action memo: request for time-critical removal action ...proposed ceiling increase of $144,000 for...

SFUND RECORDS CrR

2198160

• . * ^ ^ . UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 5? I J S L S REGION IX ' Vpy " 75 Hawthorne Street \ %/„„.^o<^ San Francisco, CA 94105

MEMORANDUM DEC 3^ 2009

SUBJECT: Request for a Time-Crifical Removal Action Ceiling Increase at the Felton King Site, City of Phoenix, Maricopa County, Arizona.

FROM: Martin Pow/ell, On-Scene Coordinator Emergency Response Section (SFD-9-2)

TO: Daniel Meer, Assistant Director Superfund Division

THROUGH: Harry Allen, Chief Emergency Response Section (SFD-9-2)

I. PURPOSE

The purpose of this memorandum is to request and document approval of the proposed ceiling increase of $144,000 for direct extramural costs to continue the ongoing removal action at the Felton King Site (the "Site"). The Site is located at 611 South 15" Avenue in the City of Phoenix, Maricopa County, Arizona (85007). As determined in the June 30, 2009 Request for a Time Critical Removal Action at the Felton King Site (the "Action Memorandum"), the removal of hazardous substances at the Site has was initiated pursuant to 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 Substances Pollution Contingency Plan ("NCP"), 40 C.F.R. § 300.415.

II. SITE CONDITIONS AND BACKGROUND

Site Status: Non-NPL Category of Removal: Time-Critical CERCLIS ID: AZN000908770 SITE ID: SN

Please refer to the initial Action Memorandum for a description of the Felton King Site and its conditions. This increase is necessary because of the increase in the quantities of hazardous substance waste streams over those originally estimated in the Action Memorandum.

The initial response activities began on July 6, 2009. Removal actions completed include inventorying, characterizing, segregating, bulking, re-containerizing, and removing for disposal all abandoned hazardous substances and contaminated materials left in drums, containers, tanks, vats, sumps and secondary containment structures at the Site. All wastes were characterized using EPA-approved methodologies and delivered to commercial hazardous waste management facilities that were compliant with EPA's CERCLA Off-Site Disposal Policies.

During the removal action, EPA also evaluated contaminated soils, concrete and structures associated with the former plating operations. These assessment activities included soil sampling and analysis with a focus on the former hazardous waste storage area. Analytical results indicate that exposed and shallow soil contaminated with cyanide, cadmium and chromium is more pervasive than was first anticipated. Furthermore, cyanide levels in soil are at levels that significantly increased the disposal costs estimated.

EPA response personnel now estimate that an additional two weeks will be : needed on-Site to complete the removal action and dispose of the significantly contaminated soils. This will necessitate a ceiling increase of $144,000.00 in extramural cleanup costs. A large percentage of the ceiling increase is associated with the cost for labor and equipment for an additional two weeks, and the transportation and disposal of contaminated soil.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, AND STATUTORY AND REGULATORY AUTHORITIES

Conditions at the Site continue to represent a release, and potential threat of release, of CERCLA hazardous substances that threaten the public health or welfare, or the environment, based on the factors set forth in the National Oil and Hazardous Substances Pollution Contingency Plan ("NCP"), 40 C.F.R. § 300.415(b)(2).

IV. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances from this Site, if not addressed by continuing the ongoing Time-Critical Removal Action may present an imminent and substantial endangerment to public health, or welfare, or the environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Proposed action description

EPA proposes to mitigate imminent and substantial threats to human health, welfare, or the environment by additionally excavating approximately 240 cubic yards of contaminated soils and debris associated with the former plating operations and remove for disposal, as necessary, all exposed materials posing an imminent threat of endangerment. The EPA will not investigate or respond to deep soil (i.e., greater than five feet below ground surface) or groundwater contamination at the Site.

All activities will be performed in conformance with prescribed health and safety procedures. Sampling and analysis activities will conform to EPA approved methodologies and mandatory specifications for quality assurance and quality control.

B. Estimated Costs

Regional Removal Allowance Costs

Current Celling Proposed Increase Proposed Ceiling

Cleanup Contractor $400,000.00 $120,000.00 $520,000.00

USCG PST $ 25,000.00 0 $ 25,000.00

Extramural Costs Not Funded from the Regional Allowance

START Contractor $ 97,000.00 0 $ 97,000.00

Extramural Subtotal $522,000.00 $120,000.00 $642,000.00

Extramural Contingency $104,400.00 $ 24,000.00 $128,400.00

Removal Action Ceiling $626,400.00 $144,000.00 $770,400.00

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN

Given the Site conditions, the nature of the hazardous substances documented on-Site and the potential exposure pathways to nearby populations described in Sections III and IV of the Action Memorandum, actual or threatened releases of hazardous substances from the Site, if not addressed by increasing the project ceiling and implementing the response actions selected in the Action Memorandum, will continue to present an imminent and substantial endangerment to public health or welfare, or the environment.

VII. OUTSTANDING POLICY ISSUES

There are no outstanding policy issues with the Site identified at this time.

Vlll. ENFORCEMENT

Please see the Confidential Enforcement Addendum attached to the Action Memorandum for a discussion regarding potentially responsible parties and enforcement. In addition to the extramural costs estimated for the proposed action, a cost recovery enforcement action also may recover the following intramural costs:

Intramural Costs^

Current Ceiling Proposed Increase Proposed Ceiling

EPA Direct Costs $ 40,000 $ 10,000.00 $ 50,000

EPA Indirect Costs $243,770 $56,332 $300,102 (36.58% of direct costs) TOTAL Intramural Costs $283,770 $ 66,332.00 $350,102

The total EPA extramural and intramural costs for this removal action, based on full-cost accounting practices that will be eligible for cost recovery, are estimated to be $ 1,120,502. Of this, an estimated spending of $ 545,000.00 comes from the Regional removal allowance.

IX. RECOMMENDATION

To eliminate the continuing threat to the environment that would be created by failure to complete the removal action at the Site, and consistent with the removal criteria contained in Section 300.415(b)(2) of the National Contingency Plan, I recommend you approve this ceiling increase request for $144,000 in direct costs from the Regional Allowance. Your approval would raise the total project ceiling from $626,400 to $770,400. Please indicate your approval by signing below.

' Direct costs include direct extramural costs and direct intramural costs. Indirect costs are calculated based on an estimated indirect cost rate expressed as a percentage of site-specific direct costs, consistent with the full cost accounting methodology effective October 2, 2000. These estimates do not include pre-judgment interest, do not take into account other enforcement costs, including Department of Justice costs, and may be adjusted during the course of a removal action. The estimates are for illustrative purposes only and their use is not intended to create any rights for responsible parties. Neither the lack of a total cost estimate nor deviation of actual costs from this estimate will affect the United States' right to cost recovery.

Approved: 1 ^ 15(3(^9 stantDiitector Date Daniel Meer, Assistant Diitector

Response, Planning and Assessment Branch

Attachment

Felton King Site Action Memorandum

cc: Sherry Fielding, USEPA, OEM, HQ

bcc: Site File John Jaros, SFD-9-4 Craig Whitenack, SFD-9-4 Martin Powell, SFD-9-2 Craig Benson, SFD-9-2 Andrew Helmlinger, ORC-3 Celeste Temple, SFD-9-4

<>' .s^eosr,.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

V - <p 75 Hawthorne Street I X S / ^ ? REGION IX

' iPRQi ^ San Francisco, CA 94105

MEMORANDUM

DATE: JUN 3 0 2009

SUBJECT: Request for a Time-Critical Removal Action at the Felton King Site, City of Phoenix, Maricopa County, Arizona.

FROM: Martin Powell, On-Scene Coordinator Emergency Response Section (SFD-9-2)

TO: Daniel Meer, Assistant Director Superfund Division

THROUGH: Harry Allen, Chief < ^ ^ Emergency Response Section (SFD-9-2)

I. PURPOSE

The purpose of this Action Memorandum is to obtain approval to spend up to $626,400 in direct extramural costs to mitigate threats to human health and the environment posed by uncontrolled hazardous substances (i.e., cyanide, chromium, cadmium, nickel, oxidizers, acids, and caustic liquids and solids) in bulk and non-bulk containers, sludges, and building materials associated with the unmanaged metal plating facility known as the Felton King Site (the "Site"). The Site is located at 611 South 15* Avenue, in the City of Phoenix, Maricopa County, Arizona (85007). The proposed removal of hazardous substances would be taken pursuant to Section 104(a)(1) ofthe 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 Substances Pollution Contingency Plan ("NCP"), 40 C.F.R. §300.415.

On June 17, 22 and 23, 2009, the United States Environmental Protection Agency ("EPA") conducted joint assessments with state officials to assess the current conditions and threats posed at the Site. The actions proposed in this document will complete a time-critical removal of the threat posed by hazardous substances remaining at the Site. These time-critical actions include the off-Site transfer and disposal of containerized hazardous wastes and hazardous substances and the continuing identification of and removal of contaminated sludges, soils, building materials and debris that pose threats to the public and environment. Specific threats are described below.

II. SITE CONDITIONS AND BACKGROUND

Site Status: Non-NPL ^ Category of Removal: Time-Critical CERCLIS ID: AZN000908770 SITE ID: SN

A. Site Description

1. Physical location

The Site is located at 661 South 15'^ Avenue in the City of Phoenix, Maricopa County, Arizona. The surrounding area is comprised of light industrial/commercial use, with residential properties across the street to the south. The nearest major waterway, the Salt River, is approximately 1.75 miles to the south. The coordinates of the Site are N33° 26' 28.2", W 112° 05' 28.2".

