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
On 10/18/2010, ERRS continued to clear space for a drum staging area by cutting RCRA empty drums and containers and placing the carcasses in a roll-off box for disposal. ERRS also removed any metal debris that was inhibiting clear access to drums, vats, and other containers. Metal debris was placed in a separate roll-off box for recycling. One load of scrap metal was hauled off site, and a replacement roll-off box was left on site. ERRS also mobilized a hazard characterization (haz cat) chemist and began to set up a laboratory hood, tables, and staging area for haz catting contents of full and partially full containers.
On 10/19/2010, ERRS continued cutting RCRA empty drums and other non-metal debris and placing it in a roll-off box for disposal at C&C Landfill in Marshall, Michigan. Metal debris was placed in a separate roll-off box for recycling. One load of RCRA empty drums and debris was hauled off site to be disposed of at C&C Landfill in Marshall, Michigan. ERRS began haz catting small containers from the laboratory area. ERRS started and tested the supplied air trailer. Phone and Internet service was established in the office trailers, and a windsock was installed.
On 10/20/2010, ERRS hazcatted approximately 50 small containers from the laboratory area. ERRS continued cutting RCRA empty drums and other non-metal debris and placing it in a roll-off box for disposal at a C&C Landfill in Marshall, Michigan. Metal debris was placed in a separate roll-off box for recycling. One load of scrap metal was hauled off-site, and a replacement roll-off box was left on-site.
On 10/21/2010, ERRS completed hazcatting the laboratory chemicals and continued cutting RCRA empty drums and scrap metal. ERRS continued cutting RCRA empty drums and other non-metal debris and placing it in a roll-off box for disposal at C&C Landfill in Marshall, Michigan. Metal debris was placed in a separate roll-off box for recycling.
On 10/22/2010, ERRS started sampling and hazcatting non-laboratory small containers. The supplied air trailer was used by the samplers. The RCRA empty drums/debris roll-off box was hauled off site to C&C Landfill in Marshall, Michigan, and the scrap metal box was removed and transported for recycling. Replacements were left for both.
Throughout the week, USCG performed health and safety oversight and conducted work zone air monitoring with a MultiRae. No readings elevated above background were reported and no safety incidents were noted.
START monitored the air around the perimeter of the facility with AreaRaes. HCN sensors were installed in the units, and they were operated while ERRS was in the work zone. No readings elevated above background were recorded. START also developed a field sampling plan for sampling that will occur during the first week of November 2010. START developed a Site Contingency Plan that was posted in office trailers and the two facility emergency exits. START also continued documentation and file keeping.
A reporter from the Battle Creek Enquirer was on-site on 10/20/2010. A front page news story was published in the Battle Creek Enquirer on 10/21/10 regarding the Removal Action at the Site.
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 and General Debris |
Solid |
30 CY |
0057 |
|
C&C Landfill |
RCRA Empty Containers and General Debris |
Solid |
30 CY |
0059 |
|
C&C Landfill |
RCRA Empty Containers and General Debris |
Solid |
30 CY |
0058 |
|
C&C Landfill |
Scrap Metal |
Solid |
40 CY |
N/A |
Recycled |
|
Scrap Metal |
Solid |
40 CY |
N/A |
Recycled |
|
Scrap Metal |
Solid |
40CY |
N/A |
Recycled |
|
|