UNITED STATES 7NVIRONMENTAL ... - Records Collections

/), UNITED STATES 7NVIRONMENTAL PROTECTION AGENCY

REGION 5

77 WEST JACKSON BOULEVARD

CHICAGO, IL 60604-3590

US EPA RECORDS CENTER REG ON 5

MEMORANDUM

REPLY TO THE ATTENTION OF:

SUBJECT: Request for Approval and Funding for Emergency and Time-Critical Removal Actions at the Karl Industries, Inc. Site, 11415 Chamberlain Road, Aurora, Portage County, Ohio (Site ID C5FG)

FROM:

James Justice, On-Scene Coordinator Jason Cashmere, On-Scene Coordinator Emergency Response Branch 1

THRU:

Jason H. El-Zein, Chief Emergency Response Branch 1

TO:

Margaret M. Guerriero, Acting Director

Superfund Division

I. PURPOSE

This memorandum requests and documents your approval to expend up to $585,454 to conduct emergency and time-critical removal actions at the Karl Industries, Inc. Site (the Site) in Aurora, Portage County, Ohio. Emergency Response Branch 1 Chief, Jason El-Zein, verbally authorized $50,000 in funding on February 16, 2017, to begin emergency cleanup and stabilization at the Site. Mr. El-Zein verbally authorized an additional $10,000 on March 20, 2017, and $15,000 on March 28, 2017, to complete emergency response actions to mitigate an imminent and substantial threat of release.

Emergency response actions included securing various hazardous substances found within and outside of Site structures and storage sheds. Includes the over-packing of 18 leaking drums, disposal of approximately 80 cubic yards of ash and debris from the burned down chemical laboratory, shipment of approximately 20,000 gallons of contaminated fire-suppression water from the laboratory ash and debris piles, and the recovery and removal of 37 compressed gas cylinders from the fire debris.

The response actions proposed herein are necessary to mitigate threats to public health, welfare,

During emergency response actions, EPA inventoried 137 additional drums around the Site with labels or placards indicating the presence of hazardous substances. Many of the drums were in poor condition and 18 had to be over-packed due to observed leaks. Additionally, it was observed that some incompatible chemicals [methylene chloride (flammable), hydrogen peroxide

Recycled/Recyclable n Printed with Vegetable Oil Based Inks on 100% Recycled Paper (100% Post-Consumer)

and potassium persulfate (strong oxidizers) and sulfuric acid (strong acid)] were stored in close proximity to each other and above floor drains. Approximately 2,000 small laboratory containers were observed in the warehouse on the Site. Labels indicated the presence of hazardous substances; however, a number of the containers labels were illegible. A number of compressed gas cylinders were also observed in the warehouse on the Site.

This Action Memorandum would serve as approval for expenditures by EPA, as lead technical agency, to take actions described here to abate the imminent and substantial endangerment posed by hazardous substances at the Site. The proposed removal of hazardous substances would be taken pursuant to Section 104(a)(1) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. ? 9604(a)(1), and 40 C.F.R. ? 300.415 of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).

The uncontrolled conditions of the hazardous substances present at the Site, and the potential threats they present, require that this action be classified as a Time-Critical Removal Action. The response actions described in this Action Memorandum will require an estimated 40 on-site working days to complete.

There are no nationally significant or precedent setting issues associated with the Site. The Site is not on the National Priorities List (NPL).

II. SITE CONDITIONS AND BACKGROUND

CERCLIS ID: Category:

0HN000507766 Emergency Response / Time-Critical Removal Action

Site Description

I. Removal Site Evaluation

On December 30, 2016, a fire occurred at the Site which caused a release to the environment. The Mantua Fire Department responded to the fire and reported that 12,000 to 14,000 gallons of fire-suppression water was used to extinguish the fire. During fire suppression efforts, it was noted that water flowing from the former location of the synthesis laboratory exhibited an orange color and was flowing towards an adjoining wetland. The Fire Department notified the Ohio Environmental Protection Agency (OEPA) and efforts were made with the help of a third-party cleanup contractor to capture the runoff in a trench and sumps to prevent impact to the wetland.