2. Site characteristics

The Site is located in an active commercial/industrial area with small commercial and manufacturing facilities adjacent to the Site on the east, across Lincoln Street to the north andis"^ Ave. to the west. Across Grant Ave., to the south, are retail businesses and residential properties. The Site is comprised of seven parcels that combine to approximately 36,000 square feet. Figure 1 depicts the Site parcel data. The building structure that houses the electroplating operation is approximately 1,500 square feet. The wastewater treatment system is located outdoors to the south east next to the garage area. There is a large gravel lot on the east side of the plating building where waste containers are stored. The entire Site is surrounded by a fence.

The Felton King facility was a custom plating operation utilizing a black oxide line, and conducted nickel, copper, and chrome electroplating. According to the business owner/operator, Felton King, the business operated as an electroplater for seventeen years, ceasing in April 2009. Operations ceased when Philip GoettI and Sons Enterprises, Inc. ("PG & Sons") foreclosed on real property that comprises the Site, and obtained a restraining order against Mr. King that precludes his access to the property.

3. Removal site evaluation

The Site was referred to EPA by the Arizona Department of Environmental Quality ("ADEQ"). On June 8, 2009 OSC Martin Powell met with members of the ADEQ Hazardous Waste Inspection and Compliance Unit ("HWICU") to discuss Site conditions. ADEQ staff expressed concerns over the recent abandonment of the

Site and the large quantity of unsecured corrosive and toxic waste remaining in open process vats, tanks, sumps, drums, and containers throughout the Site.

On June 9, 2009, OSC Powell contacted Mr. King via telephone and verbally advised him of his potential obligations under CERCLA. Mr. King stated that he was unable to perform Site clean-up activities. OSC Powell also spoke with one of the property owners' representatives, Gordon GoettI, and made arrangements to meet on-Site on June 17, 2009, to facilitate Site access and discuss EPA's response process. The Site is owned by PG & Sons.

On June 17, 2009, OSC Powell participated in an initial walk-through inspection with HWICU Unit Manager Mel Bunkers, HWICU Compliance Officer Jessica Olmstead and property owner representatives Gordon GoettI and Sharon Goldman. Also present were EPA Civil Investigators John Jaros, and Craig Whitenack. OSC Powell received signed consent for access to the Site from Mr. GoettI and Ms. Goldman. OSC Powell also advised Mr. GoettI and Ms. Goldman of the potential liability of PG & Sons. Mr. GoettI stated that PG & Sons did not have the resources to undertake a Site clean-up. EPA mailed General Notice Letters providing written notice of potential liabiiity to Mr. GoettI and Ms. Goldman on June 25, 2009.

During the initial walk-through inspection, EPA observed a large quantity of liquid and solid hazardous waste streams that included: caustic, acidic, cyanide bearing and metal bearing plating process solutions and sludge in unsecured plating vats; containers; tanks; sumps; and wastewater treatment unit process wastes. Accumulated chemical waste was evident throughout the plating area and in unsecured storage areas throughout the Site. EPA observed etching of the secondary containment cement and etching and degradation of plating waste impacted building materials. Based on these observations a removal Site assessment was scheduled for June 22 and 23, 2009.

On June 22 and 23, 2009, OSCs Powell and Craig Benson conducted a removal Site assessment with HWICU Unit Manager Bunkers and HWICU Compliance Officers Olmstead, Aleksandra Argals, Pamela Nicola, Jaclyn Palmero, Eder Delgadillo, and Kevin Wilkinson. Also present were personnel from the Superfund Technical Assessment and Response Team ("START") contract and Emergency and Rapid Response Service contract. On June 23, 2009, Arizona Assistant Attorney General Rick Zeise visited the Site for an orientation.

During the assessment, a preliminary chemical and container inventory was developed by START (Appendix 1). This inventory includes over 300 various sized drums, containers, tanks, cubic yard sacks, clarifiers and vats containing thousands of gallons and/or pounds of caustic, acidic, cyanide-bearing or metal-bearing wastes. There are potentially more chemical containers and an undetermined volume of contaminated debris, sludge's, building material, soils, concrete, and sump and wastewater treatment system materials awaiting full inventory and characterization.

Based on the apparent characterization, EPA observed incompatible materials stored in close proximity, which creates an additional risk of chemical reaction resulting in combustion, explosion or toxic vapor. The building, chemical storage areas and plating lines were found in poor condition.

The START conducted field chemistry analysis on some accessible larger tanks and containers, and confirmed the presence of acidic and caustic solutions both inside the building and in exterior waste storage areas. The START implemented an approved Emergency Response Quality Assurance Sampling Plan and collected nine samples from waste materials including cubic yard sacks (one sample), plating vats (three samples), sumps (two samples), and surface soil (three sample). The samples were submitted to an approved off-Site laboratory for rush EPA-approved analysis of heavy metals, pH, and total and amenable cyanide.

On June 23, 2009, OSC Powell and Civil Investigator Whitenack met with Mr. King at the offices of Harper Law. Mr. King was accompanied by his attorney(s) Kevin Harper and Brian Stines. OSC Powell provided a written notice of potential general liability under CERCLA to Mr. King.

4. Release or threatened release into the environment of a hazardous substance, or pollutant or contaminant

The objective of the June 23, 2009 EPA sampling event was to obtain an analytical data set meeting EPA Quality System guidelines that is representative of current Site conditions and that could be used to identify key hazardous substances of interest for project health and safety needs and future waste profiling purposes. A Preliminary EPA Laboratory Results Summary Table and ADEQ Sampling Results Table for samples collected on April 9, 2009, are contained in Appendix 2. Field testing and preliminary laboratory analytical data confirmed the presence of large quantities of corrosive solutions, high concentration cyanide solutions and numerous heavy metal contaminated waste streams associated with former electroplating, and industrial wastewater treatment processes.

Analytical and Site data indicate the presence of Resource Conservation and Recovery Act ("RCRA") listed wastes "F007", "F008" and "F009" (associated with electroplating operations where cyanides are in used in the process), "F006" wastewater treatment sludge waste, wastes exhibiting the RCRA hazardous waste characteristic of corrosiveness under 40 C.F.R. § 261.22, and wastes (i.e., chromium, cadmium) exhibiting the RCRA hazardous waste characteristics of toxicity in accordance with 40 C.F.R. § 261.24 and reactivity under 40 C.F.R. § 261.23.

Maximum concentrations recorded were 95,000 mg/kg total cyanide, 200,000 mg/kg nickel, 33,000 mg/kg chromium, 97,000 mg/kg cadmium, 2,000 mg/kg lead, and 4,700 mg/kg zinc. RCRA listed and characteristic wastes, including chromium, cadmium, lead, nickel and zinc, are hazardous substances as defined by Section

101(14) of CERCLA. Other hazardous substances or pollutants and contaminants not discovered to date or not specifically identified herein may exist at the Site. These substances also may pose a threat to human health and the environment.

There are no security guards or personnel working at the Site, and the hazardous wastes and substances located in unsecured storage areas throughout the Site may be accessed by climbing over the fence or through an opening in the chain connecting two sections of fence. Due to the absence of on-Site activity, it is likely that any person accessing the Site would be undeterred.

The potential for fire, vandalism and continuing deterioration of containers at the unmanaged Site may result in the combustion, physical exposure or commingling of incompatible hazardous substances resulting in harm to the public health or welfare or the environment. Considering the proximity of nearby residence, businesses and public highways, the Site represents a significant threat of release affecting nearby populations by fire and vapor and by direct contact exposure to nearby workers and trespassers.

5. National Priorities List ("NPL") status

The Site is not currently on or proposed for inclusion on the NPL.

B. Other Actions to Date

No other actions have been taken to abate the threats posed by the abandonment of hazardous substances at this closed facility. Neither the business nor property owners have taken appropriate actions to address the on-going violations of state hazardous waste control law.

C. State and Local Authorities' Roles

1. State and local actions to date

From November 19, 1999, to the present, HWICU has inspected and cited Felton King on several occasions for numerous violations of Arizona law, or an applicable permit/license, administrative order or civil judgment. Violations most recently cited in an October 2, 2008 Notice of Violation include: storage of hazardous waste without a permit; failure to submit Annual Report; failure to comply with provisions of Compliance Order; and failure to furnish information pertaining to hazardous waste generation, storage, treatment, transportation, and disposal.

The Site poses physical dangers to vandals and trespassers as the facility is contaminated with heavy metals and other hazardous substances that would pose a human health risk if ingested, inhaled or burned. Continuing non-compliance issues and the accumulation of large quantities of unsecured hazardous substances led to

the ADEQ referral to EPA and delivery of a written Request for Federal Action on June 23, 2009.

