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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 10/8/12. 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.
- The Mayor of Mishawaka discussed site activities / site progress with OSC Atkociunas.
- High School Students from Penn High School interviewed OSC Atkociunas regarding site activities for an Environmental Science Class.
- EPA, START, and ERRS continued to monitor the source material from the September 14 incident. Analytical data from the September 26 sampling event was reviewed. Based upon analytical data / physical characteristics of the drums, the contents of six containers were consolidated into one 55-gallon drum and two containers were consolidated into another 55-gallon drum. Prior to consolidation, ERRS conducted a 'bucket test' to determine if any reactions, heat, and/or byproducts of consolidation would be generated. No anomolies were detected. The empty containers were washed and rinsed; rinsewaters were collected for off-site disposal. EPA, ERRS and START monitored the two drums for reactions, heat, and/or byproducts of consolidation; no anomolies were detected. ERRS procured disposal services for the source material from the incident and scheduled shipment for the week of October 14.
- Backfill operations in Area A continued. ERRS placed recycled concrete in the cleaned secondary containment pits to bring the area closer to grade.
- Cleanup in Area Z continued. ERRS completed clean-up of Vat Z6 (the vat is approximately 70 feet in length and 7 feet wide. Debris in the tank was cleaned and placed into the appropriate container. ERRS accessed / cleaned Vats Z66, Z58, Z59, Z26 and Z27. Sludges were collected for off-site disposal. ERRS cleaned / powerwashed structures and collectd rinsewater for characterization and off-site disposal. ERRS demolished piping and a portion of the cat walk to access the Vats in the northeast section of the room.
- The 4,900 gallon Rain for Rent poly tank (which was cleaned / decontaminated during the week of September 24) was demobilized from site.
- A tanker load of non-RCRA material (cyanide wastewater) was shipped for off-site disposal. The wastewater was generated from clean-up operations in Area A. See Table below for details.
- Cleanup in Area E continued. ERRS pumped liquids from tank E, which is located below grade in the Northwest corner of the room. Hazard Categorization, using improved procedure developed by ERRS were used with START oversight to determine the chemical characteristics of several unknown wastes in containers.
EPA is supporting the haz cat work with additional air monitoring instruments. Non-hazardous waste sludges generated from clean-up in Area E were shipped off-site for disposal; see Table below for details.
- Cleanup in the Haz Cat area (Southwest corner of Area R) 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.
- EPA and START continued to develop a Quality Assurance Project Plan (QAPP) 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. Soil sampling to characterize site soils will also be included in the QAPP.
- The Engineering Structural Condition Report was received and is in the process of being reviewed. Recommendations will be implemented, as necessary.
- EPA’s supplied air trailer is onsite to support Level B work.
- EPA and its contractors are implementing Green Practices onsite (double sided printing, Culligan water servoce / dedicated water bottles, dedicated steel toed Chem boots, city electrical power, CFL bulbs, etc...). To date 42,700 pounds of scrap steel has been recycled.
2.1.4 Progress Metrics
The following waste has been staged for disposal as of October 12, 2012:
20 55-gallon drums of Haz basic vat bottom sludge
15 55-gallon drums of Haz acid vat bottom sludge
2 330-gallon totes of Haz cyanide containing liquid
3 55-gallon drums of Haz cyanide containing vat bottom sludge
3 Cubic-yard boxes of Haz cyanide solids
0 95-gallon overpacks of Haz cyanide solids
17 Cubic-yard boxes of Haz solids
2 330-gallon totes of Haz acid liquid
3 55-gallon drums Decon water
2 55 gallons drums of cyanide waste from incident
0 55-gallon drums of Haz neutral liquid
29 RCRA-empty vats (various sizes)
79 330-gallon tote metal frames (poly portion has been cut apart and placed in roll-offs)
1 330 gallon tote Haz base liquid
33 330 gallon tote Haz neutral liquid
48 55-gallon drums of Haz neutral solids
0 55-gallon drums of Haz base liquid
6 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
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 |
Solid Waste Debris |
9/25/12 |
30 CY |
014 |
|
WM landfill, Wyatt, IN |
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 |
Non RCRA Material (cyanide wastewater) |
10/08/12 |
4811 gallons |
010461892JJK |
|
Vickery Environmental, Vickery, OH |
Nonhazardous solids (Area E waste) |
10/08/12 |
10 tons |
016 |
|
WM landfill, Wyatt, IN |
Solid Waste Debris |
10/10/12 |
25 CY |
015 |
|
WM landfill, Wyatt, IN |
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