See POLREP Nos. 1 and 2 for additional information.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

See POLREPS Nos. 1,2 and 3.

10/15/2014:  OSC Wise notified the lawyers for the PRP that EPA would be assuming the lead for the cleanup.  This decision was based on their inability to hire a qualified HAZWOPER compliant contractor.

10/22/2014:  Lawyers for the PRP notified EPA that they had retained Enviroserv to conduct the removal of the liquids from Plating Lines #1 and #3.

10/24/2014:  The lawyers for the PRP were notified by OSC Wise that they had until November 10, 2014 to provide EPA with the name of a contractor that would be able to complete the remainder of the removal action.

11/03/2014 thru 11/06/2014:  1 OSC, 1 START

The PRP’s contractor, Enviroserv, began hazardous waste bulking operations.  Bulking operations this week will be conducted on Plating Lines #1 and #3.  The START implemented an air surveillance program on the outside perimeter of the facility.  The program included air monitoring for volatile organic compounds, cyanide and dust as well as air sampling for cyanide, metals and acid gases.  Air surveillance documented no contaminants in excess of the action levels.  A total of 38,436 gallons of Hazardous Waste were sent off-site for disposal.   Waste was transported off-site in totes and vacuum trucks.   See Section 2.1.4 for a description.

11/10/2014:  The lawyers for the PRP failed to respond to the November 10, 2014 deadline directing them to provide the name of the contractor that would be conducting the removal.

11/12/2014:  OSC notified the PRPs that EPA would again be assuming the lead for the removal.

11/24/2014:  A contractor for the PRP contacted OSC Wise and indicated that his firm, DCE, Inc. would be conducting the removal action.   DCE will be managing the removal while, Advanced Chemical Transport (ACT) will be conducting the actual work.  DCE may not conduct any hot zone work, as they are not incompliance with HAZWOPER.

11/25/2014:  OSC Wise and one START met DCE and ACT on-site for a job walk.  During this job walk, OSC Wise reiterated that DCE is not allowed to conduct any of the hot zone operations including any demolition work.  During this site walk, the DCE representative informed OSC Wise that they were not contracted to remove the chemicals in Plating Line #2.  The removal action is expected to begin on December 8, 2014.

The PRP's contractor, ACT is anticipating having their health and safety plan to EPA by during the week of December 1, 2014.  The removal is currently slated to begin on December 8, 2014.

2.2.2 Issues

The pending bankruptcy of the building and property may present challenges to the PRP and regulators.  The attorneys for the PRP are currently in negotiations with Farmers Insurance to fund the removal action.  Farmer's has provided an additional $$150,000 to the insured to get the cleanup started.

The prime contractor, DCE does not meet the minimum requirements for HAZWOPER compliance pursuant to 29 CFR 1910.120(b).  Pursuant to 40 CFR 300.150, all removal actions conducted under the NCP must be in compliance with HAZWOPER.    DCE will be acting as the general contractor with ACT conducting all of the work where exposure to hazardous waste may occur.

Due to inclement weather in Southern California during the week of December 1, 2014, areas previous pumped may now contain rain water which might have to be disposed of as hazardous waste.

The Orange Square property adjacent to the north of Highland is in negotiation with Farmer's concerning potential contamination as a result of the fire.