2. Potential for Continued State/Local Response

ADEQ has asserted that it lacks the resources to undertake the required cleanup action at this time. ADEQ requested EPA's assistance with a removal of hazardous substances and provided a written Request for Federal Action on June 23, 2009. Nonetheless, EPA may request assistance from State and local response agencies for various services including water and power hook-ups, traffic control, inspection of building integrity, concurrence with cleanup action levels and goals, community relations and other tasks that are necessary for an efficient, effective, and safe operation. Assistance from the State and local agencies likely will be limited to technical support and services rather than direct financial contribution to the response.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, AND STATUTORY AND REGULATORY AUTHORITIES

Conditions at the Site represent a release, and potential threat of release, of CERCLA hazardous substances that threaten the public health or welfare, or the environment, based on the factors set forth in the NCP, 40 C.F.R. § 300.415(b)(2). These factors include:

1. Actual or potential exposure to nearby populations, animals or the food chain from hazardous substances or pollutants or contaminants

There is an actual or potential exposure to nearby populations from hazardous substances at the Site, including the now unmanaged and unsecured heavy metal (i.e., chromium, hexavaient chromium, cadmium, and nickel) solutions, sludge and debris. These hazardous substances exist in liquid and solid wastes deposited throughout the facility and in Site debris and building materials. There also are large quantities of acidic and strong caustic cyanide laden plating solutions and wastes in open and degraded vats. The proximity of incompatible acidic solutions and cyanide bearing solutions in severely degraded containers poses a threat of mixing and creating toxic hydrogen cyanide gas.

In EPA's experience, closed and abandoned industrial plants are likely to attract trespassers, including children and vagrants. Although the Site is fenced, the outer fence can easily be climbed. The facility remains a human health risk to any vandals or trespassers, including young children, who might enter the premises. Any person entering the building or rear storage yard may be exposed to hazardous substances by direct contact with open containers, leaking equipment and contaminated building material. Nearby populations may be exposed to hazardous substances in the event deteriorated drums or containers leak causing incompatible

chemicals to mix and generate toxic gases that may be inhaled or flammable gases that may ignite. Direct contact, inhalation or ingestion of the hazardous substances at the Site poses an acute health threat to these individuals. Threats from some specific materials at the Site are discussed below.

Cyanide is readily absorbed through the skin, mucous membrane, and by inhalation. Symptoms of cyanide poisoning include anxiety, confusion, vertigo, nausea, convulsions, paralysis, coma, cardiac arrhythmia, and transient respiratory stimulation followed by respiratory failure or death.

Chromium is an eco-toxic heavy metal that is an inhalation, ingestion, and dermal exposure risk. Chromium bioaccumulates and targets the liver, kidneys, reproductive organs, circulatory system, and gastrointestinal system. Acute exposure to chromium can cause harmful effects to the gastrointestinal system. Chronic exposure can cause harmful effects to the skin, lungs, mucous membranes, and possibly cancer.

Cadmium is a highly toxic heavy metal, especially by inhalation of dust or fumes. Cadmium is a potential occupational carcinogen that targets the respiratory system, kidneys and blood. Cadmium poisoning can result in pulmonary edema, dyspnea (breathing difficulty), emphysema, anemia, nausea and vomiting. Cadmium is also flammable in powder form.

The large quantity of solutions exhibiting the hazardous waste characteristic of corrosiveness presents a direct contact and inhalation threat that could cause sever burns of the skins and lung tissue. Corrosive solutions at the Site are attributed to:

Nitric acid is a strong oxidizing agent and corrosive material that can burn the skin, eyes, and respiratory tract on direct contact or inhalation of vapors. It can cause acute pulmonary edema or chronic pulmonary diseases from inhalation. When heated or reacted with water, it produces toxic and corrosive fumes.

Sulfuric acid is a corrosive material that can burn the skin, eyes, and respiratory tract on direct contact or inhalation of vapors. It can cause acute pulmonary edema or chronic pulmonary diseases from inhalation. When heated or reacted with water, it produces toxic and corrosive fumes.

Hydrochloric acid is a strong corrosive that can burn the skin, eyes and mucous membranes on dermal contact. It also is moderately irritating to the respiratory tract when inhaled. Hydrochloric acid produces toxic and corrosive fumes when exposed to water.

Sodium hydroxide is a strong alkaline material (pH levels greater than 7.0). Sodium hydroxide is corrosive and has an irritating effect on all body tissue, causing burns and deep ulcerations. Inhalation can cause damage to the upper respiratory

tissue and lung tissue, with effects ranging from mucous membrane irritation to severe pneumonitis.

Other hazardous substances or pollutants and contaminants not discovered to date or not specifically identified herein may exist at the Site. These substances also may pose a threat to human health and the environment.

2. Actual or potential contamination of drinking water supplies

No specific contamination of a drinking water supply has been identified to date.

3. Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other bulk storage containers, that may pose a threat of release.

A preliminary inventory of containers (Appendix 1) includes over 300 various sized drums, containers, tanks, supersacks, clarifiers and vats containing thousands of gallons and/or pounds of caustic, acidic, cyanide-bearing or metal-bearing wastes. Most containers were unmarked or improperly marked and many containers are in very poor condition. Some process vats and containers inside the building and containers stored haphazardly outdoors were observed to be actively leaking to the ground surface.

There are more chemical containers and an undetermined volume of contaminated debris, sludges, building material, soils, concrete, and wastewater treatment system materials awaiting full inventory and characterization. Full disclosure of the character and volume of hazardous wastes will only be possible during subsequent removal activities conducted under the necessary health and safety program elements

4. High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface that may migrate

Areas of concrete flooring, secondary containment structures and sumps associated with the plating lines showed signs of degradation, etching and staining. Portions of the inside and outside east wall of the plating building and exterior soil adjoining the east wall are stained yellow. The analysis of two soil samples collected during the June 23, 2009 EPA sampling event reveal elevated chromium, hexavaient chromium and cyanide concentrations in exposed soils (Appendix 2).

A goal of this proposed response action is to further delineate and remove contaminated shallow soils from potential source areas. Concrete floors, secondary

containment areas, drainage systems, trenches, sumps and other building materials will also be evaluated and removed or decontaminated as further analytical data dictates.

5. Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released

During the monsoon, or summer thunderstorm season, Arizona experiences severe weather. High winds, dust and severe downpours resulting in flash floods are common monsoon occurrences.

Exterior waste storage areas and the wastewater treatment area are exposed to rainfall. Surface water runoff contaminated with cyanide and heavy metals could migrate off-Site, which could pose a human health risk to neighboring communities. Further, weathering of contaminated structural material and waste storage areas by wind, sun and rain can cause the deterioration of remaining materials and result in a release of heavy metals and cyanide located within those materials.

6. Threat of fire or explosion

The Site is abandoned and not maintained or operated to minimize the possibility of fires, explosions, or any unplanned sudden or non-sudden release of hazardous substances. Waste paints and flammables are located within 50 feet of the property line. In addition, EPA observed incompatible and unmanaged materials stored in close proximity, which creates an additional risk of chemical reaction resulting in combustion, explosion or toxic vapor. The presence of these materials (in addition to all the present unknown materials), combined with the lack of facility management, increases the risk of fire or explosion at the Site.

The mixing of strongly acidic and caustic materials could generate sufficient heat to ignite surrounding combustible materials. If a fire engulfed the building, sheds or waste storage areas, it could release highly toxic chemical vapors and particulates into the surrounding community. The use of large volumes of firefighting water would likely produce contaminated runoff that could flow into the sewers and storm drain system causing a discharge of pollutants and contaminants into surface waters.

7. Availability of other appropriate federal or state response mechanisms to respond to the release

No other appropriate federal, local or state public funding source has been identified. EPA is informed that the proposed action exceeds the financial capability of ADEQ and local response mechanisms.

IV. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing the response action selected in this Action Memorandum, may present an imminent and substantial endangerment to pubiic health, or welfare, or the environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Proposed action description

EPA proposes to inventory, characterize, segregate, bulk, re-containerize, and remove for disposal all abandoned hazardous substances and contaminated materials left in drums, containers, tanks, vats, sumps and secondary containment structures at the Site. All wastes will be characterized using EPA-approved methodologies and delivered to commercial hazardous waste management facilities that are compliant with EPA's CERCLA Off-Site Disposal Policies.

EPA further proposes to evaluate contaminated soils, concrete and structures associated with the former plating operations and to remove for disposal, as necessary, all exposed materials posing an substantial threat of endangerment. The EPA will not investigate or respond in this action to deep soil or groundwater contamination at the Site.

All activities will be performed in conformance with prescribed health and safety procedures. Sampling and analysis activities will conform to EPA approved methodologies and mandatory specifications for quality assurance and quality control.

2. Contribution to remedial performance

EPA does not anticipate a long term remedial action at this Site. This removal action should remove all immediate threats posed by uncontrolled hazardous substances at the Site.

The long-term cleanup plan for the Site:

Final reporting of this removal action will be provided to the ADEQ and other identified local agencies for consideration in any further activities under state or local programs.

Threats that will reguire attention prior to the start of a long-term cleanup:

There is no EPA long-term cleanup planned for this Site. The immediate threats that have been identified in this memorandum will be addressed by the proposed removal action.

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The extent to which the removal will ensure that threats are adeguatelv abated:

The removal of abandoned and above ground hazardous substances is expected to abate the immediate threats from the Site.

Consistency with the long-term remedy:

Removal activities undertaken in this action can be considered and incorporated into state and local facility closure proceedings.

Post Removal Site Control

EPA will evaluate, with ADEQ, the need for post-removal Site controls consistent with the provisions of Section 300.415(k) of the NCP. The elimination of all accessible threats, however, is expected to eliminate or minimize the need for post-removal Site control.

3. Applicable or relevant and appropriate requirements ("ARARs")

Section 300.415(j) of the NCP provides that removal actions must attain ARARs to the extent practicable, considering the exigencies of the situation.

