|
|
2.1.1 Narrative
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 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 prior to August 27, 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.
- Disposal options for the sludge in the secondary containment units for Area A continue to be considered.
- Cleanup in Area C continues. The accumulated water on the floor of the room was pumped for off-site disposal; see Table below for details. Dirt/debris was removed and the floor power-washed. Waste material continues to be pumped from the Vats and categorized for off-site disposal. Vats are power-washed and managed accordingly. Demolished tanks are placed into the appropriate roll-off for off-site disposal. Process piping is demolished and power-washed for off-site disposal. Rinse waters are collected for off-site disposal.
- Cyanide wastes were shipped for off-site disposal; see Table below for details.
- Waste continued to be removed from tanks associated with the wastewater treatment system located in Area E. The tanks are cleaned, power-washed, demolished or are rendered unusable. The filter press was cleaned and rendered unusable. Rinse waters were collected for off-site disposal
- One roll-off of Nonhazardous debris was removed from Site; see Table below for details.
- EPA, ERRS and START continued to assess options for accessing, removing wastes in Area W.
- EPA’s supplied air trailer is onsite to support Level B work. The air trailer was serviced by Breathing Air Systems, which indicated that the system was working properly.
- Six cylinders were returned for reuse/recycle to the supplier. The cylinders included two Argon, one Acetylene, one Helium/Argon, and two Oxygen.
- EPA and its contractors is implementing Green Practices onsite (double sided printing, dedicated water bottles, dedicated steel toed Chem boots, city electrical power, CFL bulbs, etc...). To date 17,220 pounds of scrap steel has been recycled. Use of Culligan water service and reusable bottles has saved approximately 2,056 disposable water bottles.
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.
2.1.4 Progress Metrics
The following waste has been staged and ready for disposal as of August 31, 2012
17 55-gallon drums of Haz basic vat bottom sludge
3 55-gallon drums of Haz acid vat bottom sludge
6 330-gallon totes of Haz cyanide containing liquid
3 55-gallon drums of Haz cyanide containing vat bottom sludge
0 Cubic-yard boxes of Haz cyanide solids
0 95-gallon overpacks of Haz cyanide solids
7 Cubic-yard boxes of Haz solids
6 330-gallon totes of Haz acid liquid
19 55-gallon drums of Haz neutral liquid
25 RCRA-empty vats (various sizes)
69 330-gallon tote metal frames (poly portion has been cut apart
and placed in roll-offs)
5 330 gallon tote Haz base liquid
18 330 gallon tote Haz neutral liquid
23 55-gallon drums of Haz neutral solids
3 55-gallon drums of Haz base liquid
42 55-gallon drums of non-Haz neutral solids
0 4,900 gallon poly tank
1 330-gallon tote non-Haz neutral liquid
Waste Stream |
Date |
Quantity |
Manifest # |
Treatment |
Disposal facility |
Solid Waste Debris |
6/6/12 |
30 Cubic yards (CY) |
001 |
|
WM Landfill Wyatt IN |
Solid Waste Debris |
6/8/12 |
30 CY |
002 |
|
WM Landfill Wyatt IN |
Haz Waste Debris |
6/18/12 |
25 CY |
004354475FLE |
|
Envirosafe Services of Ohio, Oregon Ohio |
Solid Waste Debris |
6/21/12 |
30 CY |
003 |
|
WM Landfill Wyatt IN |
Haz Waste Debris |
6/26/12 |
30 CY |
004354473 FLE |
|
Envirosafe Services of Ohio, Oregon Ohio |
Solid Waste Debris |
6/29/12 |
30 CY |
004 |
|
WM Landfill, Wyatt IN |
Haz Waste Debris |
7/03/12 |
25 CY |
004354477FLE |
|
Envirosafe Services of Ohio, Oregon, Ohio |
Solid Waste Debris |
7/12/12 |
30 CY |
005 |
|
WM landfill, Wyatt, IN |
Solid Waste Debris |
7/18/12 |
30 CY |
006 |
|
WM landfill, Wyatt, IN |
Cyanide Waste (UN 1935) |
7/31/12 |
3440 gallons |
010411950JJK |
|
Dynecol Inc., Detroit, MI |
Waste Toxic,
Inorganic (UN 3288) |
7/31/12 |
6400 pounds |
010411950JJK |
|
Dynecol Inc., Detroit, MI |
Solid Waste Debris |
8/02/12 |
30 CY |
007 |
|
WM landfill, Wyatt, IN |
Chromic Acid (UN 1755) |
8/02/12 |
2700 gallons |
010411037JJK |
|
Dynecol Inc., Detroit, MI |
Acid Liquid (UN 3264) |
8/02/12 |
1475 gallons |
010411037JJK |
|
Dynecol Inc., Detroit, MI |
Haz Waste Debris |
8/09/12 |
25 CY |
004354466FLE |
|
Envirosafe Services of Ohio, Oregon, Ohio
|
Waste Corrosive Liquid, Basic (UN 3266) |
8/10/12 |
4638 gallons |
010411219JJK |
|
Dynecol Inc., Detroit, MI
|
Acid Liquid (Nitric, Chromium, Cadmium, UN 3264) |
8/10/12 |
1320 gallons |
010411079JJK |
|
Dynecol Inc., Detroit, MI
|
Waste Acid Liquid (Hydrochloric, Sulfuric, Chromium, UN 3264) |
8/10/12 |
1920 gallons |
010411079JJK
|
|
Dynecol Inc., Detroit, MI
|
Solid Waste Debris |
8/15/12 |
30 CY |
008 |
|
WM landfill, Wyatt, IN |
Waste Chromic Acid (UN 1755) |
8/17/12 |
3420 gallons |
010411337JJK |
|
Dynecol Inc., Detroit, MI |
Waste Acid Liquid (Nitric, UN3264) |
8/17/12 |
790 gallons |
010411337JJK |
|
Dynecol Inc., Detroit, MI |
Hazardous Waste Solid (NA3077) |
8/20/12 |
22 CY |
005607311FLE |
|
Michigan Disposal, Belleville, MI |
Solid Waste Debris |
8/20/12 |
30 CY |
009 |
|
WM landfill, Wyatt, IN |
Waste Corrosive Liquid, Basic (UN3266) |
8/21/12 |
3249 gallons |
010411359JJK |
|
US Ecology, Detroit, MI (formerly Dynecol) |
Solid Waste Debris |
8/24/12 |
30 CY |
010 |
|
WM landfill, Wyatt, IN |
Cyanide Waste (UN1935) |
8/27/12 |
1500 gallons |
010413023JJK |
|
US Ecology, Detroit, MI |
Waste Toxic, Inorganic (UN3288) |
8/27/12 |
2400 pounds |
010413023JJK |
|
US Ecology, Detroit, MI |
Cyanide Waste (UN1935) |
8/27/12 |
2200 gallons |
010413024JJK |
|
US Ecology, Detroit, MI |
Non-hazardous Liquids |
8/28/12 |
5465 gallons |
010413028JJK |
|
US Ecology, Detroit, MI |
Non-hazardous Liquids |
8/28/12 |
4967 gallons |
010413027JJK |
|
US Ecology, Detroit, MI |
Solid Waste Debris |
8/28/12 |
30 CY |
011 |
|
WM landfill, Wyatt, IN |
Non-hazardous Liquids |
8/30/12 |
4717 gallons |
010413049JJK |
|
US Ecology, Detroit, MI |
|