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Site Number: |
C5AY |
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Contract Number: |
EP-S4-16-02 |
D.O. Number: |
BA5-12 |
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Action Memo Date: |
8/29/2016 |
Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
Response Lead: |
EPA |
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Incident Category: |
Removal Action |
NPL Status: |
Non NPL |
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Operable Unit: |
N/A |
Mobilization Date: |
10/31/2016 |
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Start Date: |
10/31/2016 |
Demob Date: |
12/1/2016 |
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Completion Date: |
12/1/2016 |
CERCLIS ID: |
INN000506173 |
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RCRIS ID: |
INR000142760 |
ERNS No.: |
N/A |
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State Notification: |
IDEM Notified |
FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Time-critical removal action - closed paint store, abandoned paint related wastes
1.1.2 Site Description
1.1.2.1 Location
The Bethel Avenue Paint Site is located at 3150 Bethel Avenue, Indianapolis,
Marion County, IN (39.741283 latitude, -86.110395 longitude). The Site included an old shopping strip mall of approximately 20,000 square feet in size. The mall was divided into
eight store fronts of which paint wastes were abandoned in 4 storefronts (suites). The Site is owned by a religious organization (Church) whose information is recorded in the Site file.
The Site is located in a mixed use area southeast of
downtown Indianapolis. The population within a half mile is approximately 9,457
people. The Site is bordered on the north by a low income neighborhood (former
Habitat for Humanity target area), on the east by a religious center and
school, on the south by residential housing and on the west by a cemetery and
city park. The nearest waterway is Bean Creek approximately 0.5 miles to the
southeast. Bean Creek is a tributary of Pleasant Run and White River.
1.1.2.2 Description of Threat
The threat of release of hazardous substances or pollutants or contaminants was present at the Site. Thousands of gallons of ignitable wastes (oil base paints, stains and resins), corrosive wastes (acids, caustics) and other coatings products were abandoned at the Site. The wastes included containers with the hazard labels: flammable, corrosive, toxic or poisonous.
Breaking and entering and trespassing in the Site building had occurred. Electrical wiring was partially removed from the Site building causing fire hazards in areas where ignitable, oil based wastes were stored. Containers of wastes were severely corroded and crushed under large piles and spills of ignitable wastes were pooled on the floor. A fire at the Site could lead to the offsite transport of hazardous substances, pollutants or contaminants by fire, smoke and wind action and by surface runoff. Storm water drains are located adjacent to the Site building. Storm water runoff flows to Bean Creek approximately 0.5 miles away.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
On February 29, 2016, the EPA On-Scene Coordinator (OSC) conducted an initial site visit with representatives from the Church, Indianapolis Fire Department (IFD), Marion County Public Health Department (MCPHD) and Indiana Department of Environmental Management (IDEM). The Church representative maintained locked doors at the
Site; however, doors and windows had been broken out and doors and subsequently boarded by MCPHD to prevent unauthorized access.
During the site visit, the OSC observed tall stacks and piles
of paints, stains and other coating materials inside the Site building. Three
of four suites containing paints and stains were filled with containers such that little to no space was
left for walking through the Suite. The roof was open or collapsing in areas and containers
were subject to precipitation and weathering. Rusted and leaking metal containers were present. Spilled materials were visible on the floor.
Containers included small cans up to 5-gallons and rusting
metal cans and containers with damaged or missing labels. Container labels that
were present included markings for flammable liquids, corrosives and poison or
toxic materials.
The IFD representative identified electrical wiring in the
building had been dismantled and temporary lighting had been installed. The
temporary wiring included open wiring junctions that do not meet fire code
requirements and would be a potential fire hazard if the lines were energized
with electricity. (During removal actions, EPA later confirmed electrical wiring was still energized where ignitable waste spills were stored.)
During the February 29, 2016 site visit, the Church representative advised that the Church does not
have the financial resources to stabilize the storage conditions or
dispose of the abandoned wastes.
IFD, MCPHD and IDEM verbally requested EPA assistance for the removal of hazardous substance at the Site.
On March 1, 2016, IFD notified EPA that a (fire fighting) Hazard File had been established for the Site. The Hazard File states that the Site building has no working fire alarm or sprinkler system, contains large quantities of oil based paints and stains, and a working fire at the Site would present a clear danger to fire fighters.
On March 4, 2016, MCPHD submitted a written request for EPA assistance for the disposal of hazardous substances at the Site. The request stated the Site contains large amounts of hazardous substances, unknown substances and possible public safety and environmental threats.
