michigan Department of Environmental Quality

4. Personnel On Site
  U.S. EPA - 1
START contractor (Tetra Tech) - 1
ERRS contractor (Lata Kemron/Marine Pollution Control) - 7
Security guard (off-shift) - 1

TOTAL PERSONNEL = 10

5. Definition of Terms
 

CO - Carbon Monoxide
ERRS - Emergency and Rapid Response Services
HASP - Health and Safety Plan
HAZCAT - Hazard Categorization
H2S - Hydrogen Sulfide
LEL - Lower Explosive Limit
PPE - Personal Protection Equipment
START - Superfund Technical Assessment and Response Team
U.S. EPA - United States Environmental Protection Agency
VOCs - Volatile Organic Compounds


6. Additional sources of information
  No information available at this time.

7. Situational Reference Materials
  No information available at this time.

POLREP #2 Last Updated 11/3/2014