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

See Initial Polrep.

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

See Initial Polrep.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results  
See Initial Polrep.

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 10, 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 continued.  Analytical results for the sludge in the secondary containment pits has been received.  The sludge in the secondary containment pits is being solidified with corn cob / portland cement.  Liquids in Vats A87 and A88 were pumped and transferred to an onsite Vat.      

- Cleanup in Area C continued.  The majority of the operations in Area C has been completed.  Waste has been pumped from Vats and containers have been removed. Vats have been washed, rinse waters have been collected for off-site disposal.  Vats have been left in place, however the vat / tank system has been rendered unusable.  Process piping has been removed and power-washed for off-site disposal.  Removal / disposal options for the air handling system are being explored.  Methods to recycle the zinc ball anodes continues to be explored.  

- Cleanup in Area E continued.  Several tanks were cut open.  Waste / sludge was removed for off-site disposal.  Tanks, process equipment, and decking for the wastewater treatment system has been power washed.  Rinse waters are collected for off-site disposal.   

- Several large tanks in Area J have been cut open.  Tank J-12 has several feet of sludge.  Tank J-13 contained residual sludge and scale.  The tank has been cleaned, rinsed and rendered unusable.   

- Waste liquids from Area Z were pumped from several vats into tanks / containers for off-site disposal. 

- A trailer load of corrosive waste was shipped for off-site disposal; see Table below for details. 

- A bulk load of hazardous waste liquids was shipped for off-site disposal; see Table below for details. 

- A bulk load of non-hazardous liquids was 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.   

- Four cylinders - 3 acetylene, and 1 liquefied petroleum have been returned to the local supplier / manufacturer. 

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 for disposal as of September 7, 2012

18 55-gallon drums of Haz basic vat bottom sludge

7 55-gallon drums of Haz acid vat bottom sludge

0 330-gallon totes of Haz cyanide containing liquid

0 55-gallon drums of Haz cyanide containing vat bottom sludge

1 Cubic-yard boxes of Haz cyanide solids

3  95-gallon overpacks of Haz cyanide solids

11 Cubic-yard boxes of Haz solids

10 330-gallon totes of Haz acid liquid

0 55-gallon drums of Haz neutral liquid

26 RCRA-empty vats (various sizes)

74 330-gallon tote metal frames (poly portion has been cut apart and placed in roll-offs)

9  330 gallon tote Haz base liquid

11 330 gallon tote Haz neutral liquid

31 55-gallon drums of Haz neutral solids

6 55-gallon drums of Haz base liquid

42 55-gallon drums of non-Haz neutral solids

1 4,900 gallon poly tank (filled with about 500 gallons of Non-Hazardous Neutral Liquid)

0 330-gallon tote non-Haz neutral liquid 

0 55-gallon  drums acid liquid

2 330 gallon Haz oil/water mix

Planned removal activities on Site include:

1. Inventory and perform hazard categorization on substances contained in vats, pits, drums, and other containers; 
2. Perform sampling and analysis to determine disposal options.
3. Continue to consolidate and package hazardous substances, pollutants, and contaminants for  
   transportation and off-site disposal;  
4. Dismantle and decontaminate process equipment and building components associated with 
   the plating areas, as necessary;
5. 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) . 
6. 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 17, 2012, the following activities are anticipated:

- Continue cleanup work in Areas A, E and Z. 
- Assess options to access / managage wastes located in Area W.     
- START to sample sludge in Vat J12, which appears to be associated with process equipment in Area W.  START to complete Field Sampling Plan and initiate QAPP process per the START3 QAPP Procedures.  The OSC determined this to be a time-critical sampling need to determine threats 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.  An ERRS Chemist is performing compatibility testing on all materials to ensure proper management.  

The Health and Safety Plan was approved and signed by all site personnel. 
Health and 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.