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Home My WebLink About17050_Surrett Dr_Completion of Haz Waste Removal and Initial Decontamination Report_Ensci_19930602RECEIVED 71 19 01 19 10 Id ENVIRONMENTAL, INC. June 2, 1993 Maurice S.S. Hull, Esq. Keziah, Gates & Samet 300 North Main Street, Suite 400 High Point, North Carolina 27260 STATE FILE SEP 18 1995 SUPERFUND SECTION Custom Processing RE: ENSCI Job #S92038,, Completion of Hazardous Waste Removal and Initial Decont.aininat.ion of the Custom Processing & Mant,facturijig, Inc. facility, 1110 Surret.t Drive, High Point, North Carolina Confidential: Attorney -Client. Privilege Attorney Work Product Generated in Anticipation of Litigation Dear Mr. Hull: ENSCI Corporation completed the removal and disposal of waste material as well as initial decontamination of the above -referenced facility on September 3, 1992. The enclosed Waste Removal and Facility Decontamination Report details the activities which were performed during this phase of work. It will be included as an addendum to the Environmental Assessment Report (revised draft dated April 21, 1992), on which ENSCI is awaiting comment. If you have any questions, or if I can be of additional service, please do not hesitate to contact me. Sincerely, ENSCI Environmental, Inc. Russell R. Ridlon Project ,ag �Augu s 1A. rgc]titha E. "feical Opera ti on s pe c f o r 1 108 Old'rhomaMle Pcad High Point, Ninth Ccnolinn 2`72 0 T(719) 883-7505 F(919) 802-79,58 Post Office, &,x 802!5 T (() I9) /8,Y-67�0V F(919)881 V0 6 ■ ■ Confidential: Attorney -Client Privilege Attorney Work Product Generated in Anticipation of Litigation Waste Removal and Facility Decontamination Report Custom Processing & Manufacturing, Inc. Facility High Point, North Carolina Prepared for High Point Bank & Trust Company Russell R. Ridlon Project Manager ENSCI Corporation' 1108 Old Thomasville Road High Point, North Carolina 27260 (919) 883-7505 June 2, 1993 Augustus IVI. Mergenthaler, P.E. Technical Operations Director 01. It - 94 ENSCI Corporation An Environmental Service Company 4 1. Introduction I 14 ENSCI Corporation has completed debris removal and initial decontamination of the Custom Processing & Manufacturing, Inc. (Custom Processing) facility located at 1110 Surrett Drive in High Point, North Carolina. These activities were implemented in order 14 to mitigate potential environmental and human health risks at the former electroplating facility. ENSCI made its determination that action was necessary to abate, prevent, minimize, stabilize, mitigate, and eliminate the release or the threat of release at the Custom Processing site based on examination of the following factors: 0 Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances or pollutants or contaminants; • Actual or potential contamination of drinking water supplies or sensitive ecosystems; • Hazardous Substances or pollutants or contaminants in drums, barrels, tanks, or other bulk storage containers that might pose a threat of release; S High levels of hazardous substances or pollutants or contaminants in soils largely at or near surface that may migrate; • Weather conditions that might cause hazardous substances or pollutants or contaminants to mitigate or be released; • Threat of fire or explosion; • The availability of other appropriate federal or state response mechanisms to respond the release; and • Other situations or factors that might pose threats to public health or welfare or the environment. 1.1 Site History Custom Processing was a metal furniture fabrication and component manufacturing facility owned by Mr. Allen Austin. Mild steel tube, flat and bar stock were cut and welded to customer specifications. Metallic finishes were then applied through electroplating processes, including nickel, brass, and chrome plating operations. Plated stock was further processed by polishing, buffing and coating with clear or colored lacquer prior to shipping. IS92038 1 61 2/93 0 . r ENSCI Corporation An Environmental Service Company Operations at the facility ceased when Custolll process ing'dcclared Chapter 7 bankrupLey on January 22, 1991. An auction of equipment and machinery was conducted in April 1991. High Point Bank & Trust Company foreclosed on the property on June 25, 1991. Following the foreclosure, EKSCI was contracted to remove and properly dispose of plating solutions which existed at the site, and to take an inventory of all, chemicals in storage. Completion of these activities was followed by a site assessment, Which included an assessment of the facility itseif as well as groundwater and sail underlying the facility. In addition, ENSCI removed underground storage tanks located at the site. These activities, as well as a more detailed site history, are discussed