1.1.1 Incident Category

Time Critical Removal Action

1.1.2 Site Description
The site is a former chemical plating facility, currently owned by the Kent County Land Bank. When the property tax reverted, historically accumulated plating wastes were abandoned in the building, and discovered by the Land Bank. 

1.1.2.1 Location

The site is located at 1516 Blaine Avenue SE, Grand Rapids, Kent County, Michigan 49507. The site totals approximately 1/4 acre, and contains a one story industrial building and an open lot. The site was recently occupied by the Hard Chrome Plating and HCP Finishing LLC companies, and tax reverted to the Kent County Land Bank in 2014.

1.1.2.2 Description of Threat

Actual or potential exposure to nearby human populations, animals, or the food chain from
hazardous substances or pollutants or contaminants.
The site is located in a mixed industrial/residential area. River Scholars School is located directly across the street, and 23,500 people live within 1 mile of the site. Approximately 160 drums, 14 tanks of hazardous waste and numerous small containers and lab chemicals are abandoned at the site. With limited building security, exposure could result from trespass, an accidental or intentional release, and/or fire.

Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other
bulk storage containers, that may pose a threat of release.
None of these containers identified at the site had secondary containment. Minor to moderate spillage/leaking was observed inside and outside of the building. The building shows signs of severe disrepair, with a leaking roof and broken windows.

Weather conditions that may cause hazardous substances, pollutants, or contaminants to
migrate or be released.
Grand Rapids averages 32 inches of annual precipitation per year, and winter temperatures are normally well below freezing. Weather conditions will continue to contribute to the deterioration of the building, and precipitation will continue to cause damage to drums and containers. The freezing of waste can lead to bulging and rupture of drums.

Threat of fire or explosion.
Because the building is abandoned, there is a high threat of fire at the site. Several containers are marked as flammable and oxidizers, and an EPA sample was found to be half the 140 °F flash point characteristic of ignitable hazardous waste. If a fire were to occur, it would have the potential to produce toxic gases, irritants, acidic-smoke, and contaminated fire-water runoff. The presence of approximately 160 drums likely containing characteristically toxic waste, combined with other debris increases the threat of fire.

The availability of other appropriate federal or state response mechanisms to respond to
the release.
No other federal or state response mechanism is available to respond in a timely manner given the exigencies of the situation.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

On August 3, 2015, EPA conducted a site assessment that confirmed approximately 160 drums, 14 vats, and a large number of small containers and lab chemicals at the site. Some of the drums show signs of deterioration, damage, and possible leaking. Labels on some containers indicated the potential presence of ammonium hydroxide, muriatic acid, sulfuric acid, nickel compounds, hydrochloric acid, sodium hydroxide, trioxochromium, chromium (IV) trioxide, copper sulfate, and other chemicals.

EPA collected 8 samples during the site assessment.  Analytical results were compared to the criteria set forth in 40 CFR Part 261 to determine whether the wastes stored at the site are considered hazardous.  The analytical results for all 8 samples, which are summarized below, indicated the presence of characteristically hazardous wastes at the site:

·     Arsenic, chromium, lead, and mercury levels as high as 140 milligrams/liter (mg/L), 120,000 mg/L, 1,100 mg/L, and 0.35 mg/L, respectively.  These results are above the hazardous waste levels for arsenic, chromium, lead, and mercury of 5.0 mg/L, 5.0 mg/L, 5.0 mg/L, and 0.2 mg/L, respectively.

·     The pH of one container sample and four tank samples were below 1, while the pH of one drum sample was 14.  A waste is considered hazardous, for corrosivity, if it has a pH less than or equal to 2 or greater than or equal to 12.5.

·   The flashpoint of one bucket sample was 71ºF.  A waste is considered hazardous, for ignitibility, if it has a flashpoint below 140ºF.

We are considering all containers to have unknown contents until further characterization  is completed.