Section 300.5 of the NCP defines applicable reguirements as cleanup standards, standards of control, and other substantive environmental protection requirements, criteria or limitations promulgated under federal environmental or state environmental or facility siting laws that specifically address a hazardous substance, pollutant, contaminant, remedial action, location or other circumstances at a CERCLA site.

Section 300.5 of the NCP defines relevant and appropriate requirements as cleanup standards, standards of control and other substantive requirements, criteria, or limitations promulgated under Federal environmental or State environmental or facility siting laws that, while not "applicable" to a hazardous substance, pollutant, or contaminant, remedial action, location, or other circumstances at a CERCLA site, address problems or situations sufficiently similar to those encountered at the CERCLA site and are well-suited to the particular Site.

Because CERCLA on-site response actions do not require permitting, only substantive requirements are considered as possible ARARs. Administrative requirements such as approval of, or consultation with, administrative bodies, issuance of permits, documentation, reporting, recordkeeping, and enforcement are not ARARs for the CERCLA response actions confined to the Site.

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The following ARARs have been identified for the proposed response action. All can be attained.

Federal ARARs: Potential Federal ARARs are the RCRA Land Disposal Restrictions, 40 C.F.R. § 268.40 Subpart D; the CERCLA Off-Site Disposal Restrictions, and the U.S. Department of Transportation Hazardous Materials Regulations, 49 C.F.R. Part 171, 172 and 173.

State ARARs: Potential state ARARs are the Arizona Soil Remediation Standards Rule, Pre-Determined Remediation Standards promulgated in Arizona Administrative Code § Rl 8-7-205.

4. Project schedule

Emergency removal activities are scheduled to begin during the week of July 6, 2009. Removal activities will require approximately four weeks to complete.

B. Estimated Costs

Regional Removal Allowance Costs

Cleanup Contractor $ 400,000.00

USCG PST $ 25,000.00

Extramural Costs Not Funded from the Regional Allowance

START Contractor $ 97,000.00

Extramural Subtotal $ 522,000.00

Extramural Contingency (20%) $ 104.400.00

TOTAL, Removal Action Project Ceiling $ 626,400.00

VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN

Given the Site conditions, the nature of the hazardous substances documented on-Site and the potential exposure pathways to nearby populations described in Sections III and IV above, actual or threatened releases of hazardous substances from the Site, if not addressed by implementing the response actions selected in this Action Memorandum, will continue to present an imminent and substantial endangerment to public health or welfare, or the environment.

VII. OUTSTANDING POLICY ISSUES

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There are no outstanding policy issues with the Site identified at this time.

Vlll. ENFORCEMENT

Please see the attached Confidential Enforcement Addendum for a discussion regarding potentially liable parties and enforcement. In addition to the extramural costs estimated for the proposed action, a cost recovery enforcement action also may recover the following intramural costs:

Intramural Costs^

U.S. EPA Direct Costs $ 40,000.00

U.S. EPA Indirect Costs (36.58% of Spending $626,400.00-^ $40,000) $ 243,770.00

TOTAL Intramural Costs $ 283,770.00

The total EPA extramural and intramural costs for this removal action, based on full-cost accounting practices that will be eligible for cost recovery, are estimated to be $ 910,170.00. Of this, an estimated spending of $ 425,000.00 comes from the Regional removal allowance.

[Recommendation and Approval on following page.]

' Direct costs include direct extramural costs and direct intramural costs. Indirect costs are calculated based on an estimated indirect cost rate expressed as a percentage of site-specific direct costs, consistent with the full cost accounting methodology effective October 2, 2000. These estimates do not include pre-judgment interest, do not take into account other enforcement costs, including Department of Justice costs, and may be adjusted during the course of a removal action. The estimates are for illustrative purposes only and their use is not intended to create any rights for responsible parties; Neither the lack of a total cost estimate nor deviation of actual costs from this estimate will affect the United States' right to cost recovery.

13

IX. RECOMMENDATION

This decision document represents an appropriate removal action for the Felton King Site, at 611 S. 15 Avenue in Phoenix, Arizona, as developed in accordance with CERCLA and not inconsistent with the NCP. based on the Administrative Record for the Site.

This decision is

Because conditions at the Site meet the NCP criteria for a time-critical removal, 1 recommend that you concur on the determination of imminent and substantial endangerment and the removal action proposed in this Action Memorandum. The total removal action project ceiling if approved will be $ 626,400.00, of which an estimated $ 425,000.00 comes from the Regional removal allowance. If you approve of this action, please indicate your decision by signing below.

Approved: l l Daniel Meer','7GFistant Dfrector Superfund Division

Date

Disapproved:. Daniel Meer, Assistant Director Superfund Division

Date

14

Enforcement Addendum

Index to the Administrative Record

Figures

Figure 1 Felton King Parcel Data

Appendices

1. Preliminary Chemical/Container Inventory

2. Preliminary EPA Laboratory Results Summary Table and ADEQ Sampling Results Table

cc: Sherry Fielding, USEPA, OEM, HQ

bcc: Site File John Jaros, SFD-9-4 Craig Whitenack, SFD-9-4 Martin Powell, SFD-9-2 Craig Benson, SFD-9-2 Andrew Helmlinger, ORC-3 Celeste Temple, SFD-9-4

15

Index to the Administrative Record

• Arizona Department of Environmental Quality, Compliance Order, Docket No. Z-118-05, August 22, 2005

• Arizona Department of Environmental Quality, Notice of Violation issued to Felton King Company Inc., October 2, 2008

• Arizona Department of Environmental Quality, Hazardous Waste Inspection Report, Inspection Dates March 16, March 24, April 2, and April 9 of 2009

• Columbia Analytical Services, Inc., Analytical Data Package for Arizona Department of Environmental Quality, April 28, 2009

17

Figure 1

Felton King Parcel Data

18

FELTON KING PARCEL DATA PER MARICOPA COUNTY

Parcel Number 112-11-059 112-11-057 112-11-055 112-11-053 112-11-060 112-11-058 112-11-056

Owner PHILIP GOETTL AND SONS ENTERPRISES INC

POLI MADRIGAL

PHILIP GOETTL AND SONS EN 1 bHPRISES INC PHILIP GOETTL AND SONS ENTERPRISES INC PHILIP GOETTL AND SONS ENTERPRISES INC PHILIP GOETTL AND SONS ENTERPRISES INC PHILIP GOETTL AND SONS ENTERPRISES INC

APPENDIX 1

Preliminary Chemical/Container Inventory

19

Preliminary Chemical/ Container Inventory Felton King Plating, Phoenix, Arizona

Completed June 22-23, 2009

;;'•;?¥ - - y : •iry^-'^y^Vf:^ ••y'-}^wytpmi^'^?^:s^m'^^Fs:fir^¥mmf^^^^^ . : , ^ , . , j ^ ^ , j - ; ^ . ^ , ^ ;; • ; r ^ ~ ; v - , ^ p ; - - j i ; y ^ r ^ ^

W¥^y-• S T A R T ID

1

2 3 4

5

6

7

8

9 10

11

12

13

14

15

16

17

18

19

20 21

22

23 24 25 26 27

28 29

30

31

32

33

34

35

36

37

38

39

40

41

. - i^ t ; . "-.• . - . - . i . - . . ^ . , - , « ' ' • •^3-

' . y . : - s i te Lociatlon:: • !!i-^

Storage Yard

Storage Yard Storage Yard,

Storage Yard Storage Yard

storage Yard

storage Yard

storage Yard Storage Yard

storage Yard

storage Yard

storage Yard

Storage Yard

Storage Yard

Storage Yard

storage Yard

Storage Yard

Storage Yard

Storage Yard

Storage Yard Storage Yard Storage Yard

Storage Yard Storage Yard • Storage Yard Storage Yard Storage Yard

Storage Yard Storage Yard

Storage Yard

Storage Yard

Storage Yard

Storage Yard

Storage Yard

Storage Yard

Storage Yard

Storage Yard

Storage Yard

Storage Yard

Storage Yard

Storage Yard

^PRrpx.SIze

! - ( f t ' o r l i a l ) :

300

300 2x4x2 2x2x2

300

55

55

55 55

55

55

55

55

55

55

55

55-

55

30

30 55 55

55

55 55 5

55

55

55

30

55

10

55

55

55

55

55

55

55

55

55

m^y7 t^T-J,-"-.-:':"'?.-

yv"f>::y Container

T

T

O

o T D

D

D

D D

D

D

D

D

D

D

0

D

D

D D

D

D D D

O D

D D

D

D

D

D

D

D

D

D

D

D

D

D

UX-yW0mk i^,^y-ym'm^m. CdntalperDesicr lpUbn

plastic

plastic plastic bin

plastic bin

plastic

blue plastic

blue plastic

blue plastic black plastic

black plastic

blue plastic

blue plastic

blue plastic

blue plastic

black plastic

black plastic

blue plastic

black plastic

black metal

fiber board black metal rusty metal

rusty metal rusty metal rusty metal

pail

rusty metal

rusty metal rusty metal

black metal

rusty metal

black plastic

blue plastic

blue plastic

blue plastic

black plastic

blue plastic

blue plastic

black plastic

black plastic

rusty metal

feS'W?ste;/;-Yolunie(9al/ ^ - j ' l b i ) . . ^

150

40 100

50 60

40

55

55

18

18

0

30

55

55 55

30

40

20

30

30 40

30

30

30 30 3

55

full

30

15

55

5

30

55

40

30

55

55

55

55

55

i | f r p c e s s : S t e | y L a ^ |

—

... — ... ... ...

