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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: |
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Completion Date: |
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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 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 includes an old shopping strip mall of approximately 20,000 square feet in size. The mall is divided into
eight store fronts. 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 is present at the Site. Thousands of gallons of paint, stains and other coatings products were abandoned at the Site. The wastes include containers with hazard markings for: flammable, corrosive, toxic or poisonous. Breaking and entering and trespassing in the site building has occurred. Electrical wiring has been partially removed and electrical service related fire hazards are located at the Site. A fire at the Site could lead to the offsite transport of hazardous substances, pollutants or contaminants by fire, smoke and wind action. Waste spills are present on the floor in the Site. Storm water drains are located on the Site. Storm water or fire suppression water runoff at the Site could enter storm water drains and discharge to Bean Creek approximately 0.5 miles away.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
On February 29, 2016, EPA 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 has maintained locked doors at the
Site; however, doors and windows had been broken out and doors and subsequently boarded by MCPHD to prevent access.
EPA 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 a walkway. 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. 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. As of this report, the following hazardous substances have been noted:
-Benzene
-2-Butanone (methyl ethyl ketone / MEK)
-Ethylbenzene
-Toluene
-Methyl Isobutyl Ketone
-Phosphoric Acid
-1,2,4 Trimethylbenzene
-Acetone
-n-Butyl Acetate
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2.1.1 Narrative
2.1.1.1 Current situation
EPA has mobilized ERRS and START contractors to conduct a time-critical removal action. The following plans govern removal actions at the Site:
-Emergency Contingency Plan (shared with public safety agencies)
-Site-specific health and safety plan (including daily safety meetings)
-Air Monitoring Plan
-Work Plan
Work hours are daily from 7AM to 5:30 PM. No work will be conducted overnight, on weekends or Federal holidays. Private security monitors the Site during non-working hours. The removal action is estimated to last five to seven weeks, including all process from preparing wastes for offsite transportation to the actual removal of wastes from the Site.
2.1.2 Response Actions to Date
Week of October 31 through November 4, 2016
-EPA mobilized the OSC and EPA contractors (ERRS and START)
-The OSC notified / met with public safety agencies.
-Secured the site with fencing and overnight security
-Established an onsite Field Office with signage
-Established work zones and erected waste staging shelter
-Assembled waste disposal containers (cubic yard boxes on skids)
-Began and completed removal of wastes in Suite 3150
-Wastes were brought outside the building, segregated and boxed by waste type
-Wastes are staged in temporary shelter pending offsite transportation
-Waste disposal options are being arranged
-Gathered additional information on hazardous substances at the Site
-Searching for information on potential responsible parties
START is conducting air monitoring for volatile organic compounds (VOC) in accordance with the Site Air Monitoring Plan. Monitoring is performed at the Site perimeter and work areas at various times during working hours. Perimeter readings are taken at four
locations, including one upwind location and three downwind locations. Work
area monitoring is conducted in the immediate work area five times a day, once
before work begins, twice in the morning and twice in the afternoon.
For this operational period, air monitoring at the perimeter has documented that peak
readings have not exceeded 0 parts per million (ppm). Peak readings in the
work area within the Site building were up to 10.1 ppm over October 31 to November 1. ERRS began using large fans to vent the Site building on November 2. The peak VOC reading in the work area since venting was 1.3 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
Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
Hazardous Liquids
(oil based) |
Liquid |
13 cubic
yard boxes |
TBD |
TBD |
TBD |
Non-hazardous Liquids
(water based) |
Liquid |
15 cubic
yard boxes |
TBD |
TBD |
TBD |
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