OEPA requested that the surface runoff water be sampled to determine the presence or absence of constituents of concern (COCs) associated with the synthesis laboratory and any potential related impacts to the wetland. OEPA noted a pH of 14 in runoff water from the Site. Following the fire, runoff water continued to be collected from the trench and sump system and was transferred to a frac tank pending characterization, transport, and disposal (Administrative Record Index Document (AR) 14).

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On January 9, 2017, OEPA issued a Notice of Violation to Karl Industries, citing unauthorized release of water and liquids following a fire at the Chamberlain Road facility (AR 13). OEPA observed a discharge of a corrosive solution, a pollutant, into a tributary of the Aurora Branch of the Chagrin River and a wetland. The water within the tributary and wetland are "Waters of the State" of Ohio. The unauthorized release of a pollutant into "Waters of the State" is a violation of Ohio Revised Code (ORC) 6111. The Notice required the following initial abatement actions to be taken:

? Recover grossly impacted water from the tributary and wetland; ? Stop the discharge of additional solution and impacted water runoff from the facility; ? Evaluate if soil, sediment and water was impacted above regulatory standards; and ? Properly evaluate, characterize, manage and dispose of all waste material in accordance

with the applicable regulations.

On January 12, 2017, a consultant for Karl Industries provided a report to OEPA (AR 14) that provide the following:

? A brief description of the business operations and categories of chemicals at the facility; ? Extent of damage to the facility; ? Acute environmental release resulting from fire; and ? Measures taken to mitigate release.

The Consultant's report contained results of surface water samples collected from three locations -- the runoff water collection sumps, influent to the wetland, and effluent from the wetland. Detected chemicals included, but was not limited to, acetone, phenol, nickel (dissolved and particulate). Concentrations of volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), total metals, dissolved metals, and cyanide generally decreased from the sump locations to the wetland effluent location.

On February 9, 2017, OEPA requested EPA attend a follow-up inspection at the Site. The inspection noted the presence of fire-damaged wastes in debris from the laboratory building including containers, drums, totes and compressed gas cylinders (Photo 4). In addition, an inspection of the warehouse noted the presence of approximately 70 55-gallon drums and numerous small containers. Labels on some containers indicated flammable/ignitable (D001), corrosive (D002), toxic and/or listed (e.g., carbon tetrachloride, chloroform, methylene chloride, tetrahydrofuran) hazardous wastes. Some of the containers were in poor condition as evidence of staining and spills on the floor. (AR 20).

At the conclusion of the inspection OEPA issued a second Notice of Violation on February 9,

2017 (AR 15), citing the violation of Ohio Administrative Code (OAC) 3745-52-11, part of

?

managcmcnt rules.

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? Karl Industries, Inc. failed to determine if the fire damaged laboratory building, as well as its contents are a hazardous waste. The contents include, but are not limited to, ash, debris, containers, drums, totes and compressed gas cylinders.

? Karl Industries, Inc. failed to determine if the water and liquids ("run-off') from the December 30, 2016, fire involving the laboratory building is a hazardous waste.

? Karl Industries, Inc. failed to evaluate the contents of numerous containers, ranging in size from approximately one-quart to 55-gallons, as well as compressed gas cylinders located in the warehouse building. Some of these containers are deteriorated and/or leaking.

On February 13, 2017, OEPA referred the Site to EPA to be evaluated for an Emergency Response and Time-Critical Removal Action (AR 20).

On February 17, 2017, EPA requested and was granted access to the Site by the owner. The owner and operator indicated that they did not have the financial resources to address the fire debris, runoff from the Site, the leaking drums, compressed gas cylinders or collected runoff water in the frac tanks. An initial walk-through was conducted with OEPA, EPA contractors. EPA interviewed the Karl Industries operator to ascertain what chemicals may have been involved in the fire.

On February 20 through 23, 2017, EPA, in conjunction with OEPA, initiated a site survey, emergency removal action, and site stabilization activities at the Site (AR 16). During the site survey, numerous Material Safety Data Sheets (MSDS) were located and indicated that Karl Industries used the following chemicals and may be present on Site: ketones, amines, amides, alcohols, ethers, esters, nitriles, carbon tetrachloride, hydrochloric acid, ethanol, acetone, sodium hydroxide, ethyl acetate, dichloromethane, toluene, chloroform, tetrahydrofuran, quinolones, sulfuric acid, sodium cyanide, hydrogen peroxide, other organic acids, halo-aromatics, petroleum hydrocarbons, and other VOCs.