...

... — ...

...

...

...

...

...

Sodium Cyanide

Anionic Water Clarf agent

... No Label

Label not readable

... Sodium Cyanide

...

...

corrosive

no label

unknown

... Marked as Acid

...

jsisoiid-i

S

S S

S

S

S

s s L

s

s

SL

S

S

s . s

u s

. s

s s L

SL. SL

SL

s S

S

S

S

s s s s s s s s

s

s

s

'mmmm^^W^mi feJContenPDescrlptlori/^: 5i<**V>'eomment5'::f4>ii i i : black brown material, 1/8

full

black brown material. 1/8 full black brown material

black brown material

black brown material white

white solid, yellow stain on bung bolt white solid

clear liquid

solid, 1/2 top cut

solid, closed top, empty?

oily, 1/2 top cut off unknown

closed top closed top

closed top

Not accessible, estimated volume.

open top

closed top

closed top closed top

unknown

yellow staining yellow staining

yellow staining pieces of black glass closed top

debris/ solid waste unknown

... unknown

unknown

cakey, open-top

unknown, closed top

black, open top

closed top

closed top

closed top

black/gray, yellow stained solid, open top

black/gray, yellow stained solid, open top

black yellow solid, open top

SgiJSSSffiSiSFIeiaiTeiBffl^SSfflCi^

m

10

'bxidlicer dyan jde Flammabl l l t

m«mfw^:":Stmsii ' s .m^m^m 'smm i

t Corresponding SampleSii

last updated 6/25/09 Page 1 of 6



'^-•.•~iyf-^y-yi-Tw.y'''-y-^yy^'V!:y'Pyyr'^~^f^:y^yyv'^:''m ' ,--..:.y.,.,.r-.. '^.-,y.^...,^,,,r:yy:lp^-j. ' ,^

•'^y-'H'..''-

STANTID," 42 43 44 45 46 47 48

49

50 51 52 53 54

55

56

57

58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75

76 77

78 79 80

81 82

: \ ' ^ y . ^ ; v ; j K v v ; • • •;' Y ' - ' ' ^ ^ > : ^ - y ' y ' ^ ^

*. ' site Location.Q,: storage Yard Storage Yard storage Yard Storage Yard Storage Yard Storage Yard Storage Yard

Storage Yard

Storage Yard Storage Yard Storage Yard Storage Yard Storage Yard

Storage Yard

Storage Yard

Storage Yard

Storage Yard WWTA WWTA WWTA WWTA WWTA WWTA WWTA WWTA WWTA WWTA WWTA WWTA WWTA WWTA WWTA WWTA WWTA

WWTA WWTA

WWTA WWTA WWTA

WWTA WWTA

fPRfoxSIze »;(ft or gal) /

55 55 55 30

1x1x2 10 55

55

55 55 55 55 55

16 (L)

16 (L)

20

55 quart

1 1 5 5 5 5 5 5 5 5 55 30 30 30 30 55

30 30

5 55 30

55 30

y ^ ' ^ > ^ ' : ^ 'Cbntainer ;;.Type;- ;

D D D D V D D

D

D D D D D

c

c

D

D 0 0 O O O O 0 O 0 0 O D D D D . D D

D O

0 D D

D D

Container Description black plastic black plastic white plastic white plastic

plastic blue plastic blue plastic

rusty metal

black plastic blue plastic black plastic black plastic blue plastic

rusty metal

blue poly metal container metal container metal container metal container metal container plastic bucket blue plastic white plastic white plastic white plastic blue plastic blue plastic black plastic blue plastic blue plastic blue plastic blue plastic

white plastic black plastic tote

white plastic tote black plastic fiber board

fiber board metal

p:Wastes„i yp!Htne(g|!/

55 55 55 20 5 8 55

20

30 30 55 55 30

16 (liters)

3 liters

10

8 1

0.5 1 3 5 3 5 5

2.5 2.5 5 55 30 30 30 15 20

30 30

5 30 full

300 5

^R!^«itSs;st|RA^a^e[3 ii'.«jt.,jlnformatlonS;!iSt« unknown unknown

... unknown

...

...

...

Cole-Fill 500 Aminoplastfoam resin

unknown

...

...

...

....

DOT-4BW240

no label

... Sealer tape primer paint sealer kerosene zinc purifier

Corrosive HCl Brighter zinc replenisher 88 CU-CEL+ Brighter H2S04 Latex DL460NA 30% HCl solution unknown unknown unknown

... hydrogen peroxide, 35%

— corrosive nickel stripper

... CH-90

Pyrene 1345 HN03

r^K ' i f r :&^

:s1=Sbiid;

*>G'=:gas>. S

s s s s s s

SL

SL S

s s s

G

G

s

SL L L L L L L L L L L L L L L L L S

L L

L L S

S L

'^:!Cohtent Descrlptlbn/^.';< * j i . :; iCommentr&H4t closed top closed top closed top open top green; open top green; open top closed top

oily black sludge, closed top

oily black sludge, closed top closed top closed top closed top closed top

Gas cylinder; approx 16 L Gas cylinder; approx 16L total volume and it's 1/5th full. gray/greenish solid, open top

oily black sludge, closed top with open bung closed top closed top closed top closed top closed top open bung closed top closed top closed top closed top closed top closed top closed top closed top closed top closed top open top

oxidizer; full, closed top closed top; full; unknown

closed top unknown white solid, NaOH closed top; could be off-white powder based on research closed top

rmw&msfmaifesm^??nmf

Ary-,\:

m

6

14

Oxidizer Cyanide Flammablllt

mmm

i ^ M ^ ^ i S W W S ^ si??fiP7g35¥' ':'rSr?.>?jr«

':Correspondlng:Sainples;




;.-^.-:;r-r:-;:^::y-':^t^.y.y:y-'f^'y\-)^T..y'^yL:^^ .-,..,..-.,. .. .,,j,,;;.,-. ..,5' j,-.n- ••r?~':v f«f rMii; ?r?«y7T!sefGonteiffi

" .' • " i • ' ' .

'START lb 83

84 85 86 87 88 89

90

91

92 93 94

95

96 97

98 99 100

101 102

103 104 105 106 107 108 109 110 111

112 113

114

r ; • • •? • ! : . 'S ; - ' , ' f • • • . • ; • • • ' ' . . . • . t ' ' : - . '

^^""":siie;i:ociatlbn'.''.; WWTA

. WWTA WWTA WWTA WWTA WWTA WWTA

WWTA

WWTA

WWTA WWTA WWTA

WWTA

WWTA WWTA

WWTA WWTA WWTA

WWTA WWTA

WWTA . WWTA

WWTA WWTA WWTA WWTA WWTA WWTA WWTA

WWTA WWTA

WWTA

mm 30

150 1x2x2 1x2x2 1x3x2

1x2x2

1x4x2

1x2x2

1x4x2 55 55

500

5 55

55 30 30

55 55

55 30 55 55 55 30 55

4x4x4

4x4x4

30

D

T V V V

c V

V

V

V D D

T

O D

D D D

D 0

D D D D D D D

V

V T

0

f:y-~-yr;:.xyr~i

Container Description blue plastic .,

white plastic plastic/ fiberglass plastic/ fiberglass plastic/ fiberglass

plastic/ fiberglass

plastic/ fiberglass

plastic/ fiberglass

plastic/ fiberglass black plastic black plastic

plastic

blue plastic tote black plastic

gray plastic blue plastic blue plastic

blue plastic blue plastic

blue plastic blue plastic blue plastic gray plastic white plastic blue plastic white poly

plastic plastic/ fiberglass

plastic/ fiberglass plastic

blue plastic

:?Estl(iiated^

S-ytîi' ^^';lbs).*^5?

15

125 20 15 40

20

10

20

10 55 55

250

3 30

30 25 30

lOgal sludge, 10 gal dark

liquid 55

55 full 15 15 30 30 55

300

250

25

fBracessfstep/IUabÛ ft t.SJ'Informatlon&'iss

...

Muriatic acid nitric, nickel strip

... Cl strip Propane D Paint strip

Rinse

...

... corrosive label

...

"Black Pearl"

...

SIRIUS, black nickel no label

...

... no label, SIRIUS

... Chrome rinsing

... SIRIUS

... Evaporative tank

...

... Evaporative tank SIRIUS, Corrosive; Class 9

msm |j!=iLlquld; '"Gngas^:

S

L L L L G L

L

L

L S S

L SL

L U U

SL L

S U SL L L L L L L

L L

L

fcsnpilMr!p0|i iSfw??»? Comment ..?.:-'-j ,:-;#i!;. white solid, open top dark green liquid, closed top; multlRAE indicated 9 ppm of HON blue/greenish liquid blue/greenish liquid bluish green, open top gas cylinder black liquid

Greenish liquid

Yellow liquid

clear liquid closed top gray flaky material

needed to drop a bailer in this tank to see the liquid and determine how full

closed top; internet research indicates black pearl is a kind of plating that was historically used on chrome. "Black pearl" mostly not used anymore. reddish brown sludge

black brown liquid, open top closed top closed top

open top open top solid, cakey material, open top closed top yellowish brown sludge closed top blue green, closed top closed top closed top

Greenish liquid; vat full

green liquid; vat 3/4 full

wmms^f\e\ii:t€^L^!îmam m '.i-'-'-i-' ^ ' • : ' j '

1

0 14

7

2

13

10

7

12 7

4

7

10

^•*fe? 'oxidizer

Yes

No

No

Yes

Yes

Cyanide

No

No

No

No

No

iS'mmmmsmm mwmM^rcyimms-

rCorrespondlng Samples.