in ENSCI's April t 21, 1992 Environmental Assessment Report. The report concluded that the widespread presence of chemicals anO metals associated with plating operations i ndicates that various materials within the Custom Processing facility have come in contact with materials originating from electroplating processes. A recommendation was made to remove the remaining process chemicals and waste materials, and to perform an initial facility decontamination. outside the facility, the UST removal and groundwater investigation indicated no evidence of a release of petroleum hydrocarbons from the UST system into soil or groundwater. The groundwater investigation did, lzoever, cletect contaminants apparently associated with metal plating and finishing operations. Some contaminants, including metals and volatile organic compounds, were present at levels exceeding gratijid eater quality standards specified in the North Carolina Administrative Code, 15A NCAC 2L. 1.2 Scope of Work ENSCI's original scope of work for this phase of site remediation, as submitted in the May 5, 1992 Proposal for Interim Remedial Measures, was altered due to site conditions discussed below. Changes included reorganizing the chronology of the proposed tasks as well as implementing steps to increase site security. The revised scope of work consisted of the following tasks: • Task I, Securing the Site • Task II, Waste Removal and Disposal • Task III, Debris Removal and Disposal id. • Task IV, Initial Decontamination of the Building. 6/ 2/93 45ih3N ENSCI Corporation An Environmental Service Company it 2. Task I: Securing the Site ENSCI's initial task was securing the site in order to prevent accidental human contact INwith hazardous materials. This task was originally scheduled at the project's end, but due to signs of unauthorized entry, it became the primary activity. 01 The May 5 proposal specified that securing the site would consist of spot welding the windows in a closed position and barring the doors. However, the evidence of unauthorized entry indicated a need to implement additional security. These actions included barring the windows as well as the doors and boarding up the windows in the office area. Plywood was purchased to board the windows in the office area, and material which existed at the site was used to bar the majority of the windows and doors. Additional stock metal was purchased to complete the task. Due to these actions to increase security, the estimated time frame to complete Task I was exceeded. 3. Task II: Waste Removal and Disposal ENSCI's second task consisted of the removal of process chemicals which were stored at the Custom Processing facility. The chemical waste was stored in small containers, h partial and full drums, and vats. ENSCI consolidated approximately 100 small containers of waste material into 12 DOT - approved 17H 55-gallon containers. The drums were separated into two non -regulated waste streams and one regulated waste stream. The next step was to overpack existing containers of chromic acid, nitric acid and cadmium oxide into DOT -approved 17H 55- gallon containers. It was also necessary to overpack damaged 55-gallon containers containing waste flammable liquids. The last step was to transfer plating waste and oil from drums and vats into bulk shipping containers. All waste drums were labelled and marked in accordance with EPA, DOT and treatment, storage and disposal (TSD) facility regulations prior to shipping to an approved TSD facility. Table 1 illustrates the chemicals which were removed from the site during this task, and the disposal facility which was the final destination of the chemicals. In the case of the non -regulated oil waste, the material was bullied at ENSCI's facility and subsequently collected by an oil recycler. Copies of the shipping manifests for all materials are attached to this report. The generator must keep a copy of each manifest (signed in accordance with 40 CFR S92038 3 6/ 2/93 a ENSCI Corporation An Environmental Service Company 262.23a) for a period of three years from the date on which the waste was accepted by the initial transporter per 40 CFR 262.40a. Table 1: Chemical Wastes Removed from the Site ¢¢tti _NM hmlkvr!� :tr..' Y4'LE< #. ....¢,1.....: '-<.. E }.<}'{t.}$..p1'{Y'1k{1.'