U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Commonwealth Site - Removal Polrep
Final Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
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Subject:
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POLREP #3
Final
Commonwealth Site
Detroit, MI
Latitude: 42.3606980 Longitude: -83.0852929
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To:
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From:
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Brian Kelly, OSC
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Date:
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12/11/2014
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Reporting Period:
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1. Introduction
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1.1 Background
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Site Number: |
C52R |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
8/28/2014 |
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Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
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Response Lead: |
EPA |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
10/20/2014 |
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Start Date: |
10/20/2014 |
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Demob Date: |
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Completion Date: |
12/15/2014 |
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CERCLIS ID: |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
Yes |
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FPN#: |
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Reimbursable Account #: |
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Incident Category
Fund lead CERCLA time-critical removal action.
Site Description and Location
The Commonwealth Site (site) is located at 5923 Commonwealth Street, Detroit, Michigan 48208. The site is the former location of E.L.M. Industries, Inc. and Triune Iron & Metal, Inc. It is unknown when the businesses ceased operations, but the property was tax foreclosed by the city of Detroit on January 19, 2010. During an assessment of the property, several hundred drums, totes, cylinders, and small containers of waste were found.
Description of Threat and Preliminary Removal Assessment
On May 15, 2014, EPA conducted a site assessment that documented drums, totes and small containers at the site. Some of the drums show signs of deterioration, damage and possible leaking. Drum labels include trichloroethylene, acetylene gas, hydraulic and motor oil, coating enamels, propylene glycol n-propyl ether, and hydrogen peroxide. EPA also collected samples (CW-AR-01-051514 and CW-AR-02-051514) that when tested had a flash point less than 140 degrees Fahrenheit (°F). These wastes are considered hazardous for the characteristic of ignitability, pursuant to 40 C.F.R. § 261.21. Tetrachloroethene was detected in sample CW-DR-01-051514 at a concentration of 1.1 milligrams per liter [mg/L]). This result exceeds the toxicity criterion for tetrachloroethene of 0.7 mg/L. Therefore, the waste associated with this sample is considered hazardous according to 40 C.F.R. § 261.24.
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2. Current Activities
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2.1 Operations Section
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Narrative
See prior POLREPs for actions completed in previous reporting periods.
Response Actions to Date
Between November 1 and December 15, 2014, EPA completed hazard categorization (HAZCAT) of waste streams, bulked and prepared composite samples for laboratory analysis, and cut and crushed all drums and totes to confirm RCRA empty status. Free-standing liquids throughout the site were solidified and collected for disposal. EPA solicited, awarded, and completed the transportation and disposal of hazardous substances at an off-site RCRA disposal facility.
During removal work, START conducted perimeter and exclusion zone air monitoring for volatile organic compounds (VOCs), carbon monoxide (CO), hydrogen sulfide (H2S), lower explosive limit (LEL%) and oxygen (O2%) utilizing an AreaRAE network and a multiRAE. There have been no exceedances of action levels.
Security was on site during nonworking hours and during temporary shut down prior to final transport and disposal activities.
Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The bankrupt E.L.M. Industries, Inc. and Triune Iron & Metal, Inc. are the only known PRPs.
2.1.4 Progress Metrics
| Waste Stream |
Medium |
Quantity |
Manifest # |
Disposal |
| Friable Asbestos |
solid |
1-20yd3 rolloff |
MIK 396399685 |
Carelton Farms Landfill28800 Clark RoadNew Boston, MI 48164 |
| UN3077 Environmentally Hazardous Substances(Xylene, Toulene) |
solid |
365 G |
012480824 JJK |
Petro-Chem Processing Group 421 Lycaste Detroit, MI 48214 |
| UN3802 Environmentally Hazardous Substances (Xylene, Napthalene) |
liquid |
1465 G |
012480824 JJK |
Petro-Chem Processing Group 421 Lycaste Detroit, MI 48214 |
| UN1993 Waste Flammable (Xylene, Toluene) |
liquid |
2325 G |
012480824 JJK |
Petro-Chem Processing Group 421 Lycaste Detroit, MI 48214 |
| UN3077 Environmentally Hazardous Substances(Acetone, 2- Butanone) |
solid |
95 G |
012480824 JJK |
Petro-Chem Processing Group 421 Lycaste Detroit, MI 48214 |
| UN3200 Waste Corrosive(Hydrochloric Line Descaler) |
solid |
55 G |
012480824 JJK |
Petro-Chem Processing Group 421 Lycaste Detroit, MI 48214 |
| Non DOT/Non Regulated |
solid |
55 G |
012480824 JJK |
Petro-Chem Processing Group 421 Lycaste Detroit, MI 48214 |
| Non DOT/Non Regulated |
solid |
30 Y |
012480841 JJK |
Petro-Chem Processing Group 421 Lycaste Detroit, MI 48214
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| Regional Metrics |
| This is an Integrated River Assessment. The numbers should
overlap. |
Miles
of river systems cleaned and/or restored |
0 |
| Cubic yards of contaminated sediments removed
and/or capped |
0 |
| Gallons of oil/water recovered |
0 |
| Acres of soil/sediment cleaned up in
floodplains and riverbanks |
0 |
| Stand Alone Assessment |
Number
of contaminated residential yards cleaned up |
0 |
| Number of workers on site |
9 |
| Contaminant(s)
of Concern |
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| Oil
Response Tracking |
| Estimated volume |
Initial
amount released |
N/A |
| Final amount collected |
N/A |
| CANAPS Info |
FPN
Ceiling Amount |
N/A |
| FPN Number |
N/A |
| Body of Water affected |
N/A |
| Administrative
and Logistical Factors (Place X where applicable) |
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Precedent-Setting HQ