Labeled containers throughout the warehouse, storage shed, and storage trailer indicated toxic, flammable, corrosive, and oxidizing materials (See Attachment II -- Photo Log Photos 12, 29, 30). EPA observed poor housekeeping throughout the storage trailer, warehouse building, and storage shed--several drums and containers were noted to be leaking, bulging, and/or rusted (Photos 9, 11, 15, 36).

Within the warehouse, crystallization was observed on the exterior of numerous small containers. Numerous unlabeled containers were stored on shelving, in cabinets, and in piles throughout the warehouse with unknown compatibilities (Photos 19-36). EPA also noted incompatible drums that were staged adjacent to one another (i.e. a drum labelled "flammable" next to a drum labelled "oxidizer") in the warehouse (Photo 30). Two floor drains were identified in the warehouse building which convey wastewater to the septic system Several drums that had spilled contents onto the floor were noted in the vicinity of the floor drains.

All drums and/or containers that were observed to be leaking and/or of compromised integrity were over-packed and relocated to the warehouse building. All drums identified as incompatible

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were separated and staged with like materials. In total, 18 drums of compromised integrity and/or leaking contents to the environment were over-packed by EPA. OEPA assisted EPA with documenting approximately 2,000 small (30 gallons) were inventoried. Drums were found in the warehouse, an on-site semi-tractor trailer and in and around a small shed on the Site. (AR 17). Four compressed gas cylinders labeled carbon tetrachloride were also located in the warehouse (Photo 40).

Following the inventory and stabilization activities, EPA conducted field hazardous categorization screening on a subset of drums labelled as flammable, corrosive, or oxidizer. The drums were selected to verify contents based on labels found on the drums. Field screening results indicated that the five tested drums labelled as flammable exhibited high VOC readings (>450 parts per million and as high as 10,403 ppm), greater than 99% of the lower explosive limit (LEL), and had a positive ignitability test. One drum labelled as an oxidizer was selected for field screening. Test results confirmed that the drum contained an oxidizer and a peroxide test indicated 15 milligrams per liter (mg/L) of peroxide. Three drums labelled as corrosive had a pH of two or less.

Following the collection of a composite waste sample from the fire debris, EPA initiated cleanup of the destroyed synthesis laboratory building and segregated salvageable scrap metal for recycling. The waste sample was analyzed for pH, ignitability, reactive sulfides, polychlorinated biphenyls (PCBs), total cyanide, Toxicity Characteristic Leaching Procedure (TCLP) VOCs, TCLP SVOCs, and TCLP Metals including Mercury. Laboratory analytical results indicated the waste to be non-hazardous. In total EPA disposed of the following as part of emergency response actions:

? Approximately 20,000 gallons of non-hazardous contaminated runoff water ? 80 cubic yards of non-hazardous contaminated ash and debris ? 37 compressed gas cylinders

On March 31, 2017, OEPA issued Karl Industries a third Notice of Violation (NOV) (AR 18) citing a failure to comply with Ohio's hazardous waste laws as enumerated in Chapter 3734 of the Ohio Revised Code (ORC) and the rules adopted pursuant to ORC ?3734.12 found in OAC Chapter 3745 on numerous occasions. OEPA noted the following violations during several inspections:

Karl Industries failed to determine if the fire damaged laboratory building, as well as its contents, were a hazardous waste. The contents included ash, debris, containers, drums, and compressed gas cylinders. As part of the EPA emergency removal action, the ash, debris, and compressed gas cylinders were segregated, characterized, and shipped off-site for management. In addition, the containers and drums were seg egated, over-packed as necessary, and relocated to the warehouse building ? Karl Industries failed to determine if the water and runoff from the December 30, 2016, fire involving the laboratory building were a hazardous waste. As part of the EPA emergency removal action, the collected runoff was characterized and shipped off-site for management.

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