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

ERRS re-mobilized a skeleton crew to the site on 02/15/2016 to begin site setup and receive equipment deliveries, including a skidsteer, mini-excavator, light plants, generators, and a roll-off dumpster.

02/22/2016 – ERRS mobilized additional crew members to site.  EPA, 2 USCG personnel, and one START member mobilized to the site.  The crew continued site setup, including uncovering boarded up doors and unlocking the site buildings.  The chemist generated a list of 59 containers with neutral solids and sludge, and the crew began waste bulking the materials in a roll-off dumpster.

02/23/2016 – The crew continued waste bulking the neutral solids in the roll-off dumpster. The chemist also generated a list of 23 containers with hazardous neutral solids, and the crew began staging the containers in the northern portion of the building. The materials will be waste bulked in a separate roll-off dumpster next week. 24 hour security was re-established at the site during non-working hours due to repeated trespass at the site.

02/24/2016 – The crew continued waste bulking the non-hazardous neutral solids in the roll-off dumpster. The chemist also generated a list of 6 containers with slightly water reactive solids and sludge. The crew transferred each material to a separate 55-gallon drum and stabilized the waste. 

02/25/2016 – The chemist added 5 containers with non-hazardous neutral solids to the previous list, and the crew completed waste bulking the materials in the roll-off dumpster.  The crew also mixed neutral sludge and liquids in an empty vat, and added inert solids to dry the mixture.  After the material was dry, the crew blended the material into the roll-off dumpster. 

02/26/2016 – The crew swept and shoveled floor debris from the northern and central portions of the building and loaded the debris into cubic yard boxes. The roll-off dumpster containing non-hazardous neutral solids was removed from the site and transported for disposal at C&C Landfill located at 14800 North P Drive, Marshall Michigan.

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 PRP's bankruptcy and inability to finance the cleanup.

2.1.4 Progress Metrics

2.2.1 Anticipated Activities

Work has resumed. The crew will be working next on hazardous neutral solids and bulking mineral acids. 

2.2.1.1 Planned Response Activities

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

Additional budget is required to complete the Time-Critical Response Actions and has been requested and is within the Action Memorandum Ceiling.  At this time, the OSC is awaiting allocation of the additional funds for the project. 

Site logistics are being managed by ERRS.

Permanent power has been established.

3.1 Unified Command

No Unified Command.  This is a Time-Critical Response directed by EPA, not an ICS incident.

3.2 Cooperating Agencies

Jackson County Treasurer's Office
City of Jackson Water Department
Michigan Department of Environmental Quality (MDEQ)