U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Advance Plating Works - Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
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Subject:
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POLREP #3
Progress PolRep
Advance Plating Works
C589
Indianapolis, IN
Latitude: 39.7152000 Longitude: -86.1417000
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To:
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From:
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Shelly Lam, On-Scene Coordinator
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Date:
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12/16/2011
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Reporting Period:
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December 13 - 16, 2011
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1. Introduction
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1.1 Background
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Site Number: |
C589 |
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Contract Number: |
EP-S5-09-05 |
D.O. Number: |
0082 |
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Action Memo Date: |
12/5/2011 |
Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
Response Lead: |
EPA |
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Incident Category: |
Removal Action |
NPL Status: |
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Operable Unit: |
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Mobilization Date: |
9/20/2011 |
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Start Date: |
9/20/2011 |
Demob Date: |
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Completion Date: |
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CERCLIS ID: |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
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FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Time-Critical Removal - Former plating shop
1.1.2 Site Description
The Site is the former Advance Plating Works. It was a family-owned business that operated on the south side of Indianapolis from 1912 to 2009. Former operations at the facility included nickel, chrome, zinc, cadmium, and copper plating.
The Site is 3 acres in size and includes two buildings, one of which was formerly used for plating operations and office space and a second building, which was used as a warehouse.
1.1.2.1 Location
The Site is located at 1005 E. Sumner Avenue in Indianapolis, Marion County, Indiana. Site coordinates are latitude 39.7152000 degrees north and longitude 86.1417000 degrees west. The facility is in an area of the south side of Indianapolis that is primarily industrial and commercial. However, there is a residential facility adjacent to the Site to the east and additional residential properties within a few hundred feet to the northeast.
1.1.2.2 Description of Threat
On September 20, 2011, the Marion County Public Health Department (MCPHD) responded to the Site based on abandoned building and trespassing complaints from the Indianapolis Metropolitan Police Department (IMPD). Upon arriving at the Site, MCPHD personnel observed 25-30 drums stored in poor condition outside the buildings. Additionally, MCPHD noticed that building doors were open and a section of fence had been removed to allow access for trespassing. MCPHD immediately requested assistance from the Indiana Department of Environmental Management (IDEM) and U.S. Environmental Protection Agency (EPA).
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
EPA On-Scene Coordinator (OSC) Shelly Lam responded to the Site on the afternoon of September 20th, where she met with representatives from MCPHD and the property owners. After obtaining access, OSC Lam conducted a reconnaissance and documented 75-100 drums, totes, plating vats and other containers inside and outside the facility buildings. Many drums were unlabeled. However, labeled drums included toxic, corrosive, oxidizing, and flammable materials. OSC Lam also documented that trespassing had been occurring and that trespassers had been cutting metal process piping above the plating vats.
EPA completed an inventory of drums and containers on September 22, 2011. EPA documented 164 drums, ten 275-gallon totes, hundreds of small containers, 6 plating vats, and 5 pits/sumps. Identified materials included sodium hydroxide, hydrogen peroxide, potassium cyanide, sodium cyanide, sulfuric acid, hydrocyanic acid, nitric acid, and paint thinner. Based on this information, OSC Lam determined that there was a threat to human health and the environment from abandoned drums, many of which were in poor condition and leaking. There was also a threat of fire or explosion from improperly stored flammable materials in a building where trespassing was occurring.
Analytical results from the Site Assessment verified that hazardous substances were present on-Site. EPA collected six samples from drums and a small container during the Site Assessment. Four samples exhibited a pH less than 2 standard units (SU) and one sample had a pH of 13.5 SU, meeting the characteristic of corrosivity per 40 Code of Federal Regulations (CFR) 260.22(a)(1). One sample had a flashpoint of 110 degrees Fahrenheit, which is below the characteristic for ignitability, per 40 CFR 261.21(a)(1). Total and reactive cyanide were detected in one sample at concentrations of 15,000 milligrams per kilogram (mg/kg) and 1,300 mg/kg, respectively.
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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 20, 2011, EPA responded to a request for assistance from MCPHD regarding abandoned drums at a former plating facility. EPA conducted emergency response operations from September 20 - 22, 2011, including segregating, staging, and securing drums. EPA signed an Action Memorandum on December 5, 2011 to complete time-critical removal activities including developing site plans such as a site-specific Health and Safety Plan (HASP), Emergency Contingency Plan, and work plan; inventorying and performing hazard categorization on substances contained in vats, pits, drums, and other containers; performing sampling and analysis to determine disposal options; dismantling and decontaminating process equipment and building components associated with plating operations; and consolidating and packaging hazardous substances, pollutants, and contaminants for transportation and off-Site disposal in accordance EPA's Off-Site Rule.
