Advance Plating Works

All POL/SITREP's for this site Advance Plating Works
Indianapolis, IN - EPA Region V
Progress PolRep
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Advance Plating Works - Removal Polrep

Region V

Subject: POLREP #7
Progress PolRep
Advance Plating Works
Indianapolis, IN
Latitude: 39.7152000 Longitude: -86.1417000

From: Shelly Lam, On-Scene Coordinator
Date: 1/27/2012
Reporting Period: January 23 - 27, 2012

1. Introduction
  1.1 Background
Site Number: C589    Contract Number: EP-S5-09-05
D.O. Number: 0082    Action Memo Date: 12/5/2011
Response Authority: CERCLA    Response Type: Time-Critical
Response Lead: EPA    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date: 9/20/2011    Start Date: 9/20/2011
Demob Date:      Completion Date:  
CERCLIS ID: INN000510649    RCRIS ID: IND985059898
ERNS No.:    State Notification:
FPN#:    Reimbursable Account #:

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.  Former operations at the facility included nickel, chrome, zinc, cadmium, and copper plating.  During an interview with the current owner's stepson on December 22, 2011, EPA learned that Advance Plating Works had been in business in 1912 but had only been at the current location since the 1970's.  Prior to ownership by Advance Plating Works, the Site was previously a slaughterhouse, cannery, and wax factory.

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. 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. 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 140 degrees Fahrenheit, meeting 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.

2. Current Activities
  2.1 Operations Section
    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 week of January 23rd, EPA conducted the following activities:

  • Pressure washed Zinc/Nickel Plating Room;
  • Cut up empty drums and other containers prior to disposal;
  • Dismantled and cleaned baghouse;
  • Transferred waste into shippable containers;
  • Bulked non-characteristic waste; 
  • Completed removal of fluorescent light bulbs and ballasts;
  • Found building's original water well in Polishing Room;
  • Collected one sample from the well for laboratory analysis;
  • Submitted one sample from the Base Liquid Oxidizer waste stream to the laboratory;
  • Conducted air monitoring using AreaRAEs and Single Point Monitors;
  • Conducted exploratory excavation in suspected burial area; and
  • Maintained Site security.

EPA conducted Green Initiatives during the removal action including recycling of paper, plastic, glass, aluminum, ink cartridges, and scrap metal.  EPA is also using alternative fuel in government vehicles and recycled paper products.

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
Hazardous waste solids Solid 20 yards MID000724831 Michigan Disposal Waste Treatment Plant

 R5 Priorities Summary
Integrated River Assessment 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 Acres Protected
Number of contaminated residential yards cleaned up 0
Human Health Exposures Avoided  
Number of workers on site  

  2.2 Planning Section
    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.  The removal action is expected to last 2-3 months. Planned Response Activities
EPA will shut down the site from January 30 - February 7, 2012, because EPA will be involved with Super Bowl operations.  EPA will resume operations the on February 8th.  Starting February 8th, EPA will conduct the following activities:

  • Bulk waste for disposal;
  • Continue waste disposal;
  • Finish removing fluorescent light bulbs and ballasts;
  • Pressure wash rooms within the facility;
  • Stage hazardous debris for disposal; and
  • Maintain Site security. Next Steps
EPA will dispose of waste in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Off-Site Rule. 

2.2.2 Issues

  2.3 Logistics Section
    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.

  2.4 Finance Section
    No information available at this time.

  2.5 Other Command Staff
    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 (HASP).  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.  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.

3. Participating Entities
  3.1 Unified Command

3.2 Cooperating Agencies

4. Personnel On Site
  The following personnel were on-Site during the reporting period.

Agency Position # Personnel
ERRS Response Manager 1
Foreman 1
Laborer 3
Field Cost Accountant 0
Chemist 1

5. Definition of Terms
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
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

6. Additional sources of information
  6.1 Internet location of additional information/report
Refer to and for additional information.

6.2 Reporting Schedule
The OSC will submit the next PolRep the week of February 6, 2012.

7. Situational Reference Materials

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