H/kZCAT completed on 6/23/09

HfiZCAT completed on 6/23/09

HAZCAT completed on 6/23/09

H/\2CAT completed on 6/23/09

H/^CAT completed on 6/23/09




f ' . • ' ' - ' • - . ^ ' " . - ' " . . . . „ - r — - „ - . •.^-^.

;*START1D "

115

116

117

118 119

' 120

121

122

123

124

125

126

127

128

129

130

131

132

133

134

135

136

137 138 139 140

141 142

143

f -

L

Site Location

WWTA

WWTA

WWTA

WWTA WWTA

WWTA Parking Bays, outside, S

End of site bldg Parking Bays, outside, S










End ot site bldg Parking Bays, outside, S





End ot site bldg Parking Bays, outside, S

End of site bldg plating room 1 plating room 1 plating room 1

plating room 1 plating room 1

plating room 1

^ -'

Approx Size (ft or gal)

30

1000

750

55 55

55

1

100 lbs

100 lbs

50 kg

50 kg

100 lbs

30

5

5

5

5

5

5

20

10

5

20 5 5

2x6x10 2x2x2

2x2x2

•s i f ' ^ v i r y z ^ y K m ^ Container InvelitoiV ' 17 >• ' " ~ "^Container Information^ ^

Container Type

D

T

T

D D

D

O

0

0

0

O

O

O

o

0

0

0

o

o

0

o

0

c o o o

o V .

V

If

<

Container Description

blue plastic

black plastic

white plastic

blue plastic black plastic

black plastic

glass jar

metal drum/ pail

metal drum/ pail

metal drum/ pail

metal drum/ pail

metal drum/ pail

white plastic

black plastic

black plastic

plastic

metal

black metal

blue plastic

green metal

fiber board

white plastic

green metal plastic bucket plastic bucket

sump plastic/ fiberglass

plastic/ fiberglass

Ist lmated waste '

Volume (gal/ l b s ) .

25

500

300

30 55

55

0.25

100

100

25 kg

25 kg

100

30 lbs

5

5

5

5

5

5

10

5

20 5 5

180 30

15

t-y-^ " - r - -

Process Ste|i/ Label '»'lnf ormation)

SIRIUS, Corrosive; Class 9

pH Adjusted rinse tank rinse water, pH adj rinse

sandocolor, TSN-Liquid class 9 class 9, electroless nickel solution

chloroform

copper cyanide

potassium cyanide

KCN, toxic 6

KCN, toxic 6

KCN, toxic 6

Cadmium Oxidizer

toxic 6, corrosive 8

toxic 6, corrosive 8 Chromium plating agent

Oxidizer, corrosive

20-XL Special Liquid

...

Oxide Coating

Corrosive/Poison

...

...

...

. . . " • • •

...

" - s

^ f

S = Solid, C= Liquid,

G = gas

L

L

L

L U

L

L

S

s

s .

s

s

s

s

s

s

u

s

L

u

s

s

G SL SL SL

L L

L

" " J. " * J ^ r - * - ^ .t, ^

> «- , \ ... f Content Description/ , * <. '^Comment

solid, closed top closed top

closed top

liquid

solid, closed top

solid, closed top

solid, closed top

solid, closed top

solid

solid

ROHCO Cad-SolxL

ROHCO Cad-SolXL

closed top

no access

closed top

closed top

no access; closed top

Propane Cylinder white sludge/solid white sludge/solid white sludge/solid

yellowish clear liquid acid

yellow clear liquid

m^^^^mmmwEmm'. smPiVm'mi<f^esiy^:Ws^iS^

'A'r.^'^'

.pH

7

12 0

11

Oxidizer

Yes

No

'••''.y^-^l

Cyanide

Yes

Yes

Riatnmablllt

. i

^ .* " ^ -* ^ ^

A .t.

Corresponding Samples

HAZCAT on 6/23/09; FKR-04-062309

HAZCAT completed on 6/23/09




r ':'; yy^- y y y y T i i r iS-; S'-i! ?>-f '::'CfKJ:' r«rf ;:' -7^^ - ^ f i r - ^ - ' y ' " - - ^ " • • •^• ; ;^^?r : '^ • 'T: r : ; :^^Si ; . " . ' ^^^^^r^^^ ' ' r ' fS^.Cbnta lnef lh

:^^TARt lD 144 145 146

147

148A

148B 149 150 151 152 153 154 .

-' 155A

155B 156

157 158 159 160

161

162 163 164 165 166

167

168 169 170 171 172 173 174 175 176

•:-f. j , - - . ; : • . . • i ; s ^ . . . • ; • . . • • ; • K

y y f o ' K M ^ 0 t ^r- -Sl teLocat ion^^t

plating room 1 plating room 1 plating room 1

plating room 1

plating room 1

plating room 1 plating room 1 plating room 1 plating room 1 plating room 1 plating room 1 • plating room 1

*

plating room 1

plating room 1 plating room 1

plating room 1 plating room 1 plating room 2 plating room 2

plating room 2

plating room 2 plating room 2 plating room 2 plating room 2 plating room 3

plating room 3

plating room 3 plating room 3 plating room 3 plating room 3 plating room 3 plating room 3 plating room 3 plating room 3 plating room 3

' ' p y : ; y y

jApproxSIze i i t f to rga i ) : :

1x1x2 2x4x2 2x10x2

55

2x4x2 . . f . - . . . . . . .

2x4x2 1x2x2 1x2x2 1x2x2 1x1x2 2x2x2 1x1x2

5

5 25

5 5

8x2x2 5

8x2x2

2x1x2 55 55

10x2x2 30

10x1 x2

1 0 x 2 x 2 1 0 x 2 x 2 10x2 x2 10x1 x2 10x2x2 12x1x2

55 55 55

py '--yx'' !cpntajner l - iType?:

V V V

D

V

V

V J V V V V V

0

0 0

0 0 V

o

V

V D D V D

V

V V V V V V D D D

Container Description plastic/ fiberglass plastic/ fiberglass plastic/ fiberglass

metal

plastic/ fiberglass

plastic/ fiberglass plastic/ fiberglass plastic/ fiberglass plastic/ fiberglass plastic/ fiberglass plastic/ fiberglass plastic/ fiberglass

blue poly

blue poly rolling bin

blue metal blue metal

plastic/ fiberglass blue tote

plastic/ fiberglass

metal vat black poly gray poly

plastic/ fiberglass white poly

plastic/ fiberglass

plastic/ fiberglass plastic/ fiberglass plastic/ fiberglass plastic/ fiberglass plastic/ fiberglass plastic/ fiberglass

gray plastic blue plastic blue plastic

KEstimatedt

Voliime-(gat/ .T jbs). ' ' ' . '

10 120 60

55

15

15 4 6 10 10 30 8

5

5 25

5 5

240 5

250

30 55 55 300

1

75

300 300 60 75 300 180 40 25 25

i^^f ! lnfdfn«t ion;]^ l j black oxide rinse black oxide rinse black oxide rinse

...

Cadmium Rinse '

Cadmium Rinse Cadmium Rinse nitric 1% Nitric rinse Chromate liquid Chromate Rinse Chromate Rinse

RODIPCZ-210

RODIPCZ-210

...

Silicone Dry Fill Silicone Lubricant Cd Plate ROHCO-20-XL

...

copper cyanide

... copper rinse acid copper

...

chrome Rinse

Chrome Nickel Rinse Nickel Rinse .... ... ... ... ... —

&!G;=-gasa L

SL L

S

L

L L L L L L L

L

L L

L L

SL L

L

L

L L L S

L

L L L L L L L L L

i#Conteht,Descrlptlon/j;; '?f •.K-?^CommehtS':.;.;;. -.f acid brown sludge pale brown liquid

brown gray solid, open top

yellow clear liquid

clear liquid ' clear liquid clear liquid clear liquid liquid liquid liquid

V iW7&mmi : le \H i res t$mS^MEs

FpH,

14

11

10 11 11 7 1 2 3

Oxidizer

Yes

•• N o '

No"

Cyariidb

No

Yes

Yes

FiamiTrabillt

, . . „ . , , . ,

closed top; FROM THE INTERNET; "RODIP. CZ-219 is a liquid, single-immersion, chromate conversion coating that produces a bright iridescent yellow corrosion protective coating on electroplated zinc and cadmium surfaces. RODIP CZ-219 provides high polishing action and high wet strength. In addition, it provides an excellent base for paint or lacquer. Its pleasing appearance makes it suitable for decorative applications as well. RODIP CZ-219 is effective on acid and alkaline non-cyanide and cyanide zinc deposits.' oily liquid closed top; liquid based on research closed top open top

yellow clear liquid

yellow clear liquid, open top liquid open top liquid, open top liquid, open top blue crystal solid reddish-yellow open top liquid Reddish-yellow liquid, open top Greenish liquid Greenish liquid liquid clear liquid green liquid clear, It green liquid yellow liquid, open top yellow liquid, open top

13

12

11

2 2 2

3

7 7 2 7 2

13 14

2

No

No

No

Yes

wmmmmw^i^m^v s=g^??3ra¥f'S5sr5?'