Consultations (e.g., fracking, asbestos) |
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Community challenges or high
involvement |
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Radiological |
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More than one
PRP |
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Endangered
Species Act / Essential Fish Habitat issues |
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Explosives |
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AOC |
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Historic
preservation issues |
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Residential
impacts |
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UAO |
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NPL site |
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Relocation |
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DOJ involved |
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Remote location |
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Drinking water
impacted |
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Criminal
Investigation Division involved |
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Extreme weather
or abnormal field season |
X |
Environmental
justice |
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Tribal
consultation or coordination or other issues |
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Congressional
involvement |
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High media
interest |
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Statutory
Exemption for $2 Million |
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Statutory
Exemption for 1 Year |
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Active fire
present |
| X |
Hazmat Entry
Conducted – Level A, B or C |
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Incident or
Unified Command established |
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Actual air
release (not threatened) |
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| Green
Metrics |
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Metric |
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Amount |
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Units |
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Diesel Fuel Used |
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42 |
gallons |
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Unleaded Fuel Used |
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unknown |
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gallons |
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Alternative/E-85 Fuel Used |
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85 |
gallons |
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Electricity from Coal |
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unknown |
kW |
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Electricity from solar/wind |
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unknown |
kW |
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Electricity from grid/mix |
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0 |
kW |
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Solid waste used |
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0 |
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Solid waste recycled |
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10 |
lbs |
| Version
140908 |
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2.2 Planning Section
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Next Steps
None. Removal Action completed.
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2.3 Logistics Section
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OSC Brian Kelly and ERRS removal manager (RM) organized logistics for the site.
Resources that were present on site during this reporting period included:
- Air horns
- Air monitoring equipment
- ERRS equipment storage trailer
- ERRS 'break' trailer (conex box)
- ERRS work crew
- ERRS work vehicles
- ERRS removal manager
- ERRS chemist
- ERRS field cost assistant
- Federal On Scene Coordinator
- Fire extinguishers
- Office trailers (conex box)
- Portable decontamination area (first aid kit, emergency shower & eyewash)
- Portable restrooms
- Portable generators
- Roll-off dumpster (20yd3 & 30yd3)
- Sawzall
- Security subcontractor personnel
- Semi-truck with trailer (T&D phase)
- Skid steer with attachments
- START contractor (oversight & air monitoring)
- Telescoping industrial forklift
- Truck with rear roll-off dumpster trailer system
- Wind sock
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer
The site-specific HASP was reviewed and signed by all site personnel. Safety meetings were held each morning with all site workers.
2.5.2 Liaison Officer
Brian Kelly serves as liaison with local officials and interested parties.
2.5.3 Information Officer
See Section 2.5.2
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3. Participating Entities
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3.1 Unified Command
N/A
3.2 Cooperating Agencies
City of Detroit Buildings, Safety Engineering & Environmental Department (BSEED)
Michigan Department of Environmental Quality (MDEQ)
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4. Personnel On Site
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U.S. EPA - 1
START contractor (Tetra Tech) - 1
ERRS contractor (Lata Kemron/Marine Pollution Control) - 7
Security guard (off-shift) - 1
TOTAL PERSONNEL = 10
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5. Definition of Terms
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City of Detroit BSEED - The Buildings, Safety Engineering & Environmental Department
CO - Carbon Monoxide
ERRS - Emergency and Rapid Response Services
HASP - Health and Safety Plan
HAZCAT - Hazard Categorization
H2S - Hydrogen Sulfide
LEL - Lower Explosive Limit
MDEQ - Michigan Department of Environmental Quality
OSC - On Scene Coordinator (Federal)
O2 - Oxygen
PPE - Personal Protection Equipment
RM - Removal Manager - ERRS
START - Superfund Technical Assessment and Response Team
U.S. EPA - United States Environmental Protection Agency
VOCs - Volatile Organic Compounds
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6. Additional sources of information
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No information available at this time.
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7. Situational Reference Materials
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No information available at this time.
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