2.1.2 Response Actions to Date
During the reporting period, EPA conducted the following activities:
- Mobilized Superfund Technical Assessment and Response Team (START) and Emergency and Rapid Response Services (ERRS) contractors to the Site;
- Set up work spaces including command post, break trailer, and work zones;
- Arranged for electrical and water services to be restored for lighting, heat, and washing/decontamination activities;
- Completed small container inventory;
- Established Site security.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
Information on the PRP is in the Site file.
2.1.4 Progress Metrics
Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
Pending |
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R5 Priorities Summary |
Integrated River Assessment |
Miles of river systems cleaned and/or restored |
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Cubic yards of contaminated sediments removed and/or capped |
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Gallons of oil/water recovered |
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Acres of soil/sediment cleaned up in floodplains and riverbanks |
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Stand Alone Assessment |
Acres Protected |
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Number of contaminated residential yards cleaned up |
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Human Health Exposures Avoided |
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Number of workers on site |
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2.2 Planning Section
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2.2.1 Anticipated Activities
EPA will continue with removal activities during daylight hours on weekdays. EPA is securing the facility for non-operational overnight and weekend periods using a contracted security service. EPA will generate pollution reports for each operational period. The removal action is expected to last 2-3 months.
2.2.1.1 Planned Response Activities
During the next reporting period, EPA will conduct the following activities:
- Begin removing and containerizing wastes in vats in wastewater treatment area;
- Staging hazardous debris for disposal; and
- Restore electrical power to the Site.
2.2.1.2 Next Steps
Over the next few weeks, EPA will begin hazard characterization of the totes, drums, and smaller containers.
2.2.2 Issues
On December 13, 2011, EPA observed that trespassers had cut the chain link and barbed wire fence surrounding the Site. Trespassers had also removed a wooden fence panel to allow easier access to the hole in the chain link fence. Additionally, they pushed in an overhead garage door to allow access to the interior of the building. EPA repaired the fencing and garage door. Furthermore, security is present on-Site and has been instructed to patrol the facility to discourage trespassing.
EPA is in the process of restoring electrical power to the Site for work trailers and heaters. Heaters are necessary in the work zone for worker health and safety and to keep water lines for pressure-washing from freezing. Estimates for electrical connection have been much higher than anticipated due to extensive damage from vandalism and the age of the existing electrical equipment. The OSC has considered alternatives, such as generators. However, fuel costs for generators would exceed the cost for electrical restoration.
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2.3 Logistics Section
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2.3 Logistics
ERRS is providing logistical support including:
- Temporary worksite trailers;
- Bathroom facilities;
- Electrical contractors to restore power;
- Water and plumbing service;
- Trash service;
- Drinking water;
- Security contractors for non-operational hours overnight, weekends, and holidays;
- Temporary lighting inside the facility; and
- Temporary space heaters inside the facility to facilitate removal activities.
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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
OSC Lam is the overall Safety Officer for the response. EPA's contractors have prepared a health and safety plan. Additionally, all personnel are attending daily safety briefings.
2.6 Liaison Officer
Not applicable (NA)
2.7 Information Officer
2.7.1 Public Information Officer
EPA has not received any media requests. Joshua Singer is the Public Information Officer for the Site. The Office of Public Affairs (OPA) will issue a press release when time-critical activities are complete.
2.7.2 Community Involvement Coordinator
The community involvement coordinator is Susan Pastor, who has established a website and coordinated a fact sheet for distribution.
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3. Participating Entities
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3.1 Unified Command
NA
3.2 Cooperating Agencies
IDEM
MCPHD
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4. Personnel On Site
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The following personnel were on-Site during the reporting period.
Agency |
Position |
# Personnel |
EPA |
OSC |
2 |
ERRS |
Response Manager |
1 |
Foreman |
1 |
Equipment Operator |
1 |
Laborer |
1 |
START |
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1 |
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5. Definition of Terms
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CFR |
Code of Federal Regulations |
EPA |
Environmental Protection Agency |
ERRB |
Emergency Response and Removal Branch |
ERRS |
Emergency and Rapid Response Services |
HASP |
Health and Safety Plan |
IDEM |
Indiana Department of Environmental Management |
IMPD |
Indianapolis Metropolitan Police Department |
MCPHD |
Marion County Public Health Department |
mg/kg |
milligrams per kilogram |
NA |
Not Applicable |
OPA |
Office of Public Affairs |
OSC |
On-Scene Coordinator |
PolRep |
Pollution Report |
PRP |
Potentially Responsible Party |
START |
Superfund Technical Assessment and Response Team |
SU |
Standard Units |
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6. Additional sources of information
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6.1 Internet location of additional information/report
Refer to www.epaosc.org/advanceplatingworks and www.epa.gov/Region5/cleanup/advanceplating/ for additional information.
6.2 Reporting Schedule
The OSC will submit the next PolRep on December 23, 2011.
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7. Situational Reference Materials
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NA
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