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 #5
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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Paul Ruesch, OSC and Elizabeth Nightingale, OSC
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Date:
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12/15/2014
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Reporting Period:
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12/8/14 - 12/12/14
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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: |
EP-S5-09-05 |
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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
2.1.2 Response Actions to Date
From December 8 - 12, 2014, work focused on the following activities:
Operations
- Completed sampling and field hazcatting of all staged containers with unknown contents (non-empty drums, buckets & totes);
- Continued consolidation of dross/smelting waste from across the site, and decontamination of foundations/pits/bins. Work focused on removing dross/smelting waste from pits and along railroad spurs on the east & west sides of the site. Sweeping was focused in the southern section of the site. Excavated waste was consolidated into waste piles #4 and #5. Foundation decontamination is estimated to be 90% complete.
- Continued sorting non-conforming debris from large dross/smelting waste piles and shaping piles. Piles 1, 2 & 4 are ready to ship for disposal. Piles 3 and 5 contain non-conforming debris which needs to be further sorted prior to sampling & characterization for disposal;
- Continued repackaging of baghouse dust waste in compromised supersacks into shippable supersacks, and staged sacks for disposal. To date, 43 bags have been repackaged, 13 were already in shippable condition and did not needed to be repackaged; and another 10 sacks still need to be repackaged;
- Continued temperature monitoring of waste piles & supersacks of baghouse dust;
- Evaluated bids & selected contractors for transportation & disposal of dross/smelting waste piles 1 & 2; and
- Met with representatives from the proposed disposal facility on site on December 12 to evaluate the dross/smelting waste material for acceptablity in the landfill. In addition, transport, documentation and loading/unloading procedures were discussed to ensure safe & proper handling of the material.
Air Monitoring
- Continued implementation of the air monitoring plan to ensure public and worker safety.
- Continuously monitored data from particulate and chemical monitors for compliance with established standards. Real-time data are transmitted back to the site command post where they are monitored continuously. Any exceedances are addressed immediately.
- Maintained a website (VIPER) with current and past perimeter air monitoring data. See Section 6.1 for instructions on accessing the website.
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. The perimeter action level for PM-10 particulates has been set at a time weighted average (TWA) of 150 micrograms per cubic meter (μg/m3), as established in 40 CFR Part 50, National Ambient Air Quality Standards (NAAQS).
One personal data ram (PDR) particulate air monitor is deployed daily in the work zone during the removal action. The particulate monitor will data-log instantaneous TWA particulate concentrations during active operations. Action level exceedances will be managed by setting the monitor to alarm at the established action level to notify on-site personnel. 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.
During the week of December 8, 2014, occasional exceedances of the perimeter action levels for particulates were detected, but the TWA was not exceeded.
MultiGas Air Monitoring:
AreaRAE multi-gas monitors are being deployed at the container staging area and at 3 perimeter locations. 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).
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 December 8, 2014, no 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 |
| Scrap metal |
steel |
40 yds (est) |
NA |
recycling
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Padnos Recycling,
Benton Harbor, MI |
RCRA empty
containers & debris |
solid |
30 yds (est) |
A5-156-01 |
disposal |
Forest Lawn Landfill,
Three Oaks, MI |
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2.2 Planning Section
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2.2.1 Anticipated Activities
2.2.1.1 Planned Response Activities
Please see initial POLREP for planned removal activities on-site.
2.2.1.2 Next Steps
Next week, work will continue to consolidate dross from across the site; prepare to ship dross/smelting waste for disposal; commence shipment waste piles 1 & 2 for disposal; sort non-conforming debris from large dross piles and shape piles; and repackage baghouse dust into intact bags. Samples collected from containers of unknowns will be shipped for analysis in preparation for disposal.
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
NA
3.2 Cooperating Agencies
MDEQ
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4. Personnel On Site
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12/8/14:
EPA - 1
START - 1
ERRS - 6
12/9/14:
EPA - 1
START - 1
ERRS - 6
MDEQ- 1
12/10/14
EPA - 1
START - 1
ERRS - 6
12/11/14
EPA - 2
START - 1
ERRS - 6
12/12/14
EPA - 1
START - 1
ERRS - 6
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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
http://www.epaosc.net/alreco
Air monitoring data is posted real time at http://viper.ert.org. Users need to create a login upon their first visit to the website. Once logged in, select R05 ALRECO Metals 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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