U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Pickens Plating - Removal Polrep
Initial Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
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Subject:
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POLREP #1
Initial
Pickens Plating
MIN000510460
Albion, MI
Latitude: 42.2521035 Longitude: -84.7757838
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To:
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Gregg Brettmann, MDNRE
Carol Ropski, U.S. EPA
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From:
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Jeff Lippert, OSC
John Rogers, OSC
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Date:
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10/14/2010
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Reporting Period:
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10/12/10 - 10/15/2010
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1. Introduction
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1.1 Background
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Site Number: |
B5XE |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
9/2/2010 |
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: |
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Mobilization Date: |
10/12/2010 |
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Start Date: |
10/13/2010 |
Demob Date: |
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Completion Date: |
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CERCLIS ID: |
MIN000510460 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
Yes |
FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Time Critical Removal Action per request of the City of Albion and Calhoun County, Michigan.
1.1.2 Site Description
The Site consists of a 4-acre parcel bordered by industrial properties to the south and west, wooded and open land to the north, agricultviral land to the east, and residential properties to the northeast. The Site is the former location of Pickens Plating, an electroplating business specializing in zinc plating. The Site includes one main building with multiple additions.
1.1.2.1 Location
The Site is located at 1000 Industrial Boulevard in Albion, Calhoun County, Michigan, 49224, in a mixed residential/industrial/agricultural area. Coordinates for the Site are 42.2551 degrees north and -84.7753 degrees west.
1.1.2.2 Description of Threat
The building at the Site was found to contain uncontrolled hazardous wastes (containers labeled chromic acid, nitric acid, sodium hydroxide, hydrogen peroxide, and hydrofluoric acid). Numerous vats, drums, and small containers of various sizes were found opened and unlabeled both inside the buildings and around the grounds. U.S. EPA quantified containers on-site that could potentially contain over 100,000 gallons of uncontrolled and unidentified liquid wastes. Four waste liquid samples were collected yielding pH results that are characteristically hazardous or TCLP levels that are characteristically toxic. The site has over 40 open vats of plating chemicals that had pHs which are considered characteristically hazardous.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
U.S. EPA conducted an assessment at the Site on June 4, 2010. The site assessment entailed the collection of four liquid samples and one solid sample. Both the solid and liquid samples were analyzed for pH. Corrosive substances in drums, containers and vats were sampled and returned with pHs as low as 0.8 standard units (su) and as high as 12.5 su. Both levels are considered characteristically hazardous. Numerous drums labeled "hydrofluoric acid" were also present in the building. These drums were not opened during the Site Assessment due to the extreme hazard they present for inhalation and skin absorption. Fumes from stainless steel drums labeled as "nitric acid" produced a pH of 0.0 su on field equipment.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
On September 2, 2010 the Action Memo was approved to expend up to $1,039,042 to conduct a time-critical removal action at the Pickens Plating Site. Corrosive substances in drums, containers and vats were sampled and returned with pHs as low as 0.8 standard units (su) and as high as 12.5 su. Both levels are considered characteristically hazardous. Numerous drums labeled “hydrofluoric acid” were also present in the building. These drums were not opened during the Site Assessment due to the extreme hazard they present for inhalation and skin adsorption. Fumes from stainless steel drums labeled as “nitric acid” produced a pH of 0.0 su on field equipment. The site has over 40 open vats of plating chemicals that had pHs which considered characteristically hazardous.
The floors of the building were in poor condition and showed numerous signs of chemical spills. Staining on the floor indicated years of waste accumulation from general operation and poor house keeping on-site.
The building is unwatched and fairly secluded with no perimeter fencing to keep out prospective vandals and scavengers. Leaks in the roof in many locations will lead to premature corrosion of containers within the building, increasing the chance for a release of these substances. The rain water from the leaky roof also has the potential to enter open-top acid vats and react, causing an airborne vapor release.
2.1.2 Response Actions to Date
a) Mobilization to Site;
b) Hooked up water and electricity;
c) Established the contamination reduction zone;
d) Office trailers, portable toilets, and municipal waste dumpster delivered to Site;
e) Began consolidating empty containers, cutting them in half, and disposing of them;
f) Began removing and disposing of non-hazardous waste;
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The title search report and information obtained from Calhoun County indicate that the current
owner of the Site is the Calhoun County Treasurer's Office. U.S. EPA will obtain an appraisal of the property to ascertain its value. Depending on the value of the property (and whether Calhoun County has Bona Fide Prospective Purchaser (BFPP) status under CERCLA), U.S. EPA may place a lien on the property, pursuant to CERCLA sections 107(1) or 107(r). A 104(e) information request may also be sent to a representative of the dissolved corporation, to discover whether assets were transferred from the corporation within the clawback period established by relevant Michigan law. If substantial assets were transferred from the corporation within the clawback period, U.S. EPA will attempt to capture those assets to offset the costs of the response action.
2.1.4 Progress Metrics
Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
RCRA Empty Containers |
Solid |
30 CY |
0057 |
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C&C Landfill |
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2.2 Planning Section
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2.2.1 Anticipated Activities
a) Telephone and internet connection established;
b) Continue RCRA empty container disposal;
c) Begin full and partially full container inventory;
d) Distribute fact sheet to local community.
2.2.1.1 Planned Response Activities
a) Inventory and perform hazard characterization, in compliance with a site-specific QA/QC
Plan, on all substances contained in containers, drums, and vats;
b) Consolidate and package all hazardous substances, pollutants and contaminants for
transportation and off-site disposal;
c) Dismantle and/or decontaminate contaminated structures as necessary;
d) Transport and dispose of all characterized or identified hazardous substances, pollutants,
wastes, or contaminants that pose a substantial threat of release at a RCRA/CERCLAapproved
disposal facility in accordance with U.S. EPA's Off-Site Rule (40 CFR §
300.440).
e) Decontaminate or remove highly contaminated facility flooring.
f) 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
N/A
2.2.2 Issues
Wildlife that has inhabited portions of the Site building.
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2.3 Logistics Section
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Not applicable
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer U.S. EPA, Jeff Lippert, OSC
2.6 Liaison Officer Not applicable
2.7 Information Officer
2.7.1 Public Information Officer
Jayna Legg
2.7.2 Community Involvement Coordinator
Janet Pope
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3. Participating Entities
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3.1 Unified Command Not Applicable.
3.2 Cooperating Agencies City of Albion Public Services
City of Albion Economic Development Corporation
Calhoun County Treasurer's
Michigan Department of Natural Resources and Environment
U.S. Coast Guard
U.S. EPA
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4. Personnel On Site
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U.S. EPA-2
U.S. Coast Guard-2
START-1
Environmental Quality Management-3
Inland Waters of Ohio-4
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5. Definition of Terms
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U.S. EPA - United States Environmental Protection Agency
USCG - United States Coast Guard
START - Superfund Technical Assessment and Response Team
ERRS - Emergency and Rapid Response Service
NCP - National Contingency Plan
CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act
RCRA - Resource Conservation and Recovery Act
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6. Additional sources of information
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6.1 Internet location of additional information/report None.
6.2 Reporting Schedule Polreps will be issued weekly.
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7. Situational Reference Materials
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NCP
CERCLA
RCRA
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