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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 10/1/12. During the reporting period, EPA conducted the following activities:
- OSC Atkociunas held a meeting with the residents of the Penelope 60 Apartments. The senior community was evacuated during the September 14 incident. OSC Atkociunas discussed the removal activities to date, the incident and future activities planned for the site. Approximately fifteen residents attended the meeting.
- EPA and START continued to conduct site perimeter and work area air monitoring to ensure worker and community protection.
- EPA, START, and ERRS continued to monitor the eight 55-gallon drums (stored in Area H) that contain the source material from the incident that occurred on 9/14. Additional monitoring equipment for possible degradation products remains on site. The equipment includes SO2 sensors, and Drager CMS Chips (H2S, SO2, and HCN). No heat or evidence of reaction were present. Analytical results of the September 26 sampling event of source material have been received. ERRS initiated the bid process for off-site disposal of the waste.
- Cleanup in Area A continued. The sludge in the secondary containment pits was solidified with corn cob & portland cement. The solidified sludge was excavated for disposal. During the reporting period, 18 cubic yards (one steel roll off container) of Hazardous Waste Solids was removed from the secondary containment pits and sent for off-site disposal; see table below for details. The pits were washed and cleaned with caustic water and that rinse water was pumped out and stored for disposal. The pits have been emptied, cleaned and backfilled / partially backfilled. An additional load of recycled concrete has been delivered to continue backfill operations.
- Cleanup in Area Z continued. Process piping and tank supports were demolished and placed into the appropriate roll off. Vats Z9, Z10, Z15, Z16, and Z17 were cleaned and rendered unusable. A large opening was cut into Vat Z6. ERRS accessed the Vat and began to remove debris and baskets containing zinc ball anodes. The Vat is approximately 70 feet long and 7 feet wide and contains substantial amount of material. ERRS accessed a hatch to Z25, which appears to be a dryer for the plating process. Mechanical equipment was observed inside.
- Cleanup in Area E continued. Hazard Categorization, using improved procedure developed by ERRS were used with START oversight to determine the chemical characteristics of several unknown wastes in small containers.
EPA is supporting the haz cat work with additional air monitoring instruments. ERRS loaded solidified non-hazardous waste sludges from containers / vats located in Area E and placed into a roll-off for off-site disposal.
- Cleanup in Area J continued. ERRS removed liquid / sludge from Vat J12.
- EPA and START continued to develop a Quality Assurance Project Plan for START sampling associated with the removal. The sampling includes the sample collected from J12 to determine the threat posed by wastes associated with Area W.
- A representative from Keller Engineering, Inc. conducted a site visit on October 4 to conduct a structural integrity assessment of the Site. A report is expect during the week of October 8. EPA requested a determination on structural soundness of the building, methods to access / remove waste from Area W and methods to remove air handling systems.
- EPA OSC and START completed their sweep of the site and found no signs of combustion, heat, or reactions.
- EPA’s supplied air trailer is onsite to support Level B work.
- EPA and its contractors are 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.
2.1.4 Progress Metrics
The following waste has been staged for disposal as of October 5, 2012:
20 55-gallon drums of Haz basic vat bottom sludge
15 55-gallon drums of Haz acid vat bottom sludge
6 330-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
0 95-gallon overpacks of Haz cyanide solids
16 Cubic-yard boxes of Haz solids
2 330-gallon totes of Haz acid liquid
3 55-gallon drums Decon water
8 55 gallons drums of cyanide waste from incident
0 55-gallon drums of Haz neutral liquid
26 RCRA-empty vats (various sizes)
77 330-gallon tote metal frames (poly portion has been cut apart and placed in roll-offs)
10 330 gallon tote Haz base liquid
17 330 gallon tote Haz neutral liquid
48 55-gallon drums of Haz neutral solids
0 55-gallon drums of Haz base liquid
0 55-gallon drums of non-Haz neutral solids
3 330-gallon tote non-Haz neutral liquid
5 55-gallon drums acid liquid
2 330 gallon Haz oil/water mix
0 95 gallon drum Haz base liquid
1 20 cubic yard roll-off box of non-Haz sludge
Waste Disposal Information Table:
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 (NA3082) |
9/05/12 |
3371 gallons |
010413083JJK |
|
US Ecology, Detroit, MI |
Solid Waste Debris |
9/07/12 |
30 CY |
012 |
|
WM landfill, Wyatt, IN |
Hazardous Waste Liquids (NA3082) |
9/10/12 |
3615 gallons |
010130168JJK |
|
Vickery Environmental,
Vickery, OH |
Waste Corrosive Liquids, Acidic (UN3264) |
9/10/12 |
1700 gallons |
010413113JJK |
|
US Ecology, Detroit, MI |
Waste Corrosive Liquids, Basic (UN3266) |
9/10/12 |
335 gallons |
010413113JJK |
|
US Ecology, Detroit, MI |
Waste Corrosive Liquids, Acidic (UN3264) |
9/10/12 |
1500 gallons |
010413107JJK |
|
US Ecology, Detroit, MI |
Waste Chromic Acid (UN1755) |
9/10/12 |
385 gallons |
010413107JJK |
|
US Ecology, Detroit, MI |
Non-hazardous Liquids |
9/14/12 |
4310 gallons |
010413050JJK |
|
US Ecology, Detroit, MI |
Solid Waste Debris |
914/12 |
30 CY |
013 |
|
WM landfill, Wyatt, IN |
Hazardous Waste Solid (NA3077) |
9/18/12 |
15 CY |
004354467FLE |
|
US Ecology, Detroit, MI |
Non-hazardous Liquids |
9/19/12 |
4717 gallons |
010413265JJK |
|
US Ecology, Detroit, MI |
Non-regulated material |
9/24/12 |
400 pounds |
010413339JJK |
|
US Ecology, Detroit, MI |
Non-Hazardous, Non D.O.T., regulated sludge, N/A |
9/24/12 |
3140 pounds |
010413339JJK |
|
US Ecology, Detroit, MI |
UN1564, RQ, Barium compounds, n.o.s., (Barium carbonate), 6,1,III |
9/24/12 |
150 pounds |
010413340JJK |
|
US Ecology, Detroit, MI |
Waste Corrosive Liquids, Basic (UN3266) |
9/24/12 |
330 gallons |
010413340JJK |
|
US Ecology, Detroit, MI |
Cyanide Waste (UN1935) |
9/24/12 |
165 gallons |
010413340JJK |
|
US Ecology, Detroit, MI |
Hazardous Waste Solid (NA3077) |
9/24/12 |
15 CY |
010413252JJK |
|
US Ecology, Detroit,MI |
Hazardous Waste Solid (NA3077) |
9/27/12 |
15 CY |
010413250JJK |
|
US Ecology, Detroit, MI |
Hazardous Waste Solid (NA3077) |
10/01/12 |
18 CY |
010413251JJK |
|
US Ecology, Detroit, MI |
|