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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 several waste water treatment systems. The OSC and its contractors have adopted a work plan to prioritize the high hazard areas / plating lines.
2.1.2 Response Actions
Please refer to previous Polreps for response actions prior to September 4, 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 continues to be considered.
- Cleanup in Area C continues. Waste material continues to be pumped from the Vats and categorized for off-site disposal. Vats are washed and managed accordingly. Demolished tanks are placed into the appropriate roll-off for off-site disposal. Remaining tanks are rendered unusable. Process piping is demolished and power-washed for off-site disposal. Rinse waters are collected for off-site disposal. Zinc ball anodes were collected from Area C; methods of cleaning the zinc for recycling are being explored. The majority of cleanup operations in Area C is scheduled to be completed by Tuesday, September 11.
- The Map of Area Z was finalized. Waste liquids from Area Z were pumped from several vats into tanks / containers for off-site disposal.
- Hazardous Waste Liquids (Chromium) were shipped for off-site disposal; 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.
- 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 25,780 pounds of scrap steel has been recycled.
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 for disposal as of September 7, 2012
18 55-gallon drums of Haz basic vat bottom sludge
6 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
8 Cubic-yard boxes of Haz solids
10 330-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)
7 330 gallon tote Haz base liquid
7 330 gallon tote Haz neutral liquid
28 55-gallon drums of Haz neutral solids
3 55-gallon drums of Haz base liquid
42 55-gallon drums of non-Haz neutral solids
1 4,900 gallon poly tank (filled with 3,200 gallons of Hazardous Waste Liquid)
1 330-gallon tote non-Haz neutral liquid
8 55-gallon drums acid liquid
2 330 gallon Haz oil/water mix
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 |
Hazardous Waste Liquids (Chromium) |
9/05/12 |
3371 gallons |
010413083 JJK |
|
US Ecology, Detroit, MI |
Solid Waste Debris |
9/07/12 |
30 CY |
012 |
|
WM landfill, Wyatt, IN |
|
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2.2.1 Anticipated Activities
2.2.1.1 Planned Response Activities
Planned removal activities on Site include:
- Inventory and perform hazard categorization on substances contained in vats, pits, drums, and other containers;
- Perform sampling and analysis to determine disposal options.
- Continue to consolidate and package hazardous substances, pollutants, and contaminants for
transportation and off-site disposal;
- Dismantle and decontaminate process equipment and building components associated with
the plating areas, as necessary;
- 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) .
- Take any other response actions to address any release or threatened release of a hazardous substance, pollutant and contaminant that the U.S. EPA OSC determines may pose an imminent and substantial endangerment to the public health or the environment
2.2.1.2 Next Steps
During the week of September 10, 2012, the following activities are anticipated:
- Continue cleanup work in Areas A, C, E and Z.
- Transport a bulk shipment of hazardous waste liquids (cadmium, chromium) for off-site disposal.
- Transport a shipment of containerized acid waste for off-site disposal.
- Determine management / disposal options for wastes accumulated in the secondary containment units in Area A.
- Continue to remove wastes, powerwash, and manage wastes from the management of the wastewater treatment system located in Area E.
- Assess options to access / managage wastes located in Area W.
- Consolidate / repackage waste into containers as needed into D.O.T. shippable containers.
- Demolish RCRA empty containers.
- Conduct hazcat testing / waste sampling to determine waste characteristics and disposal options.
- Continue air monitoring in the work zone and the perimeter of the Site to protect workers and residents.
- 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 scrap metal generated from clean-up operations.
2.2.2 Issues
The main health and safety concerns 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 issue is addressed through engineering controls, PPE, and good work practices. On September 6, levels of carbon monoxide were detected in Area C above the action level due to the use of 2-cycle gas chop saw. Work in the Area was suspended while the area was ventilated. An additional door was accessed / opened to improve air flow. The area/operation will continue to be monitored. An ERRS Chemist is performing compatibility testing on all materials to ensure proper management.
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