^'Cofrespbridlng Samples'

H/\ZC/\T completed on : 6/23/09; FKP-02-062309 H/\ZG/KT on 6/23/09; FKP-03-062309 (also duplicate

sample)

H/\ZCAT completed on 6/23/09

H/\ZCAT completed on 6/23/09




- T ^ ^ p r ^ t g ^ y f f i - ^ f f l ? r g y r ! ^ 3 ; a n t a l n e r i h V e a i ^ ^ .K'-'-yi.':'', y •^>^.uiy-"^S.VCbntainerriifdPmation'.'"?.'-i, W^.:^^^?^^S^MW'^fV''!i^^'ji^?^^¥S^S^!&-^^^' ^Si'^^g^ggFieiaTests-gsaggês ??!¥ '.'^'i'.Â^

START ID • Site Lbcatibn" Approx. Size ^(ftorgal): ,

•Siy-^yi' Container

f'K-VTVi*\''^-:c-"^\ •• """'^^ y

W7'> . T ' -

CohtalnerDescrlptlon

•iE|tlmated; ;!|{^|vya|te yp|iime'(gai/

<:.<:•:*".•it.liyi'^y-'.'-'i - ' :y<iy.iÂ:mK'y .Process Stiep/'.Labeif ^ - liiforrnatldnftte-?

L'^=LlqMld; ;': G = jgas'-

.^Gonteht'Descrlptibri/ji'

i f»ei t^r i fe i^ Oxidizer Cyanide Flamlnabirit .; '- ' . ' , ' :; '" i 'V'if. ' .",.*

'• • •• t . . \ i±g : . ^^^MS-''- '-^-

.'.Corresponding Samples

177 plating room 3 55 white plastic 17 clear liquid 10 No No HAZCAT completed on

6/23/09 178 plating room 3 30 white plastic 15 brown liquid 179 plating room 3 white plastic tote chrome CAT liquid, closed top 180 plating room 3 10x1 plastic/ fiberglass 1/2 full liquid open top 14

181 plating room 3 15 ft deep X 5

x5 sump 500

mostly liquid, some solid, olive green thick liquid; about 1 ft pf liquid/ sludge' in bottom of sump Yes No

HAZCAT completed on 6/23/09; FKP-b5-062309

182 WWTA 55 blue plastic 55 solid, closed top

183 Storage Yard 100 plastic upright unknown SL

yellow sludge-like material oozing from bottom; open top

184 Storage Yard 100 plastic upright unknown unknown; open top

185 Storage Yard 5 cubic yards?

Notes WWTA Wastewater Treatment Area

* too much color in soln. No pH T^tank V = vat D = drum O = other C = cylinder S = Solid; L = Liquid; SL = sludge; U = unknown; G = gas

super sacks 5 cubic yards? gray and white solid

HAZCAT cornpleted on 6/23/09; Sample ID ' FkP-01-062309

likely requires additional investigation blue highlight is samples sent to lab


APPENDIX 2

START Preliminary Laboratory Results Summary Table

20


June 22, 2009

ITEMS LISTED HERE WERE NOT NUMBERED DUE TO INACCESSABILITV OR OTHER ISSUES

Site Area Storage YarcJ Storage Yard Storage Yard Storage Yard Storage Yard Storage Yard Storage Yard Storage Yard

WWTA WWTA

WWTA, Shelves in a little storage roon in WTA WWTA, Shelves in a little storage roon in WTA WWTA, Shelves in a little storage roon in WTA WWTA, Shelves in a little storage roon in WTA WWTA, Shelves in a little storage roon in WTA

WWTA, Shelves in a little storage roon in WTA WWTA, Shelves in a little storage roon in WTA WWTA, Shelves in a little storage roon in WTA

WWTA, Small storage room in WTA

Outside Hazardous Storage Area Outside Hazardous Storage Area Outside Hazardous Storage Area Parking Bays, outside, S End of site bldg Parking Bays, outside, S End of site bldg Parking Bays, outside, S End of site bldg

Office Area, Inside Main Site Bldg Office Area, Inside Main Site Bldg Office Area, Inside Main Site Bldg Office Area, Inside Main Site Bldg Office Area, Inside Main Site Bldg Office Area, Inside Main Site Bldg

Other Note description 16 of 5 gallon pail/totes along with connex box line: unknown, not accessible 4 of 55 gallon rusty metal drums with solid material, gray powder look 2 of blue poly totes, 30 gallon: unknown, not accessble 1 of 30 gallon metal drum open top not accessible 1 of gray 55 gallon poly misshaping contents unknown, open top, no accessible 1 of 55 gallon metals drum, contents unknown, open top, not accessible 1 of 30 gallon black metal drum, Sodium Cyanide Solid, UN 1689, 50 kg 1 of 20 gallon black poly tote, unknown

50 of 1 gal metal paint/latex/glazing contaniers 24 of 5 gal plastic bucket, soiid latex/paint full

20 of 5 gal poly buckets full solid 23 of 1 gal paint metal containers, paint/adhesives/coating/enamel 4 of 1 gal metal container full liquid, paint adhesion, siloxane, PVC cement surgacer

1 of 12.5 lbs marble tile setting motar, full 46 of misc 1/2 pint lo ' l quart size metals containers, coating/oil based enamel, undercoat zinc phosphate, glue sealer, epoxy enamel 12 of paint spray 5 of 1 gal plastic acrylic additive bond

7 of black and white metal buckets, solid, full cement, open bung

4 of 1 gal glass bottle HN03 label 2 unknown 55 gal metal drums, no access 4 30 gal black poly label H2S04, no access 5 bags of Hydrogen Difluoride Solid, UNI727, Corrosive, 50 lbs each 1 bag of caustic soda, UN 1823, 50 lbs 1 bag of caustic potash, 50 lbs, corrosive 8

2 of 1 quart clean metal primer 4 of glossy protective enamel, adhesive spray bottle 1 gal kerosene metal container 1 of 17L propane cylinder 1 quart of Lite-Weight 3 1 gal premixed Thin set

Page 1 of 2


June 22, 2009

ITEMS LISTED HERE WERE NOT NUMBERED DUE TO INACCESSABILITV OR OTHER ISSUES

Site Area Office Area, Inside Main Site Bldg Office Area, Inside Main Site Bldg Office Area, Inside Main Site Bldg

Other Note description 1 quart lube oil 4 of 1 gal latex paint 2 of 1 gal cooler cleaner treatment

Page 2 of 2

PRELIMINARY LAB RESULTS U.S. EPA/ START Sampling Results

Sainples Collected June 23, 2009; Felton King Plating, Phoenix, Arizona

sswmnmmmm

Sampleêscriptipn^

\ymmtm^mmmk\ Mmmmmmm

mmmmm&m. mmi m/m&m. Aluminum (Al) Antimony (Sb) Arsenic (As) Barium (Ba) Beryllium (Be) Cadmium (Cd) Chromium (Cr) Hexavaient Chromium Cobalt (Co) Copper (Cu) Iron (Fe) Lead (Pb) Magnesium (Mg) Manganese (Mn) Nickel (Ni) Selenium (Se) Silver (Ag) Thallium (Tl) Vanadium (V)" Zinc (Zn) Mercury (Hg) [TGLE Metal (mgflL) Arsenic Barium Cadmium Chromium Lead Mercury Selenium jSilver

wrnmimmm ' composite samples S flfronr;the?three5: ? 4supepsacksnnithes »tcMiffie&ss ^ ^ i S I S l i i C

K*v-mg/kg,>iwet iWtn';"'

?i|FKEK)2.1Sj f§MPM^W^&^Sii iS^ 'iJ:?rUiqffidj?firpn^

HazCati^lCN

mmmmm V':--148A?^^:-

m:€4F::Kyi^£^y positive HazCat

&imMM!yM Svs;-#i;M8B5^jgf}

Hiffiift

"Bupiicatefof -^'.'t-.^^.t'-'.'<iv-'..-^^.>'^':

