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 August 6, 2012.

During the reporting period, EPA conducted the following activities:

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

- Cleanup in Area A continues.  Two vats containing acid liquids, two vats containing basic liquids, and seven vats containing neutral liquids were emptied, cleaned, and removed. Contaminated debris and structures were removed from secondary containment. 

- Cleanup in Area H continues.  The floor beneath the the plating line in Area H was scraped and cleaned. Process equipment and structures from vat H22 were removed, cleaned and deposited in the appropriate disposal roll-off.

 - Diagrams of Areas B & H and Area A have been added the the documents area of the site website to indicate vats that have been cleaned and removed (shaded).

- Small containers staged in Area E were labeled with the appropriate waste stream identifier. Compatible containers were also consolidated. 

- Acid liquids were transferred to D.O.T. approved totes in preparation for shipment.

- The 4,500 gallon poly tank containing bulked Base Liquid was pumped into a tanker truck and transported off site for disposal, see table below for details.

- 1 load of Acid waste was shipped off-site, see table below for details.

- 1 roll-off box of Haz Debris materials was transported off site for disposal, see table below for details. 

- EPA's air trailer is onsite to support Level B site work.

- EPA and its contractors is implementing Green Practices onsite (double sided printing, dedicated water bottles, dedicated steel toed Chem boots, city electrical 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 August 10, 2012

15           55-gallon drums of Haz basic vat bottom sludge

2            330-gallon totes of Haz cyanide containing liquid

26           55-gallon drums of Haz cyanide containing vat bottom sludge

0              cubic-yard boxes of Haz cyanide solids

2              95-gallon overpacks of Haz cyanide solids

20            cubic-yard boxes of Haz solids

10             330-gallon totes of Haz acid liquid

18            55-gallon drums of Haz neutral liquid

66            RCRA-empty vats (various sizes)

54            330-gallon tote metal frames (poly portion has been cut apart and placed in roll-offs)

10             330 gallon tote haz base liquid

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 in Areas H and 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.  

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 August 13, 2012,  

- Transport and Dispose of three loads of waste: 1) Non-Hazardous Debris; 2) Acids; 3) Bases
- Continue cleanup work in Plating Lines 1-2-3 in Area A, specifically cyanide containing vats and secondary containment areas.  
- Continue cleanup work in Area H & B focusing on removal of hazardous solids from vat H22 prior to cleaning and rendering unusable. 
- Consolidate Base liquids into the 4,500 gallon poly tank in preparation for shipment. 
- Consolidate / repackage waste into containers as needed into D.O.T. shippable containers.  
- Demolish RCRA empty containers.
- Conduct hazcat testing to charaterize additional waste samples for disposal.
- Continue air monitoring in the work zone and the perimeter of the Site to protect workers and residents.
- Continue Evaluate the bids for the disposal of hazardous waste and chose facility as needed.
- Continue to submit waste profiles to selected disposal facilities as needed.
- 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, acid vapor/spills, and particulates containing Cadmium and any other contaminants present.  The issues is addressed through engineering controls, PPE, and good work practices.  Lab results indicate small concentrations of mercury in the composite waste profile samples.  EPA/START will conduct mercury screening of waste and air in the work areas to ensure worker protection and correct waste disposal practices.  An ERRS Chemist is performing compatiblity testing on all materials prior to being bulked together in the poly tank.

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.

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.