U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
ALRECO Metals - Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
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Subject:
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POLREP #3
Progress
ALRECO Metals
C52N
Benton Harbor, MI
Latitude: 42.1389684 Longitude: -86.4362357
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To:
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From:
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Elizabeth Nightingale, OSC
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Date:
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11/26/2014
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Reporting Period:
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11/24/14-11/26/14
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1. Introduction
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1.1 Background
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Site Number: |
C52N |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
8/8/2014 |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
11/10/2014 |
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Start Date: |
11/10/2014 |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
MIN000504648 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
Yes |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Time Critical Removal Action
1.1.2 Site Description
See initial POLREP.
1.1.2.1 Location
See initial POLREP.
1.1.2.2 Description of Threat
See initial POLREP.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
See initial POLREP.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
Removal activities will be suspended on 11/27/14 - 11/28/14. Security will be onsite until work resumes on Monday 12/1/14.
2.1.2 Response Actions to Date
Over the week beginning the November 24, 2014 work focused primarily on the following activities:
- Continuing to implement air monitoring and site security plans.
- Continuing to collect containers (non-empty drums, buckets and totes) and stage them in staging area. The majority of known containers have been relocated to the staging area at this time.
- Continuing to consolidate dross/smelting waste from across the site. This week, this work focused on removing dross/smelting waste from 3 large pits, 2 small pits and 1 long trench on the southern end of the site. Excavated waste is being consolidated in a separate waste pile (Pile 4). Smelting waste is also being removed from large onsite concrete storage bins (there are roughly 31 of these bins), and consolidated into Pile 4. The crew is attempting to conduct this decontamination work from the site perimeter towards the center, to the extent possible. Roughly 1/4 of the site foundations/pits/bins have been decontaminated to date - primarily on the northern and southern ends of the property.
- Continuing to sort non-conforming debris from large dross/smelting waste piles and shaping piles. Piles 1 and 2 have been sorted, shaped and covered pending disposal. Pile 3 contains a very large amount of non-conforming debris. Further work is still needed on Pile 3.
- Continuing to repackage bag house dust waste in compromised supersacks into shippable supersacks for disposal. Shippable supersacks are being staged in the staging area. To date, waste in 26 supersacks has been repackaged to date, and 5 were found to be in shippable condition already.
- Temperature Monitoring. The crew is monitoring the temperature of waste piles and supersacks of baghouse dust. Most readings have been normal to date. One bag of what appears to be baghouse dust that also contained some wood and cardboard showed an elevated temperature (142* F). Any materials with elevated temperatures are being segregated.
Air Monitoring:
Every day that cleanup activity work will be ongoing, air monitoring will be conducted to ensure public and worker safety. Chemical hazards due to fugitive emissions from removal activities are anticipated to be low since the ERRS contractor will employ administrative and engineering controls to minimize fugitive emissions and particulates that migrate off-site.
Meteorological data will be obtained daily from the NWS website that provides current weather conditions and documented in the site logbook.
Particulate Air Monitoring:
Datarams (DR4) are deployed daily at four fixed locations in each direction along the site perimeter boundaries where off-site receptors are most at risk to exposure from fugitive emissions. Real-time PM-10 particulate data is transmitted back to the site command post where it is monitored continuously.
A website has been established to view the current and past perimeter air monitoring data for the site. To view the data go to the web address: viper.ert.org. You have to create a login on your first visit to the site. Once logged in, go to the R05 ALRECO Metals Deployment to view site data. Currently data from 2 of the 4 particulate meters are available online via VIPER.
The perimeter action level for PM-10 particulates has been set at 150 micrograms per cubic meter (μg/m3). Should a DR4 unit detect sustained particulate concentrations greater than 150 μg/m3, the source of emissions will be investigated, and administrative and/or engineering controls will be initiated to reduce the particulate emissions.
One personal data ram (PDR) particulate air monitor will be deployed in the work zone during the removal action. The particulate monitor will data-log instantaneous and time weighted average (TWA) particulate concentrations during active operations. Data logs will be downloaded and stored.
The particulate action level within the work zone has been established as 2.0 mg/m3 for the respirable fraction of total particulates. This is a Site specific action level based on a calculation of airborne dust concentration. The crew will implement appropriate engineering control measures if an exceedance of the established action level is sustained for more than 60 seconds. Action level exceedances will be managed by setting the monitor to alarm at the established action level to notify on-site personnel.
During the week of November 24, 2014, no exceedances of the perimeter or work zone action levels for particulates were detected.
MultiGas Air Monitoring:
RAE Systems, Inc. AreaRAE multi-gas monitors are being deployed at the container staging area and at 3 perimeter locations (figure forthcoming soon). The AreaRAE multi-gas monitors will be used to monitor ammonia in parts per million (ppm), hydrogen sulfide (ppm), VOCs (ppm), and percent lower explosive limit (LEL). Real-time multigas data are transmitted back to the site command post where they are monitored continuously. These data are also available real time through the VIPER system described above.