FKP-03-

mmmtm §MMmM miii iiiiiii

^.FKP;04 1 FKP-05 isiampSjin tHeiplating^buU^^

iiiiiii wmmMim

| :]3r|e|3|f; | f||jûmiJs||p|

'mmmmM FsiiiquiaSî

FKP;06| FKP-07 | FKP,08 #jvi:5r lrsumGe;SGil. samples i:^

.;stainmg

btwn'yellqw Maitiiibliie^

.staining,-

•miey:m::f. mmm-ayellQw.,g staining

i l t ic isnt l i i i i^Kil^^

stingflcg;*

'-rr:>...v«.;c.;^..y,-f.--fN-..:,.5i-

^^?^yyi i drywt

'fy y y y yii ^ y ^ m ^ y y '!^-'yy:a:'^''^Ks.'yî''yfyy-i^-'i^y.yyjfS'yiymA y y ^ : yyymyy:"y:y:.yy^'y--^

f?4;jG6mMrisoiS^ntenai&

mmmmmmk •iiiy i;y i::is^s^sy.y!-y:' r.'y

i l i i ^ i S ; ? i l i S | l i a s a | § g g l ^ 900

<500 <100 <50 <25

97,000 33,000

NA <50 2,600 13,000 2,000 2,000 130 250

<100 <50 <500 <50 4,700 0 14 J —

NA NA NA NA NA NA NA NA

<10 <10 <2 < 1

<o;5 2,700

14 < 0.025

< 1 820 31 <2 33

0.95 64 <2 <1 <10 < 1 520 0 25

1

<2 <2

2700 14 < 1

0.0043 <1 .<2

9.0 <10 < 2 <1

<0.5 580 2.8

<0.025 < 1 130 8.2 <2 42 <1 11

<2 <1 <10 <1 77

<0 02 - JT * ^ . ^

<0.4 <0.4

49 1.8

<0.2 < 0.002

<0.2 <0.4

5.5 < 10 < 2 <1

<0.5 260 2.1

<0.025 < 1 130 10 < 2 26 < 1 10 < 2 < 1 <10 < 1 65

< 0 02 1

<0.2 <0.2

62 2.3

<0.1 < 0.002

0.17 <0.2

<10 <10 < 2 <1

<0.5 26 42 33 <1 11 26

0.61 17

<1 0.72 <2 <1 0.87 <1 3.1

0 057

0.15 J <0.2 1.0

34.0 <0.1

< 0.002 <0.1 <0.2

<3,300 < 3,300 <660 <330 <160 4,700 10,000

89 <330 2,700 7,100

160 1,400 <330

200,000 <660 <330 <3300 <330 2,000 < 0 1 6

,

< 0.002

12,000 <10 10 100 0.75 1.8 31 1.9 8.3 21

17,000 7.4

7,900 320 22 < 2 < 1 1.3 36 41

< 0 02

< 0.002

7,500 <10 7.2 110 0.5 5.4 420 150 6.5 69

14,000 17

5,800 350 28 <2 <1 <10 29.0 49.0

0 016 J ^ "

.

< 0.002

6,700 0.99 6.3 83

0.38 1.6 760 790 6.9 24

11000 13

5000 300 17 <2 <1 1.4

24.0 39.0

0 063 J -

< 0.002

76,000' 31 U 10^

15,000 '•' 150' 3 9 '

280' 3 0 ' 23 '

3,100''' 55,000 ' 400 '•' N/A

1,800 ' 1,500 ' 390 '•' 390 '•' 5.1' 7 8 '

23,000 '•' 4 3 '

'

5 = 100'

1 = 5 ' 5 '

0 .2 ' 1 ' 5 '

Page 1 of 2

PRELIMINARY LAB RESULTS

U.S. EPA/ START Sampling Results Samples Collected June 23, 2009; Felton King Plating, Phoenix, Arizona

• i ^ ^ ^ m

SampleiDescriptioa%'

jfipmpositeisamples'-

^supeKsacKSsrajthel', ''"Usstoriigeiateafiffi

i^nj^fllg^îji

g ^ j E j ^ i m ^ îEKRifla^lîEMioai^ il^Lifluidjgongjheiata^njfhgpk^g^^^^

m m^m^m^^

mMmi m : g j ^ g j ^

pbsitiyejHazCat % s s i : ^ 5 S B p ^

i^H^M

lEKajioai atBlgBlJffii§laSEiagi95§S

plieale ot

: 3 R | 0 3 S ^

îli^ .!itequi(i#i. ^^Png/ia-iia

jFjjBifife gaEMiQiji liERipijy f.surDps,|iniuieipJaUjngjbjiujm

iiagSg

tSSiJ,MSuffa ee>sou s8UTipJe,fe|tai #,

H g J i l M i

31

'IBliiilif? istainingi'

tptwri|yellow;

ggafloibUiep ft-%$8"''3%'i?v;f.";i-.

Istaming^

ISiMaiiîSlliiEjiM ^s#S8iMSi '•Ing/kgild^y^^yt '7fc:i'5rl':t^'ig'!îj"i[^:?gi.'^-'^

Sisoua •;. nig/kg. ->

;'Slvfesip?SiSg?®;l5aii;

^ ^ ' ^ " l ^ a l y s i ^ ^ ISSifflliKeriitii^

Cyanide, Total 95,000 4,500 630 310 270 <0.025 <0.51 260 0.54

Reactive: It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases vapors or fames in a quantity sufficient to present a danger to human health or the environment. (40 CFR 261.23)

CN, Amenable 87,000 2,200 610 280 240 <0.025 <0.51 <5.1 0.54 EH. 9.91 9.62 9.62 10.60 6.38 pH<2,pH>12.5

Cyanide (free) r

1,200-Cyanide (hydrogen) 11

Bold results indicate exceeded comparison criteria Notes: N/A = Not Analyzed mg/kg = milligrams per kilogram Laboratory was Test America, Irvine, CA selected action level is the lowest number of the U.S. EPA PRGs vs. /KZ SRLs with the exception of Arsenic. For Arsenic, the state SRL of lOmg/kg is used because it takes into account background concentrations.

mg/L = milligrams per liter

TCLP = Toxicity Characteristic L.eaching Procedure

=U.S. EPA Residential Regional Screening Level

=U.S. EPA Industrial Regional Screening Level

r=Arizona Residential Soil Remediation Level

=Arizona Non-Residential Soil Remediation Level P = TCLP

Hexavaient Chromium was analyzed by EPA Method 7196A

Total and Amenable Cyanide were analyzed by EPA Method 9014.

Not Detected results are indicated as less than the reporting limit

n. , . , ^ n r^f '1

ADEQ Sampling Results Samples Collected April 9, 2009

Felton King Plating, Phoenix, Arizona

Sample ID

SampleDescription f arcel ff/ ~L.ocanoa Descriptio'h Photo #s -Matrix Metals (mg/kg) Arsenic (As) Barium (Ba) Cadmium (Cd) Chromium (Cr) Lead (Pb) Selenium (Se) Silver (Ag) Mercury (Hg) iTCIJPMetal(ing/L) Chromium (TCLP) Cadmium (TCLP) OtheitI Analjfisls r-: V

Cyanide

IPH Temperature (°C)

FKC-01-A|FKC-02-A| FKC-03-A

plating sludge super sacks marked "hazardous waste"

- , ,StorageArea

1-6 ~ - -fSobd Sohd " .Solid

FKC-04-A

chrome plating tank

' _ Chrome Platine Room

16,17 Liquid

P-Ol-A

open container of plating

sludge.

112-11-053

'11,12 , Sohd

P.02-A

open 55 gal dnim -

112;li-053

9,10 SoUd

P-03-A

open corroded container, labeled "sodium cyanide"

112-11-053'

7;8 Sohd

P-04-A

large leaking container

112-11-053

13,15 Solid

P-05-A

open drum of plating sludge

112-11-053'

, 18,19 .. Sohd/Laquid

' ' ' " ' " ' . . _ *

<500 <50

94,000 67,000 3,400 <50 <50 0.34

" " : • • " • ' ~ - , " / j ; . ^ , ' J . ' • - ; •

400 N/A

<500 53

70,000 14,000 1,300 <50 <50

0 099

N/A 1,200

<500 <50

69,000 49,000 2,000 <50 <50

<0 083

N/A N/A

N/A N/A N/A

110,000* N/A N/A

. N/A N/A

N/A 1 N/A

<500 75

51,000 38,000 1,200 <50 <50

<0 083 -

N/A N/A

<500 <50

47,000 63,000

400 <50 <50 0 12

980 N/A

<500 290

36,000 12,000

960 <50 <50

0 085 -

N/A N/A

<500 <50

3,200 170,000

<50 <50 <50

<0 083

8,400 N/A

<500 <50

6,600 3,000 290 <50 <50

<0 083 T

N/A 1 N/A

r . ; • • ' - . - • " ; • • • • • • • • • ; _ • • ' " • - • . " • ; " 1 = : • • ' • . • . • • • • • ' • - • , ' ' • - • • • ' - " . . • • • • - . • , • . • • • • ; : • • • • - • - . ; • • • • • ' • • ' - - . y ' ' ' - ~ ' . _ ' " • ' - ' ' y . : ' : " ' • ' - ' • " " : : - ' y [ ^ ' . . ' ' . . " • " _ . • ' • : • . V M ; - - w • ' • ' ' " > : r - - - ' • ~ f - . . • ^ ' . ' ' ~ ' ^ • . ' ^ • ' . ' • " . ^ ^ ~ y , - ' " " • . ' • ' . , : • - • - r . ' / - . ' • - ' . ' " ' ' ' '•'

N/A

8.7

1 22

N/A

9.7

1 21.5

N/A

6.5

22

N/A

0.2

22

N/A

6.1

22:5

N/A

7.5

22

880

•7.3

1 22

N/A

10.1

22.5

1 N/A

13.5

22

Comparison Criteria

"- '

TCLPiriig/L j 5

1 ; RCRA CKaractMistic^i Reactive: A Cyanide or Sulfide containing material capable of releasing dangerous amounts of poisonous gas when mixed with corrosives pH<2; pH>12.5

Notes: * Analysis requested on COC was TCLP chromium by SW1311/6010B, but result was reported as total chromium by 6010B in mg/kg N/A = Not Analyzed mg/L = milligrams per liter Bold results indicate exceeded TTLC or TCLP mg/kg = milligrams per kilogram TTLC = Total Threshold Limit Concentration TCLP = Toxicity Characteristic Leaching Pn laboratory was Colombia Analytical Services

action memo: request for time-critical removal action ...proposed ceiling increase of $144,000 for...

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