.'Jk <'F+j{j{•+}%:j;- b T}v Cadmium Oxide 1 55-gallon Chem Met Hazardous Waste container Wyanotte, Mf Nitric Acid >40% 2 55-gallon Environmental Enterprise Hazardous Waste containers Cincinnati, OH Chromic Acid 1 55-gallon Environmental Enterprise Hazardous Waste container Cincinnati, OH Paint Related Mat. 7 55-gallon Southeastern Chemical Hazardous Waste containers Sumter, SC Plating Waste 2,125 Gallons Cyanokem Hazardous Waste Detroit, MI Surfactant 5 55-gallon Southeastern Chemical Non -regulated Waste containers Sumter, SC Oil 2 55-gallon ENSCI Corporation Non -regulated Waste containers High Point, NC Oil 600 Gallons ENSCI Corporation Non -regulated Waste High Point, NC The above -listed quantities which were removed from the Custom Processing site are in reasonable agreement with the quantities which were estimated in the May 5, 1992 proposal. S9203B 4 6/ 2193 ENSCI Corporation An Environmental Service Company 4. Task III: Removal and Disposal of Bulk Debris ENSCI's third task consisted of the removal of all bulk debris. ENSCI had hoped to be able to segregate the debris into regulated and non -regulated waste streams, but after several conversations with representatives of EPA Region IV, the NCDEHNR, and several TSD facilities accustomed to the disposal of similar waste material and debris, it was determined that all debris removed from the site for disposal, other than the above -listed chemicals and recyclable metals, would carry the EPA waste code F009. In compliance with 40 CFR 261.6 (a)(B)(iv), all metal debris witli the exception of empty 55-gallon and smaller containers, was segregated, placed into rolloff boxes, and sent to D.H. Griffin Wrecking Company located in Greensboro, North Carolina for recycling. The metal debris included stock metal, furniture frames, metal plates, machinery and vats. Visibly contaminated bar stock, machinery and vats were sand blasted and decontaminated prior to shipment to D.H. Griffin. A compactor was used on the majority of the remaining debris, and large pieces of debris were cut using an assortment of hand tools, chainsaws and acetylene torches in order to maximize space in the rolloffs. Compacting, cutting, and hand packing the debris eliminated the need for an additional three to four rolloffs at a cost savings of between $37,500.00 and $49,500.00 in waste transportation and disposal. Nine rolloff boxes of contaminated debris were sent to USPCI for disposal as hazardous waste. The debris consisted of the following materials: * Empty metal and plastic 55-gallon and smaller containers • Paper, wood, dust, fiberglass, glass, plastic, etc. • Debris collected around the exterior of the building and wooded area. 5. Task IV: Initial Building Decontamination ENSCI's final task, initial decontamination of the interior of the building, began by hand - sweeping the interior floor of the facility multiple times to remove small debris and dust. Heavy residue buildup on the walls and floors was removed by hand scraping. S6R03L 5 6/ 2/93 ENSCI Corporation An Environmental Service Company It was ENSCI's intention to clean the entire interior 'of the building using HEPA vacuums, but it was found that the accumulated dust had been saturated with oil mist, making it difficult to remove. The mist was concentrated in the area occupied by the metal sanding operation, and appeared to have been generated from this operation. As an alternative cleaning approach, high-pressure steam was used to clean the ceiling, walls and floor of the building. The buffing room, which is located in the far southeast corner of the building, was diked off and used to contain the water generated from steam cleaning. Minimal water was generated due to rapid evaporation caused by the high ambient temperature in the building and the initial temperature of the steam. The remaining standing water was contained in six DOT -approved 17H-55 gallon containers which remain on site and will be solidified at a later date. Due to the heavy buildup of grease, the floor was cleaned multiple times with the use of a two -ton floor scrubber as well as hand brushes. All sumps were steam cleaned and scrubbed by hand. The office area was cleared of carpet, fixtures and assorted debris. The walls and floor were scrubbed and cleaned by hand using a industrial surfactant. ENSCI personnel attempted to decontaminate the fluorescent light fixtures in the facility, but this action was not possible if the fixtures were to be kept intact. A decision was made to leave the light fixtures in place in order to meet the present lighting needs. The majority of the fixtures should be removed and recycled once the final facility lighting requirements are determined. At all times, personnel working in the exclusion zone were required to wear a minimum of Level C Personnel Protective Equipment (PPE). This included the use of a full -face respirator with HEPA cartridges, barricade suit with hood, latex inner gloves, nitrile middle gloves, leather outer gloves, and rubber boots with steel toe and shank. Equipment and material taken from the exclusion zone was decontaminated or disposed of as hazardous waste. The facility yard was raked and swept in order to remove debris from the area, and the fence line was repaired. MOB 6 6/ 2/93