On March 5, 2016, IDEM submitted a written referral of the Site to EPA for a removal action. The referral stated the Site contains hundreds of containers of 5-gallons or less and a building roof that is collapsing and IDEM does not have the resources to conduct the removal action.
On April 22 and May 27, 2016, EPA and EPA's Superfund Technical
Assessment and Response Team (START) contractor conducted an assessment at the
Site. The assessment included collection of liquid samples for lab analysis and
a container inventory. A site assessment report summarizes findings of the
assessment. A total of nine liquid samples, including two duplicates, were
collected during the assessment. The analytical results documented:
• Samples
BP-1, BP-3, BP-7 and BP-8 had the pH of (standard units): 1.57; 13.5; 1.61; and
0.54. These results exhibit the characteristic of corrosivity as defined by 40
C.F.R. § 261.22.
• Samples
BP-1 and BP-2 had flashpoint temperatures of 102 and 112 degrees Fahrenheit.
These results exhibit the characteristic of ignitability as defined by 40 C.F.R.
§ 261.21.
• Sample
BP-9 documented the presence of the hazardous substances benzene and methyl
ethyl ketone at 27 parts per million (ppm) and 290 ppm, respectively.
START conducted an inventory of containers on May 27th,
2016. START documented approximately 2,520 quarts, 6,858 gallon containers, and
1,175 5-gallon containers of paint, stains, sealers, and strippers.
On October 31, 2016, EPA and EPA contractors began a removal action at the Site and START began documenting various hazardous substances on container labels at the Site. The following hazardous substances were noted on container labels:
-Benzene
-Ethylbenzene
-Toluene
-Xylene (mixed isomers)
-1,2,4 Trimethylbenzene
-2-Butanone (methyl ethyl ketone / MEK)
-Methyl Isobutyl Ketone
-Acetone
-n-Butyl Acetate
-Hexavalent Chromium [Chromium(VI)]
-Methanol
-Manganese chloride (MnCl2), tetrahydrate
-Sodium dichromate
-Hydrochloric Acid
-Phosphoric Acid
-Sulfuric Acid (D002)
-Liquids meeting the characteristic for corrosivity, including liquids with pHs of 1 standard units (SU) and 13 SU (D002)
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2.1.1 Narrative
On October 31, 2016, EPA mobilized ERRS and START contractors to conduct a time-critical removal action. The following plans governed removal actions at the Site:
-Emergency Contingency Plan (shared with public safety agencies)
-Site-specific health and safety plan
-Air Monitoring Plan
-Work Plan
Removal actions were conducted weekdays from 7AM to 5:30 PM. No work was conducted overnight, on weekends or during Federal holidays. Private security services monitored the Site during all non-working hours. The removal action lasted five weeks and concluded when the final shipment of waste was transported offsite December 1, 2016.
2.1.2 Response Actions to Date
For actions conducted prior to this period, see prior Pollution Reports (POLREP) at www.epaosc.org/bethelavepaint.
For the week of November 28 through December 1, 2016:
-All paint related waste containers were removed from the Site building, including Suites: 3150, 3146, 3142, and 3138.
-Paint related waste spills in the Suites were absorbed and placed into waste containers for disposal.
-Waste disposal profiles were established for all waste streams.
-Wastes were segregated by waste stream, labeled and staged in a temporary on-site shelter pending offsite transportation.
-Two semi-truckloads of wastes were shipped offsite for disposal on: November 29 and December 1, 2016.
-The Site was secured 24 hours a day until all wastes were shipped offsite.
-EPA and EPA contractors demobilized from the Site.
The OSC conducted air monitoring for volatile organic compounds (VOC). For this operational period, peak readings in the
work area within the Site building were up to 3.50 ppm.
Air Monitoring Peak Readings |
November 28 to December 1 |
Activity |
Peak Reading |
Perimeter Air Monitoring |
0 ppm |
Work Area Monitoring |
3.50 ppm |
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
EPA has assembled an enforcement team consisting of the OSC, an enforcement specialist and attorney. The team has identified one potentially responsible party and issued a General Notice Letter. The team continues to collect information on two additional parties.