The perimeter action levels are as follows: ·
Ammonia = 10 ppm
Hydrogen Sulfide = 10 ppm
PM10 particulates = 150 micrograms per cubic meter (μg/m3)
LEL = >5%
VOCs > 5 ppm
Work zone air monitoring results are being compared with the National Institute for Occupational Safety and Health (NIOSH) 10-hour recommended exposure limit (REL) or the OSHA 8-hour time-weighted average (TWA) PEL, whichever is more restrictive.
A MultiRAE Plus 5-gas monitor (loaded with sensors for detection of oxygen, carbon monoxide, hydrogen sulfide, LEL, and VOCs) will also be used to periodically spot check AreaRAE data.
During the week of November 24, 2014, one exceedance of the perimeter action level for a few minute period on the morning of November 24th (5.6 ppm VOCs detected). This reading was confirmed with the multirae. The source of the VOCs was investigated and is unknown. The crew is continuing to monitor the area. No other exceedances of the perimeter or work zone multigas action levels were recorded.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
General notice letters were issued to current and former owners of the property. Investigation is ongoing.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
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2.2 Planning Section
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2.2.1 Anticipated Activities
2.2.1.1 Planned Response Activities
Planned removal activities on-site include:
a) Developing and implementing a site-specific Health and Safety Plan, including an Air Monitoring Plan, and a site Emergency Contingency Plan;
b) Developing and implementing a Site Work Plan that includes a Site Security Plan;
c) Securing, characterizing, and sampling known and suspected hazardous substances, including containers of liquid, baghouse dust, aluminum dross/ash waste piles, at the site;
d) Consolidating and packaging hazardous substances, pollutants and contaminants, including containers of liquid, baghouse dust, aluminum dross/ash waste piles for transportation and off-site disposal;
e) Decontaminating contaminated structures (primarily foundations) as necessary;
f) Transporting and disposing of all characterized or identified hazardous substances, pollutants, wastes, or contaminants that pose a substantial threat of release at a Resource Conservation and Recovery Act/CERCLA-approved disposal facility in accordance with EPA’s Off-site Rule (40 C.F.R. § 300.440), as applicable; and
g) Taking 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
Next week, planned work will continue to consolidate dross from across the site; sort non-conforming debris from large dross piles and shape piles; and repackage baghouse dust into intact bags.
2.2.2 Issues
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2.3 Logistics Section
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ERRS is managing site logistics.
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer
OSC is serving in this role.
2.5.2 Liaison Officer
OSC is serving in this role.
2.5.3 Information Officer
OSC is serving in this role.
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3. Participating Entities
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3.1 Unified Command
n/a
3.2 Cooperating Agencies
MDEQ
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4. Personnel On Site
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11/24/14:
EPA: 1
START: 1
ERRS: 8
11/25/14:
EPA: 2
START: 1
ERRS: 8
11/26/14:
EPA: 1
START: 1
ERRS: 8
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5. Definition of Terms
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| ATSDR |
Agency for Toxic Substances and Disease Registry |
| BZ |
Breathing Zone |
| CERCLA |
Comprehensive Environmental Response, Compensation, and Liability Act |
| CERCLIS |
Comprehensive Environmental Response, Compensation, and Liability Information System |
| DNR |
Department of Natural Resources |
| EPA |
Environmental Protection Agency |
| ERNS |
Emergency Response Notification System |
| ERRS |
Emergency and Rapid Response Service |
| LEL |
Lower Explosive Limit |
| MDEQ |
Michigan Department of Environmental Quality |
| mg/m3 |
miligrams per cubic meter |
| NCP |
National Oil and Hazardous Substance Pollution Contingency Plan |
| NOAA |
National Oceanic and Atmospheric Administration |
| NPL |
National Priorities List |
| NRC |
National Response Center |
| OSC |
On Scene Coordinator |
| PPE |
Personal Protective Equipment |
| PPM |
Parts per million |
| RCRIS |
Resource Conservation and Recovery Act Information System |
| RP |
Responsible Party |
| RRT |
Regional Response Team |
| START |
Superfund Technical Assessment and Response Team |
| ug/m3 |
micrograms per cubic meter |
| US FWS |
United States Fish and Wildlife Service |
| USCG |
United States Coast Guard |
| VOC |
Volatile Organic Compound |
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6. Additional sources of information
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6.1 Internet location of additional information/report
www.epaosc.net/alreco
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viper.ert.org. Once logged in, go to the R05 ALRECO deployment to view site data.
6.2 Reporting Schedule
POLREPs will be issued weekly over the course of the removal action.
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7. Situational Reference Materials
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No information available at this time.
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