Time-Critical Removal Action:  Manufacturing/Processing/Maintenance – Electroplating, Metal Finishing

Baycote Metal Finishing (Baycote or the Site) began operation in 1982.  The facility electroplated and anodized steel and steel casings with zinc, cadmium, and chromium for the automotive, recreational vehicle, and trailer industries.  The facility ceased operations in January 2008, however, according to facility records approximately 111,000 gallons of waste remained on site at the time.  In October 2009, the Indiana Department of Environmental Management (IDEM) and the owner of the site entered into an Order to remove and dispose of all hazardous waste.  However, work ceased and in February 2010, approximately 50,000 gallons of waste remained on-site.

1.1.2.1 Location

The Baycote Metal Finishing Site is located at 1302 Industrial Drive in Mishawaka, St. Joseph County, Indiana 46544.  The geographical coordinates for the Site are 41°39’0.03” North latitude and 86°09’57.11” West longitude.  The Site is bordered by industrial properties to the north, east, and south and Industrial Drive and industrial properties to the west.  Residential properties are located approximately 700 feet to the west.  Seven churches and two schools are located within 1 mile of the Site. The St. Joseph River, a major surface water body that terminates in Lake Michigan, is located 0.85 mile northwest of the Site. 

1.1.2.2 Description of Threat

Abandoned and unknown waste in vats, pits, tanks, drums and containers was located throughout the building.  Many vats, pits, tanks and containers are open with contents exposed.  Animal prints were observed in material piles on the building floor.  Several drums are corroded and leaking onto the floor.  Evidence of previous spills was noted in several areas.  The building is in a deteriorating condition; a section of roof in the Wastewater Treatment Room had collapsed, exposing the room and its contents to weather.  Due to the roof collapse and holes in the roof in other areas, rain water has accumulated in several sections of the building.  Vats, totes, and containers that contain incompatible wastes (acids, caustics, cyanides) are present inside the facility.  Based on these conditions, nearby populations and the environment could be exposed to potentially hazardous materials if contaminants migrate off site.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results  

U.S. EPA On-Scene Coordinators (OSCs) Theresa Holz and Jacob Hassan conducted a Site visit on November 21, 2011, with the St. Joseph County Health Department (SJCHD).  During the visit, the OSCs documented numerous tanks, drums, containers and spilled material on the floor.  The OSCs also observed containers labeled as acid, chromate, nitrate, hexavalent chrome, and cyanide.  The Site was in disrepair, with a portion of the roof collapsed inside the facility.    The containers were not organized, secured, or maintained in a manner necessary to prevent spillage, inter-mixture of potentially flammable or combustible materials, and/or release.  The containers also were not all properly or sufficiently labeled or identified, for safety purposes.

On December 12 and 13, 2011,  U.S. EPA performed a Site Assessment including sample collection. The Site Assessment documented numerous drums, plating vats, pits, tanks, small containers, and spilled material.  Drums and containers were labeled as acid, chrome, and caustic.  Numerous plating vats and other process equipment were documented inside the building. 

Analytical results documented reactive cyanide and total cyanide at concentrations of  up to 30,000 mg/l  and verified the presence of a characteristic of a hazardous waste for reactivity (D003).

Analytical results from liquid samples documented pH values of less than 2.  and represent waste that meets the definition of characteristically hazardous waste for corrosivity (D002) because the pH value is less than or equal to 2 standard units (SU) or greater than or equal to 12.5 SUs. 

Analytical results from solid samples also found concentrations which exceeded the TLCP regulatory limits for Chromium and Cadmium, indicating that characteristically hazardous wastes representing those two metals are present at the Site.  Results also found characteristic hazardous waste based on exceedence of the ignitability criteria.

In a letter dated November 11, 2011, the St. Joseph County Health Department (SJCHD) requested assistance from the U.S. EPA to secure hazardous wastes left on-site.  SJCHD was concerned that the Site posed a significant threat to the health and safety of companies within the industrial park as well as the residential area located less than a 1,000 feet from the facility.  On February 23, 2012, the Director of U.S. EPA's Superfund Division approved an Action Memorandum approving funding for a time-critical removal action at the Baycote Metal Finishing Site.

In a letter dated November 11, 2011, the St. Joseph County Health Department (SJCHD) requested assistance from the U.S. EPA to secure hazardous wastes left on-site.  SJCHD was concerned that the Site posed a significant threat to the health and safety of companies within the industrial park as well as the residential area located less than a 1,000 feet from the facility.  On February 23, 2012, the Director of U.S. EPA's Superfund Division approved an Action Memorandum approving funding for a time-critical removal action at the Baycote Metal Finishing Site.

On April 6, 2012, U.S. EPA issued a Unilateral Administrative Order to the potentially responsible parties to conduct a removal action at the Site.  The potentially responsible parties presented and inability to pay argument and indicated that they did not intend to conduct a removal action at the Site.  EPA began time-critical removal actions at the Baycote Site on May 29, 2012. 

This is a large Site, with 11 plating lines in 6 areas and an onsite waste water treatment plant with a collapsed roof.  The OSC and its contractors have adopted a work plan to cleanup one area/plating line at a time, starting with the most contaminated while ensuring safety and efficiency.

 
2.1.2 Response Actions

Please refer to previous Polreps for response actions before July 2, 2012.

During the reporting period, EPA conducted the following activities:

-  Additional containers in Areas A and B have been identified, marked, measured, and are in the process of being sampled for hazardous categorization for disposal. 

-   Request for Proposal was sent out and Bids are being evaluated for the transportation and disposal of the bulk of cyanide and acid hazardous waste identified at the Site. 
 