2.1.4 Progress Metrics
Regional Metrics |
This is an Integrated River Assessment. The numbers should
overlap. |
Miles
of river systems cleaned and/or restored |
NA |
Cubic yards of contaminated sediments removed
and/or capped |
NA |
Gallons of oil/water recovered |
NA |
Acres of soil/sediment cleaned up in
floodplains and riverbanks |
NA |
Stand Alone Assessment |
Number
of contaminated residential yards cleaned up |
NA |
Number of workers on site |
7 |
Contaminant(s)
of Concern |
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Oil
Response Tracking |
Estimated volume |
Initial
amount released |
NA |
Final amount collected |
NA |
CANAPS Info |
FPN
Ceiling Amount |
NA |
FPN Number |
NA |
Body of Water affected |
NA |
Administrative
and Logistical Factors (Place X where applicable) |
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Precedent-Setting HQ
Consultations (e.g., fracking, asbestos) |
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Community
challenges or high involvement |
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Radiological |
x |
More than one
PRP |
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Endangered
Species Act / Essential Fish Habitat issues |
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Explosives |
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AOC |
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Historic
preservation issues |
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Residential
impacts |
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UAO |
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NPL
site |
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Relocation |
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DOJ involved |
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Remote
location |
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Drinking
water impacted |
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Criminal
Investigation Division involved |
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Extreme
weather or abnormal field season |
x |
Environmental
justice |
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Tribal
consultation or coordination or other issues |
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Congressional
involvement |
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High
media interest |
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Statutory
Exemption for $2 Million |
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Statutory
Exemption for 1 Year |
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Active
fire present |
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Hazmat Entry
Conducted – Level A, B or C |
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Incident
or Unified Command established |
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Actual
air release (not threatened) |
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Green
Metrics |
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Metric |
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Amount |
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Units |
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Diesel Fuel Used |
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199.69 |
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gallons |
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Unleaded Fuel Used |
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719.51 |
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gallons |
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Alternative/E-85 Fuel Used |
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0 |
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gallons |
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Electricity from electric company |
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0 |
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kWh |
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Electric Company Name and Account # |
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NA |
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Electricity from
sources other than the electric company |
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8500 |
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kWh |
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Solid waste reused |
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NA |
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NA |
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Solid waste recycled |
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NA |
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NA |
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Water Used |
|
50 |
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gallons |
Waste Metrics Table |
Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
Ignitable Paint Related Waste (D001, oil based) |
Liquid |
12 x 1 cubic
yard boxes |
016566969JJK |
Solvent recovery /
Fuels blending |
Chemtron
Avon, Ohio |
12 x 1 cubic
yard boxes |
016567018JJK |
12 x 1 cubic
yard boxes |
016567094JJK |
14 x 1 cubic
yard boxes |
016567127JJK |
14 x 1 cubic
yard boxes |
016567154JJK |
3 x 1 cubic
yard boxes |
016567190JJK |
Water Based Paint Related Waste |
Liquid |
12 x 1 cubic
yard boxes |
016566969JJK |
Solidification and landfilling |
Chemtron
Avon, Ohio |
12 x 1 cubic
yard boxes |
016567018JJK |
12 x 1 cubic
yard boxes |
016567094JJK |
12 x 1 cubic
yard boxes |
016567127JJK |
14 x 1 cubic
yard boxes |
016567154JJK |
6 x 1 cubic
yard boxes |
016567190JJK |
Solid Waste |
Solid |
3 x 20 cubic
yard
roll off dumpster |
NA |
NA |
Twin Bridges Landfill
Danville, Indiana |
Ignitable Resin / Catalyst Related Waste (D001) |
Liquid |
10 x 1 cubic
yard boxes |
016567190JJK |
Incineration |
Chemtron
Avon, Ohio |
Ignitable Paint Related
Waste containing Zinc (D001)
|
Liquid |
2 x 55 gallon
drums |
016567190JJK |
NA |
Chemtron
Avon, Ohio |
Ignitable Amine-containing Catalyst Related Waste (D001) |
Liquid |
1 x 55 gallon
drum |
016567190JJK |
NA |
Chemtron
Avon, Ohio |
Phosphoric Acid (D002) |
Liquid |
1 x 55 gallon
drum |
016567190JJK |
NA |
Chemtron
Avon, Ohio |
Corrosive Waste containing Hydrochloric Acid and Hexavalent Chromium (D002)
|
Liquid |
1 x 55 gallon
drum |
016567190JJK |
NA |
Chemtron
Avon, Ohio |
Sulfuric Acid (D002) |
Liquid |
1 x 55 gallon
drum |
016567190JJK |
NA |
Chemtron
Avon, Ohio |
Corrosive Waste (D002,
peel away stripper) |
Liquid |
1 x 55 gallon
drum |
016567190JJK |
NA |
Chemtron
Avon, Ohio |
Sodium Hydroxide (D002) |
Liquid |
1 x 5 gallon
bucket |
016567190JJK |
NA |
Chemtron
Avon, Ohio |
Ignitable Paint Related Waste containing Aluminum (D001) |
Liquid |
1 x 5 gallon
bucket |
016567190JJK |
NA |
Chemtron
Avon, Ohio |
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