1.1.1 Incident Category

Time-Critical Removal Action.

1.1.2 Site Description

Michner Plating Mechanic Street (Site) is a former plating shop which operated from the 1930s until 2007.  Michner Plating also operated a separate facility on Angling Road in Jackson, Michigan, until May 2015. The Site contains approximately 1,100 drums, vats, totes, and other containers. Labels and sample analytical results indicate the potential presence of cyanide, zinc cyanide, nickel chloride, chromic acid, hydrogen peroxide, sulfuric acid, ignitable wastes, reactive wastes (including water reactive chemicals), and other chemicals.

1.1.2.1 Location

The Site is located at 520 North Mechanic Street in Jackson, Jackson County, Michigan, in a mixed commercial and residential area and is bound to the north by a commercial property, to the east by North Mechanic Street with residential dwellings and commercial properties beyond, to the south by East Trail Street with commercial properties beyond, and to the west by a railroad and the Grand River. The Site sits on roughly 4 acres, and contains four buildings totaling approximately 137,000 square feet.    

1.1.2.2 Description of Threat

 
The Site contains approximately 1,100 drums, vats, totes, and other containers. Labels and sample analytical results indicate the potential presence of cyanide, zinc cyanide, nickel chloride, chromic acid, hydrogen peroxide, sulfuric acid, ignitable wastes, reactive wastes (including water reactive chemicals), and other chemicals.


1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

EPA previously conducted an assessment and determined a Time-Critical Action was warranted. See Sitrep 1 for additional information.

2.1.1 Narrative

EPA began a Time-Critical action consisting of the removal of over 1,100 containers of hazardous waste on August 24, 2015.

2.1.2 Response Actions to Date

11/09/2015 – The crew finished bulking the non-cyanide containing alkaline solids in Composite group 6.   The crew donned level B PPE to retrieve and transfer one drum in Composite 6 because the drum was located with a group of drums that spontaneously release high levels of hydrocyanic acid gas.   The chemist generated a list of 34 containers with combustible liquids and sludge, and the crew began bulking these materials.  The liquid was combined in 250-gallon totes, which were labeled as Comp 19, for “Composite Sample 19”.   The crew completed waste bulking of the combustible liquids, but they ran out of open topped drums which are used for bulking the sludge.  The crew noted the drums that have not been transferred, and will continue bulking the sludge material in Composite 19 once the new drums are received. The crew also began sweeping in the northern rooms of the building, moving and clearing non-hazardous debris materials (i.e. wood pallets, boxes, and household items), and combining the floor sweepings into piles. 

11/10/2015 -   The chemist generated a list of 10 containers with cyanide containing flammable, alkaline liquids, sludge, and solids, and the crew began bulking the materials.  The liquid was combined in 55-gallon drums, which were labeled as Comp 21, for “Composite Sample 21”.   The crew completed waste bulking the liquids, but did not have any drums for bulking the sludge and solid materials.   The crew noted the drums that have not been transferred, and will continue bulking the sludge and solid materials in Composite 21 once the new drums are received.  The chemist generated a list of 24 containers with neutral solids, and the crew completed bulking the materials.  The materials were combined in cubic yard boxes, which were labeled as Comp 7, for “Composite Sample 7”.     The crew also began sweeping in the northern rooms of the building, moving and clearing non-hazardous debris materials, and combining the floor sweepings into piles.  The crew received 25 1-cubic yard boxes for bulking solids.

11/11/2015 –   The chemist generated a list of 25 drums with cyanide containing alkaline solids, and the crew began bulking the materials.  The material was combined in cubic yard boxes, which were labeled as Comp 12, for “Composite Sample 12”.   The crew continued sweeping in the northern rooms of the building, moving and clearing non-hazardous debris materials, and began shoveling the floor sweepings into cubic yard boxes. 

11/12/2015 - The crew completed waste bulking of the cyanide containing alkaline solids in Composite 12.  The chemist generated a new list of 25 drums with cyanide containing alkaline solids, and the crew began bulking the materials.  The material was combined in cubic yard boxes, which were labeled as Comp 13, for “Composite Sample 13”.  The crew continued sweeping in the northern rooms of the building, moving and clearing non-hazardous debris materials, and shoveling the floor sweepings into cubic yard boxes.  The crew received a shipment of 55-gallon open-topped drums for bulking sludge and solid materials.  The crew completed bulking the cyanide containing flammable, alkaline solids and sludge from Composite 21.

11/13/2015 – The crew continued bulking cyanide containing alkaline solids in Composite 13.  The crew also finished bulking the combustible sludge from Composite 19. The crew continued sweeping in the northern rooms of the building, moving and clearing non-hazardous debris materials, and shoveling the floor sweepings into cubic yard boxes. 

On 11/14/2015 and 11/15/2015, no site work occurred.  24-hour security was on site.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

Michner Plating Company is the potentially responsible party (PRP), however, the company relinquished ownership of the property to the Jackson County Treasurer's Office due to tax reversion and bankruptcy. The removal action is a Fund Lead as a result of the RP's bankruptcy and inability to finance the cleanup.

2.1.4 Progress Metrics

2.2.1 Anticipated Activities

 
Anticipated activities for the next reporting period include continuing to collect samples, performing hazard categorization of the samples collected from on-site containers, bucket compatibility tests for each waste bulking group, and the continuation of waste bulking.

2.2.1.1 Planned Response Activities

Inventory and perform hazard characterization on all substances contained in containers, drums, tanks and spilled material on the floor and in pits;

Investigate the potential for soil contamination on the property;

Consolidate and package all hazardous substances, pollutants and contaminants for transportation and off-site disposal;

Dismantle and decontaminate process equipment, tanks and building components associated with the product process area, as necessary;

Remove from site and recycle or dispose of vats and waste containers and contaminated process equipment;

Transport and dispose of all characterized or identified hazardous substances, pollutants, wastes, or contaminants that pose a substantial threat of release at a RCRA/CERCLA approved disposal facility in accordance with EPA's Off-Site Rule (40 CFR § 300.440);

Take any other response actions to address any release or threatened release of a hazardous substance, pollutant or contaminant that the EPA OSC determines may pose an imminent and substantial endangerment to the public health or the environment.

2.2.1.2 Next Steps

Continue to perform the planned response actions until cleanup is complete.

2.2.2 Issues

No issues to report at this time.

Site logistics are being managed by ERRS.

Permanent power has been established.