-  Cleanup work is 100% complete in the first three plating lines heavily contaminated with Cyanide (aka Area U on Lines 5,6,9 ) All the vats have been removed and decontaminated with all sludge, cyanide liquid and containerized for disposal. Acid wastes were also containerized separately for disposal.  Sumps in this area have been pumped out and cleaned out. Air control units were left in place due to its potential structural damage to the roof is removed. 

-  Cleanup work has been initiated in Area A., 15 vats containing acid wastes have been cleaned out and their contents secured in drums and cubic yard boxes.  In addition, approximately 8 drums of sludge and 1 cubic yard of solids  were removed from the vats' secondary containment.  

-  Cleanup work has been initiated in Area B and H to clear out debris for removal work.

-  EPA and START continued to conduct site perimeter and work area air monitoring to ensure worker and community protection.

-  One hazardous debris box and 1 solid waste debris box were shipped off-site for disposal. 
  
-  Additional totes, drums, and other containers holding hazardous wastes to be disposed are being stored in Area J and R (See update list in Section 2.1.4).
 
-  EPA and its contractors is implementing Green Practices onsite (double sided printing, dedicated water bottles, dedicated steel toed boots, city electical power, etc...)



2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

Information on the PRP is in the Site file.  Enforcement strategies are included in a confidential enforcement memorandum.

The following waste has been staged and ready for disposal as of July 13, 2012

2              55-gallon drums of Haz basic vat bottom sludge

5              330-gallon totes of Haz cyanide containing liquid

10           55-gallon drums of Haz cyanide containing vat bottom sludge

4            cubic-yard boxes of Haz cyanide solids

2              95-gallon overpacks of Haz cyanide solids

13              cubic-yard boxes of Haz solids

16         330-gallon totes of Haz acid liquid

27           55-gallon drums of Haz neutral liquid

34           RCRA-empty vats (various sizes)

36           330-gallon tote metal frames (poly portion has been cut apart and placed in roll-offs)

Removal activities on Site will include:

1.  Continue cleanup in plating Lines 1-2-3 in Area A.  This room is heavily contaminated with acids and cyanides;
2. Continue cleanup in plating lines 8-15 in Area B.
3. Recycle RCRA empty containers.
4. Continue to consolidate and package hazardous substances, pollutants, and contaminants for  
             transportation and off-site disposal;
5. Evaluate bids to determine disposal options/facility.  
6. Dismantle and decontaminate process equipment and building components associated with
             the plating areas, as necessary;
7. Transport and dispose of all characterized or identified hazardous substances, pollutants, or 
             contaminants to a RCRA/CERCLA-approved disposal facility in accordance with U.S. EPA 
             Off-Site Rule (40 CFR § 300.440)
8. Site Work plan and schedule have been submitted and will continue to be adjusted as needed.  Work is planned to continue the end of Oct. 2012 with an estimated budget of about $1,000,000.

2.2.1.2 Next Steps

Cleanup of the plating shop and off-site disposal of wastes is anticipated to take approximately 6 months to complete.  When time-critical removal actions are completed, EPA will refer the Site to the Indiana Department of Environmental Management (IDEM). 

During the week of July 17, 2012,  
 -  Continue cleanup work in Plating Lines 1-2-3 in Area A, and Lines 8-15 in Area B.  
-  Plan procedures for the excavation and packaging of sludge and liquids from Area A                            secondary  containment (approximate volume about 10,200 gallons). 
- Consolidate / repackage containers as needed into D.O.T. shippable containers.  
- Demolish RCRA empty containers.
- Continue air monitoring in the work zone and the perimeter of the Site.
- Evaluate the bids for the disposal of hazardous waste and chose facility.
-  Recycle RCRA empty containers.

2.2.2 Issues

The main health and safety issues during the period at the Site are potentially harmful emissions of hydrogen cyanide and acid vapor/spills.  The issues is addressed through engineering controls and good work practices.  In addition,  all workers briefed everyday to make sure everyone stays vigilant and safe.  OSC and START are closely monitoring all areas, especially piles of solids and liquids to ensure no unsafe emissions or acid spills are occuring.

Temperatures onsite reached 91 degrees (F) in the shade on 7/12/2012.  To protect workers from the heat the following steps are being taken:  
- Workers are advised using Ice vest, 
- Multiple breaks are taken (up to once per hour)  as needed,
- buddy system is in place to check for signs of heat stress (in addition to the RM and OSC observing).
- Cold water and gatorade are supplied at all times.
-  Work Shift are started earlier as needed based on the weather to beat the heat.
-  Workers are briefed everyday during the tailgate/safety meetings on weather and heat stress.

The Health and Safety Plan  and was approved and signed by all site personnel.  Safety meetings are held daily. 

2.5.2 Liaison Officer
NA

2.5.3 Information Officer:
Community Involvement Coordinator: Ginny Narsete

IDEM

City of Mishawaka

St. Joseph County Health Department

Mishawaka Fire Department

The following numbers of personnel were on-Site during the reporting period:

Baycote            Baycote Metal Finishing Site

CERCLA           Comprehensive Environmental Response, Compensation, and Liability Act
CRZ                  Contamination Reduction Zone

EPA                 Environmental Protection Agency

ERRS               Emergency and Rapid Response Services
D.O.T.              Department of Transportation

FCA                 Field Cost Accountant

HASP               Health and Safety Plan

HAZCAT Hazardous Categorization 
IDEM                Indiana Department of Environmental Management

NA                    Not Applicable

OSC                 On-Scene Coordinator

PolRep              Pollution Report

RCRA                Resource Conservation and Recovery Act

PRP                  Potentially Responsible Party

RM                    Response Manager

PolReps will be submitted on a weekly or bi-weekly basis.