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

 10/26/15 – The chemist completed hazard categorization of samples.   Crews completed bulking flammable liquids and sludge from Comp 16, and continued bulking cyanide containing alkaline solids from the vats. The crew donned level B PPE to retrieve and transfer one drum in Comp 16, because the drum was located with a group of drums with high levels of HCN.  The chemist generated a new list of 25 containers with neutral liquids and sludge, and the crew completed waste bulking of the materials.  The liquid was combined in a 250-gallon tote, and sludge was combined in 55-gallon drums, which were labeled as Comp 17, for “Composite Sample 17”. 

10/27/15 – Crews continued bulking cyanide containing alkaline solids from the vats. Crews also completed bulking solids from Composite 2 (flammable solids) that were too hard and could not previously be transferred to new containers. Crews also began clearing out drums and containers in the northern portion of the warehouse building to make room for two roll-off dumpsters, which will be stored in the area.  The roll-off dumpsters will be used to dispose empty drums and containers after the contents are transferred. An EPA owned XRF and Hazmat ID-360 arrived onsite for use by the chemist with any additional hazard categorization or bucket bulking tests. Crews also received a shipment of 20 closed-topped poly drums, which will be used for bulking liquids.

10/28/15 – Crews continued bulking cyanide containing alkaline solids from the vats. The chemist generated a new list of 25 containers with alkaline liquids and sludge, and the crew began waste bulking of the materials.  The liquid was combined in a 250-gallon tote, and sludge was combined in 55-gallon drums, which were labeled as Comp 10, for “Composite Sample 10”. Crews received a small excavator, which will be used to break up very hard solid material. 

10/29/15 – Crews completed bulking alkaline liquids and sludge from Comp 10, and continued bulking cyanide containing alkaline solids from the vats.  USCG received a mechanical pump and air compressor, which will be used by the crew to transfer liquids. Crews also received 20 open-topped poly drums to be used for bulking.

10/30/15 - Crews continued bulking cyanide containing alkaline solids from the vats.  The chemist generated a new list of 13 containers with neutral liquids and sludge, and the crew completed waste bulking of the materials.  The liquid was combined in a 250-gallon tote, and sludge was combined in 55-gallon drums, which were labeled as Comp 8, for “Composite Sample 8”.  Two roll-off dumpsters arrived onsite.  The chemist conducted  bucket bulking compatibility tests.

On 10/31/2015 and 11/1/2015, no site work occurred.  24-hour site 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.