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2.1.1 Narrative
The time-critical removal response actions will be conducted by the bankruptcy Trustee and Paradigm Minerals, in accordance with Section 104(a)(1) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. § 9604(a)(1) and Section 300.415 of the National Oil and Hazardous Substance Pollution Contingency Plan (NCP, 40CFR 300.415, to abate or eliminate the immediate threat posed to public health and/or the environment by the presence of the hazardous substances on the Site.
2.1.2 Response Actions to Date
Following all final approvals of the CD, the Estate of Chemetco and Paradigm Minerals mobilized a contractor (Precision Crushing) to the site at the end of September 2013. In working with the OSC, the contractor began some minor site clean-up (house keeping); scrap metal recycling, skull removals and sales and mobilizing heavy equipment.
On November 14, 2013, U.S. EPA mobilized START contractors to perform oversight of approved site activities previously initiated by the Estate of Chemetco that include renting and leasing of dozers, tracked excavators, cranes, articulated dump trucks and magnetized metal handling equipment used for:
· On-going demolition work of facility plant production equipment and buildings previously used for copper smelting and product processing. Please note that the current demolition work with resultant scrap metal recycling is a necessary step to help finance the needs of the Estate for future site work that will enhance the removal and recovery of metals commodities contained in the slag.
· The location, excavation, loading and recovery of “skulls” containing higher copper or other metal content. This recovery is another important step to aid in the financing for future work performed by the Estate. Please note that a hand-held X-ray fluorescence (XRF) instrument is used to determine the skulls copper or other metal concentrations.
· Loading the skulls into containers for shipment to over-seas businesses that will recover and refine the copper.
· Relocating slag materials to create a work area to be used for future work.
· Relocating slag materials to construct a haul road from the slag pile to the work area.
On December 6, 2013, the Estate contractors initiated the construction of a loading dock adjacent to the Tank House that will be used as part of a UMBM container loading operation. It was completed on December 13, 2013.
On December 9, 2013, the Estate contractors started the assembly of the series of material conveyor circuits in the Tank House to be used as a part of forthcoming material bagging (Super-sack) operations.
On December 14, 2013, the Estate submitted to the agency the following documents:
1. CHEMETCO Health and Safety Form;
2. Site Safety Briefing Form;
3. Estate Safety Briefing – Winter;
4. CHEMETCO Site Emergency Evacuation Plan;
5. IEPA Seal Order Handout;
6. MSDS – Copper Slag.
On December 16, 2013, the Estate took delivery of five particulate monitoring instruments that will be used for the perimeter air monitoring approach. A metrological station was also delivered. The estate will electronically store the air monitoring data results. An additional hand-held particulate meter was obtained on December 31, 2013.
On January 3, 2014, the loading-dock next to the “Tank” building construction was completed.
On January 10, 2014, the Estate of Chemetco contractor, Precision Crushing, Inc., initiated a “bump” test of the crushing circuit as a preliminary step to access the crushing output goal to meet the 1-inch minus product requirement set forth by the buyer.
On January 14, 2014, Precision Crushing initiated full scale crushing and bagging operations. To date, approximately 3000 tons have been processed and 1272 one-ton bags have been set aside for future loading into ocean containers.
On January 16, 2014, the Estate if Chemetco purchased two additional cameras to supplement the eight existing plant security cameras.
On January 23, 2014, the estate submitted a QAAP for the air monitoring program.
On January 29, 2014, the first 25 ocean-tight containers of crushed and separated “Mixed Copper Tin Material” was loaded and trans-shipped for metals recovery at the Northeast Yejin Co., Ltd. Facility in Chenzhou City, Hunan Province, China.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
U.S DOJ, U.S. EPA, State of Illinois, the Estate of CHEMETCO and Paradigm Minerals negotiated a Consent Decree to govern the removal activities.
2.1.4 Progress Metrics
Waste or Product Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal/Recycle/Intermodal Loading |
Final Reclamation
Destination |
Copper Spills |
Recyclable Copper |
88.81 tons |
NA |
Recycle |
Interco Trading Co.
Madison, Illinois |
Aurubis
Lunen, Germany |
Cupro |
Recyclable Copper/Tin |
43.66 tons |
NA |
Recycle |
Interco Trading Co.
Madison, Illinois |
Aurubis
Lunen, Germany |
Copper Pot Slag (MBM) |
Recyclable Copper |
43.37 tons |
NA |
Recycle |
Interco Trading Co.
Madison, Illinois |
Aurubis
Lunen, Germany |
Copper Reverts |
Recyclable Copper |
502.95 tons |
NA |
Recycle |
Interco Trading Co.
Madison, Illinois |
Aurubis
Lunen, Germany |
High-grade Copper (processed) |
Recyclable Copper |
21.27 tons |
NA |
Recycle |
Interco Trading Co.