2.1.1 Narrative

2.1.2 Response Actions to Date

2.1.2.1 Actions During Reporting Period

Over the week beginning the December 1, 2015 work focused primarily on the following activities:

- Project planning, setup, orientation and coordination
- Drafting and revising the site health and safety plan
- Drafting the site air monitoring plan, implementing air monitoring and setting up VIPER to report out results over the internet
- Finalizing and distributing the site emergency contingency plan to the local fire and police departments; the County Emergency Management Agency, Health Department and Land Bank; the hospital
- Finalizing and distributing a post card about the removal action to the neighborhood surrounding the site.
- Clearing perimeter debris from the site and non-hazardous debris within the building
- Implementing site security measures including fencing and signage
- Establishing the exclusion and contamination reduction zones 
- Establishing a staging area for containers 
- Reconnecting electricity to office area within building-Trial run depressurizing bulging drum and sampling in level B PPE

2.1.2.2 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 crew 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. 

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 Hard Chrome Metals Deployment to view site data.

Particulate Air Monitoring:
Datarams (DR4) are deployed daily at three fixed locations in each direction along the site perimeter boundaries where off-site receptors are most at risk to exposure from fugitive emissions, and at one location within the building in the work zone. Real-time PM-10 particulate data is transmitted back to the site command post where it is monitored continuously.

The perimeter action level for PM-10 particulates has been set at 150 micrograms per cubic meter (μg/m3), averaged over the work day. The work zone action level is 2.5 milligrams per cubic meter (mg/m3) averaged over the work day. Should a DR4 unit detect sustained particulate concentrations above the action levels, the source of emissions will be investigated, and administrative and/or engineering controls will be initiated to reduce the particulate emissions.

During the week of December 1, 2015, no exceedances of the perimeter or work zone action levels (calculated as work day averages) for particulates were detected. 


MultiGas Air Monitoring:
RAE Systems, Inc. AreaRAE multi-gas monitors are being deployed in the work zone in the building and at 3 perimeter locations during any chemical handling.  The AreaRAE multi-gas monitors will be used to monitor oxygen (O2) in percent, hydrogen sulfide (H2S) in ppm, hydrogen cyanide (HCN) in 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.

The perimeter action levels are as follows: ·         
H2S = 0.5 ppm
%LEL = >5%
VOCs > 5 ppm for 5 minutes 

HCN = 2.0 ppm

%O₂ – Less than 19.5% or greater than 23.5%

Work zone action levels are available in the Air Monitoring Plan (see documents section of epaosc.org/hardchromeplating).  

A MultiRAE Plus 5-gas monitor (loaded with sensors for detection of oxygen, carbon monoxide, hydrogen sulfide, LEL, and VOCs) will be used to monitor for carbon monoxide (CO) in ppm, and periodically spot check AreaRAE data.  Ammonia (NH₃₎ and HCN GasAlert monitors will also be used continuously in the work zone during chemical handling. 

Multigas monitoring was only conducted on December 4, 2015, as that was the only day that chemicals were handled. We are troubleshooting HCN and H2S problems on a couple AreaRAEs - they are indicating low levels of gas in the atmosphere. However, we double checked these readings with the MultiRAE and Gas Alert monitors and are not seeing any detections. We are working to correct the issue.

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

2.2.1 Anticipated Activities

2.2.1.1 Planned Response Activities

The following actions were planned in the action memorandum approved for the Hard Chrome removal action: 

a) Develop and implement a site health and safety plan;
b) Develop and implement an air monitoring plan; 
c) Develop a contingency plan for site work and distribute to local responders;
d) Develop and implement a work plan; and
e) Secure, characterize, remove, and properly dispose of the drums, containerized
wastes, spilled waste materials, and hazardous debris located at the site.

All hazardous substances, pollutants or contaminants removed off-site pursuant to this removal action for treatment, storage, and disposal shall be treated, stored, or disposed of at a facility in compliance with the EPA Off-Site Rule, 40 C.F.R. § 300.440, as determined by EPA.

The removal action will be conducted in a manner not inconsistent with the NCP. Elimination of threats presented by containerized and spilled hazardous substances is expected to eliminate the need for post-removal site actions.

2.2.1.2 Next Steps
Over the next week, we will begin work to stage containers, sample containers and categorize wastes.

2.2.2 Issues

3.1 Unified Command

3.2 Cooperating Agencies

Kent County Land Bank
MDEQ