Madison, Illinois |
Aurubis
Lunen, Germany |
Carbon Steel (magnetic Fe) |
Recyclable Steel |
|
NA |
Recycle |
Not yet determined |
NA |
Non-crushable Steel (Shredder) |
Recyclable Steel |
6.15 tons |
NA |
Recycle |
Not yet determined |
|
Scrap Steel |
Recyclable Steel |
852.61 tons |
NA |
Recycle |
Grossman Iron & Steel,
St. Louis, MO |
|
Mixed Copper Tin Materials |
Recyclable Metals |
1151.49 tons |
NA |
Recycle |
CMAC |
Northeast Yejin Co. Ltd., Liyu Jiang Town, Chenzhou City, China |
White-goods, computers, office equipment, etc. |
Recyclable Steel |
3.32 tons |
NA |
Recycle |
Component Level Recycling, Sauget, IL |
|
Hydraulic oil spill materials |
Sorbent pads, PPE |
2 drums |
|
Land Disposal |
Heritage Enviro. Services |
|
Refractory brick |
Broken refractory |
|
|
|
Pending at this time |
|
North Polishing Pond Zinc Dry Sludge |
Recyclable Zinc |
217.19 tons |
NA |
Recycle |
CMAC |
Northeast Yejin Co. Ltd. Liyu Jiang Town, Chenzhou City, China |
Construction/Demolition Debris (non-hazardous) |
General Refuse |
8.43 tons |
NA |
Land Disposal |
Republic Waste Services
Roxana, IL |
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U.S. EPA Emergency Response and Removals Branch will perform oversight to the recovery of metals bearing materials and the forthcoming UMBM metals processing reclamation & removal actions to take place in early 2014.
2.2.1 Anticipated Activities
1. Oversee the site maintenance and enhancements to site security and access controls to the entire facility. Security cameras and recorders will be utilized. Additional security lights will be added and a guard service will be contracted for off-hours and weekend security needs.
2. Participate in weekly meetings with the Estate, Estate employees, Estate contractors and Estate Trustee.
3. Review the Health and Safety Plan (HASP) assembled by the Estate related to all employees and its contractors.
4. Plant Demolition – Conduct oversight of the ongoing demolition and resultant scrap metal recovery work.
5. Perimeter Air Monitoring Program – Review the air monitoring plan to be used by the Estate to monitor fugitive dusts from materials handling and crushing operations.
6. Oversee the implementation and approach to process crush, screen, bag, load, containerize, and trans-ship unprocessed metal bearing materials (UMBM, cupro, copper bearing, Zinc sludges) at the Site, which should include, at a minimum:
- Installing and grading slag product materials (hill) for access roads that will be used for UMBM materials recovery;
- Excavating/loading and delivery of cuprous bearing materials delivered to the crushing circuit;
- Product crushing circuit will include a jaw crusher, magnetic conveyor separator, screening tables along with several material conveyors. Generous water-spray and misting for dust suppression will be included in critical areas of jaw crushing and UMBM size screening;
- Operation and Maintenance of the UMBM bagging systems;
- Freight forwarding transporting the loaded ocean-tight cargo containers to an Agency approved intermodal loading facility with ultimate destination to reclamation facility(s) in accordance with EPA's Off-Site Rule (40 CFR § 300.440) and the project Consent Decree (CD), up to and including oversea port destinations in Germany and China;
- Control access to the contaminated areas to prevent further migration of contamination, by fencing, traffic restrictions or other applicable means;
- The Estate will subcontract a street sweeping service to maintain clean roadway surfaces inside and near the facility main gate;
- Load one or two-ton super-sacks into ocean-tight containers for freight forwarding trans-shipment to nearby rail loading terminals with destinations to domestic port loading facilities with outbound oversea destinations to China and Germany.
2.2.1.1 Planned Response Activities
- Take all necessary steps to implement source control of the slag and scrubber sludge. Source control may include surface water and storm water control measures to control off-site migration of zinc oxides and other metals.
- Prepare for the forthcoming Paradigm process work by which metals will be separated and concentrated to enhance the metals commodity value.
- Backfill any subgrade excavated areas with clean fill to effectuate storm water control and grade the Site as necessary.
Backfill any subgrade excavated areas with clean fill to effectuate storm water control and grade the Site as necessary.
2.2.1.2 Next Steps
- Await court approval of the amended Asset Purchasing and Processing Agreement (APPA).
- Prepare and execute forthcoming loading and shipping containers of all product streams for metals recycling either domestic or abroad.
2.2.2 Issues
While full production to separate, size, bag and load the “mixed copper and tin materials” into ocean-tight containers is possible, logistical delays in transportation of the materials has been experienced due to the extreme cold weather experienced throughout the East and Midwest.
However, inclement weather may create weather delays to the project schedule. Also, the Estate financing challenges could create possible delays in the future related to the forthcoming Paradigm materials processing approach.
Financing of the Paradigm "process" could delay future schedules.
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APPA – Asset Purchase and Processing Agreement
ATSDR – Agency for Toxic Substances and Disease Registry
CERCLA – Comprehensive Environmental Response, Compensation, and Liability Act
CD – Consent Decree
CFR – Code of Federal Regulations
Chemetco – Chemetco Superfund Site , (“the Estate,” “Trustee for the Estate of bankruptcy Trustee” or, “Trustee”), previously d.b.a. Chemetco Metals Corporation
Cupro – Copper containing (aka cupriferous, cupronickel)
CWA – Clean Water Act, 33 U.S.C. §§ 1251-1387
HASP – Health & Safety Plan
IDPH - Illinois Department of Public Health
IEPA – Illinois Environmental Protection Agency
ILCS – Illinois Compiled Statues
NCP – National Oil and Hazardous Substance Pollution Contingency Plan
NPL – National Priorities List
PA/SI – Preliminary Assessment / Site Inspection
Paradigm – Paradigm Minerals & Environmental Services
PMES – Paradigm Minerals & Environmental Services
PRP – Private Responsible Parties
RCRA – Resource Conservation and Recovery Act
Skulls – Slag with copper bearing commodity value
START – Superfund Technical Assessment & Response Team
Super-sack – 1 to 2-ton polypropylene woven bags used to store and handle bulk processed materials
TCLP – Toxicity Characteristic Leaching Procedure
UMBM – Unprocessed Metal Bearing Materials
XRF – X-ray fluorescence
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